9285.9-19C
EPA/540/R-95/137
PB96-963204
August 1996
Superfund
wEPA Chemical Safety Audits
(165.19)
Student Manual
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
-------
9285.9-19C
EPA540/R-95/137
PB96-963204
FOREWORD
This manual is for reference use of students enrolled in scheduled training courses of the U.S.
Environmental Protection Agency (EPA). While it will be useful to anyone who needs information
on the subjects covered, it will have its greatest value as an adjunct to classroom presentations
involving discussions among the students and the instructional staff.
This manual has been developed to provide the best available current information; however,
individual instructors may provide additional material to cover special aspects of their presentations.
Because of the limited availability of the manual, it should not be cited in bibliographies or other
publications.
References to products and manufacturers are for illustration only; they do not imply endorsement
by EPA.
Constructive suggestions for improvement of the content and format of the Chemical Safety Audits
(165.19) manual are welcome.
i
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CHEMICAL SAFETY AUDITS (165.19)
4 Days
This course, which is presented in cooperation with the U.S. Environmental Protection Agency's (EPA) Office
of Chemical Emergency Preparedness Planning, introduces safety auditing for highly hazardous chemicals.
It is based on EPA's Chemical Safety Audit Program, the Occupational Safety and Health Administration's
(OSHA) Process Safety Management (29 CFR 1910.119), and EPA's Risk Management Programs for
Chemical Accidental Release Prevention (40 CFR Part 68-as proposed). The course covers basic chemical
systems and processes, chemical process hazards, process safety systems, process safety management,
emergency response, chemical hazard mitigation, chemical hazard evaluation, hazard evaluation techniques,
and incident (hazardous material release) investigation. Interviewing techniques, computer modeling, and
report writing are also covered.
Participants receive practical auditing experience by forming an audit team and conducting a mock chemical
safety audit at a fictitious chemical plant. The mock audit follows protocol established in EPA's Guidance
Manual for EPA Chemical Safety Audit Team Members.
This introductory course provides an overview of chemical process safety management, risk management
planning, and chemical safety auditing. Participants responsible for reviewing emergency response and safety
programs at chemical plants, petrochemical plants, refineries, or chemical storage facilities will benefit from
this course.
After completing this course, participants will be able to:
Describe chemical processes, process hazards, process safety systems, safety management,
emergency response, hazards evaluation, and incident investigation in process plants.
Discuss interviewing, computer modeling, and report-writing techniques.
List the required and suggested activities covered in the Guidance Manualfor EPA Chemical Safety
Audit Team Members, OSHA's Process Safety Management (29 CFR 1910.119), and EPA's Risk
Management Programs for Chemical Accidental Release Prevention (40 CFR Part 68-as proposed).
Perform a chemical safety audit using EPA protocol, interviewing techniques, and report-writing
skills.
Continuing Education Units: 2.45
ABIH Certification Maintenance Credits: 3.5
iii
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CONTENTS
Chemical Safety Audit Fact Sheet
Acronyms and Abbreviations
Section 1
Section 2
Section 3
Section 4
Orientation and Introduction
Lecture Viewgraphs
Chemical Safety Audit Program
Chemical Systems and Processes
Chemical Process Hazards
Chemical Safety Audit Manual Review
Audit Report Writing
Lecture Viewgraphs
Process Safety Equipment
Process Safety Operations
Conducting Interviews
Lecture Viewgraphs
Incident Investigation
Hazard Evaluation
Hazard Evaluation Techniques
Emergency Response
Computer Applications
Inspection Techniques
Risk Reduction
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Guidance Manual for EPA Chemical Safety Audit Team Members
(June 1993 version)
Chemical Safety Audit Program Resource Guide
Computer Systems for Chemical Emergency Planning
Chemical Safety Audit Report Worksheet
vi
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4? EPA
FACT SHEET MARCH 1993
CHEMICAL SAFETY AUDIT PROGRAM
BACKEROUHO
The Chemical Safety Audit (CSA) program has evolved
from the efforts of the U.S. Environmental
Protection Agency (EPA) under the Chemical Accident
Prevention (CAP) program. The CAP program emerged
from concerns raised by the release of methyl
isocyanate at Bhopal, India, and of aldicarb oxime
at Institute, West Virginia. Awareness of the
critical threat to public safety posed by similar
incidents led to an emphasis on preparedness and
planning for response to chemical accidents.
Simultaneous with- the development of preparedness
activities by EPA was the passage and
implementation of the Emergency Planning and
Communi ty Right-to-Know Act -- Title 111 of the
S-jperfund Amendments and Reauthorization Act (SARA)
by Congress in 1986, Because prevention is the
most effective form of preparedness, the CAP
program prorates an effort to enhance prevention
activities. The primary objectives of the CAP
program are to identify the causes of accidental
releases of hazardous substances and the means to
prevent them from occurring, to promote industry
initiatives in these areas, and to share activities
with the community, industry, and other groups.
Many of the key concerns of the CAP program arise
from the SARA Title HI section 305(b) study
entitled Review of Emergency Systems. As part of
the information gathering efforts to prepare this
study, EPA personnel conducted a number of facility
site visits to learn about chemical process safety
management practices. The study covers
technologies, techniques, and practices for
preventing, detecting, and monitoring releases of
extremely hazardous substances, arid for alerting
the public to such releases. One of the key
recommendations resulting from the study was the
continuation and expansion of the audit program.
As a follow-up to this national prevention study,
EPA has undertaken cooperative initiatives with
federal agencies, states, industry groups,
professional organintions, and trade associations,
as well as environmental groups and academia.
These joint efforts will serve to determine and
implement a means to share- information on release
prevention technology and practices, and to enhance
the state of practice in the chemical process
safety arena.
PROGRAM GOALS
The CSA program is part of this broad initiative
and has been designed to accomplish the following
chemical accident prevention goals:
Visit facilities handling hazardous substances
to gather information on and learn about safety
practices and technologies;
Heighten awareness of the need for, and promote,
chemical safety among facilities handling
haiardous substances, as well as in communities
where chemicals are located;
Build cooperation among facilities, EPA, and
other authorized parties by coordinating joint
audits; and
Establish a database for the assembly and
distribution of chemical process safety
management information obtained from the
facility audits.
PROGRAM MJTHORITY
The Comprehensive, Environmental Response,
Compensation and Liability Act (CERCLA or
Superfund) was enacted December 11, 1980, and
amended by SARA on October 17, 1986. CERCLA
authorizes the federal government to respond where
there is a release or a substantial threat of a
release' into the environment of any haiardous
substance, pollutant, or contaminant that may
present danger to the public health or welfare or
to the environment.
CERCLA Sections 104(b) and 104
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AUDIT scwe
REPORT DISTRIBUTION
The audit consists of interviews with facility
personnel, and on-site review of various aspects of
facility operations related to the prevention of
accidental chemical releases, Specific topics
addressed include:
Awareness of chemical and process hazards;
Process characteristics;
Emergency planning and preparedness;
Hazard evaluation and release detection
techniques;
Operations and emergency response training;
faciIity/corporate management structure;
Preventive maintenance and inspection programs;
and
Community notification mechanisms and
techniques.
Observations and conclusions from audits are
detailed in a report prepared by the audit team.
The report identifies and characterizes the
strengths of specific Chemical Accident Prevention
program areas to allow the elements of particularly
effective programs to be recognized. Copies of the
report are provided to the facility so that weak
and strong program areas may be recognized. The
audit is conducted following the Guidance Manual
for EPA Chemical Safety Audit Team Members, issued
by EPA Headquarters. This guidance contains
recommended actions, as well as mandatory
procedures that must be followed to ensure the
health and safety of program auditors and program
integrity. Each member of the audit team should
have a copy of the manual, and a copy of the manual
is transmitted to the audited facility.
AUDIT TEAM COMPOSITION
An EPA audit team primarily consists of EPA
employees, and other designated representatives
including contractors and the American Association
of Retired Persons (AARP) enrol lees. Other
federal, state, and local government personnel may
also be team mentiers. The audit team can vary in
size, depending upon the level of detail of the
audit (e.g., number of chenicals and/or processes
under investigation; national significance).
FACILITY SELECTION
At present, there are no established procedures for
selecting a facility for an audit. Each EPA region
has flexibility in identifying facilities. Options
to consider in selecting a facility include:
Previous history of the facility;
SERC and/or LEPC referral;
Proximity to sensitive population(s);
Public sensitivity;
Regional accident prevention initiatives;
Opportunity for sharing new technology;
Population density; and
Concentration of industry in the area.
Standard distribution by EPA regional offices of
the audit report uili be at a miniiwjn to:
SERC and LEPC in which the facility is located;
Facility owner/operator and facility CEO;
EPA Headquarters; and
Any oth&r federal, state, and local agencies or
departments that assisted in conducting the
audit.
Distribution is avaitable to other EPA offices,
other federal, state, and local agencies or
departments, and other private and public sector
organizations.
ACCOMPLISHMENTS
During the first four years of the CSA program, the
regions have conducted audits at over 150
facilities in 46 states and Puerto Rico. EPA has
analyzed the conclusions and reconmendations listed
in the audit reports to identify trends, within and
across industries, processes, and chemicals to
assist in the further development of the CSA and
CAP programs, particularly in light of the
accidental release provisions of section 112(r) of
the Clean Air Act. At the same time, follow-up
activities performed by several of the regional
offices indicate that the majority of the
recommendations to improve chemical process safety
practices suggested by the audit teams have been
implemented or are scheduled to be implemented at
audited facilities.
CSA PROGRAM BENEFITS
Identification of effective, field-proven
chemical accident prevention technologies and
practices.
Better understanding of the causes of chemical
releases.
Greater awareness by facilities of chemical
safety and understanding of available
techniques, and specific suggestions for
improved programs.
Identification of problem areas in industry
where more attention is needed.
Cooperation and coordination of chemical safety
programs with other federal and state agencies
through joint audits and training.
For more information on the Chemical Safety Audit
program, contact the Chemical Emergency
Preparedness Program (CEPP) office in your EPA
regional office.
11/95
viii
EPA Fact Sheet
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ACRONYMS AND ABBREVIATIONS
AC
alternating current
AARP
American Association of Retired Persons
ALOHA
Areal Locations of Hazardous Atmospheres (model)
ARIP
Accidental Release Information Program
CAER
Community Awareness and Emergency Response
CAMEO
Computer-Aided Management of Emergency Operations
CBI
confidential business information
CERCLA
Comprehensive Environmental Response, Compensation and Liability Act of 1980
CHARM
Complex Hazardous Air Release Model
CEPPO
Chemical Emergency Preparedness and Prevention Office
CSA
chemical safety audit
CFR
Code of Federal Regulations
DC
direct current
EIS
emergency information system
EPA
U.S. Environmental Protection Agency
ERNS
Emergency Response Notification System
FMEA
Failure Modes and Effects Analysis
FMECA
Failure Modes, Effects, and Criticality Analysis
FEMA
Federal Emergency Management Agency
FOIA
Freedom of Information Act
GIGO
garbage in - garbage out
HMIS
Hazardous Management Information System
HAZMAT
hazardous materials
HAZOP
hazardous operations
IDLH
immediately dangerous to life and health
LEPC
local emergency planning committee
MSDS
material safety data sheet
NFPA
National Fire Protection Association
NIOSH
National Institute of Occupational Safety and Health
NOAA
National Oceanic and Atmospheric Administration
OSHA
Occupational Safety and Health Administration
ORC
Office of Regional Council
11/95
ix
Acronyms and Abbreviations
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P&IDs piping and instrumentation diagrams
PHA preliminary hazards analysis
PFD process flow diagram
POTW publically owned treatment works
PPE personal protective equipment
PSM process safety management
RMP risk management program
SAFER Systems Approach for Emergency Response
SARA Superfund Amendments and Reauthorization Act
SERC state emergency response commission
SOP standard operating procedure
TAT technical assistance team
TSD treatment, storage, and disposal facility
11/95
x
Acronyms and Abbreviations
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Chemical Safety Audits (165.19)
Orientation and Introduction
Student Guide
-------
CHEMICAL SAFETY AUDITS
(165.19)
PRESENTED BY:
Halliburton NUS Corporation
EPA Contract No. 68-C2-0121
S-l
Orientation and Introduction
Agenda:
Environmental Response Training Program (ERTP) overview
Synopsis of ERTP courses
Course layout and agenda
Course materials
Facility information
Ghซmical Safety Audit*
Orientation and Introducton
11/05
page 2
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Notes
Chem>cal Safety Audit* 11/85
Orientation and Introduction pa9* 3
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ERTP OVERVIEW
Comprehensive Environmental Response, Compensation
and Liability Act of 1980
(CERCLA)
Superfund Amendments and Reauthorization Act of 1986
(SARA)
U.S. Environmental Protection Agency
(EPA) J
Environmental Response Training Program I
(ERTP)
S-2
ERTP Overview
In 1980, the U.S. Congress passed the Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA), also known as Superfiind. In 1986, the Superfund Amendments and
Reauthorization Act (SARA) was passed. This act reauthorized CERCLA. CERCLA provides for
liability, compensation, cleanup, and emergency response for hazardous substances released into the
environment and for the cleanup of inactive waste disposal sites. The Environmental Protection Agency
(EPA) allocated a portion of Superfund money to training. EPA's Environmental Response Team (ERT)
developed the Environmental Response Training Program (ERTP) in response to the training needs of
individuals involved in Superfund activities.
Chemical Safety Audit*
Orientation and introduce on
11/95
page 4
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Notes
Chemical Safety Audits 11/95
Orientation and introduction sปsa 5
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ERTP OVERVIEW
U.S. Environmental Protection Agency
(EPA)
I
Office of Solid Waste and Emergency Response
(OSWER)
I
Environmental Response Team
(ERT)
Environmental Response Training Program
(ERTP)
S-3
ERTP Overview
ERTP is administered by ERT, which is part of EPA's Office of Solid Waste and Emergency Response
(OSWER). ERT offices and training facilities are located in Cincinnati, Ohio, and Edison, New Jersey.
ERT has contracted the development of ERTP courses to Halliburton NUS Corporation (EPA Contract
No. 68-C2-0121). The ERTP program provides education and training for environmental employees at
the federal, state, and local levels in all regions of the United States. Training courses cover areas such as
basic health and safety and more specialized topics such as air sampling and treatment technologies.
Ciwnical Safety Audits
Orientation and introduction
11/86
paeปs
-------
Notes
Chamical Safety AwfifH* 11ฎ5
Onarปtปt]Qrt and introduction 7
-------
Types of Credit Available
Continuing Education Units
(2.45 CEUs)
CEU Requirements
100% attendance at this course.
>70% on the exam.
American Board of Industrial Hygiene
(3.5 Certification Maintenance [CM] points, ABIH approval #9632)
Chemical Safety Audits 11/05
Onซntaboo and Introduction 8
-------
Notes
Chemical Safety Audits 11/95
Orientation end Introduction page 9
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ERTP Courses
S-4
S-5
S-6
S-7
S-8
Chemical Safety Audits
Orientation and Introduction
Health and Safety Courses
Hazardous Materials Incident Response Operations (165.5)
Safety and Health Decision-Making for Managers (165.8)
Emergency Response to Hazardous Material Incidents (165.15)
Technical Courses
Treatment Technologies for Supetfund (165.3)
Air Monitoring for Hazardous Materials (165.4)
Risk Assessment Guidance for Superfund (165.6)
Introduction to Groundwater Investigations (165.7)
Sampling for Hazardous Materials (165.9)
Radiation Safety at Supetfund Sites (165.11)
Special Courses
Health and Safety Plan Workshop (165.12)
Design of Air Impact Assessments at Hazardous Waste Sites (165.16)
Removal Cost Management System (165.17)
Inland Oil Spills (165.18)
Courses Offered in Conjunction with Other EPA Offices
s Chemical Emergency Preparedness and Prevention Office (CEPPO)
Chemical Safety A udits (165.19)
S Site Assessment Branch
Preliminary Assessment
Site Investigation
Federal Facilities Preliminary Assessment/Site Investigation
Hazard Ranking System
Hazard Ranking System Documentation Record
11/85
pa go 10
-------
Notes
Ch#mjcai Sataiy Audits 11/95
Onซnta0on and Intoduction 11
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COURSE GOALS
* Describe chemical processes, hazards, and
safety systems
Describe chemical safety management,
emergency response, and computer
modeling
Describe hazard evaluation techniques and
incident investigation
S-9
COURSE GOALS (cont.)
* Describe interviewing techniques and
audit report writing
Conduct an audit based on the U.S.
EPA Guidance Manual for EPA
Chemical Safety Audit Team Members
S-10
Course Goats
This course is based on requirements and guidance specified by the EPA's Chemical Safety Audit
Program, the Occupational Safety and Health Administration's (OSHA) Process Safety Management (29
CFR 1910.119), and EPA's Risk Management Programs for Chemical Accidental Release Prevention (40
CFR Part 68 - as proposed). The material presented, and any corresponding activities, are included to
accomplish the course goals.
Oemieaf Safety Audits
Orientation introductkx*
11/05
-------
Notes
Chemical Safety Audits 11/55
Ormmabon ซfKl Introduction page 13
-------
Course Layout and Agenda
Key Points:
* Agenda times are only approximate. Every effort is made to complete units, and to
finish the day, at the specified time.
* Classes begin promptly at 8:00 am. Please arrive on time to minimize distractions
to fellow students.
* Breaks are given between units.
Lunch is 1 hour.
Direct participation in field or lab exercises is optional. Roles are randomly assigned
to ensure fairness.
Attendance at each lecture and exercise is required in order to receive a certificate.
Cbซmปc*i Siftrty Audit*
Orwittbofl ami IntoducSon
11/95
p*0*14
-------
Notes
Ch#mieal Safaty Audrti 11/95
Orientation and Introduction page 15
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Training Evaluation
The Training Evaluation is a tool to collect valuable feedback from YOU
about this course.
We value YOUR comments!! Important modifications have been made to
this course based on comments of previous students.
DO
DON'T
Write in your comments at the end of
each unit!
Hold back!
Tell us if you feel the content of the
course manual (and workbook) is clear
and complete!
Focus exclusively on the presentation
skills of the instructors.
Tell us if you feel the activities and
exercises were useful and helpful!
Write your name on the evaluation, if
it will inhibit you from being direct
and honest.
Tell us if you feel the course will help
you perform related duties back on the
job!
Complete the first page at the end of
the course before you leave!
Write comments in ink.
Chซmie*i Safety Audrts
Qntntatkm and introduction
11*5
-------
Notes
Chemical Safซ!y Audrts 11/95
Griontabon and introduction pag#t?
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Facility Information
O
Qwm
o
Please put beepers in the vibrate mode and
turn off radios. Be courteous to fellow
students and minimize distractions.
Emergency
Telephone
Numbers
S
Emergency Exits
Alarms
Sirens
Chemical Safely Audits
Omentatian and introduction
11*5
page 18
-------
Notes
Chemical Safety Audits 11
Oriftfttatien and Introduction papa 19
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CHEMICAL SAFETY
AUDIT PROGRAM
STUDENT PERFORMANCE OBJECTIVES
At the conclusion of this unit, students will be able to:
1. Describe the chemical release incidents at Bhopal, India
2. State the lesson learned from the Bhopal, India, incident
3. Describe the chemical release incident at Institute, West
Virginia
4. State the lesson learned from the Institute, West Virginia,
incident
5. Describe the Superfund Amendments and Reauthorization
Act, Title III
6. State three goals of the Chemical Accident Prevention
Program, including the fundamental goal
7. State three goals of the Accidental Release Information
Program
8. State three goals of the Chemical Safety Audit Program
9. List four purposes of Chemical Safety Audit training
NOTE: Unless otherwise stated, the conditions for
performance are using all references and materials
provided in the course, and the standards of
performance are without error.
8/96
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STUDENT PERFORMANCE OBJECTIVES (cont.J
10. List three provisions of the Clean Air Act of 1990
11. List five requirements of the OSHA Process Safety
Management regulation
12. List four requirements of the U.S. Environmental Protection
Agency's Risk Management Program.
NOTE: Unless otherwise stated, the conditions for
performance are using all references and materials
provided in the course, and the standards of
performance are without error.
-------
NOTES
CHEMICAL SAFETY
AUDIT PROGRAM
S-t
CHEMICAL SAFETY AUDIT
PROGRAM
Overview and history of the EPA Chemical
Safety Audit Program
INCIDENT
Bhopal, India - Dec. 2, 1984
Facts:
* Release of 50,000 lb of methyl
isocyanate
2,000 deaths and 150,000 injuries
Chung 1993
8/96
1
Chemical Safety Audit Program
-------
NOTES
INCIDENT (cont.)
Bhopal, India - Dec. 2, 1984
Significance:
All the deaths occurred offsite
Lack of understanding of hazards
presented by methyl isocyanate
Chung 1993
INCIDENT (cont.)
Backup system - spare storage tank
Emergency system - refrigeration unit
Monitoring system - pressure gauge
Mitigation system - flare tower, scrubber
Cttung 1993 S*5
Chemical Safety Audit Program
LESSON LEARNED
Having safety equipment is only part
of the solution. Having the right
equipment, proper use and maintenance
is at least as important.
Chung 1993
8/96
-------
NOTES
INCIDENT
Institute, West Virginia - Aug. 11, 1985
Facts:
Accidental release of 5,000 lb of
methylene chloride and aldicarb
oxime
134 persons hospitalized
All injuries were offsite
Chung 1993 S-7
LESSON LEARNED
Institute, West Virginia - Aug. 11, 1985
Poor emergency response contributed
to the number injured
Chung 1993 S-8^
SUPERFUND AMENDMENTS AND
REAUTHORIZATION ACT (SARA)
SARA Title III - Emergency Planning and
Community Right-to-Know Act -1986
Emergency preparedness
* Right-to-know
8/96
3
Chemical Safety Audit Program
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NOTES
SUPERFUND AMENDMENTS AND
REAUTHORIZATION ACT (SARA)
SARA Title III - Emergency Planning and
Community Right-to-Know Act -1986
Structure
- State Emergency Response
Commission (SERC)
- Local Emergency Planning
Committee (LEPC)
Review of emergency systems
EMERGENCY SYSTEMS REVIEW -
1988
Findings:
Holistic approach for prevention
No generic state of art technology
Large chemical producers seem more
aware of the need for chemical process
safety
Chung 1993 S-11
EMERGENCY SYSTEMS REVIEW -
1988 (cont.)
Findings:
Research needed - detectors, sensors,
computer models, etc.
Improve communications for public alert
Chung 1993 S-12
Chemical Safety Audit Program
4
8/96
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NOTES
CHEM|CAL ACCjDENT
PREVENTION PROGRAM
Fundamental Goal:
"Prevent accidental releases of hazardous
chemicals."
Cfang W93 S-13
CHEMICAL ACCIDENT
PREVENTION PROGRAM (cont.)
Program Goals:
Identify needs/develop and share
information
Strengthen SARA Title III process
Work with stakeholders
Chung J993 S-M
ACCIDENTAL RELEASE INFORMATION
PROGRAM (ARIP) GOALS
Identify causes of accidents and ways to
prevent them and stimulate industry
initiatives
Significant releases
National database
Lessons learned and shared
Chung 1993 S-15
8/96
5
Chemical Safety Audit Program
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NOTES
CHEMICAL SAFETY AUDIT (CSA)
PROGRAM GOALS
Understand the problems and successful
practices/technologies for preventing
and mitigating chemical accidents
Heighten awareness of the need for
chemical safety among facilities and
their neighbors in the community
[ U.S. EPA 7903 s-fe
CSA PROGRAM GOALS (cont.)
Establish and enhance a dialogue with
facilities to learn how hazards are
managed
U.S. EPA 1933 S 17 J
CSA PROGRAM GOALS (cont.)
Establish a database for the assembly
and distribution of chemical safety
information obtained from facility
audits and from other sources
U.S. EPA 19S3 S-t8
Chemical Safety Audit Program
6
8/96
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NOTES
FACILITIES AND CHEMICALS
AUDITED
Refineries/petrochemical - fuels, plastics,
etc.
Chemical producers - acids, pesticides,
etc.
Refrigeration plants - ammonia
Water treatment plants - chlorine gas
U.S. EPA 19959 S-18
Chemical Safety Audits and
Reports by Region
FY 1989 through 1994
Reaion Audits
Reports
Region
Audits
Reports
1 20
20
6
26
26
2 19
14
7
42
42
3 29
29
8
26
26
4 49
48
9
22
22
5 22
17
10
26
26
Total Audits - 281
Total Reports -
270
U.S. EPA 1995b S-20
PURPOSE OF CSA
TRAINING
Provide an understanding of EPA's CSA
program
Provide tools and knowledge to conduct
effective audits
Chung 1SS3 S-21
8/96
7
Chemical Safety Audit Program
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NOTES
PURPOSE OF CSA
TRAINING (cont.)
Provide basis for participation in an audit
with EPA
Provide knowledge of chemical process
safety management for use in enhancing
dialogue with industry
Chung 1993 S-22
CLEAN AIR ACT AMENDMENTS
OF 1990
General duty clause: Industry's
responsibility to prevent release
and minimize the consequences
of accidental releases
Regulations and guidance
- Process safety management (OSHA)
- Risk management program (EPA)
as. EPA 1996a S-23
CLEAN AIR ACT AMENDMENTS
OF 1990 (cont.)
Creation of Chemical Safety and Hazard
Investigation Board
SERCs and LEPCs will be involved
States may adopt various parts of the
regulations
U.S. EPA 1995a S-24
Chemical Safety Audit Program
S
-------
NOTES
CLEAN AIR ACT AMENDMENTS
OF 1990 (cont.)
Process Safety Management
- OSHA 29 CFR 1910.119
(1992, final rule)
Risk Management Program
- EPA 40 CFR Part 68
(1996, final rule)
REGULATIONS
OSHA - workplace impacts
EPA - offsite consequences
Chung 1093 S-26
REGULATIONS (cont.)
OSHA-29 CFR 1910.119
- 137 highly hazardous chemicals,
toxics, and reactives
S-27,
8/96
Chemical Safety Audit Program
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NOTES
REGULATIONS (cont.)
* EPA - 40 CFR Part 68
- 140 regulated substances
- 77 regulated toxic substances
- 63 regulated flammable
substances
US, EPA 1996c; 50 FB 447a S-28
PROCESS SAFETY
MANAGEMENT
Process safety information
Process hazard analysis
(Standard) operating procedures
(SOPs)
29 CFR 1910.119; 40 CFR ซ
PROCESS SAFETY
MANAGEMENT (cont.)
Training
Contractors (OSHA only)
Prestartup (safety) reviews
Mechanical integrity (maintenance)
28 CFR 1310.1 IB: 40 CFR SB S-30
Chemical Safety Audit Program
10
8/96
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NOTES
PROCESS SAFETY
MANAGEMENT (cont)
Management of change
Incident (accident) investigation
Compliance (safety) audits
Emergency planning and response
29 cm 1910.119; 40 Cfft 88 8-31 j
R|SK MANAQEMENJ
PROGRAM
Offsite consequence analysis
Five-year history of releases
Prevention program
40 CFR 68 S-32
RISK MANAGEMENT
PROGRAM (cont.)
Emergency response program
Management system
Risk management plan (RMP)
40 CFR ฃ8 S-33
8/96
11
Chemical Safety Audit Program
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NOTES
RISK MANAGEMENT
PROGRAM (cont.)
Levels of compliance
- Program 1
- Program 2
- Program 3
40 cm 65
S-34
RISK MANAGEMENT
PROGRAM (cont.)
Register electronically
Available to:
- SERC
- LEPC
- Public
40 CFfl 68
S-35
CHEMICAL SAFETY AUDIT
PROGRAM
Causes - Bhopal, etc.
SARA Title III
Chemical safety auditing
- Process safety management
- Risk management program
S-36,
Chemical Safety Audit Program
12
-------
REFERENCES
29 CFR 1910.119. Process Safety Management of Highly Hazardous Chemicals.
40 CFR 68. Accidental Release Prevention Requirements: Risk Management Programs Under the
Clean Air Act; Section 112(r)(7).
59 FR 4478 (to be codified at 40 CFR 9 and 68). List of Regulated Substances and Thresholds for
Accidental Release Prevention and Risk Management Programs for Chemical Accidental Release
Prevention; Final Rule and Notice.
Chung, T.D. 1993. Chemical Accident Prevention Program. Unpublished report prepared for the
Chemical Safety Audits training course. U.S. Environmental Protection Agency, Chemical
Emergency Preparedness and Prevention Office, Washington, DC.
U.S. EPA. 1993. Chemical Safety Audit Program. Factsheet. U.S. Environmental Protection
Agency, Chemical Emergency Preparedness Program, Washington, DC.
U.S. EPA. 1995a. Chemical Safety Audit Database. EPA Regional Edition. U.S. Environmental
Protection Agency, Chemical Emergency Preparedness Program, Washington, DC.
U.S. EPA. 1995b. The Chemical Safety Audit Program: FY 1994 Status Report (May 1995). U.S.
Environmental Protection Agency, Chemical Emergency Preparedness Program, Washington, DC.
U.S. EPA. 1996a. Chemical Accident Prevention and the Clean Air Act Amendments of 1990.
Factsheet. 550-F-96-004. U.S. Environmental Protection Agency, Office of Solid Waste and
Emergency Response, Chemical Emergency Preparedness and Prevention Office, Washington, DC.
U.S. EPA. 1996b. Clean Air Act Section 112(r): Excerpts from Statute. Factsheet. 550-F-96-005.
U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, Chemical
Emergency Preparedness and Prevention Office, Washington, DC.
U.S. EPA. 1996c. List of Substances for Accidental Release Prevention: Clean Air Act Section
112(r). Factsheet. 550-F-96-003. U.S. Environmental Protection Agency, Office of Solid Waste
and Emergency Response, Chemical Emergency Preparedness and Prevention Office, Washington,
DC.
U.S. EPA. 1996d. Risk Management Planning: Accidental Release Prevention. Final Rule: Clean
Air Act Section 112(r). Factsheet. 550-F-96-002. U.S. Environmental Protection Agency, Office
of Solid Waste and Emergency Response, Chemical Emergency Preparedness and Prevention Office,
Washington, DC.
8/96
13
Chemical Safety Audit Program
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CHEMICAL SYSTEMS
AND PROCESSES
STUDENT PERFORMANCE OBJECTIVES
At the conclusion of this unit, students will be able to:
1. List the function of the following chemical facility
equipment:
a. Pipes
b. Valves
c. Pumps
d. Tanks
e. Fans
f. Compressors
g. Heat exchangers
2. Describe the function of water treatment and steam
generating systems
3. Describe the function of reactor and distillation systems
4. List the function of the following basic types of chemical
facility instrumentation:
a. Sensors
b. Recorders
c. Alarms
d. Controllers
e. Basic control loops/systems
NOTE: Unless otherwise stated, the conditions for
performance are using all references and materials
provided in the course, and the standards of
performance are without error.
11/95
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NOTES
CHEMICAL SYSTEMS
AND PROCESSES
S-1
SYSTEMS AND EQUIPMENT
Equipment
- Piping
- Valves
- Pumps
SYSTEMS AND EQUIPMENT
Systems
- Water treatment systems
- Control systems
- Reactor systems
- Distillation systems
11/95
i
Chemical Systems and Processes
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NOTES
BASIC CHEMICAL PLANT
OPERATIONS
Introduction
Process Equipment
Process Systems
Chemical Process Systems
Instrumentation and Control s.<
j
Chemical Systems and Processes
2
11/95
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REFERENCES
NUS Training Corporation. 1984. Basic Chemical Plant Operations, Segments 1 through 5:
Introduction, Process Equipment, Process Systems, Chemical Systems, and Instrumentation and
Control. NUS Training Corporation, Gaithersburg, MD. Used with permission of NUS Training
Corporation,
11/95
3
Chemical Systems and Processes
-------
CHEMICAL PROCESS HAZARDS
STUDENT PERFORMANCE OBJECTIVES
At the conclusion of this unit, students will be able to:
1. Describe three chemical process hazards associated with
pressure
2. Describe four chemical process hazards associated with flow
3. Describe two chemical process hazards associated with level
4. Describe two chemical process hazards associated with
temperature
5. Describe three chemical process hazards associated with
storage and handling
6. Describe three chemical process hazards associated with
mixing
7. Describe four chemical process hazards associated with loss
of containment
8. Describe four chemical process hazards associated with
facility design.
NOTE: Unless otherwise stated, the conditions for
performance are using all references and materials
provided in the course, and the standards of
performance are without error.
-------
NOTES
Chemical Process
Hazards
CHEMICAL HAZARDS
Flammability
Explosivity
Radioactivity
CHEMICAL HAZARDS (cont.)
Reactivity
Corrosivity
Toxicity
11/95
1
Chemical Process Hazards
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NOTES
PROCESS HAZARDS
* Process variables
* Process operations/design
PROCESS VARIABLES
Pressure
Flow
Level
Temperature
PRESSURE
Overpressure
Underpressure
Shock/stress - "water hammer"
Chemical Process Hazards
2
11/95
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NOTES
FLOW
Fluctuating flow
Overflow
Underflow
Reversed flow
LEVEL
Overfilling
Underfilling
TEMPERATURE
High temperature
Low temperature
S-9
J
11/95
3
Chemical Process Hazards
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NOTES
PROCESS
OPERATION/DESIGN
Storage and handling
Mixing
Containment
Design
Human factors
STORAGE AND HANDLING
Storing incompatible materials
together
Storing materials under improper
conditions
Handling materials improperly
INCOMPATIBLE MATERIALS
Flammables and oxidizers
Flammables and poisons
Corrosives and organics
Explosives and anything else
Chemical Process Hazards
4
11/95
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NOTES
MIXING
Uneven mixing
Loss of agitation
Vibration
S-13
CONTAINMENT
Loss of Containment
Overfilling tanks
Pump seal leaks
Corrosion
Spills
DESIGN
Utilities failure
Control system failure
Underdesign/redesign
Natural disasters
11/95
5
Chemical Process Hazards
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NOTES
HUMAN FACTORS
Human error
Terrorism
Revenge
AUDIT TEAM PERSPECTIVE
What hazards does the facility
recognize?
What value does the facility place on
perceived hazards?
How does the facility manage
hazards?
S-17
Chemical Process Hazards
6
11/95
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REFERENCES
U.S. EPA. 1991. Chemical Safety Audit Program Resource Guide. U.S. Environmental Protection
Agency, Office of Solid Waste and Emergency Response, Washington, DC.
11/95
7
Chemical Process Hazards
-------
CHEMICAL SAFETY AUDIT
MANUAL REVIEW
STUDENT PERFORMANCE OBJECTIVES
At the conclusion of this unit, students will be able to:
1. State the authority for the chemical safety audit program
2. Describe U.S. Environmental Protection Agency (EPA)
policy and procedures relative to:
a. Facility consent or invitation
b. Handling of confidential business information
c. Attorney client privilege
d. Relationship of chemical safety auditing to enforcement
and compliance with EPA regulatory programs
3. Describe the roles and responsibilities of chemical safety
audit team members
4. List seven actions that are required activities under the EPA
chemical safety audit program protocol.
NOTE: Unless otherwise stated, the conditions for
performance are using all references and materials
provided in the course, and the standards of
performance are without error.
11/95
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NOTES
CHEMICAL SAFETY
AUDIT
MANUAL REVIEW
GUIDANCE MANUAL FOR EPA
CSA TEAM MEMBERS
Revised June 1993
Purpose
* Provides EPA policies and
procedures for implementing
the Chemical Safety Audit
(CSA) program
GUIDANCE MANUAL FOR EPA
CSA TEAM MEMBERS (cont.)
Contents
Introduction
Program authority under CERCLA
Role of audit team members
Preparing for the audit
11/95
1
Chemical Safety Audit Manual Review
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NOTES
GUIDANCE MANUAL FOR EPA
CSA TEAM MEMBERS (cont.)
Contents
Conducting the audit
Audit protocol/report preparation
guidance
Audit follow-up activities
SECTION 1: INTRODUCTION
Program background and overview
Required vs. recommended activities
CSA and Section 112(r) of the Clean
Air Act
SECTION 2: PROGRAM
AUTHORITY UNDER CERCLA
Statutory authority
EPA policy and practice
Facility consent
- Confidential information
- Attorney-client privilege
Chemical Safety Audit Manual Review 2
11/95
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NOTES
PROGRAM AUTHORITY
UNDER CERCLA (cont.)
Response actions
Relationship to
enforcement/compliance
regulatory programs
CERCLA and SARA Title 111
8-7
-
STATUTORY AUTHORITY
CERLCA Sections 104(b) and 104(e)
as amended by SARA in 1986
Authority to EPA and designated
representatives
Authority not applicable to other
federal agencies or state and local
governments
CONFIDENTIAL INFORMATION
Facilities can claim information is
confidential under CERCLA Section
104(e)
EPA employees and authorized
representatives can access
confidential business information
under CERCLA
11/95
3
Chemical Safety Audit Manual Review
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NOTES
ATTORNEY-CLIENT PRIVILEGE
Facility may withhold information
based on attorney-client privilege
* Procedures to follow
- Continue audit unless absence
of information makes it impossible
to do so
8-10
ATTORNEY-CLIENT
PRIVILEGE (cont.)
Procedures to follow
- Contact EPA's Office of
Regional Counsel (ORC)
8-tl
ATTORNEY-CLIENT
PRIVILEGE (cont.)
Procedures to follow
- Provide ORC with
J Name of document(s) withheld
/ Reason why withheld
J Facility attorney, address, and
telephone number
8*12
Chemical Safety Audit Manual Review
4
11/95
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NOTES
RESPONSE ACTIONS
If threat of release is observed during
an audit, the following actions must
be taken:
- Regroup the team
- Inform facility
RESPONSE ACTIONS (cont.)
- If the facility fails to appropriately
respond to the threat of a release,
contact the Regional Response
Center to determine scope of action
3-14
RESPONSE ACTIONS (cont.)
If release occurs at a facility:
- Follow facility procedures for
protection
- Contact the National and Regional
Response Centers
3-16
11/95
5
Chemical Safety Audit Manual Review
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NOTES
ENFORCEMENT/COMPLIANCE
REGULATORY PROGRAMS
EPA CSA is not an enforcement or
compliance inspection
Findings and recommendations are not
mandatory
Observed violations should be referred to
the respective program office for further
action
t-i#
ROLE OF AUDIT
TEAM MEMBERS
Audit team composition
Training and safety requirements
Non-EPA audit team participation
Liability
Conflict of interest
8-1?
AUDIT TEAM
COMPOSITION
Team composition considerations
- Size (3-6 members)
- Expertise
S-fซ
Chemical Safety Audit Manual Review
6
11/95
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NOTES
AUDIT TEAM
COMPOSITION (cont.)
Team leader - leads site visit;
including logistics, assignments,
liaison with facility personnel, and
quality assurance of site visit report
EPA employee
$18
AUDIT TEAM
COMPOSITION (cont.)
Deputy team leader - provides
logistical support and assumes
other responsibilities as directed
by the team leader
EPA employee or representative
S-20
AUDIT TEAM
COMPOSITION (cont.)
Chemical process hazards reviewer -
evaluates chemical hazards, process
engineering, maintenance
procedures, and process operations
EPA employee or representative
8-21
11/95
7 Chemical Safety Audit Manual Review
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NOTES
AUDIT TEAM
COMPOSITION (cont.)
Chemical accident prevention
reviewer - evaluates hazard
assessment and modeling
techniques, release prevention
systems, and mitigation systems
AUDIT TEAM
COMPOSITION (cont.)
Safety and training reviewer -
evaluates operator and maintenance
safety and worker right-to-know
training programs
S-23
AUDIT TEAM
COMPOSITION (cont.)
Emergency planning and response
reviewer - evaluates facility
emergency planning and response
procedures
am
Chemical Safety Audit Manual Review
8
11/95
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NOTES
AUDIT TEAM
COMPOSITION (cont.)
Select the appropriate mix of skills
- Process and safety system
technologies
- Operating procedures
- Training programs
- Management programs
AUDIT TEAM
COMPOSITION (cont)
Identify specific roles for each team
member
Team member representatives
- EPA employees
- Technical Assistance Team (TAT)
members
s-2e
AUDIT TEAM
COMPOSITION (cont.)
Team member representatives
- American Association of Retired
Persons (AARP) enrollees
- Other federal, state, and local
governments
S-27
11/95
9
Chemical Safety Audit Manual Review
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NOTES
TRAINING AND SAFETY
REQUIREMENTS
Required for EPA team members
24- or 40-hour health and safety
course, In accordance with EPA
Order 1440.2
Site safety plan
Annual medical monitoring
EPA CSA training course
3-2S
LIABILITY
Federal employees
- Federal Employees Liability
Reform and Tort Compensation
Act of 1988
- Suit can be brought against
the United States government
8*29
LIABILITY (cont.)
Contractors/TAT
- No coverage for audit activities
AARP enrollees
- No provisions currently exist
to indemnify AARP enrollees
from personal liability
Chemical Safety Audit Manual Review
10
11/95
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NOTES
LIABILITY (cont.)
Non-EPA personnel
- Require own liability coverage
8*91
CONFLICT OF INTEREST
All persons are prohibited from any
involvement with an audit if any of
the following situations exist:
Prior interest
Financial interest
Prior consultant
Other
SECTION 4:
PREPARING FOR THE AUDIT
Facility selection
Facility notification
Facility background information
Site visit preparation
11/95
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Chemical Safety Audit Manual Review
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NOTES
FACILITY SELECTION
Basic requirements
- Any facility that releases a
CERCLA hazardous substance,
pollutant, or contaminant or
any facility at which there
is a "reason to believe" that
a threat of such a release
exists
144
FACILITY SELECTION (cont.)
Basic requirements
- ORC and SERC/state have been
consulted to identify any
legal actions currently being
pursued or anticipated
S-3S
FACILITY SELECTION (cont.)
Information sources
- National or Regional Response
Center
- Accidental Release Information
Program (ARIP)
- Emergency Response Notification
System (ERNS)
sse
Chemical Safety Audit Manual Review
12
11/95
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NOTES
FACILITY SELECTION (cont)
Previous release history
SERC/LEPC referral
Proximity to sensitive population
Public sensitivity
3-37
FACILITY SELECTION (cont.)
Opportunity for sharing
Population density
Concentration of industry
FACILITY NOTIFICATION
Telephone call to facility
- Establish a point of contact
- Communicate intent of the audit
11/95
13
Chemical Safety Audit Manual Review
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NOTES
FACILITY NOTIFICATION (cont.)
Follow-up notification letter
- Summarize the telephone call
- State authority
- Allow claiming of CB1
- Identify contractor personnel
iซ40
.
FACILITY BACKGROUND
INFORMATION
Release history
Regulatory history
Hazardous chemicals
Chemical processes
Community involvement
SITE VISIT PREPARATION
Review audit objectives
Designate authority and
responsibilities
Identify health and safety issues
Establish objectives and agenda for
each day, including logistical issues
S-42
Chemical Safety Audit Manual Review
14
11195
-------
NOTES
SECTION 5:
CONDUCTING THE AUDIT
Entry
Opening meeting
Onsite activities
Exit briefing
ENTRY
Team arrival at predetermined time
and place
Blank sign-in sheet vs. "waiver" or
"visitor release"
Facility revocation of consent to enter
- Notify ORG
8-44
OPENING MEETING
Meeting between audit team and key
facility personnel
Meeting agenda includes:
- Introductions of team and
facility personnel
11/95
15
Chemical Safety Audit Manual Renew
-------
NOTES
OPENING MEETING (cont.)
Meeting agenda includes:
- Overview of audit purpose and
scope
- Facility selection
- Proposed procedures and
schedule
ONS1TE ACTIVITIES
Plant tours
Assign specific tasks - interview,
review, observe
Report items of concern beyond the
scope of the audit to the Team Leader
8*47
EXIT BRIEFING
Meeting with team and facility
personnel
Summarize observations and findings
Present conclusions only if a team
consensus exists
8-4*
Chemical Safety Audit Manual Review
16
11/95
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NOTES
AUDIT FOLLOW-UP ACTIVITIES
Approaches
- Mail worksheets
- Revisit
Information required
- Name and address of facility
- List of recommendations
9*49
J
AUDIT FOLLOW-UP
ACTIVITIES (cont.)
Information required
- Schedule of recommendations that
have been or will be implemented
- Rationale for any
recommendations that have not
been implemented
S-50
AUDIT FOLLOW-UP
ACTIVITIES (cont.)
Information required
- Facility attitude toward audit
- Successful and problematic
audit activities
S-51
11/95
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Chemical Safety Audit Manual Review
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REFERENCES
U.S. EPA. 1993. Guidance Manual for Chemical Safety Audit Team Members. U.S.
Environmental Protection Agency, Office of Solid Waste and Emergency Response, Washington,
DC.
Chemical Safely Audit Manual Review
18
11/95
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AUDIT REPORT WRITING
STUDENT PERFORMANCE OBJECTIVES
At the conclusion of this unit, students will be able to:
1. List three steps involved in preparing to write a U.S.
Environmental Protection Agency (EPA) Chemical Safety
Audit report
2. Describe the report disclaimer
3. Describe the writing style and consistency requirements for
an audit report
4. List the thirteen sections of an EPA Chemical Safety Audit
report
5. Describe the following:
a. Limiting access to draft reports
b. Handling confidential information
c. Finalizing and distributing the report.
NOTE: Unless otherwise stated, the conditions for
performance are using all references and materials
provided in the course, and the standards of
performance are without error.
11/95
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NOTES
AUDIT REPORT WRITING
AUDIT REPORT WRITING
Preparing to write
Writing the report
Distributing the report
PREPARING TO WRITE
Postvisit meeting
Follow-up information
Standard report disclaimer
11/95
1
Audit Report Writing
-------
NOTES
POSTVISIT MEETING
Reassemble the team as soon as
possible
Details can fade from memory
Details can become confused
1 k
FOLLOW-UP INFORMATION
Team leader designates someone to
ask follow-up questions as needed
Follow-up
- Letter
- Telephone call
- In person
STANDARD REPORT
DISCLAIMER
Describes the scope and limitations of
the audit
Required part of the audit report
Found in Section 6.2, page 46, of the
guidance manual
Audit Report Writing
2
11/95
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NOTES
WRITING THE REPORT
Writing style
Flexibility
Report sections
WRITING STYLE
Factual
Relevant
Complete
Objective
WRITING STYLE (cont.)
Clear
Consistent
- Statements in the report
ARE NOT contradictory
- The report appears to be
written by one person
11/95
3
Audit Report Writing
-------
NOTES
FLEXIBILITY
All 13 sections of the audit report
MUST be addressed
If a section is not relevant or was not
audited, state this in the report
Subsections DO NOT have to be
addressed separately
REPORT SECTIONS
Introductory and background
information
- Sections 1 - 4
Chemical hazards and process
information
- Sections 5-6
S-11
REPORT SECTIONS (cont.)
Accident prevention and emergency
preparedness
- Sections 7-11
Conclusions and recommendations
- Sections 12-13
Appendices
Audit Report Writing
4
11/95
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NOTES
INTRODUCTORY AND
BACKGROUND INFORMATION
Section 1 - Introduction
Section 2 - Summary of Findings and
Conclusions
Section 3 - Background
Section 4 - Facility Background
Information
CHEMICAL HAZARDS AND
PROCESS INFORMATION
Section 5 - Chemical Hazards
Section 6 - Process Information for
Hazardous Chemicals
8-14
ACCIDENT PREVENTION AND
EMERGENCY PREPAREDNESS
Section 7 - Chemical Accident
Prevention
Section 8 - Accidental Release
Incident Investigation
8-18
11/95
5
Audit Report Writing
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NOTES
ACCIDENT PREVENTION AND
EMERGENCY PREPAREDNESS
Section 9 - Facility Emergency
Preparedness Activities
Section 10 - Community and Facility
Emergency Response
Planning Activities
S-1#
ACCIDENT PREVENTION AND
EMERGENCY PREPAREDNESS
Section 11 - Public Alert and
Notification Procedures
8-17
CONCLUSIONS
Section 12 - Conclusions
- Based on facts
- Positive and negative
- Highlight safety practices
8-1S
Audit Report Writing
6
11/95
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NOTES
RECOMMENDATIONS
Section 13 - Recommendations
- Observed and documented facility
practices
- Factual, clear, and nonjudgmental
- Technically feasible
S-10
APPENDICES
Useful and relevant to the report
Referenced in the body of the report
Examples - list of audit team
members, MSDS, maps and charts,
accidental release report(s), and
unique SOPs
DISTRIBUTING THE REPORT
Information access
Report recipients
8-21
11/95
1
Audit Report Writing
-------
NOTES
INFORMATION ACCESS
Mark preapprovai (draft) report as
follows:
1. "Pre-decisional Document, Not
Disclosable Under FOIA"
2. "Do Not Cite or Quote"
8-22
INFORMATION ACCESS (cont.)
Confidential business information
- Available to EPA, TATs, and AARP
- Not available to state or local
team members
3-23
REPORT DISTRIBUTION
Handled by Regional CEPPO
Distributed to:
- SERCs and LEPCs
- Facility owner and operator
- EPA headquarters
- Any assisting agencies
3-24
Audit Report Writing
8
11/95
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PROCESS SAFETY EQUIPMENT
STUDENT PERFORMANCE OBJECTIVES
At the conclusion of this unit, students will be able to:
1. State the purpose of process safety systems
2. State the purpose of preventive process safety equipment
3. Describe the function of the following preventive process
safety equipment:
a. Sensors
b. Position indicators
c. Alarms
d. Safety/relief valves
e. Controllers
f. Programmable controllers
g. Distributed control systems
h. Emergency shutdown systems
i. Explosion-proof switches
j. Fail-safe valves
k. Backup pumps
1. Battery backup systems
m. Separators
n. Containment.
NOTE: Unless otherwise stated, the conditions for
performance are using all references and materials
provided in the course, and the standards of
performance are without error.
U/95
-------
NOTES
PROCESS SAFETY
EQUIPMENT
SAFETY SYSTEMS
AND EQUIPMENT
Place process systems
in a safe condition
SAFETY SYSTEMS
AND EQUIPMENT
* Protect workers
* Protect facility
Protect environment
Meet codes, standards, and
regulations
11/95
1
Process Safety Equipment
-------
NOTES
DESIGN
* Prevention
- Designed to prevent an
accident
Mitigation
- Designed to minimize the
effects of an accident
PREVENTION
Instrumentation and control
Fail-safe components
Redundant components
Physical separation
Containment
INSTRUMENTATION
AND CONTROL
Pneumatic (air operated)
Electromechanical
Computer based
Process Safely Equipment
2
11/95
-------
NOTES
INSTRUMENTATION
AND CONTROL (cont.)
Sensors
Indicators/gauges
Alarms
INSTRUMENTATION
AND CONTROL (cont.)
Safety/relief valves
Controllers
Distributed control systems
Emergency shutdown systems
EMERGENCY
SHUTDOWN SYSTEMS
Systems that activate to place a
process, a process unit, or an
entire facility in the safest possible
condition
11/95
3
Process Safety Equipment
-------
NOTES
EMERGENCY
SHUTDOWN SYSTEMS (cont.)
Independent from process system
On-line testing capabilities
Manual or automatic operation
Highly reliable
s-io,
FAIL-SAFE COMPONENTS
Explosion-proof switches
Fail-safe valves
- Fail open
- Fail closed
- Fail as is
REDUNDANT COMPONENTS
Backup pumps
DC (battery) backup for AC controls
(essential service systems)
Process Safety Equipment
4
11/95
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NOTES
PHYSICAL SEPARATION
Separated by
Distance
Walls
Doors
Inert gas
S-13
CONTAINMENT
Double-walled vessels
Containment walls, berms, and dikes
S-14
.
BARRIERS
Flare towers
Water curtains
Scrubbers
S-15
11/95
5
Process Safety Equipment
-------
NOTES
SITE SELECTION
Proximity to sensitive ecosystems
Meteorology
Topography and seismology
Availability and reliability of utilities
RELATIONSHIP TO CHEMICAL
SAFETY AUDITS
What hazards has the facility
identified?
What actions has the facility taken to
prevent or mitigate chemical
releases?
8-17
Process Safety Equipment
6
11/95
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REFERENCES
Crowl, D.A., C. DeFrain, and A. Edelson. 1988. Safety in the Chemical Process Industries. Tape
3, Part 1: Process Area Safety Features, Videotape and Study Guide. Wayne State University,
Detroit, MI. Distributed by the American Institute of Chemical Engineers, Education Department,
345 E. 47th Street, New York, NY.
11/95
1
Process Safety Equipment
-------
PROCESS SAFETY OPERATIONS
STUDENT PERFORMANCE OBJECTIVES
At the conclusion of this unit, students will be able to:
1. List five facets of facility operations that should be reviewed
during a chemical safety audit
2. List three indications of effective safety management
3. Describe four types of information to be covered in standard
operating procedures
4. Describe three types of preventive maintenance
5. Describe the purpose of the following procedures:
a. Lockout/tagout
b. Confined space entry
c. Hot work permit
6. List the four types of required training
7. List five required components of management of change.
NOTE: Unless otherwise stated, the conditions for
performance are using all references and materials
provided in the course, and the standards of
performance are without error.
-------
NOTES
PROCESS SAFETY
OPERATIONS
FACILITY OPERATIONS
Management
Operating procedures
Maintenance
Training
Management of change
MANAGEMENT
Safety-conscious culture
Information flow
Control of change
11/95
1
Process Safety Operations
-------
ฆ" 1 ฆ 11 ""V
OPERATING PROCEDURES
Standard operating procedures
(SOPs)
Lockout/tagout
Confined space entry
Hot work permits
STANDARD
OPERATING PROCEDURES
Normal operations
- Initial start-up
- Normal shut-down
Emergency operations
- Emergency shut-down
- Start-up following
NOTES
Process Safety Operations
2
11/95
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STANDARD OPERATING
PROCEDURES
29CFR 1910.119
Steps for each operating phase
Operating limits
Safety and health considerations
Safety systems and their functions
J J S~6
s *
STANDARD OPERATING
PROCEDURES (cont.)
Process flow diagrams
Piping and instrumentation diagrams
(P&IDs)
S-7
NOTES
11/95
3
Process Safety Operations
-------
UREA BLOCK FLOW DIAGRAM
CO,
NH,
COMPRESSOR
HEATER
Carbamate
Recycle
NH3 Recycle
UREA
S-8
NOTES
Process Safety Operations
4
11/95
-------
r
Ammonia
V 149
Carbon
Dioxide
CV 117
V 150
RATIO
CONTROLLER
RC 101
V 159
PG 121
V 151
CV 118
Cooling Water
V1 52
PRESSURE
CONTROLLER
PC 108
V 153
V 155
V 154
TEMPERATURE
CONTROLLER
TC 107
CV118
Steam
Carbamate Recycle
X
v ieo
V 156
V 158
UREA REACTOR 101
LEGEND
X Manual valve, normally open
Manual valve, normally closed
Control valve, fail open
Control valve, fail closed
Pressure relief valve
0
HHT
HT
HHP
HP
Pressure gauge
High temp, cutoff
High temp, alarm
High press, cutoff
High press, alarm
S-9
V t
NOTES
11/95
5
Process Safety Operations
-------
NOTES
MAINTENANCE
Types of maintenance
- Mechanical
- Pipe fitting
- Welding/boilermaking
- Electrical
- Instrumentation and control
MAINTENANCE (cont.)
Sources of procedures
- Written procedures
- Technical manuals
- Equipment manuals
PREVENTIVE MAINTENANCE
Periodic maintenance
Preventive maintenance
Predictive maintenance
Process Safety Operations
6
11/95
-------
NOTES
LOCKOUT/TAGOUT
29CFR 1910.147
Energy Control Program
- Procedures
- Training
- Inspections
LOCKOUT/TAGOUT (cont.)
29CFR 1910.147
Energy Isolating Devices
- Types
- Requirements
/ Durable
/ Standardized
/ Substantial
- Removal
CONFINED SPACE ENTRY
29CFR 1910.146
Written permit
Hazards monitoring
Protective equipment
Training
11/95
7
Process Safety Operations
-------
NOTES
HOT WORK PERMITS
OSHA 1910.252 (a)
Written permit
Flammable atmospheres
Protective equipment
TRAINING REQUIREMENTS
Operations/maintenance training
Hazard communication training
Emergency response training
Contractor training
PERFORMANCE-BASED
TRAINING
Job/task analysis
Training needs assessment
Performance-based objectives
Process Safety Operations
8
11/95
-------
NOTES
JOB/TASK ANALYSIS
Job/task based
* Skills criteria
Knowledge criteria
S-19
TRAINING NEEDS
ASSESSMENT
Employee based
Skills levels
* Knowledge levels
S-20
PERFORMANCE-BASED
OBJECTIVES
Compare criteria to levels
Identify deficiencies
Develop training objectives
11/95
9
Process Safety Operations
-------
NOTES
HAZARD COMMUNICATION
TRAINING
29 CFR 1910.1200
Identify hazardous materials
Inform employees
- Marking and labeling
- Material safety data sheets (MSDS)
Establish training objectives
322
HAZARD COMMUNICATION
TRAINING (cont.)
29 CFR 1910.1200
MSDS
- Hazards
- Physical/chemical characteristics
- Fire/explosion hazards
- Reactivity
- Health hazards
- Precautions ฑ
EMERGENCY RESPONSE
TRAINING
Evacuation training - 29 CFR
1910.38(a)
Emergency response training - 29
CFR 1910.120
- Awareness level
- Operations level
Process Safety Operations
10
11/95
-------
NOTES
EMERGENCY RESPONSE
TRAINING (conq
Hazardous materials (HAZMAT)
training
- Technician
- Specialist
- Incident commander
CONTRACTOR TRAINING
Application
Employer responsibilities
Contract employer responsibilities
S-26
/
MANAGEMENT OF CHANGE
29CFR 1910.119
Technical basis for change
Impact on safety and health
Modifications to SOPs
11/95
11
Process Safety Operations
-------
NOTES
MANAGEMENT OF
CHANGE (cont.)
29CFR 1910.119
Necessary time period for the change
Authorization requirements
S'20
OPERATING PROCEDURES
REVIEW
Process flow diagrams
- Flow logic
- Raw materials
Piping and instrumentation diagrams
(P&IDs)
- Accuracy
- Last update
| S-29
OPERATING PROCEDURES
REVIEW (cont.)
Material safety data sheets (MSDS)
- Accessibility
- Employer knowledge
Process Safety Operations
12
11/95
-------
NOTES
MAINTENANCE
REVIEW
Are lockout, confined space, and hot
work procedures in place, used, and
documented?
Is type of maintenance supported by
documentation?
S-31 ,
MAINTENANCE
REVIEW (cont.)
Are procedures written for existing
equipment?
Are manufacturers' suggested
procedures being used?
S-32
TRAINING
REVIEW
Are training materials up to date?
Are training materials at proper
educational level?
Is training documentation up to date?
11/95
13
Process Safety Operations
-------
REFERENCES
29 CFR 1910.38(a). Emergency Action Plan.
29 CFR 1910.146. Permit-required Confined Spaces.
29 CFR 1910.147. The Control of Hazardous Energy (Lockout/tagout).
29 CFR 1910.119. Process Safety Management of Highly Hazardous Chemicals.
29 CFR 1910.120. Hazardous Waste Operations and Emergency Response.
29 CFR 1910.252(a). Fire Prevention and Protection.
29 CFR 1910.1200. Hazard Communication.
Process Safety Operations
14
11/95
-------
CONDUCTING INTERVIEWS
STUDENT PERFORMANCE OBJECTIVES
At the conclusion of this unit, students will be able to:
1. List four locations to consider when setting the climate for
interviews
2. List five types of effective questions and an example of each
type
3. List four different situations in which chemical safety audit
interviews could be used
4. List two incentives for interviewee participation
5. List two disincentives for interviewee participation
6. List four ways to get people to share information
7. List six possible responses to questions concerning mistakes
8. List three methods of recording an interview
9. List three management/corporate personnel and types of
information to ask
NOTE: Unless otherwise stated, the conditions for
performance are using all references and materials
provided in the course, and the standards of
performance are without error.
-------
STUDENT PERFORMANCE OBJECTIVES (cont.)
10. List five plant personnel and types of information to ask
11. List six items to cover at the end of the interview process
-------
NOTES
CONDUCTING
INTERVIEWS
SETTING THE CLIMATE
Location
- Office
- Conference room
- Outside plant
- Plant floor
sz
SETTING THE CLIMATE (corit.)
Establish tone
Clarify meeting purpose
Provide nonverbal clues
11/95
1
Conducting Interviews
-------
NOTES
GETTING DOWN TO BUSINESS
Effective Questions
Open
Closed
Leading
Mirror
Loaded ^
GETTING DOWN TO BUSINESS
Effective Questions (cont.)
Open
- "What is involved in your plant's
HAZOP analysis?"
Closed
- "Which database system would
you use?"
GETTING DOWN TO BUSINESS
Effective Questions (cont.)
Leading
- "Don't you think the leaking valve
was the cause?"
Mirror
- "Can you tell me what you meant
by..."
Conducting Interviews
2
11/95
-------
NOTES
GETTING DOWN TO BUSINESS
Effective Questions (cont.)
Loaded
- "Why is the plant safety program
so ineffective?"
CSA INTERVIEWS
Opening meeting
Group interviews
Individual interviews
Closing meeting
CSA INTERVIEWS (cont.)
Incentives to participate
- Personal safety
- Self worth
- Personal goals
Disincentives to participate
- Looking foolish
- Retaliation
11/95
3
Conducting Interviews
-------
NOTES
CSA INTERVIEWS (cont.)
Listen actively
Seek clarification
Handle disagreements
8-10
HOW DO YOU GET PEOPLE TO
SHARE INFORMATION?
Be empathetic
Let them save face
Be nonthreatening
Praise them
S-11
HOW DO YOU GET PEOPLE TO
SHARE INFORMATION? (cont.)
Show appreciation when they share
information
Start with easy questions
Make questions easy to answer
Conducting Interviews
4
11/95
-------
NOTES
PHRASING THE QUESTION
In what ways do you think your
present safety features are
inadequate?
What do you think are the best
aspects of your current safety
procedures? How do you think the
procedures could be improved?
s-13
RESPONSES TO QUESTIONS
CONCERNING MISTAKES
Minimize the problem
Blame someone else
Emphasize the improbability of the
mistakes
RESPONSES TO QUESTIONS
CONCERNING MISTAKES (cont.)
Be defensive
Say the problem has already been
corrected
Protest being unfairly singled out
11/95
5
Conducting Interviews
-------
a * ~""% Trr"oi
NOTES
RECORDING AN INTERVIEW
Take notes
Tape-record the interview
Assign a note taker
Write or record from memory
immediately after the interview
8-18
MANAGEMENT/CORPORATE
PERSONNEL
Plant manager
Legal counsel
Corporate staff
SI?
MANAGEMENT/CORPORATE
PERSONNEL (cont)
Ptant manager
- Facility information
- Management attitudes
- Plant policies
- Financial information
- Management of change
Conducting Interviews
6
11/95
-------
NOTES
MANAGEMENT/CORPORATE
PERSONNEL (cont.)
Legal counsel
- Safety policy
- Workers' compensation
- Permits and compliance
- Legal issues
s-io^
MANAGEMENT/CORPORATE
PERSONNEL (cont.)
Corporate staff
- Management policy
- Safety policy
- New process design
- Audits
- Troubleshooting
3-20
PLANT PERSONNEL
Operations
Maintenance
Engineering
Safety
First responders
.
S-21
11/95
1
Conducting Interviews
-------
NOTES
PLANT PERSONNEL (cont.)
Operations
- Operating procedures
- Emergency procedures
- Day-to-day safety
- Maintenance coordination
- Release monitoring
PLANT PERSONNEL (cont)
Maintenance
- Maintenance procedures
- Replacement standards
- Day-to-day safety
- Operations coordination
S-23
PLANT PERSONNEL (cont.)
Engineering
- Technical information
- Management of change
- Construction standards
- Computer modeling
- Hazard assessment
Conducting Interviews
8
11/95
-------
NOTES
PLANT PERSONNEL (cont.)
Safety
- Training
- Incident investigation
- Construction standards
- Computer modeling
- Hazard assessment
PLANT PERSONNEL (cont.)
First responders
- Emergency plans
- Mitigation and response
- Public alert/mutual aid
- Emergency equipment
AFTER THE INTERVIEW
Thank the interviewee
Review notes
Ask follow-up questions
11/95
9
Conducting Interviews
-------
NOTES
CONCLUDING THE INTERVIEW
Summarize the discussion
Decide on follow-up actions
Obtain commitment
s-a#
Conducting Interviews
10
11/95
-------
REFERENCES
U.S. EPA. 1991, Tips for Conducting an Effective Interview. Chemical Safety Audit Program
Workshop, June 4-7, 1991, Chicago, IL. U.S. Environmental Protection Agency, Chemical
Emergency Preparedness and Prevention Office, Washington, DC.
11/95
11
Conducting Interviews
-------
INCIDENT INVESTIGATION
STUDENT PERFORMANCE OBJECTIVES
At the conclusion of this unit, students will be able to:
1. Describe four elements of analysis
2. Define the following terms:
a. Root cause
b. Primary effect
3. List four types of evidence covered by an evidence
preservation checklist
4. Describe the following:
a. Root cause analysis
b. Cause tree analysis
c. Barrier analysis
d. Change analysis
e. Personnel performance analysis
5. Define the following terms:
a. Culture
b. Climate
6. List three problem climates.
NOTE: Unless otherwise stated, the conditions for
performance are using all references and materials
provided in the course, and the standards of
performance are without error.
11/95
-------
NOTES
INCIDENT
INVESTIGATION
JgAik
3-1
INCIDENT INVESTIGATION
The analysis of an accident or chemical
release to determine why the incident
occurred and, if possible, to develop
methods to prevent its future
occurrence
BASIC ELEMENTS
OF ANALYSIS
Define the problem
Collect information
Perform analysis
Verify results
11/95
1
Incident Investigation
-------
NOTES
DEFINING THE PROBLEM
What is the problem?
When did it happen?
- Relative to time
- Relative to other parts of the
problem
DEFINING THE
PROBLEM (cont.)
Where did it happen?
- Physical location
- Relative to associated components
What is the significance?
- Relative to the goals of the facility
CAUSE-AND-EFFECT CHAIN
Root A Effect/ A Effect/ A Primary
Causet/cause \Tcause V Effect
Incident Investigation
2
11/95
-------
NOTES
ROOT CAUSE
Definition
Root cause
- The cause that, if removed, will prevent
the primary effect
Primary effect
- The effect or problem to be prevented
ROOT CAUSE CRITERIA
Prevent recurrence
Meet facility's goals
Within facility's control
CAUSE-AND-EFFECT CHAIN
/Xooling^v^r
f water A Cooling A
I valve ( i wfater (,
Vfails ^CStฐPSjK
Reactor A
heats upw
RunawayV
reaction- \
Reactor J
explodes/
Root Effect/
Cause cause"*
Effect/
cause
Primary
Effect
S-0
11/95
3
Incident Investigation
-------
NOTES
DEFINING THE PROBLEM
* What is the problem?
A reactor overheated arid exploded
When did it happen?
When the pneumatic cooling water
valve failed and moved to the "closed"
position
3-10
DEFINING THE
PROBLEM (cont.)
* When did it happen?
The cooling water valve failed when
the instrument air supply line to the
valve broke
Where did it happen?
At the cooling water valve controller
S-11
DEFINING THE
PROBLEM (cont)
* What is the significance?
The reactor overheated and exploded,
causing personal injuries, process
interruption, and loss of profit
Incident Investigation
4
11/95
-------
NOTES
COLLECT INFORMATION
Evidence Preservation Checklist
Hardware
- Equipment
- Tools
- Materials (removed arid installed)
S-13
COLLECT
INFORMATION (cont.)
Hardware
- Location and placement of objects
- Environmental factors (noise, heat,
etc.)
Note: Hardware evidence should be
preserved "as found" if possible
/"V I I fm ~"ST"
tmm mm ฆฆฆฆ I
INFORMATION (cont.)
Documentation
- Regulations and orders
- Procedures
- Work instructions
- Photographs
8-15
11/95
5
Incident Investigation
-------
NOTES
COLLECT
INFORMATION (cont.)
Documentation
- Design drawings
- Operator logs
- Charts/computer records
- Maintenance records
COLLECT
INFORMATION (cont.)
Personnel
- Personnel statements
- List of involved people
- Work history
Chronology of events
PERFORM ANALYSIS
For best results, use two or more
analytical techniques
Use cause and effect as one
technique
Write the summary as cause and
effect, starting with the primary effect
Incident Investigation
6
11/95
-------
NOTES
PERFORM ANALYSIS (cont.)
Cause-and-effect analysis
Cause tree analysis
Barrier analysis
Change analysis
Personnel performance analysis
S-18
CAUSE-AND-EFFECT
ANALYSIS
The reactor overheated and exploded
because cooling water flow stopped
when the cooling water valve closed
S*20
CAUSE-AND-EFFECT
ANALYSIS (cont.)
The cooling water valve closed
because 1) the instrument supply line
broke and 2) the valve was
installed in the fail closed position
11/95
7
Incident Investigation
-------
NOTES
CAUSE TREE ANALYSIS
Cooling Water Valve Failed Closed
Design
Valve designed to fail
closed
Maintenance
Valve installed to fail
closed
Inspection
No one noticed that the
valve was fait closed
S-22
BARRIER ANALYSIS
No one noticed the fail closed valve
Not in the inspection procedure
- Problem: Improper procedure
3-23
BARRIER ANALYSIS (cont.)
No one noticed the fail closed valve
In procedure, but not checked
- Problem: Lack of knowledge
(training)
- Problem: Lack of time
(management policy)
8-24
Incident Investigation
8
11/95
-------
NOTES
CHANGE ANALYSIS
The instrument air supply line broke
We replaced the supply line
6 months ago
We had to reroute it around the
new "H" beam
s-as
CHANGE ANALYSIS (cont.)
Investigation shows that vibration
between the supply line and the "H"
beam caused wear
The line wore through and ruptured
PERSONNEL
PERFORMANCE ANALYSIS
Used exclusively for "people
problems"
Requires a solid understanding of
human nature
Helpful in identifying culture and
climate
11/95
9
Incident Investigation
-------
NOTES
CULTURE AND CLIMATE
Culture is the sum of organizational
attitudes as expressed by behavior,
decisions, and beliefs
Climate is the working environment
that results from management policies
and actions
8-tS
CULTURE AND CLIMATE (cont.)
A direct result of management style
Often a major source of root causes
Established within the first 1 or 2
years
S-20
PROBLEM CLIMATES
Broke/fix
"If it ain't broke, don't fix it"
Regulatory fixation
7 don't care if its wrong, the regulator
said to do it"
Incident Investigation
10
11/95
-------
NOTES
PROBLEM CLIMATES (cont.)
ป Not made here
"What do they know? We've got our
own experts"
ป Management by fear
"Just do what you're told"
S3!
PROBLEM CLIMATES (cont.)
Blame someone
"He really fouled up"
Shoot the messenger
"Pm not going to tell them it didn't
work"
CULTURAL CHANGES
Major reorganization of top-levei
management is usually the only way
cultural changes occur
3*33
11/95
11
Incident Investigation
-------
NOTES
VERIFY ROOT CAUSE
Verify that the corrective action will
actually prevent recurrence
Verify that the corrective action is
commensurate with the stated root
cause
3-S4
FALSE ROOT CAUSES
"The root cause was human error"
Human error is a category, not a cause
(it is too broad)
3-35
FALSE ROOT CAUSES (cont.)
"The root cause was bearing failure"
This statement stopped too soon.
Why did the bearing fail?
s-as
Incident Investigation
12
11/95
-------
NOTES
ROOT CAUSE CATEGORIES
Personnel performance problems
Rules known but not used
Lack of attention
Inadequate communication
Inadequate training
S-37
ROOT CAUSE
CATEGORIES (cont.)
Rule problems
Not defined
Incomplete
Incorrect
Not enforced
ROOT CAUSE
CATEGORIES (cont.)
Hardware problems
Design deficiency
Manufacturing deficiency
Installation deficiency
Note: Wearout and/or maintenance are
NOT root causes
11/95
13
Incident Investigation
-------
NOTES
MAXIMS OF ROOT CAUSE
If you do not find and correct the root
cause, you are doomed to repeat it
If you repeat a problem, by definition
you have a programmatic deficiency
S-40
MAXIMS OF
ROOT CAUSE (cont.)
Satisfying the need to be needed will
prevent more personnel problems
than any other act
The essence of root cause analysis is
to think cause and effect
S-41
Incident Investigation
14
11/95
-------
REFERENCES
U.S. EPA. 1991. Incident Investigations. Chemical Safety Audit Program Workshop, June 4-7,
1991, Chicago, IL. U.S. Environmental Protection Agency, Chemical Emergency Preparedness and
Prevention Office, Washington, DC.
11/95
15
Incident Investigation
-------
HAZARD EVALUATION
STUDENT PERFORMANCE OBJECTIVES
At the conclusion of this unit, students will be able to:
Define the following:
a.
Hazards
b.
Accidents
c.
Consequences
d.
Probability
e.
Frequency
f.
Likelihood
g-
Risk
2, List an advantages and a disadvantage for each of the
following:
a. Checklists
b. Safety reviews
c. Preliminary hazard analyses.
NOTE: Unless otherwise stated, the conditions for
performance are using all references and materials
provided in the course, and the standards of
performance are without error.
-------
NOTES
HAZARD EVALUATION
HAZARD EVALUATION
Identifies and describes hazards and
hazard scenarios
Estimates the likelihood and
consequences of hazard scenarios
Establishes relative risks of hazards
Suggests approaches to risk
reduction
HAZARD EVALUATION (cont.)
Definitions
Techniques
- Checklist
- Safety review
- Preliminary hazards analysis
11/95
1
Hazard Evaluation
-------
NOTES
EVALUATION DEFINITIONS
Hazards
- Unsafe acts or conditions that
create the potential for an
accident with undesirable
consequences
EVALUATION DEFINITIONS
(cont.)
Hazards
- Loss of containment of flammable,
combustible, highly reactive, or
toxic materials
- Uncontrolled electrical hazards or
mechanical overpressure
EVALUATION DEFINITIONS
(cont.)
Accident
- Unplanned sequence of events
that has an undesirable
consequence
Hazard Evaluation
2
11/95
-------
NOTES
EVALUATION DEFINITIONS
(cont.)
Consequence
- The impact of the accident in
terms of the effects on people,
property, or environment
EVALUATION DEFINITIONS
(cont.)
Probability
- The statistical chance of an
event occurring in a given
period of time
Frequency
- The number of occurrences per
unit of time
EVALUATION DEFINITIONS
(cont.)
Likelihood
- Probability or frequency
Risk
- A measure of potential human
injury, economic loss, or
environmental impact in terms of
its likelihood and consequences
11/95
3
Hazard Evaluation
-------
NOTES
CHECKLIST
Simple to implement
Covers questions about design and
operation
Contains questions with "yes" or "no"
answers
Identifies common hazards to ensure
compliance
CHECKLIST (cont.)
Applies to equipment, materials, or
procedures associated with facility
changes
Does not help identify new or
unrecognized hazards
Prepared by experienced engineer
CHECKLIST (cont.)
Requires knowledge of system/facility
standard operating procedures
(SOPs)
Used during any stage of a project
Should be audited and updated
regularly ^
Hazard Evaluation
4
11/95
-------
NOTES
CHECKLIST
Advantages
Easy to use
Gives quick results
Level of detail can be varied
Communicates information well
s
CHECKLIST
Disadvantages
Limited to author's experience
Repetition can lead to errors
Provides minimum level of hazard
evaluation
s-
SAFETY REVIEW
Formal onsite examination of facility
Simple to implement
Identifies facility conditions or
operating procedures that could lead
to an accident
11/95
5
Hazard Evaluation
-------
NOTES
SAFETY REVIEW (cont.)
Reviews major risk situations, not
general housekeeping
Output consists of recommendations
and justifications for needed actions
9-1ซ
SAFETY REVIEW (cont.)
Includes interviews with operators,
maintenance staff, engineers, and
management
* Can use other techniques, such as
checklists and fault trees
S-17
SAFETY REVIEW (cont.)
Input should include applicable codes
and standards; P&IDs; procedures;
maintenance, inspection, and testing
records; and process material
characteristics
May take several people 1 week or
more
S-18
Hazard Evaluation
6
11/95
-------
NOTES
SAFETY REVIEW
Advantages
Studies actual equipment arid
operating procedures
Sensitizes facility staff to hazard
awareness
S-19
J
SAFETY REVIEW
Disadvantages
Method lacks formal structure
Reviewers need to be experienced
S-20
PRELIMINARY HAZARDS
ANALYSIS (PHA)
Formal in its implementation
Originally developed to identify
hazards during early design
Focuses on hazardous materials and
major plant systems
11/95
7
Hazard Evaluation
-------
NOTES
PHA (cont.)
Developed by creating a list of
hazards related to materials,
equipment, and operating
environment
3-22
PHA (cont.)
Identify the hazard
- List the potential cause and effect
- List possible corrective or
preventive measures
PHA (cont.)
Requires input data such as unit
design criteria and standards,
and equipment and material
specifications
Prioritizes system for more detailed
analysis
Hazard Evaluation
V
8
11/95
-------
NOTES
PHA (cont.)
Advantage
- Provides early identification
of hazards
PHA (cont.)
Disadvantage
- Will not provide a detailed
hazard analysis
11/95
9
Hazard Evaluation
-------
REFERENCES
U.S. EPA. 1991. Hazard Evaluation Techniques. Chemical Safety Audit Program Workshop, June
4-7,1991, Chicago, IL. U.S. Environmental Protection Agency, Chemical Emergency Preparedness
and Prevention Office, Washington, DC.
Hazard Evaluation
10
11/95
-------
HAZARD EVALUATION TECHNIQUES
[7
STUDENT PERFORMANCE OBJECTIVES
At the conclusion of this unit, students will be able to:
1. Write one question posed by a "what if analysis
2. List two advantages of a "what if analysis
3. List two disadvantages of a "what if analysis
4. List four HAZOP study guide words
5. List four HAZOP study parameters
6. List two advantages of a HAZOP study
7. List two disadvantages of a HAZOP study
8. State the full name of FMECA
9. Describe the difference beetween FMECA and FMEA
10. Draw a fault tree analysis with one "and" gate and one "or"
gate
11. List two advantages of an event tree analysis
12. List two disadvantages of an event tree analysis.
NOTE: Unless otherwise stated, the conditions for
performance are using all references and materials
provided in the course, and the standards of
performance are without error.
11/95
-------
NOTES
HAZARD EVALUATION
TECHNIQUES
HAZARD EVALUATION
"What if analysis
HAZOP studies
FMECA
Fault tree analysis
Event tree analysis
"WHAT IF" ANALYSIS
Examines possible deviations from:
- Design
- Construction
- Modification
- Operating intent
11/95
1
Hazard Evaluation Techniques
-------
NOTES
"WHAT IF" ANALYSIS (cont.)
Questions
- What if Pump A stops running?
- What if the operator opens
Valve B instead of Valve A?
"WHAT IF" ANALYSIS (cont.)
Used to identify
- Hazards
- Hazards scenarios
- Consequences
- Methods of risk reduction
Loose structure - concept adapted to
specific application
"WHAT IF" ANALYSIS (cont.)
Questions from previous analyses are
used as a guide
Questions are almost invariably added
as analysis proceeds
Commonly used to examine proposed
changes to an existing facility/unit
Hazard Evaluation Techniques
2
11/95
-------
NOTES
"WHAT IF" ANALYSIS (cont.)
Analyzes materials, products,
operating procedures, and
management practices
Questions usually start with the inputs
to the process and follow their flow
"WHAT IF" ANALYSIS (cont.)
Input information
- Facility/unit documentation
- Process documentation
- Operating procedures
- Operations interviews
- Maintenance interviews
Users should be experienced
"WHAT IF" ANALYSIS (cont.)
Advantages
- Easy to use
- Flexible
Disadvantages
- Loose structure
- Results depend on users'
experience
34
J
11/95
3
Hazard Evaluation Techniques
-------
NOTES
HAZARDS AND OPERABILITY
(HAZOP) STUDIES
More structured than "What if analysis
Description
- Muitidisciplinary team
- Deviations from design intent
- Brainstorming
HAZOP STUDIES (eont)
Description
- Systematically guided through
facility/unit design
- Structure provided by "guide
words"
HAZOP STUDIES (cont.)
Results include:
- Identification of hazards
- Operability problems
- Recommended changes to
improve safety
8-12
Hazard Evaluation Techniques
4
11/95
-------
NOTES
HAZOP STUDIES (cont.)
Deviations are shown by applying
guide words to process parameters at
nodes (processing points)
For each deviation, the team identifies
credible causes and significant
consequences
8*13
HAZOP STUDIES (cont.)
Guide words
No
More
Less
As well as
Part of
Reverse
Than
3-14
J
HAZOP STUDIES (cont.)
Parameters
Flow
Pressure
Temperature
Level
11/95
5
Hazard Evaluation Techniques
-------
NOTES
HAZOP STUDIES (cont.)
Nodes
Main feed pumps
Reactor
Reactor Feed A
Reactor cooling water
ป-ie
HAZOP STUDIES (cont.)
HAZOP studies are performed in team
meetings
Nodes are specified by the team
leader before the meeting
(example: cooling water flow)
5-17
HAZOP STUDIES (cont.)
Guide words applied
- No cooling water flow
- More cooling water flow
- Less cooling water flow
- Part of cooling water flow
The focus is problem identification,
not necessarily problem solution
s-tt
Hazard Evaluation Techniques
6
11/95
-------
NOTES
HAZOP STUDIES (cont.)
Advantages
- Provides greatest assurance
that all hazards have been
identified
- Can provide both hazard and
operability information
8-10
HAZOP STUDIES (cont.)
Disadvantages
- Effort involved can be significant
- Effort is proportional to complexity
of facility/unit and depth of detail
S-20
J
FAILURE MODES, EFFECTS,
AND CRITICALITY ANALYSIS
FMECA
Tabulates
- Facility/unit equipment
- Equipment failure modes
- Result of failure
- Modes that contribute to accidents
11/95
7
Hazard Evaluation Techniques
-------
NOTES
FMECA (cont.)
Tabulates
- Criticality ranking of accident
(likelihood + severity)
t-22
FMECA (cont.)
Advantage
- Systematic, element by element
procedure that helps ensure
completeness
FMECA (cont.)
Disadvantages
- Not efficient at identifying
combinations of equipment
failures
- Human errors are not usually
examined
8-24
Hazard Evaluation Techniques
8
11/95
-------
NOTES
FAULT TREE ANALYSIS
Formal, deductive technique that
focuses on one particular incident
(top event)
Graphically displays combinations of
equipment failures and human errors
that result in an accident
8-2S
FAULT TREE ANALYSIS (cont.)
Can be used to determine the basic
cause(s) of an incident
Can be used to estimate the
likelihood of an incident
s-ac
FAULT TREE ANALYSIS (cont.)
Requires a complete understanding of
system function, failure modes, and
their effects
11/95
9
Hazard Evaluation Techniques
-------
NOTES
TOP EVENT
AND Gate
Basic
Event
OR Gate
Basic
Event
Basic
Event
a-2ป
FAULT TREE ANALYSIS (cont.)
Advantages
- Thorough
- Systematic
Disadvantages
- Binary (not efficient at identifying
failures with more than two inputs)
- Can be time consuming
EVENT TREE ANALYSIS
Formal, inductive technique that
focuses on a sequence of events that
lead to an incident
Considers the response of operators,
safety systems, etc., to an initiating
event
S-30
Hazard Evaluation Techniques
10
11/95
-------
NOTES
EVENT TREE ANALYSIS (cont.)
Produces chronological sets of
failures that define an incident
-si
Raactor tamp,
alarm alarta
operator
Lost of
cooling
water
(Initiating
Event)
f
Failure
Oparrtor
rMtartt
cooling
watar
Shutdown
system
ฆtops
reaction
D
t
A
AC
ACD
AB
ABD
S-32
EVENT TREE ANALYSIS (cont.)
Advantages
- Graphical, systematic
representation
- Easy to perform
- Easy to understand
Disadvantage
- Binary representation of failures
S-33
11/95
11
Hazard Evaluation Techniques
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EMERGENCY RESPONSE
STUDENT PERFORMANCE OBJECTIVES
At the conclusion of this unit, students will be able to:
1. List four key elements of an emergency action plan
2. Describe three types of emergency evacuations
3. List four elements of emergency response plans
4. Define reportable quantity
5. List the three agencies who may need to be notified in the
event of a release
6. List the five things that must be reported for releases beyond
facility boundaries.
NOTE: Unless otherwise stated, the conditions for
performance are using all references and materials
provided in the course, and the standards of
performance are without error.
11/95
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NOTES
EMERGENCY RESPONSE
EMERGENCY RESPONSE
Emergency action plans
29 CFR 1910.38(a)
Emergency response plans
29 CFR 1910.120/SARA Title III
Release notification
Areas for auditor review
EMERGENCY ACTION PLANS
For evacuation only
(outside agencies handle the
response)
Written plan
(if more than 10 employees)
Covers all reasonably expected
emergencies
11/95
1
Emergency Response
-------
NOTES
ACTION PLAN ELEMENTS
Describe evacuation routes and
procedures
Cover critical operations
Account for all employees
Assign rescue and medical duties
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S-5
ACTION PLAN
ELEMENTS (cont.)
Describe means of reporting
emergencies
List personnel to be contacted for
further information
Include types of evacuations
Emergency Response
2
11/95
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NOTES
TYPES OF
EVACUATION PLANS
Full and immediate evacuation
Nonessential personnel evacuation
Partial evacuation
(e.g., locally contained fires)
ALARMS
29CFR 1910.165
Perceivable
(audible and/or visible)
Distinctive
Established activating procedure
Operational at all times
TRAINING FOR EVACUATION
Train designated personnel to assist
in evacuation
Review the evacuation plan
- When the plan is developed
- Whenever the employee's actions
change
- Whenever the plan changes
11/95
3
Emergency Response
-------
NOTES
REQUIREMENTS FOR
EMERGENCY ACTION PLANS
Shall be kept in the workplace
Shall be available for employee review
Shall include handling small releases
INCIDENTAL RELEASE
Does not pose a significant health or
safety risk
Limited in
- Quantity
- Exposure potential
- Toxicity
- Fire/explosion
8*11
J
MANDATORY EMERGENCY
RESPONSE SITUATIONS
Evacuation required
IDLH conditions
Imminent danger
Exposure to toxic substances
Emergency Response
4
11/95
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NOTES
MANDATORY EMERGENCY
RESPONSE SITUATIONS (cont.)
Limits of personal protective
equipment (PPE) exceeded
Unknown hazards
May migrate offsite
Will require offsite response team
8-13
EMERGENCY RESPONSE
Treatment, storage, and disposal
facilities (TSDs)
(Paragraph R 29 CFR 1910.120)
Agencies engaged in emergency
response to hazardous substance
incidents regardless of location
(Paragraph Q, 29 CFR 1910.120)
s-t<
EMERGENCY
RESPONSE PLANS
Pre-emergency planning
Personnel roles, authority, training,
and communication
Emergency recognition and
prevention
s-is
11/95
5
Emergency Response
-------
NOTES
EMERGENCY
RESPONSE PLANS (cont.)
Safe distances
Site security and control
Evacuation routes and procedures
S-16
EMERGENCY RESPONSE
PLANS (cont.)
Decontamination
Emergency medical treatment
Alerting and response procedures
EMERGENCY RESPONSE
PLANS (cont.)
Critiques and follow-up
- Proactive critiques
- Plan reviews
- Actual responses
PPE and emergency equipment
Emergency Response
6
11/95
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NOTES
EMERGENCY RESPONSE
PLANS (cont.)
Medical surveillance
SARA Title III and other plans
Training
8-19
FIRST RESPONDER
AWARENESS LEVEL
Identify emergencies
Recognize need for additional
resources
Initiate emergency responses
Understand the responder's role
3-20
FIRST RESPONDER
OPERATIONS LEVEL
Defensive responses
Protect nearby persons, property, or
the environment
Confine releases from a safe distance
3-21
11/95
1
Emergency Response
-------
NOTES
HAZARDOUS MATERIALS
TECHNICIAN
Respond to stop releases
Perform advanced control and
containment techniques
Facility certifies competency
S-M
HAZARDOUS MATERIALS
SPECIALIST
Support technicians
Specific knowledge of various
substances
Act as liaison with local, state, and
federal officials
S-23
ON-SCENE INCIDENT
COMMANDER
Implement facility's emergency
response plan
Know and implement the incident
command system
Emergency Response
8
11/95
-------
NOTES
SAFETY OFFICIAL
Appointed by the incident commander
Authority to alter, suspend, or
terminate scene activities
- Inform incident commander
immediately; provide direction
8-28
REPORTING REQUIREMENTS
Hazardous substances
(Reportable quantities)
Extremely hazardous substances
(Threshold planning quantities)
Exposures beyond facility boundaries
S-28
REPORTING REQUIREMENTS
(cont.)
* Reported to:
- National Response Center
- LEPC Emergency Coordinator
- SERC
Transportation releases, call 911
82?
11/95
9
Emergency Response
-------
NOTES
REPORTING REQUIREMENTS
(cont.)
Chemical name
Extremely hazardous substance
Amount released
Time and duration of release
8-2#
REPORTING REQUIREMENTS
(cont.)
Release medium/media
Health risks and precautions
Precautions to take
Name and telephone number for
additional information
3-29
AREAS OF REVIEW
Is plan complete and appropriate?
Is plan coordinated with local, state,
and regional plans?
Emergency Response
10
11/95
-------
NOTES
AREAS OF REVIEW (cont.)
Has training been completed and
documented?
Have critiques been done?
- Tabletop exercises
- Simulations
9-31
11/95
11
Emergency Response
-------
COMPUTER APPLICATIONS
STUDENT PERFORMANCE OBJECTIVES
At the conclusion of this unit, students will be able to:
1. List the three components of a typical hazardous chemical
release computer model
2. Describe three applications of hazardous chemical release
modeling programs
3. Describe three limitations of hazardous chemical release
modeling programs
4. Describe emergency information programs using EIS as an
example
5. Describe the U.S. Environmental Protection Agency
Chemical Safety Audit database.
NOTE: Unless otherwise stated, the conditions for
performance are using all references and materials
provided in the course, and the standards of
performance are without error.
11/95
-------
NOTES
COMPUTER
APPLICATIONS
COMPUTER MODELING
Modeling basics
Emergency information system video
CSA database demonstration
MODELING BASICS
Model components
Applications
Limitations
Facility viewpoint
11/95
1
Computer Applications
-------
NOTES
MODEL COMPONENTS
* Database
- Chemical characteristics
- Process characteristics
- Physical characteristics
Dispersion algorithms
Presentations
8-4
DATABASE
Chemical characteristics
- Boiling point
- Vapor density
- Flash point
- Toxicity
S-6
DATABASE (cont.)
Process characteristics
- Operating pressure
- Operating temperature
- Amount of chemical
- Containment systems
Computer Applications
2
11/95
-------
NOTES
DATABASE (cont.)
Physical characteristics
- Topography
- Meteorology
- Man-made structures
- Sensitive populations
DISPERSION ALGORITHMS
Gaussian
Buoyant/dense gases
Multiphase vapors
Multiple releases
PRESENTATIONS
Database presentations
- Release parameters
- Reports
Dispersion presentations
- Plume footprints
- Maps
Simulations and real time
11/95
3
Computer Applications
-------
NOTES
APPLICATIONS
Identifying hazards
Analyzing vulnerability
Meeting regulations
S-10
IDENTIFYING HAZARDS
Facility hazards
- Areas at risk
- Evacuation routes
Community hazards
- Populations at risk
- Evacuation corridors
8-11
ANALYZING VULNERABILITY
Establishing vulnerability zones
Facilitating community involvement
Planning emergency responses
S-12
Computer Applications
4
11/95
-------
NOTES
LIMITATIONS
Garbage in - garbage out (GIGO)
Purchase and setup costs
Qualifications and training of
operators
LIMITATIONS (cont.)
Maintenance
- Chemical inventories
- Equipment changes
Upgrades
- Real-time applications
- Multiple users
8-14
FACILITY VIEWPOINT
ON MODELING
What model(s) have they chosen?
How well do these models meet their
needs?
11/95
5
Computer Applications
-------
NOTES
FACILITY VIEWPOINT
ON MODELING (cont.)
What strengths and limitations are
evident?
What changes (if any) are planned
and why?
3-13
Computer Applications
6
11/95
-------
INSPECTION TECHNIQUES
STUDENT PERFORMANCE OBJECTIVES
At the conclusion of this unit, students will be able to:
1. Describe three major parts of an Occupational Safety and
Health Administration process safety management inspection
2. List three steps done while preparing for an inspection
3. List five types of facility documents to be reviewed
4. List three items that should be considered under the area of
overall impressions while performing process equipment
inspections
5. List five inspection criteria for valves and piping
6. List six areas of evaluation during inspection of process
controls
7. List five repair practices that should be examined during
maintenance inspections
8. List two community notification areas that should be
reviewed.
NOTE: Unless otherwise stated, the conditions for
performance are using all references and materials
provided in the course, and the standards of
performance are without error.
11/95
-------
INSPECTION
TECHNIQUES
INSPECTION TECHNIQUES
Preparing for inspections
Document review
Process equipment inspections
Maintenance inspections
Community notification
S-2
PREPARING FOR
INSPECTIONS
Review technical literature
Review process hazards
Determine scope of audit
Prepare health and safety plan
NOTES
11/95
1
Inspection Techniques
-------
NOTES
DOCUMENT REVIEW
SOPs, emergency procedures
Block diagrams, P&IDs
Training manuals
Management policies
DOCUMENT REVIEW (cont.)
Release reports
Incident investigation reports
Process hazards analyses
PROCESS EQUIPMENT
INSPECTIONS
Overall impression
- Condition
- Housekeeping
- Accessibility of safety/
emergency equipment
Inspection Techniques
11/95
-------
NOTES
PROCESS EQUIPMENT
INSPECTIONS (cont.)
Process layout
- Separation of flammables/
incompatible chemicals
- Access to emergency respirators
PROCESS EQUIPMENT
INSPECTIONS (cont.)
Tanks and vessels
- Condition and spacing
- Containment
- Marking/labeling
- Grounding
- Alarms and controls
PROCESS EQUIPMENT
INSPECTIONS (cont.)
Valves and piping
- Condition
- Suitability
- Labeling/color coding
- Accessibility
- Conformance with P&IDs
11/95
3
Inspection Techniques
-------
NOTES
PROCESS EQUIPMENT
INSPECTIONS (cont.)
Safety/emergency equipment
- Condition
- Suitability
- Accessibility
- Compatibility
S-10
PROCESS EQUIPMENT
INSPECTIONS (cont.)
Process controls
- Condition
- Control logic
- Suitability
- Visibility
- Manual operation
- Conformance with P&IDs
PROCESS EQUIPMENT
INSPECTIONS (cont.)
Operating practices
- Document availability
- Conformance with procedures
- Supervision
- Training
- Communication with others
Inspection Techniques
4
11/95
-------
NOTES
MAINTENANCE
INSPECTIONS
Preventive maintenance
- Periodic, preventive, or
predictive maintenance
- Documentation
- Inspection policies
8-13
MAINTENANCE INSPECTIONS
(cont.)
Repair practices
- Repair procedures
- Lockout/tagout procedures
- Hot work procedures
- Confined space procedures
3-14
MAINTENANCE
INSPECTIONS (cont.)
Repair practices
- Suitability of spare parts
- Compatibility of spare parts
- Coordination with operations
- Coordination with contractors
11/95
5
Inspection Techniques
-------
NOTES
NOTIFICATION
Notification procedures
Public alert procedures
8-19
HELPFUL HINTS
Determine the scope of the inspection
before the site visit
HELPFUL HINTS (cont.)
Use a logical order for the inspection
- For equipment, follow the flow
path
- For operations, start with general
concerns and work toward specific
concerns
Inspection Techniques
6
11/95
-------
NOTES
HELPFUL HINTS (cont.)
Make checklists and take notes
First impressions are often accurate
S-10
-J
11/95
7
Inspection Techniques
-------
RISK REDUCTION
STUDENT PERFORMANCE OBJECTIVES
At the conclusion of this unit, students will be able to:
1. Define risk reduction
2. Describe three ways that facility design is token into account
in each of the following:
a. Compatibility
b. Warning signs and labels
c. Facility layout
3. List four ways of reducing storage or handling hazardous
materials in a process facility
4. List eight types of equipment used in chemical plants to
mitigate hazards and releases.
NOTE: Unless otherwise stated, the conditions for
performance are using all references and materials
provided in the course, and the standards of
performance are without error.
11/95
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NOTES
RISK REDUCTION
RISK REDUCTION
Risk reduction is lowering the
likelihood or the consequences of an
accident or release
S-2 |
RISK REDUCTION
* Facility design
* Storage, handling, and transfer
Mitigation equipment
Areas for review
11/95
1
Risk Reduction
-------
NOTES
FACILITY DESIGN
Compatibility
- Equipment and process chemicals
- Equipment and process conditions
- Replacement parts
FACILITY DESIGN (cont.)
Warning signs and labels
- Hazards clearly marked
- NFPA fire diamond and HMIS
- Color coding
FACILITY DESIGN (cont.)
Facility layout
- Separation
- Isolation
- Sensitive populations
Risk Reduction
2
11/95
-------
NOTES
STORAGE, HANDLING, AND
TRANSFER
Storage
Handling
Transfer
STORAGE
Reduce inventories
- Raw materials
- Finished products
- Shipping and receiving
TRANSFER
Reduce transfers
- Small or large releases
- Aggregate or bulk storage
11/95
3
Risk Reduction
-------
NOTES
HAZARDOUS MATERIALS
REDUCTION
Substitute less hazardous chemicals
Reduce hazardous chemical
concentration
S-10
MITIGATION EQUIPMENT
Alarms
- Alert; follow with reactive mitigation
- Emergency alarms
Controls
- Automatic controls
- Activated controls
8-11
AREAS FOR REVIEW
Facility Design
Is the process equipment suitable for
its use?
Is the process equipment compatible
with other equipment, process
chemicals, and process conditions?
s-ia
Risk Reduction
4
11/95
-------
NOTES
AREAS FOR REVIEW
Facility Design (cont.)
Are replacement parts compatible
with process equipment?
Are warning signs and labels posted,
easy to read, and accurate?
S-t3
AREAS FOR REVIEW
Facility Design (cont.)
Are hazardous chemicals separated
or isolated from incompatible
chemicals?
Are hazardous chemicals separated
from sensitive populations?
AREAS FOR REVIEW
Storage and Transfer
Can raw material or product
inventories be lowered?
Can the number of hazardous material
transfers be reduced? Is it wise to
reduce them?
8-1S
11/95
5
Risk Reduction
-------
NOTES
AREAS FOR REVIEW
Storage and Transfer (cont.)
Would aggregate storage lead to
smaller releases?
Can less hazardous chemicals be
substituted?
Can hazardous chemical
concentrations be reduced?
AREAS FOR REVIEW
Equipment
What kinds of alarms and controls are
in use? Are they effective and
appropriate?
What other kinds of equipment are in
use? Is the equipment effective and
appropriate?
3-17
INFORMATION
SOURCES
Recommendations
- Past experience
- Previous audits
- Facility personnel
S-1#
Risk Reduction
6
11/95
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Guidance Manual for
EPA Chemical Safety Audit Team Members
Chemical Emergency Preparedness and Prevention Office
Office of Solid Waste and Emergency Response
U.S. Environmental Protection Agency
June 1993
-------
Note: This Manual supersedes all previous versions.
-------
Table of Contents
Item Page
1. Introduction
1.1 Purpose of this Manual 1
1.2 Program Background and Overview 1
1.3 CSA Program and Section 112 (r) of the Clean Air Act 4
2. Program Authority Under CERCLA
2.1 Purpose of the Statute
2.2 Facility Entry and Information Gathering Tools
2.2.1 Statutory Authority
2.2.2 EPA Policy and Practice
2.2.3 Confidential Information
2.2.4 Attorney-Client Privilege
2.3 Response Actions if a Release or a Threat of a Release Exists
2.4 Relationship to Enforcement/Compliance Regulatory Programs
2.5 Relationship Between CERCLA and SARA Title III
3. Role of Audit Team Members
3.1 Audit Team Composition
3.2 Training and Safety Requirements
3.3 Non-EPA Personnel Participation on Audit Team
3.4 Liability
3.4.1 Federal Employees
3.4.2 AARP Enrollees
3.4.3 Technical Assistance Team Contractors
3.4.4 Federal, State/SERC, and Local/LEPC Government Personnel
3.5 Conflict of Interest
4. Preparing for the Audit
4.1 Facility Selection 19
4.2 Facility Notification 20
4.3 Facility Background Information 21
4.4 Preparing for the Site Visit 21
5
5
5
5
6
6
7
8
9
11
14
15
16
16
16
17
17
17
-------
Item Page
5. Conducting the Audit
5.1 Entry 23
5.2 Opening Meeting 23
5.3 On-Site Activities 24
5.4 Exit Briefing 24
6. Audit Protocol/Report Preparation Guidance
6.1 Purpose and Structure 25
6.2 Writing the Report 44
6.2.1 Post-Visit Meeting 44
6.2.2 Tips for Writing the Report 44
6.2.3 Follow-up Information 46
6.2.4 Standard Report Disclaimer 46
6.3 Review and Finalization Procedures 47
6.3.1 Access to Draft Information 47
6.3.2 Facility Confidential Information 47
6.4 Report Distribution 47
6.5 Preparing the Report Profile 48
7. Audit Follow-Up Activities
7.1 Follow-Up Approaches 51
7.2 Specific Information Required 52
Exhibits
1. Outline of Protocol/Report Preparation Guidance
2. Annotated Protocol/Report Preparation Guidance
26
29
-------
Attachments
1. Chemical Safety Audit Program Fact Sheet
2. CERCLA Provisions Overview and CERCLA Statute
3. Model Site Safety Plan for Chemical Safety Audits
4. Sources of Information Concerning Hazardous Substance Releases
5. Sample First Letter to Facility Owner/Operator
6. Sample Letter to Facility Owner/Operator Who has not Responded or Consented
to the Audit
7. Standard Report Disclaimer
8. Standard Language for Audit Report Introduction
9. Documentation Pertaining to the Processes and Operations Using Hazardous
Substances
10. Description of Standard Operating Procedure Manuals
11. Blank CSA Report Profile
12. Annotated CSA Report Profile
-------
1, Introduction
1.1 Purpose of this Manual
The purpose of this Manual is to provide guidance to the U.S. EPA regional
offices in implementing the Chemical Safety Audit (CSA) program, which is an outgrowth
of the efforts of the Environmental Protection Agency (EPA) under the Chemical
Accident Prevention (CAP) program. This document is intended solely as guidance. It
does not represent final agency action nor is it ripe for judicial review. This is not
intended, nor can it be relied upon, to create any rights enforceable by any party in
litigation with the United States. The Agency may change this guidance at any time
without public notice.
This Manual, commonly referred to as the "Blue Book," includes a discussion of
the following topics:
Audit authority under CERCLA;
Roles and responsibilities of audit team members;
Audit preparation;
Conducting the audit;
Audit protocol and report preparation; and
Audit follow-up activities.
It is recommended that each audit team member have a copy of this Manual to
be used in conjunction with the Training Manuals provided at the Chemical Safety Audit
Training Course. This Manual contains recommended actions, as well as mandatory
procedures that must be followed to ensure the health and safety of program auditors as
well as program integrity. All required/mandatory procedures or activities presented in
this Manual are identified with the words "[Required Activity]" at the end of the
sentence in which they are presented. Unless noted as a required activity, the described
procedure is considered a recommendation, and the regional office has discretion in its
implementation.
1.2 Program Background and Overview
The Chemical Accident Prevention (CAP) program emerged from concerns raised
by the release of methyl isocyanate at Bhopal, India, and of aldicarb oxime at Institute,
West Virginia. Awareness of the critical threat to public safety posed by similar incidents
led to an emphasis on preparedness and planning for response to chemical accidents.
Simultaneous with the development of preparedness activities by EPA was the passage
and implementation of the Emergency Planning and Community Right-to-Know Act -
Title III of the Superfund Amendments and Reauthorization Act (SARA) in 1986.
Because prevention is the most effective form of preparedness, the CAP program
promotes the effort to enhance chemical accident prevention activities. The primary
objectives of the CAP program are to identify the causes of accidental releases of
hazardous substances and the means to prevent them from occurring, to promote
-------
industry initiatives in these areas, and to coordinate activities with the community,
industry, and other groups (e.g., academia, professional organizations, and trade
associations).
Many of the key concerns of the CAP program arise from the SARA Title III
section 305(b) study entitled Review of Emergency Systems. This study, published in
June 1988, made a number of recommendations on the future course of prevention
activities by EPA, and identified several aspects of current practices that will require
careful consideration in an overall prevention strategy. The study identified the
importance of facility management commitment to implementing and maintaining systems
to prevent, mitigate, and prepare for potential chemical accidents. First, while it is
evident that risk awareness among the larger chemical producers is high, many large
distributors and users of hazardous chemicals, as well as many smaller operations, have
not yet attained a comparable level of accident consciousness. The study also indicated
the need for new technologies in certain key areas: process area monitoring devices,
back-up detectors, mitigation devices, and practices to adequately identify disabled
equipment of these types. Third, the report suggested that a great degree of caution
must be exercised in analyses using real-time dispersion models, and indicated that
employee familiarity with hazard evaluation methods was limited, which in turn suggests
that improper or ineffective techniques may be in practice. Finally, the examination of
management practices revealed a failure to place sufficient emphasis on safety-related
issues such as standard operating procedures, employee training, preventive maintenance,
and post-accident investigation, as well as a general lack of commitment to safety.
As a follow-up to this national prevention study, EPA has undertaken cooperative
initiatives with other federal agencies, states, industry, professional organizations, and
trade associations, as well as environmental groups and academia. These joint efforts
have and will continue to serve to determine and implement a mechanism for developing
and sharing information on release prevention technology and practices, and to enhance
the state of practice in the chemical process safety arena. In addition, EPA analyzes and
disseminates information on accident prevention practices and technologies garnered
from the Accidental Release Information Program, Acute Hazardous Events, Emergency
Release Notification System, and National Response Center databases; on-scene
coordinator reports; and EPA audits and inspections. Finally, with the inclusion of the
facility risk management provisions in the Clean Air Act Amendments of 1990, the
accident prevention goals of the CSA program have been formalized.
The Chemical Safety Audit program is part of the CAP initiative and has been
designed to accomplish the following chemical accident prevention goals:
Visit facilities handling hazardous substances to gather information on
safety practices and technologies;
Heighten awareness of the need for, and promote, chemical safety among
facilities handling hazardous substances, as well as in communities where
chemicals are located;
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Build cooperation among facilities, EPA, and other authorized parties by
coordinating joint audits; and
Establish a database for the assembly and distribution of chemical process
safety management information obtained from the facility audits.
The chemical safety audit itself consists of interviews with facility personnel and
on-site review of various aspects of facility operations related to the prevention of
accidental chemical releases. Specific topics addressed include:
Awareness of chemical and process hazards;
Process characteristics;
Emergency planning and preparedness activities;
Hazard evaluation and release modelling efforts;
Release detection and monitoring techniques;
Training of operators and emergency response personnel;
Facility and corporate management structure;
Preventive maintenance and inspection programs; and
Community notification mechanisms and techniques.
Observations and conclusions from the audits are detailed in a report prepared by
the audit team. The report identifies and characterizes the strengths and weaknesses of
specific chemical accident prevention program areas to allow the elements of particularly
effective programs to be recognized, and to share information on problematic practices.
Copies of the report are given to the facility and to its corporate management so that
weak and strong program areas may be recognized. The audit reports are intended to
contribute to the study of emergency systems begun in the Review of Emergency
Systems, and in turn, to produce improvements in the ability of the audited facilities --
and industry in general - to prevent or mitigate releases of hazardous substances and to
share this information with the community and other interested groups. In this fashion,
the CSA program serves as a vital component of EPA's Chemical Accident Prevention
Program. Attachment 1 contains the Chemical Safety Audit Program Fact Sheet, which
summarizes the audit program background, goals, and scope. It can be used as a
separate document to inform interested parties about the audit program.
It should be noted that the CSA program is not a compliance or inspection
program. The audits are intended to be non-confrontational and positive, so that
information on safety practices, techniques, and technologies can be identified and shared
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between EPA and the facility. However, if serious problems are discovered during the
audit, EPA has a variety of legal authorities to use in response to them, which are
discussed later in the body of this Manual. Violations observed during the course of an
audit may also be referred to the respective EPA program office or federal agency or
department for determination of what actions are to be taken following the audit.
13 CSA Program and Section 112(r) of the Clean Air Act
The future direction of both the CAP program and the CSA program will be very
much affected by the passage of the Clean Air Act (CAA) Amendments of 1990. The
accidental release prevention requirements found in section 112(r) of the Clean Air Act
require EPA to promulgate regulations that require certain facilities to take steps to
prevent accidental releases of chemicals and mitigate the severity of releases that do
occur.
The facilities that will be covered by these regulations will be defined by a list of
substances and threshold quantities that EPA will promulgate. The Accidental Release
Prevention (ARP) regulations will require that facilities develop and implement a risk
management plan (RMP) - including a hazard assessment (off-site consequence analysis
and a five-year accident history), a prevention program, and an emergency response
program ~ within three years after promulgation of the regulation. The RMP will be
registered with EPA, and submitted to the Chemical Safety and Hazard Investigation
Board, the state, and local emergency planning and response authorities. The RMP will
also be made available to the public.
The CAA also requires EPA to establish an auditing system to review, and if
necessary require revision of the RMPs submitted by facilities. The auditing system in
the RMP rule outlines criteria for selecting facilities for audits. A more detailed auditing
strategy is being proposed in the guidance to states for implementation of the ARP
program. CAA section 507 further requires states to provide small businesses with
technical assistance on how to comply with the Act.
The role of the CSA program in advancing EPA's accident prevention initiative,
particularly its relevance in the context of the new section 112(r) requirements, will
continue to evolve. In the short term, the regions should continue to perform audits
under the current CSA format until they and the states begin administering the ARP
program under section 112(r). The goal is to ensure.that the states' auditing and
inspection programs and technical assistance capability are adequate to assume the
primary responsibilities of the ARP program.
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2. Program Authority under CERCLA
2.1 Purpose of the Statute
The Comprehensive, Environmental Response, Compensation, and Liability Act
(CERCLA or Superfund) was enacted December 11, 1980, and amended by the
Superfund Amendments and Reauthorization Act (SARA) on October 17. 1986.
CERCLA authorizes the federal government to respond where there is a release or a
substantial threat of a release into the environment of any hazardous substance,
pollutant, or contaminant that may present danger to the public health or welfare or to
the environment. Attachment 2 contains an overview of major CERCLA provisions
related to the CSA program. These include CERCLA sections 104(a), 104(b), 104(e),
and 106(a). The statutory text is also included, 42 U.S.C.A. sections 9601, 9604, and
9606.
2.2 Facility Entry and Information Gathering Tools
2.2.1 Statutory Authority
CERCLA sections 104(b) and 104(e), as amended by SARA in 1986, provide
authorities for entering a facility and accessing information. While CERCLA provides
authority for states to use statutory authorities for entry and information gathering, such
authorities may only be accessed pursuant to a contract or cooperative agreement with
the federal government. Since no state currently has such an arrangement, states, as well
as local governments, must use their own authorities for audit participation. [Required
Activity]
2-2.2 EPA Policy and Practice
When entering pursuant to CERCLA, EPA auditors must ensure that the facility
has experienced a release of a hazardous substance, pollutant, or contaminant, or that
there is "reason to believe" that there exists a threat of such a release. The audits are
intended to be non-confrontational and positive, cooperative efforts, such that
information on safety practices, techniques, and technologies can be identified and shared
between EPA and the facility. Consequently, and in conformance with other EPA
program policies, audits will be performed under the above authority pursuant to the
consent of the facility owner or operator. Consensual entry, however, can be revoked at
any time during the audit. When withdrawal of consent takes place, the audit team shall
leave the facility, regardless of the fact that the team has the authority to be there.
[Required Activity] In either situation (i.e., entry refusal prior to audit or during audit),
if consent is lacking, an order can be issued to require entry. Section 4.2 of this Manual
provides guidance on obtaining entry upon consent and actions to be taken if the facility
refuses entry.
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An audit can also be conducted at facility invitation. When entering at the
invitation of the facility (i.e., not pursuant to CERCLA authority or other statutory
authorities), the audit scope can potentially be limited, since the facility determines what
information will be made available to the audit team. In addition, invitational entry can
be revoked by the facility at any time during the audit. The audit team has no legal
authority (i.e., as compared to consensual entry) to continue the audit, and must leave
the facility. [Required Activity]
The only exception to the described facility discretion concerning entry withdrawal
for both consensual and invitational entry is if the audit team identifies a release or
threat of a release of a CERCLA hazardous substance from a facility into the
environment. If either of these situations are observed, the audit team must follow the
prescribed procedures in section 2.3 of this Manual. [Required Activity]
2-2,3 Confidential Information
During the course of an audit, team members may encounter information that
may be entitled to confidential treatment. Facilities can claim confidentiality on
information under CERCLA section 104(e), as amended. If confidential business
information (CBI) at a facility has been collected under another authority (e.g., TSCA,
CWA), CERCLA section 104(e) allows authorized team members to handle this
confidential business information as CERCLA CBI.
This information will be handled in accordance with 40 CFR Part 2. Authorized
representatives and Agency employees can access and view CBI under CERCLA.
Contractors who are pre-identified by contractor name and contract number to the
facility can have access to this data (refer to section 4.2 of this Manual). On February 5,
1993, EPA's Office of General Counsel issued a rule (58 FR 7187) that authorizes the
disclosure of CBI information (collected under a variety of environmental statutes, .
including CERCLA section 104) to enrollees in the Senior Environmental Employment
(SEE) Program. Thus, members of the American Association of Retired Persons
(AARP) now have the same access to CBI as EPA employees.
There are no specific training courses for handling CERCLA CBI, either on-site
or off-site. In general, all confidential information must be marked as such and placed in
a locked filing cabinet or a safe. It is advisable, however, that audit participants take a
regional CBI course.
2.2.4 Attorney-Client Privilege
In the event that a facility withholds information based upon "attorney-client
privilege," the regional Office of Regional Counsel (ORC) should be immediately notified
and provided the following information:
Name of document(s) withheld;
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Specific reason why withheld; and
Name of facility attorney, address, and telephone number.
If a request for information during the course of the audit is refused, the audit
should continue unless the absence of the requested document(s) makes it impossible to
do so. The Office of Regional Counsel should be consulted of the refusal after the site
visit and requested to pursue the matter as necessary.
23 Response Actions if a Release or a Threat of a Release Exists
During an audit, the team may observe a release or the potential for a release of
a CERCLA hazardous substance from a facility into the environment.
If a release is observed, the team members must take the following actions:
[Required Activity]
Follow facility emergency evacuation procedures to safety; and
Regroup; the Team Leader must notify the Regional Emergency Response
Section to inform the on-duty On-Scene Coordinator (OSC) of events
occurring at the facility. This action is not intended to serve as the facility's
notification under any statute or regulation.
If the threat of a release is observed, the Team Leader must take the following
actions: [Required Activity]
Regroup, if necessary with the entire audit team at the facility management
office;
Inform the facility owner/operator of the observed situation; and
If the facility owner/operator fails to take appropriate actions to mitigate
the potential threat of release, the Team Leader must notify the Regional
Emergency Response Section to apprise the OSC of events occurring at the
facility.
In both of the above situations, notification to the Regional Emergency Response
Section must be made regardless of whether the Team Leader or members of the audit
team are OSCs. The communication with the region will determine the scope of the
response action to be taken to mitigate the release or threat of release.
At this point, the audit must not continue until the release or threat of release has
been mitigated, as determined by the OSC. The OSC and/or Remedial Project Manager
(RPM) shall have the authority vested in them by the National Contingency Plan, 40
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CFR Part 300. In addition, the OSC and/or RPM may take any necessary response
actions when he/she determines that conditions at the site may present an imminent and
substantial endangerment.
2.4 Relationship to Enforcement/Compliance Regulatory Programs
An EPA chemical safety audit is not an enforcement inspection or multi-media
compliance audit, such as a RCRA compliance inspection or an environmental audit.
Nor should an audit be confused with compliance inspections conducted by the
Occupational Safety and Health Administration (OSHA) of the Department of Labor. A
chemical safety audit is a visit to a facility to learn about and share technologies,
techniques, and management practices for preventing and mitigating chemical accidents.
Relationship to OSHA
OSHA's primary responsibility is to protect workers, ensuring a safe and healthy
environment for employees. OSHA conducts inspections to identify facility compliance
with specific requirements and standards for employee health and safety and for accident
investigations, especially where worker injuries or death occur. EPA and OSHA have
established a Memorandum of Understanding on facility inspections, as well as
coordinating activities through a variety of other means.
Relationship to EPA Regulatory Programs
The audit findings are presented in a final report. If appropriate, the report can
include recommended process safety practices that the facility may want to consider
adopting. Report findings and recommendations are not mandatory actions that the
facility must adopt, as are those identified during an enforcement/compliance inspection.
The audit focus is not on reviewing facility compliance with other regulatory programs;
other media program offices already perform these activities. Use of CERCLA sections
104(b) and 104(e) provide EPA with the authority to enter a facility and access
information for the purpose of conducting the safety audit.
Audit team members, however, will often consist of representatives from other
EPA media program offices who are charged with the authority to conduct enforcement
or compliance inspections and audits. In this situation, the role of this media program
official must be determined prior to notifying the facility of the audit. [Required Activity]
Facility notification involves citing the CERCLA. entry and information gathering
authorities. If this media program official intends to exercise authorities other than
CERCLA sections 104(b) and 104(e), then the facility must be notified that these
additional authorities will be exercised. In this situation, there are two separate EPA
activities being conducted at the facility: a chemical safety audit and an
enforcement/compliance inspection. This additional use of other authorities must be
presented in the same letter that cites use of CERCLA authorities. [Required Activity]
Facility notification procedures are presented in section 4.2 of this Manual.
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During the conduct of a chemical safety audit that is not coupled with an
enforcement inspection as presented above, program violations may be observed. These
violations should be referred to the respective program office or federal
agency/department for determination of what actions are to be taken following the audit.
2.5 Relationship Between CERCLA and SARA Title III
The CSA program is being conducted under CERCLA authority. While the idea
of the CSA program originated from the activities undertaken to prepare the section
305(b) study mandated by Congress under SARA Title III (see the introduction to this
Manual), and from similar audits conducted following catastrophic releases, there is no
statutory link between the CSA program and the SARA Title III program.
The CERCLA and SARA Title III programs, however, have similar release
notification provisions. A release or spill of a chemical above a certain threshold amount
(the chemical's designated "reportable quantity" or "RQ") will often require two separate
notifications: if the chemical is a CERCLA "hazardous substance," the National
Response Center (NRC) must be notified under CERCLA section 103(a), and, if the
chemical is a CERCLA hazardous substance and/or an "extremely hazardous substance"
(EHS) under SARA Title III, the emergency coordinator of the local emergency planning
committee(s) (LEPC) and the state emergency response commission(s) (SERC) likely to
be affected by the release must be notified under SARA Title III section 304(a).
CERCLA hazardous substances are listed at 40 CFR Part 302; EHSs under SARA Title
III are listed at 40 CFR Part 355.
Although the two lists overlap considerably, they are not identical; approximately
138 EHSs are also CERCLA hazardous substances. It should be noted that all EHSs are
proposed to be designated as CERCLA hazardous substances. In situations where the
release is above the RQ of a chemical that is listed both as an EHS under SARA Title
III and as a hazardous substance under CERCLA, notifications under both authorities
must be given by the facility; this is because each notification is a separate requirement,
and the contents and recipients of the notifications differ.
In addition, similar goals are shared by both the CSA program and the SARA
Title III program. These include the following:
Increased level of preparedness for responding to accidental releases of
chemicals both at a facility and in a community;
Increased awareness and understanding of chemical hazards; and
Increased levels of safety practices related to producing, treating, handling,
disposing, and transporting of hazardous substances at a facility.
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Involvement in the CSA program by representatives of LEPCs and SERCs, either
as audit team members, information sources, or both, is encouraged to enhance the goals
of both these programs. However, state and local government participation in the audit,
itself, must be performed under state and local authorities.
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3. Role of Audit Team Members
3.1 Audit Team Composition
An EPA audit team consists primarily of EPA employees, and other designated
representatives, including contractors and the American Association of Retired Persons
(AARP) enrollees. The participation of other federal, state, and local government
personnel, particularly SERC and LEPC representatives, is encouraged, but they should
be made aware that they will be entering and accessing information from a facility under
their own authorities. Section 3.3 of this Manual further discusses the participation of
non-EPA audit team personnel.
The audit team can vary in size, depending upon the level of detail of the audit
(e.g., number of chemicals and/or processes under investigation; national significance).
At a minimum, however, there must be two technical experts on a team for collection
and verification of technical findings and observations. [Required Activity]
The following list represents suggested roles, responsibilities, associated
disciplinary backgrounds, and other parameters for composing a team. This list is
provided as guidance and in no way is a required format for forming an audit team. In
many cases, your team composition may require you to combine or divide roles.
Team Leader
Must be EPA employee; [Required Activity]
Coordinates audit logistics, makes team assignments, coordinates initial
liaison with facility personnel, and coordinates preparation and distribution
of final site visit report; and
Provides any needed follow-up information.
Deputy Team Leader
Must be EPA employee or designated representative; [Required Activity]
Provides logistical support, as directed by Team Leader; and
Assumes other responsibilities delegated by Team Leader.
Chemical Process Hazards Reviewer
Must be EPA employee or designated representative;
Responsible for collection and verification of process-related information;
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Primary liaison with facility technical personnel; and
Requires technical knowledge of chemical hazards, process engineering,
and maintenance procedures.
Chemical Accident Prevention Reviewer
Must be EPA employee or designated representative;
Responsible for collection and verification of facility information;
Liaison with appropriate facility technical personnel;
Requires technical knowledge of chemical accident prevention, including
hazard evaluation and modeling techniques and release
prevention/mitigation systems.
Safety and Training Reviewer
Must be EPA employee or designated representative;
Responsible for collection and verification of facility information;
Primary liaison with facility health and safety personnel;
Requires knowledge of operator, safety, and worker right-to-know training
programs.
Emergency Planning and Response Reviewer
Must be EPA employee or designated representative;
Responsible for collection and verification of facility information;
Primary liaison with appropriate facility personnel responsible for planning
and response;
Requires knowledge of emergency planning and response requirements.
Technical expertise for the chemical safety audit program refers to knowledge,
experience, and disciplinary training in plant process design, engineering, operations,
training, and emergency planning. Example disciplines include:
Chemical, civil, industrial/safety, and environmental engineering,
Plant process experience,
Environmental science,
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Industrial hygiene,
Geology, and
Environmental and emergency management and planning.
Personnel with the appropriate expertise can be found in the following regional program
offices: media (e.g., air, water, radiation); RCRA; TSCA; Superfund (e.g., emergency
preparedness and response, removal, health, and safety); and Research and
Development.
In selecting team members, the skill base of the team must accommodate the
need for coverage of the major audit elements:
Process and safety system technologies;
Operating procedures;
Training programs;
Emergency planning activities; and
Management activities.
Specific tasks should be assigned to each team member. Each member should know
his/her respective role in all facets of the facility audit. Certain members may be
assigned the lead on one or more facets of the audit, and the other team members,
because of their individual skills and experiences, should be prepared to contribute to the
completion of that facet of the audit.
In summary, an EPA audit team can consist of EPA employees, EPA contractors
(e.g., Technical Assistance Team), AARP enrollees, and representatives from federal,
state, and local governments. Two basic restrictions apply to the "team;" one, the Team
Leader must be an EPA employee, and two, the Chemical Process Hazards Reviewer
must be an EPA employee or designated representative (i.e., EPA employee, contractor,
or AARP enrollee). [Required Activity] This last restriction is required to ensure
continuity in communicating the audit scope and intent.
The following provides an overview of the anticipated roles and responsibilities for
EPA employees, contractors/TAT personnel, and AARP enrollees:
EPA employees coordinate audit program and lead the audit team.
Contractors/TAT personnel provide technical support as defined by EPA.
AARP enrollees:
Provide support role in audits;
Apply professional expertise and experience in chemical engineering
or other technical or industrial fields for reviewing process safety
technologies at facilities;
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Apply other expertise in such areas as safety management or
training for involvement in other aspects of the audit (i.e., reviewing
emergency plans, training manuals, and emergency notification
procedures and/or systems);
Participate in report preparation, including observations and
recommendations from the audit;
Identify facilities for potential audits, using information sources such
as Accidental Release Information Program (ARIP) data, and
coordinate with regional response centers; and
Are limited to field activities that do not stress physical limitations.
3.2 Training and Safety Requirements
Field activities for EPA employees are subject to the training requirements
embodied in EPA Order 1440.2, Health and Safety Requirements for Employees
Engaged in Field Activities, The Order establishes policies, responsibilities, and
mandatory requirements for occupational health and safety training and certification, and
occupational medical monitoring.
EPA Order 1440.2 requires that a Site Safety Plan be developed for EPA
employees conducting a chemical safety audit at a facility handling hazardous substances.
EPA regional offices can either use the model site safety plan (see Attachment 3), or
develop their own program that complies with EPA Order 1440 and the Occupational
Safety and Health Administration's worker protection standards codified at 29 CFR 1910
and 1926. The plan should include a description of the proposed audit scope, facility
health hazards, necessary protective equipment, contractor participation, and
decontamination procedures, and must be completed and approved by the EPA project
coordinator, branch chief, on-scene supervisor, and health and safety manager. Under
certain circumstances, a more extensive plan may also be required. For more
information, contact the safety and health office in your region.
Audit team members should dress appropriately, including steel-toed boots, safety
glasses, and hard hats. Team members should provide their own safety equipment, and
should not rely on the facility.
Prior to participating in an audit, all EPA team members, which include EPA
employees, contractors, and AARP enrollees, must have completed the following training
courses:
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Training in occupational health and safety procedures under EPA Order
1440,2. Attending a 24-hour or 40-hour health and safety course that is
approved and sponsored by EPA and conducted by EPA or its contracted
agents fulfills the requirement of this Order; [Required Activity] and
EPA Chemical Safety Audit Training Course. (Course attendance
flexibility is discussed below.)
In addition to the listed training, annual medical monitoring is required. [Required
Activity]
In some audits, a specialized technical expert (i.e., contractor or other EPA
program personnel) who normally does not participate in CSA program activities will
assist in conducting the audit. Under these circumstances, it will be difficult for such an
individual to have taken the EPA CSA course. Consequently, the requirement for the
CSA course is flexible depending upon the situation. The health and safety training
requirements and medical monitoring, however, are not flexible. [Required Activity]
This requirement should not pose any problems, since it would be rare for a technically
qualified contractor or EPA employee not to have had this training.
Suggested topics for additional, but not required, training include:
Handling of confidential business information;
Interviewing techniques;
Hazard evaluation techniques;
Chemical processing techniques;
Negotiating techniques; and
Technical writing.
33 Noti-EPA Personnel Participation on Audit Team
Non-EPA team members may include representatives of other federal agencies
and departments, states/SERCs, local officials/LEPCs, and any other group not previously
identified as an EPA team member. The regions are encouraged to invite participation
by non-EPA personnel in audits, but entry into the facility must be authorized pursuant
to authorities other than CERCLA. Participation of non-EPA personnel must be in a
support role as defined by the Team Leader. In addition, non-EPA personnel cannot
serve in the capacity of Team Leader or Chemical Process Hazards Reviewer. [Required
Activity]
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SERC and LEPC participation is encouraged to enhance their knowledge of
chemical hazards and process safety for use in planning activities under SARA Title III
and in future Clean Air Act Amendments Risk Management Program activities. SERCs,
LEPCs, and other federal agencies also serve as a valuable source of information in
preparing for the audit.
It is important to inform these representatives of the required health and safety
training that EPA employees and representatives undergo prior to audit participation.
As discussed in the next section, non-EPA participants require their own liability
coverage.
3.4 Liability
Liability associated with conducting audits is described in the following sections for
each group potentially represented on an audit team.
3.4.1 Federal Employees
Under the Federal Employees Liability Reform and Tort Compensation Act of
1988, a suit can no longer be maintained against a Federal employee in his or her
individual capacity for any act (discretionary or non-discretionary) performed within the
scope of the employee's employment. All such suits must now be brought against the
United States government. If named in a suit in his or her individual capacity, employees
should promptly notify the Office of Regional Counsel and the Office of General
Counsel.
The legislation does not change the potential liability of a Federal employee in his
or her individual capacity for grossly negligent actions (usually taking the action out from
under the scope of the employee's employment), for Constitutional violations, and for a
violation of a statute "for which a claim is otherwise authorized." All audit participants
should have audit responsibilities clearly delineated in their job description.
3.4.2 AARP Enrollees
There are no provisions for indemnifying AARP enrollees from personal liability
under the cooperative agreement between AARP and EPA. Since AARP enrollees serve
only in support roles in all aspects of CSA program implementation, the Regional
Chemical Emergency Preparedness and Prevention Coordinators and their staff are
responsible for ensuring that enrollees are not placed in situations that could result in
job-related personal liability.
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3.4.3 Technical Assistance Team Contractors
The Federal Employees Liability Reform and Tort Compensation Act of 1988
only covers TAT contractors when responding to a CERCLA hazardous substance
release or performing a clean-up/removal related to such release. Audit activities for
TAT contractors are not covered under this Act, since the contractor is not specifically
handling hazardous substances, pollutants, or contaminants. TAT contractors must
investigate liability coverage with their respective employer.
3.4.4 Federal, State/SERC. and Local/LEPC Government Personnel
All non-EPA personnel will be entering a facility under their own authorities and
would require their own liability coverage.
3.5 Conflict of Interest
Conflict of interest refers to any person (i.e., EPA employee, contractor, AARP
enrollee, non-EPA personnel) who has a financial interest associated with the facility
being audited, has been previously employed with the facility, or a facility subsidiary,
and/or has been a consultant for the facility. Persons with conflict of interest should not
participate in any activities, either on-site or off-site, associated with the facility audit.
[Required Activity] In addition, such persons must identify themselves to the Team
Leader and excuse themselves from the audit of that facility. [Required Activity]
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4. Preparing for the Audit
4.1 Facility Selection
At present, there are no established procedures for selecting a facility for an audit.
Each region has flexibility in identifying facilities. A variety of options useful to
identifying a facility are discussed below. Although there is substantial flexibility in
facility selection, there are two important requirements:
A release of a CERCLA hazardous substance, pollutant, or contaminant
must have occurred, or there must be "reason to believe" that a threat of
such a release exists at the facility; [Required Activity] and
The Office of Regional Counsel and the SERC of the state where the
audited facility is located must be consulted to identify any legal actions
currently being pursued or anticipated. [Required Activity] It is advised
that regional media programs also be consulted.
The following list provides a variety of options to consider when selecting a
facility. Information sources to be used in evaluating these options include federal, state,
and local release notification reports and follow-up reports, OSC reports, Regional
Response Centers, ARIP, ERNS, and other sources (see Attachment 4 and chart in
section 4.3).
Previous release history of the facility;
SERC and/or LEPC referral;
Proximity to sensitive population(s);
Public sensitivity;
Opportunity for sharing new technology;
Population density; and
Concentration of industry in the area.
In addition, the region may wish to select facilities for a chemical safety audit as
part of a larger regional initiative, such as an evaluation of facilities using a specific
chemical or located near a particularly sensitive environment. For example, during fiscal
year 1992 a number of facilities that produce and use hydrogen fluoride were examined
by audit teams nationally, while Region 5 conducted all of its audits in coordination with
its Great Lakes Basin pollution prevention initiative.
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4.2 Facility Notification
Once a facility has been selected, the process of notifying the facility and
scheduling the audit can be initiated. Although each region will invariably establish its
own procedures for notifying a facility and coordinating the audit, the following
suggestions and tools should be integrated into that process. These suggestions are
designed to help establish a constructive rapport with the facility and to ensure the
correct use of statutory authorities and other legal requirements.
The Team Leader should make an initial phone call to the facility owner/operator.
The purpose of this call is to identify a "contact" at the facility for all correspondences, to
communicate/explain the purpose and intent of the audit, and to schedule dates for
conducting the audit. In some instances, it may be useful to schedule a pre-audit meeting
with the facility to obtain further information.
The phone call should be followed by a letter to the facility contact that
summarizes the initial conversation and confirms any decisions made during the call. In
addition, the letter serves to confirm audit statutory authority, provide the facility an
opportunity to claim confidential information, and to identify the contractor, if a
contractor is participating. As previously stated in section 2.2.3 of this Manual, the
contractor must be identified by contractor name and contract number in order to have
access to confidential information.
Attachment 5 is a sample letter designed to fulfill the above goals. While
language may be added to the letter, such as a summary of a phone conversation, the
legal aspects of the letter as contained in the attachment should not be materially
altered. [Required Activity] It is suggested that all correspondence with the facility be
reviewed by the Office of Regional Counsel (ORG).
Unfortunately, not all efforts to schedule and coordinate an audit based upon the
voluntary consent of the facility will be successful. After receiving either the facility's
written or verbal denial of EPA's request to conduct the audit, a letter must be sent to
the facility (1) confirming this denial; and (2) invoking use of the CERCLA 104(b) and
104(e) authorities for entry. [Required Activity] Attachment 6 contains a sample letter
specifically designed for this situation. Preparation of this letter must be coordinated
with your Office of Regional Counsel. [Required Activity] The suggested letter states
that continued refusal of facility access can result in EPA issuing an order requesting
entry and/or initiating an enforcement action. Any further activities and contact with the
facility should be pursued in coordination with the Office of Regional Counsel.
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4.3 Facility Background Information
Preliminary preparation is an important factor in conducting an organized audit.
The team may find it useful to collect the facility background information several weeks
in advance of the audit. This will require contact with the facility and state and local
officials to arrange delivery of these materials. The audit team can then review this
information and become more familiar with the facility prior to the audit. Using this
technique, the team will be able to prepare a detailed list of topics and questions to help
organize their activities during the facility visit. The following list is a sampling of the
types and sources of information that will assist a team in preparing for the audit:
Type of Information
Sources of Information
Release History
OSC reports; ARIP questionnaires; ERNS; SARA
Title III sections 304 and 305(b) reports; state
release files
Regulatory History
Local, state, and federal air, water, and waste
permits; SARA Title III sections 302, 304, 311, 312,
and 313 submissions
Hazardous Chemicals
(Hazards, Amounts,
and Locations)
SARA Title III sections 311 and 312 submissions;
OSHA hazard communication and process safety
management standard documents; hazards analysis;
NIOSH Pocket Guide to Chemical Hazards
Chemical Processes
Industry standards and processing techniques from
trade and professional groups (e.g., AIChE, ASSE,
and the Chlorine Institute); process flow diagrams
and piping and instrumentation diagrams
Community Involvement
CAER; LEPC; and SERC
The "Audit Protocol/Report Preparation Guidance" as presented in section 6.0 of
this Manual provides further detail on the types of information that may be requested
from the facility prior to conducting the audit. Attachment 4 contains further
information on these listed sources.
4.4 Preparing for the Site Visit
Prior to conducting the on-site audit, a pre-visit meeting should be conducted with
the entire audit team, including any non-EPA personnel who will be visiting the facility.
This meeting should be held as close to the date of the site visit as possible to keep the
important points being emphasized fresh in everyone's mind. By this time, the audit
team should already be operating as a unit; all team members should be familiar with the
audit protocol, the information previously collected by the team should have been
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reviewed, additional information to be obtained at the facility should have been
identified, and the team members should have developed individual agendas. The pre-
visit meeting serves to reinforce what already is in place and should cover the following
items:
Clearly establish the responsibility and authority of the team leader;
Review highlights of the audit's objectives and note any specific team
member responsibilities;
Review any personal health and safety issues that may be present at the
site for the team to prepare for and avoid (see section 3.2);
Review information about key personnel and operations at the site;
Establish objectives and an agenda for each day of the site visit;
Cover logistical matters such as a nightly team meeting to discuss results
and plan the next day's activity; and
Cover any other topics that the Team Leader identifies.
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5. Conducting the Audit
The on-site chemical safety audit will consist of the following four phases;
Entry;
Opening Meeting;
On-site Activities; and
Exit Briefing.
5.1 Entty
The audit team should arrive at the facility during normal working hours at a time
and date pre-determined with the facility. At the facility entrance office, the facility may
provide a blank sign-in sheet, log, or visitor register. It is acceptable for the audit team
members to sign it. EPA employees and authorized representatives, however, must not
sign any type of "waiver" or "visitor release" which would relieve the facility of
responsibility for injury, or which would limit the rights of the Agency to use the data
obtained from the facility. [Required Activity] When such a waiver or release is
presented, the Team Leader should politely explain that such a document cannot be
signed, and a blank sign-in sheet should be requested. If the team is refused entry
because they do not sign such a release, the Team Leader must report all pertinent facts
to the ORG, and leave the facility if the matter cannot be resolved. (Required Activity]
All events surrounding the refused entry must be fully documented including the name of
the person(s) refusing entry. [Required Activity] Procedures described in section 4.2 of
this Manual concerning refusal of entry must then be followed. [Required Activity]
5.2 Opening Meeting
The entire audit team will meet with the plant manager and his/her key staff, and
will likely discuss the entire audit. The staff of the plant manager could include
superintendents of safety and operations, a lawyer, and corporate representation. The
team should be very clear about its purpose and should be prepared to discuss the audit
starting with an explanation of the CSA program, facility selection, the audit purpose and
scope, the background research performed, the specific objectives for the site visit, and
the report that will be written.
During the meeting, the audit team should outline its specific on-site agenda and
the cooperation needed to accomplish that agenda. In addition, the meeting provides a
good opportunity for the facility to provide the audit team with an overview of its
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operations and safety programs and may include a general tour of the whole facility (as
appropriate). This meeting typically requires at least a half day.
53 On-Site Activities
Once past the opening meeting, the audit team may split up into smaller groups to
take a plant tour and interview other operations and management personnel. The plant
tour should include specific tours of the chemical handling and process areas. The team
should interview personnel involved in such areas as process safety, process operations,
technical support, personnel, emergency planning and response, and environmental
management.
During these tours and interviews, individual team members should be obtaining
information and making observations that fulfill the needs of their individual
responsibilities. The questions and prompts for discussion contained in the annotated
audit protocol can be helpful.
During this or any other part of the site visit, it is possible that an observation will
be made or that information will be obtained that should be of significance to the audit
team, but that is beyond the scope of the facility audit. In this event, the Team Leader
should be notified.
S.4 Exit Briefing
In this final meeting, the entire audit team will meet with the plant manager and
his/her key staff to discuss the results of the audit as it presently stands. The plant
manager may be accompanied by the same people who attended the opening meeting.
The facility will want to know about all significant team findings and, more importantly,
about the conclusions that have been drawn and the recommendations that will be made.
Prior to the exit briefing, the audit team should have a private meeting to
establish an agenda for this meeting. Significant observations and findings should be
listed for discussion with the facility. The team should identify conclusions based on this
information only to the extent that a consensus among team members can be reached. A
team consensus is also necessary for identifying any recommendations to the facility at
this time. In the absence of team consensus, it is inappropriate to offer conclusions or
recommendations to the facility during the exit briefing. This does not, however,
preclude drawing such conclusions or making any recommendations in the audit report
that will be written later.
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6. Audit Protocol/Report Preparation Guidance
6.1 Purpose and Structure
This protocol/report preparation guidance (see Exhibits 1 and 2) provides a
detailed topic outline to direct the scope and content of the audit and a structure for
preparation of the audit report. The protocol and report format have been integrated to
accomplish the following goals:
Provide detailed guidance on the types of information that should be
reviewed during the audit and discussed in the report;
Ensure continuity in report preparation; and
Provide an organized and detailed report format for easy access to specific
lessons learned on chemical process safety management practices.
Because of the scope of the audit or the resources and expertise of the audit
team, it may not need, or be able, to address all areas of the protocol. However, all
areas of the protocol should be addressed in the audit report (e.g., state that the audit
team did not review the facility's hazard evaluation and modeling capabilities).
By providing this Manual to facility personnel prior to conducting the audit, the
facility will also have a more thorough understanding of the audit scope and intent. The
facility can prepare for the audit by assembling information and identifying personnel
with the required expertise to assist the audit team.
This guidance is structured to address each of the major elements of chemical
process safety management at the facility being audited. These include:
Facility Background Information;
Chemical Hazards;
Process Hazard Information;
Chemical Accident Prevention;
Accidental Release/Incident Investigation;
Facility Emergency Preparedness and Planning Activities;
Community Emergency Planning and Response Activities; and
Public Alert and Notification Procedures.
Preceding each of these sections in the annotated protocol/report guidance
(Exhibit 2) is a brief overview of the purpose of this section with respect to the audit
scope.
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Exhibit 1
Outline of Protocol/Report Preparation Guidance
1.0 INTRODUCTION
2.0 SUMMARY OF FINDINGS/CONCLUSIONS
3.0 BACKGROUND
3.1 General Facility and Audit Information
3.2 Purpose of the Audit and Facility Selection Process
3.3 Audit Methodology
4.0 FACILITY BACKGROUND INFORMATION
4.1 Site and Surrounding Area Description
4.1.1 Facility Profile
4.1.2 Site Topography and Meteorological Conditions
4.1.3 Site Access
4.1.4 Special/Sensitive Populations and Environments
4.1.5 Regional Demographics
4.1.6 Identification of Vulnerable Zones
5.0 CHEMICAL HAZARDS
5.1 Overview of Hazards for Chemical(s) Being Audited
5.2 Facility Management of Chemical Hazard Data
6.0 PROCESS INFORMATION FOR HAZARDOUS CHEMICALS
6.1 Storage and Handling
6.1.1 Storage Systems
6.1.2 Shipping/Receiving
6.1.3 Material Transfer
6.2 Process Description
6.2.1 Overview of Processing Steps and Operating Procedures
6.2.2 General Description of Process Equipment Capacity
6.2.3 Back-ups and Redundancy
6.2.4 Process Parameter Monitoring
6.2.5 Environmental Monitoring
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6.3 Process Hazards
7.0 CHEMICAL ACCIDENT PREVENTION
7.1 Management Activities
7.1.1 Corporate Role in Facility Process Safety Management
7.1.2 Facility Role in Process Safety Management
7.1.3 Audit Activities and Procedures
7.2 Process Operation and Maintenance
7.2.1 Standard Operating Procedures
7.2.2 Training Practices
7.2.3 Equipment Maintenance Procedures
7.2.4 Instrument Maintenance
7.3 Hazard Evaluation and Modeling
7.3.1 Hazard Evaluation
7.3.2 Modeling
7.4 Release Prevention Systems
7.5 Mitigation Systems
8.0 ACCIDENT RELEASE INCIDENT INVESTIGATION
8.1 History of Accidental Releases/Incidents
8.2 Facility Investigation Procedures
9.0 FACILITY EMERGENCY PREPAREDNESS AND PLANNING ACTIVITIES
9.1 Facility Emergency Response Plan
9.2 Emergency Response Exercises and Simulations
9.3 Fire, Evacuation, and Rescue Corridors
9.4 Emergency Equipment Provisions
9.5 Emergency Response Chain of Authority
9.6 Emergency Response Management Procedures
9.7 Emergency Communication Network within the Facility
9.8 Emergency Response Personnel Training Requirements
9.9 Follow-up Release Procedures
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10.0 COMMUNITY AND FACILITY EMERGENCY RESPONSE PLANNING
ACTIVITIES
10.1 Facility Planning and Outreach Activities with Community
10.2 Local/Community Emergency Response Planning
11.0 PUBLIC ALERT AND NOTIFICATION PROCEDURES
11.1 Procedures for Public Notification of Releases
11.2 Schedule for Testing Procedures
11.3 History of Notification Procedures and Evaluation
11.4 Community and Facility Contacts
11.5 Facility and Media Interaction
12.0 CONCLUSIONS
13.0 RECOMMENDATIONS
APPENDICES
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Exhibit 2
Annotated Protocol/Report Preparation Guidance
STANDARD DISCLAIMER (see Attachment 7)
1.0 INTRODUCTION
Purpose and scope of the audit program (Attachment 8 contains standard
language to describe the purpose and scope of the program); and
Paragraphs identifying facility name and location and why audited
2.0 SUMMARY OF FINDINGS/CONCLUSIONS
Briefly summarize audit findings (both positive and negative)
3.0 BACKGROUND
3.1 GENERAL FACILITY AND AUDIT INFORMATION
Facility name, location, principal activities;
Dates audit conducted; and
Listing of team members and their affiliation, areas of responsibility,
and expertise.
3.2 PURPOSE OF THE AUDIT AND FACILITY SELECTION PROCESS
Briefly explain why facility was selected. Audit could be conducted
for a number of reasons such as;
To follow up on an accidental release or series of releases
(include description of triggering incident);
To focus on particular technologies, processes, operations, or
chemicals;
Regional or headquarters initiatives;
At request of state and/or local officials; or
At facility invitation.
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3.3 AUDIT METHODOLOGY
Summary of the process areas and other locations that were
investigated and why they were selected; and
Important audit limitations (e.g., no comparison of safety systems
across several similar operations was performed).
4.0 FACILITY BACKGROUND INFORMATION
A history of site activities and a description of the surrounding area provides
information on the potential risk that facility activities may pose to the surrounding
community and the environment in the event of an accidental chemical release.
4.1 SITE AND SURROUNDING AREA DESCRIPTION
4.1.1 Facility Profile
Facility history and principal activities (i.e., date built,
modifications and improvements, releases, etc.), size and
layout, and ancillary operations (e.g., power generation,
warehouse, distribution center, laboratory, waste treatment,
etc.); and
Reference maps in appendix or use simple maps in text.
4.1.2 Site Topography and Meteorological Conditions
Natural disaster potential (e.g., earthquake, flood);
Geology; and
Climate.
4.1.3 Site Access
Transportation routes, including railroad and waterways; and
Site security (e.g., fencing and gates, security guards, and
access by non-authorized persons).
4.1.4 Special/Sensitive Populations and Environments
Hospitals, schools, and nursing homes; and
Wetlands, drinking water supply, etc.
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4.1.5 Regional Demographics
Economy, population, industrial and growth patterns
4.1.6 Identification of Vulnerable Zones
5.0 CHEMICAL HAZARDS
This section serves to not only focus briefly on the hazards associated with
particular substances, but to provide pertinent facts on the facility's understanding of
what are the chemical hazards for each substance.
5.1 OVERVIEW OF HAZARDS FOR CHEMICAL(S) BEING AUDITED
Brief description of hazards; and
Reference detailed information in appendix (i.e., MSDS, etc.) -- do
not rewrite MSDS information.
5.2 FACILITY MANAGEMENT OF CHEMICAL HAZARD DATA
What the facility recognizes as the hazards associated with the
chemical(s);
Documentation available on hazards associated with chemical(s)
(e.g., MSDS, corrosion rates, reactivity data, etc.);
Availability of such data to employees (e.g., OSHA Hazard
Communication Standard training);
Mechanism for reviewing and updating information;
Mechanism for documenting suspected acute and chronic toxic
effects (e.g., medical and industrial hygiene personnel); and
On-site availability of emergency medical care.
6.0 PROCESS INFORMATION FOR HAZARDOUS CHEMICALS
A review of facility operations associated with the processing of the chemical(s)
being examined can reveal facility practices and techniques for handling process hazards,
as well as reveal facility understanding of the process hazards. (Within each subsection,
the report should address every chemical and process examined during the audit for
which observations, conclusions, and/or recommendations were noted.)
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STORAGE AND HANDLING
6.1.1 Storage Systems
Storage methods;
Capacity;
Location, including compatibility and spacing;
Hazard identification (placards and labelling);
Maintenance and housekeeping of area; and
Block diagrams to illustrate major process flows.
6.1.2 Shipping/Receiving
Method(s) of receiving and shipping (e.g., tank trucks, rail
cars, pipelines, cylinders, barges, etc.);
Schedules and quantities of shipments;
Responsible personnel and level of training;
Coordination of transportation issues with the community
contingency plan; and
Transportation corridors used.
6.1.3 Material Transfer
Transfer method(s) from storage to processing areas and
between different stages of process;
Pipe coding/labelling for flow direction and contents;
Other transfer systems (e.g., compressors, ejectors, pumps,
blowers, etc.);
Housing of transfer systems; and
Off-site accessibility.
PROCESS DESCRIPTION
6.2.1 Overview of Processing Steps and Operating
Procedures
Listing different operations and process steps in chronological
order for hazardous chemical; can use block-type flow
diagram to illustrate steps;
Chemical production or use rates;
Chemical reaction(s) description (e.g., catalysts, activators,
inhibitors, exothermic, etc.);
Blending or separation steps;
Material incompatibilities;
Pressure and temperature variations; and
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Consequences of deviation: what happens to chemicals
spilled, leaked, vented, etc.
6.2.2 General Description of Process Equipment
Capacity and design conditions;
Construction material;
Flow rates;
Parameters monitored, controlled, and recorded (at
equipment or in control room);
Production or use rates for chemical; and
Comparison of design limits and operating parameters.
Note: Attachment 9 contains further guidance on reviewing process operations.
6.2.3 Back-ups and Redundancy
List systems with back-ups or automatic shutdowns;
Description of back-ups and how and why used;
Availability of back-up power systems;
Method of detecting inoperative control equipment and
availability of back-ups; and
For facility with scrubbers or flares, their capacity for
handling accidental releases.
6.2.4 Process Parameter Monitoring
Description of process parameters for operations and
processes and why used;
Performance history at facility;
Monitoring and recording procedures; and
Procedures for addressing unsafe parameter levels.
6.2.5 Environmental Monitoring
Description of system(s) used to monitor hazardous chemical
levels within work areas and in the surrounding environment
(e.g., types, location, etc.);
Connection to alarm and communication systems; and
Performance history at facility.
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6.3 PROCESS HAZARDS
Hazards facility has identified for the process and determined to
present a significant risk to the facility and/or the surrounding
community (e.g., storage tank failure, pipeline leak, process vessel
overpressurization)
7.0 CHEMICAL ACCIDENT PREVENTION
Practices and technological systems for controlling the process hazards presented
in section 6.0 of this protocol/report outline, are an important part of chemical process
safety management. This section is intended to describe mechanisms for implementing
and maintaining safe process systems. Management directives are reviewed in this
section to identify goals and implemented activities, such as training and equipment
maintenance procedures, that present the facility's perspective and commitment to safe
management of process hazards.
7.1 MANAGEMENT ACTIVITIES
7.1.1 Corporate Role in Facility Process Safety Management
Corporate safety policy, guidance, and directives; and
Technical and financial assistance (e.g., process modifications,
information exchanges, and capital improvements).
7.1.2 Facility Role in Process Safety Management
Policy and directives;
Goals and objectives; and
Employee safety committees and incentive programs.
7.1.3 Audit Activities and Procedures
Frequency of facility audits;
Responsible department and involvement of external
personnel (e.g., corporate and private consultants);
Audit scope;
Audit procedures and time frame; and
Implementation of audit recommendations (e.g., policy and
procedures).
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7.2
PROCESS OPERATION AND MAINTENANCE
7.2.1 Standard Operating Procedures
SOP manuals available (e.g., operating procedures manual,
supervisory operating manual, safety manual, accident and
fire prevention manual);
How procedures/manuals reviewed and approved;
Listing of personnel roles and responsibilities;
Applicability of manuals to tasks conducted during normal
and emergency situations;
Other process guides: operating logs, shift turnover
procedures, overtime procedures, call out procedures during
emergencies, reporting procedures for unusual circumstances
or process deviations;
Experimental operating conditions for process changes, and
management of change; and
Startup, shutdown, and routine operation checklists.
Note: Attachment 10 contains a summary of the types of documentation and other
materials that the audit team may want to review for more information on facility SOPs.
7.2.2 Training Practices
Types of training available for operations and maintenance
personnel;
Methods and frequency of training;
Who performs training and qualifications;
Frequency and procedures for revising training;
Refresher courses and retraining;
Upset simulations and drills;
Use of process simulators;
Job duty qualifications/prerequisites;
Types and frequency of job qualification evaluations (e.g.,
performance reviews, tests);
Employee turnover rate; and
Master qualification list.
7.2.3 Equipment Maintenance Procedures
Work order systems;
Maintenance and testing scheduling;
Preventive and predictive maintenance;
Equipment history records;
System for spare parts control;
Level of training;
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Frequency and method of communication between
maintenance and operations personnel;
Prioritization of maintenance and inspections;
Securing equipment during shift breaks;
Assuring proper repairs replacement; and
Management of change for equipment (e.g., appropriateness
of materials of construction).
7.2.4 Instrument Maintenance
Work order systems;
Frequency and testing of instrument calibration, sensor
inspections, and alarm and interlock inspections;
Instrument history records;
System for spare parts control;
Frequency and method of communication between
maintenance and operations personnel;
Number of employees and shift coverage;
Level of training;
Management of change for instruments (e.g., appropriateness
of calibration settings); and
Error checking.
7.3 Hazard Evaluation and Modeling
7.3.1 Hazard Evaluation
Type(s) or method(s) used at facility (e.g., What If, Hazop,
etc.) and why selected;
Processes and operations evaluated;
Procedures for targeting/scheduling evaluation (e.g., new
procedures, process modification, incidents);
Frequency and basis for updating methods;
Who participates in and reviews evaluation(s) and the
qualifications of such personnel;
Use of results and methods of documentation;
Performance of consequence analysis to understand impacts
of any potential release;
Implementation of results and recommendations; and
How is process change managed.
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7.3.2 Modeling
Uses and types of models for tracking releases into air,
surface water, and groundwater;
Processes, chemicals, and operations to which models have
been applied;
Goals of modeling activities (e.g. support for emergency
planning and emergency response);
Assumptions built in to the models (both by user and
developer) and facility perceptions of strengths and
limitations (e.g. dense gas releases, terrain effects, single-
phase versus multi-phase modeling capability);
Parameters covered by surface and groundwater models (e.g.
degradation, photolysis, volatization, geochemical processes,
local hydrology, adsorption, desorption);
Validate model against experimental measurements; and
Use during incidents and the results (e.g., improvements in
emergency response or planning).
7.4 Release Prevention Systems
Facility activities related to preventing a release
Description of type(s) of systems in place;
Why used;
Performance history at facility;
Testing and inspections; and
Modifications performed.
Examples of activities to prevent chemical releases:
Improvements in process and equipment design;
Reduction of inventories;
Changes in siting of particular equipment;
Increased training and safety reviews;
Improved process controls;
Installation of interlocks; and
Failsafe design.
7.5 MITIGATION SYSTEMS
Description of type(s) of system(s) in place;
Why used;
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Performance history at facility; and
Frequency of testing and inspections.
Examples of release mitigation systems include:
Water sprays and sprinkler systems;
Foams;
Physical separation of buildings and equipment; and
Physical barriers, including dikes, curbing, raised doorways,
and containment walls).
8.0 ACCIDENTAL RELEASE INCIDENT INVESTIGATION
Facility procedures for identifying the underlying causes of unplanned incidents,
including fires, explosions, or releases of hazardous chemicals, and for preventing similar
incidents from recurring serve as an important step toward the actual prevention of
future incidents.
8.1 HISTORY OF ACCIDENTAL RELEASES/INCIDENTS
Types (e.g., reportable, near miss);
Chronicle of releases;
Reporting history; and
Community response and interaction.
8.2 FACILITY INVESTIGATION PROCEDURES
Written procedures (e.g., guidelines, time frames);
Types of releases to be investigated (e.g., near misses; or those
reportable under federal, state, or local law);
Personnel responsible for investigations;
Management involvement;
Actions taken resulting from investigation; and
Use of reports to share results (e.g., through training programs and
lessons learned) and distribution scheme.
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9.0 FACILITY EMERGENCY PREPAREDNESS AND PLANNING ACTIVITIES
Emergency activities in preparing for and responding to accidental releases
illustrate facility knowledge, dedication, and practices for mitigating incidents.
9.1 Facility Emergency Response Plan
Type and coverage of facility response plans (e.g., OSHA emergency
action plan, SPCC plan, corporate plan);
Update schedule and procedures (i.e., how often revised and by
whom); and
Key procedural areas covered (e.g., release notification, evacuation,
response and mitigation activities).
9.2 Emergency Response Exercises and Simulations
Types, frequency, and groups involved; and
Uses of findings.
9.3 Fire, Evacuation, and Rescue Corridors
Procedures for conducting evacuations;
Condition and accessibility of fire and rescue corridors; and
Detail and location of facility and community maps (Maps should be
referenced in appendix.).
9.4 Emergency Equipment Provisions
Types;
Locations;
Inspection and maintenance policies, including testing; and
Sources of equipment (off-site versus on-site).
9.5 Emergency Response Chain of Authority
Chain of command (e.g., designation of control during an
emergency); and
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Coordination with off-site response personnel.
9.6 Emergency Response Management Procedures
Management's role in response incident situations.
9.7 Emergency Communication Network within the Facility
Types and accessibility of communication system(s) and backups,
including sirens, walkie-talkies, and phones;
Testing of communication system; and
Ability of personnel to interpret warning signals.
9.8 Emergency Response Personnel Training Requirements
Categories of facility emergency response personnel;
Type of training available and frequency;
Who performs training; and
Refresher courses.
9.9 Follow-up Release Procedures
Incident clean-up (e.g., self, private contractors); and
After-action review of response with all involved parties (e.g., public
and private organizations).
10.0 COMMUNITY AND FACILITY EMERGENCY RESPONSE PLANNING
ACTIVITIES
Communication to the community about facility activities and coordination with
the community in developing emergency response plans indicate a level of facility
commitment to safety, as well as revealing unique outreach activities.
10.1 Facility Planning and Outreach Activities with Community
Awareness and participation in LEPC activities;
Participation in CAER activities; and
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Outreach activities, scholarship programs, open houses, joint
training, education, etc.
10,2 Local/Community Emergency Response Planning
Community plan status;
Coordination between facility and community in plan preparation
and exercise;
Coordination with hospitals and emergency medical services on
treatment of chemical exposure victims;
Coordination with community response structures and procedures;
and
Mutual aid efforts and facility involvement in non-facility-related
community responses,
11.0 PUBLIC ALERT AND NOTIFICATION PROCEDURES
Public alert and notification procedures identify unique procedures and facility
commitment to safety for the community.
11.1 Procedures for Public Notification of Releases
Alarm systems (e.g. sirens, air horns, whistles);
Communication networks (e.g., radio, television, phone); and
Back-up systems.
11.2 Schedule for Testing Procedures
Frequency of tests; and
Number and type of individuals notified.
11.3 History of Notification Procedures and Evaluation
Type of incident;
Timeliness of public notification; and
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Number of individuals notified and methods of public and private
emergency notification.
11.4 Community and Facility Contacts
Alternate contacts; and
Telephone number update procedures.
11.5 Facility and Media Interaction
Direct communication links; and
History of past interaction.
12.0 CONCLUSIONS
The conclusions highlight safety practices observed at the facility. As described in
section 6.2.2, Tips for Writing the Report, the information should be presented in a factual
manner and should refrain from judgments of adequacy or inadequacy. This section
summarizes facility practices that reflect the facility's understanding of and commitment
to chemical process safety management.
13.0 RECOMMENDATIONS
If applicable, the audit team may wish to make one or more recommendations
regarding observed processes, practices, technologies, and so forth. Any such
recommendations should be stated clearly, and be practical and technologically feasible at
the facility. Recommendations are not required or mandatory actions that must be taken
by the facility. They should be presented as options that the facility may consider to
enhance their knowledge of and practices in chemical process safety management.
APPENDICES
During the audit process, the team will gather a variety of materials relating to the
operations of the facility. Most of this material, however, while very helpful in
conducting the audit and preparing the audit report, does not belong in the main body of
the audit report and should instead be placed in appendices or maintained in the files of
the regional office for future use. Examples of the types of material that might be
included as appendices are:
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Sample facility memoranda, guidelines, SOPs, policy statements;
Correspondence between the facility and the regional office; and
Graphics such as photographs, maps, charts.
All materials should be labeled with the:
Name of the facility;
Date of the audit; and
Other necessary identifying information.
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6.2 Writing the Report
6.2.1 Post-Visit Meeting
The entire audit team should reassemble as soon as possible after completion of
the site visit. This is important because the details of the site visit can become confused
and fade rapidly. Certain items should be covered in this meeting:
Require that team members immediately review and edit their notes from
the site visit to obtain clarity and completeness;
Begin using the audit report outline as a basis for organizing all audit
information;
Consider the major audit elements during the review and analysis process,
the initial stage in to the completion of the audit report:
Facility Background Information;
Chemical Hazards;
Process Hazard Information;
Chemical Accident Prevention;
Accidental Release/Incident Investigation;
Facility Emergency Preparedness and Planning Activities;
Community and Facility Emergency Response Planning Activities;
and
Public Alert and Notification.
Review all important observations and findings identified to this point in
the audit; and
Determine whether or not any particular conclusions can be drawn or
recommendations made for inclusion in the report.
6.2.2 Tips for Writing the Report
There are two main areas of consideration when preparing a report:
Writing style; and
Report format flexibility
Writing style
In many instances during report preparation, several individuals will be working on
separate sections pertaining to his/her role in conducting the audit. Although several
different writing styles may be presented in the report, it is very important that they all
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have one common element of presentation style -- information is factual, relevant,
complete, objective, and clear. The entire report, including the Conclusions and
Recommendations sections, should be presented in a factual manner and refrain from
judgments of adequacy or inadequacy.
The Conclusions section should highlight facility safety practices observed during
the audit, identifying unique facility practices that should be shared as well as areas for
improvement. This summary should reflect the facility's understanding of, and
commitment to, chemical process safety management, and should refrain from judgments
of adequacy or inadequacy. As an example of how to present conclusions, consider the
following pair of statements:
Iflcorreet. "The facility has adequate procedures to investigate and respond to the
cause(s) of accidental chemical releases."
Correct "The facility prepares follow-up reports for accidental releases of
hazardous chemicals that occur both on- and off-site. The report addresses the
cause of the incident, recommended actions to prevent the release from
reoccurring, and a schedule and list of responsible individuals for implementing
these actions." [If the facility uses a form for this practice, it could be referenced
in an appendix.]
The first statement does not provide any information on the facility's follow-up
procedures; in addition, a judgement is made on the procedures, which may or may not
be valid. The latter illustrates procedures that the facility takes following an accidental
release of hazardous chemicals both on- and off-site. Its style of presentation is factual
and provides clear information on what the facility does without commenting on the
adequacy or inadequacy of the procedures.
The Recommendations section should provide, clearly stated suggestions and
include the factual basis for each recommendation. The recommendations should be
both practically and technologically feasible for the audited facility - they are neither
mandatory nor required, and are simply being presented for consideration by the audit
team to the facility to enhance its chemical process safety management. As an example
of how to present recommendations, consider the following pair of statements:
Incorrect "The facility should implement a preventive maintenance program."
Correct "The facility should evaluate the appropriateness of its use of the
periodic maintenance system for maintaining pressure relief valves. This
evaluation could include, among other aspects, a review of alternative schemes,
such as preventive maintenance and predictive maintenance."
The first statement does not provide any information on the facility's existing
maintenance program and it does not specify the particular application for the
recommended preventive maintenance. The latter clearly describes the current status of
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the element in question and provides alternatives for consideration. In addition, the style
of presentation is appropriate for the cooperative nature of the audit program. In both
the Conclusions and Recommendations sections, all statements must address observations
that are presented in detail in the main body of the report.
Report format flexibility
The introduction to this section of the Manual addresses the purpose and uses of
the report protocol/outline. One important purpose is to ensure consistency in report
preparation. This consistency will help to facilitate analysis of conclusions and
recommendations and will assist CEPPO in effectively identifying successful and
problematic practices and technologies, and in sharing information with the regions, other
program offices, other federal agencies, state and local governments, facilities, and other
involved parties.
There are 13 major report sections (i.e., 1.0, 2,0, etc.), and when preparing the
report, each of these must be addressed. [Required Activity] For some facilities,
however, information relevant to a major section may not exist, or the audit team may
not have been able to examine materials relevant to this element. For example, the
facility may not have any system for alerting/warning the public that a release has
occurred (section 11.0), or this element may not have been reviewed by the audit team.
Rather than skip that section of the report, it should be stated that the facility does not
have a public alert/warning system, or that this element was not examined in the audit.
6.2.3 Follow-up Information
With almost any audit, there is usually a need to contact the facility after the site
visit has occurred to clarify a point or to obtain more complete information. A chemical
safety audit is no different. The preferred way to handle follow-up inquiries is for the
Team Leader to designate a person or persons to serve as the contact with the facility;
the facility may take a similar approach in making any further responses to EPA. This
minimizes the opportunity for miscommunication and lends a credible appearance to the
conclusion of the audit.
6-2.4 Standard Report Disclaimer
A standard report disclaimer accompanies all audit reports and is located after the
cover page. [Required Activity] Attachment 7 contains a sample disclaimer. The report
disclaimer serves to describe the scope and limitations of the audit report contents by
identifying the time frame in which the audit was conducted, and by clarifying the
facility's role in adopting or implementing any of the report contents.
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63 Review and Finalization Procedures
In preparing the final audit report, there are two considerations to keep in mind:
Access of draft report information through the Freedom of Information Act
(FOIA); and
Report inclusion of facility confidential information.
6.3.1 Access of Draft Information
In order to ensure that draft report information is not available to the public
through FOIA prior to report finalization, the EPA regional office can designate an EPA
official (e.g., Section, Division, or Branch Chief) to approve the report as "final." This
procedure is not mandatory, but highly recommended, since this process is cited under
the Deliberate Process Privilege Section, exemption 5 of FOIA [5 USC 552(b)5].
Additional actions can be taken to prevent draft information from being accessible
under FOIA. For example, all draft materials can be stamped "DRAFT." Draft
materials can include the following citation at the bottom of each page or on a cover
sheet:
"Pre-decisional Document, Not Disclosable Under FOIA"
" - Do Not Cite or Quote -"
Please note that these actions do not have legislative or regulatory authority, as
compared to the finalization process described above.
6.3.2 Facility Confidential Information
Another suggested activity during the report finalization process is submission of
the draft report to the facility to identify any confidential information. The facility should
be contacted to establish a deadline (e.g., two weeks) to avoid lengthy delays. Any
information identified as confidential should be treated as such. Comments on the report
that are provided by the facility can, but do not have to be taken into consideration as
the report is finalized.
6.4 Report Distribution
When the audit report is final, standard distribution by the Regional Chemical
Emergency Preparedness and Prevention (CEPP) Coordinator is required to the
following groups and organizations: [Required Activity]
SERC and LEPC in which the facility is located;
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Facility owner/operator;
Facility CEO;
EPA Headquarters, Chemical Emergency Preparedness and Prevention
Office; and
Any other federal, state, and local agencies or departments that assisted in
conducting the audit.
The region should ensure that at least one unbound copy of the report suitable for
photocopying is provided to CEPPO.
The Regional CEPP Coordinators should also consider distributing final audit
reports to other EPA offices; other federal, state, and local agencies or departments; and
other private and public sector organizations. Sharing the report with regional media
offices is encouraged. EPA Headquarters will also circulate copies to interested
headquarters media offices, the Prevention Work Group, and other federal programs.
Press releases of audit activities (e.g., facility visit, report finalization, etc.) are also
discretionary for the Regional CEPP Coordinators and EPA Headquarters CEPPO staff.
To help professionals conducting audits, EPA Headquarters is developing a
computerized database that contains profiles of all of the chemical safety audit reports.
The profiles are summaries of the audit reports organized in a uniform format consistent
with the CSA protocol. The database has search capabilities that allow the user to
identify report profiles based on SIC code, specific chemical hazards, etc. The
information contained in the database will be useful to the regions for a variety of
purposes, such as learning how a particular industry operates (e.g., the types of chemicals
and kinds of processes in use and the typical problems encountered), as well as
identifying field experts and comparing processes at different facilities for the same
chemical. CEPPO will also be able to use the database to assemble and distribute
information on chemical process safety management and chemical accident prevention
issues and to assess the implementation of the CSA program.
6.5 Preparing the Report Profile
An audit report profile should be submitted to headquarters in conjunction with
the submission of the audit report for inclusion into the database. The profile (see
Attachments 11 and 12) organizes the key information contained in the report, including
information on the facility and the audit team as well as report conclusions and
recommendations, in a format suitable for direct entry into the CSA database. In
addition to providing the basis for the continued development of the CSA database, the
profile format can also assist the audit team during the audit process. The profile can
serve as a method of organizing issues of interest and assigning areas of responsibility to
team members prior to the audit, monitoring the progress of the team during the audit
48
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visit, and organizing the collected information during report writing. The specific
information that should be included in the CSA report profile is described in the
annotated profile in Attachment 12. A hardcopy and an electronic version of the profile
should accompany the audit report when it is submitted to EPA headquarters to facilitate
entering the profile information into the database.
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7. Audit Follow-Up Activities
As a supplement to the chemical safety audit and CSA report preparation, each
regional office should establish an audit follow-up program. The follow-up program will
support EPA's efforts to evaluate the effectiveness of the CSA program in improving, as
well as heightening awareness of the need for, chemical process safety among chemical
producers, distributors, and users. In addition, it is hoped that the analysis of audit
results will provide a basis for amending the focus and direction of the CSA program to
better achieve its stated goals at the regional and headquarters level.
Although the specific nature of the follow-up activities has been left to the
discretion of the regional offices, at a minimum the program should be designed to track
audited facilities' implementation of CSA report recommendations. This will allow
Headquarters to analyze trends in the implementation of CSA recommendations as a
function of issue (e.g., employee training or instrument maintenance), level of effort (e.g.,
fixing a relief valve or replacing a storage tank), and type and size of facility. Within this
framework, the regional offices are free to examine other audit issues (e.g., format,
relationship with state and local officials) at their own discretion and to communicate
with the facility in writing or in person.
Optionally, some of the regions also may wish to develop a method to verify
whether the information received from the facility is accurate, to the extent that regional
resources permit. This may involve the continued participation of state and/or local
officials in the audit process or another facility visit by EPA or Technical Assistance
Team members.
7.1 Follow-Up Approaches
Currently, some regional offices have already developed follow-up programs.
They have approached the follow-up process from a variety of angles, ranging from
mailing worksheets to returning to the facilities for a post-audit review. For example:
* Region 6 conducted a comprehensive follow-up effort in FY 92 in which
representatives from the region revisited 14 facilities that had been audited
since 1989 to evaluate the implementation of audit team recommendations.
Issues studied included the most effective audit format; facility attitudes
toward the audit process; the role of facility size in implementing
recommendations; and the level of expertise of the audit team. Region 6
used the follow-up information to compile quantitative regional data, which
was summarized in charts and graphs to highlight key trends and issues.
The data indicated that 68 percent of the 173 recommendations were
implemented at the facilities involved in the project, with a notably lower
rate for the five facilities with greater than 1,000 employees (56%) and for
recommendations that involved changes in process design (40%), and a
notably higher rate for compliance-related recommendations (100%)
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Region 8 has sent questionnaires to facilities six and 12 months after the
audits to check on the facility's progress in implementing the
recommendations of the audit team. The questionnaire lists each of the
audit team's recommendation, and the facility indicates its response to the
recommendations, including their future plans for implementing the
recommendations. For the questionnaires completed by facilities in 1991,
the region identified an 80-85 percent response rate for facilities in
implementing audit recommendations.
Another possible follow-up option suggested by one regional office is to present audited
facilities with an evaluation form at the same time as the final audit report is distributed
to the facility.
7,2 Specific Information Required
The follow-up program should begin with the facilities at which an audit has been
conducted in fiscal year 1993. Regions also have the option of performing follow-up
efforts at facilities audited in previous years. For each audit, the regional office should
provide EPA Headquarters with the following information:
Full name and address of audited facility;
List of recommendations made by the audit team as organized in the CSA
report profile prepared by the region;
Indication of how each recommendation has been or is planned to be
implemented and/or addressed by the facility with the date completed or a
schedule for implementation, as appropriate;
Rationale for any recommendations that have not been implemented
and/or addressed by the facility; and
Audit implementation issues, including:
Facility attitude toward chemical safety audit, and
Successful and problematic audit practices.
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Attachments
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Attachment 1
Chemical Safety Audit Program Fact Sheet
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oEfW
FACT SHEET MARCH 1993
CHEMICAL SAFETY AUDIT PROGRAM
BACKGROUND
The Chemical Safety Audit (CSA) program has evolved
from the efforts of the U.S. Environmental
Protection Agency (EPA) under the Chemical Accident
Prevention (CAP) program. The CAP program emerged
from concerns raised by the release of methyl
isocyanate at Shopal, India, and of aldicarb oxime
at Institute, West Virginia. Awareness of the
critical threat to public safety posed by similar
incidents led to an emphasis on preparedness and
planning for response to chemical accidents.
Simultaneous with- the development of preparedness
activities by EPA was the passage and
implementation of the Emergency Planning and
Community Right-to-Know Act -- Title HI of the
Superfund Amendments and Reauthorization Act (SARA)
by Congress in 1986. Because prevention is the
most effective form of preparedness, the CAP
program promotes an effort to enhance prevention
activities. The primary objectives of the CAP
program are to identify the causes of accidental
releases of hazardous substances arid the means to
prevent them from occurring, to promote industry
initiatives in these areas, and to share activities
with the coffmunity, industry, and other groups.
Many of the key concerns of the CAP program arise
from the SARA Title III section 305(b) study
entitled Review of Emergency Systems. As part of
the information gathering efforts to prepare this
study, EPA personnel conducted a number of facility
site visits to learn about chemical process safety
management practices. The study covers
technologies, techniques, and practices for
preventing, detecting, and monitoring releases of
extremely hazardous substances, and for alerting
the public to such releases. One of the key
recommendations resulting from the study was the
continuation and expansion of the audit program.
As a follow-up to this national prevention study,
EPA has undertaken cooperative initiatives with
federal agencies, states, incfcjstry groups,
professional organizations, and trade associations,
as well as environmental groups and academia.
These joint efforts will serve to determine and
implement a means to share information on release
prevention technology and practices, and to enhance
the state of practice in the chemical process
safety arena.
PROGRAM GOALS
The CSA program is part of this broad initiative
and has been designed to accomplish the following
chemical accident prevention goals:
Visit facilities handling hazardous substances
to gather information on arid learn about safety
practices and technologies;
Heighten awareness of the need for, and promote,
chemical safety among facilities handling
hazardous substances, as well as in communities
where chemicals are located;
Build cooperation among facilities, EPA, and
other authorized parties by coordinating joint
audits; and
Establish a database for the assembly and
distribution of chemical process safety
management information obtained from the
facility audits.
PROGRAM AUTHORITY
The Comprehensive, Environmental Response,
Compensation and Liability Act (CERCLA or
Superfund) was enacted December 11, 1980, arid
amended by SARA on October 17, 1986. CERCLA
authorizes the federal government to respond where
there is a release or a substantial threat of a
release into the environment of any hazardous
substance, pollutant, or contaminant that may
present danger to the public health or welfare or
to the environment.
CERCLA Sections 104(b) and 104(e), as amended by
SARA in 1986, provide authorities for entering a
facility and accessing information to conduct a
chemical safety audit by EPA. While CERCLA
provides authority for states to use statutory
authorities for entry and information gathering,
such authorities may only be accessed pursuant to a
contract or cooperative agreement with the federal
government. Since there is no such arrangement,
states, as well as local governments, must use
their own authorities for audit participation.
As a matter of EPA policy under the CSA program,
all facilities that will receive an audit should
have experienced a release of a hazardous
substance, pollutant, or contaminant, or there
should be reaion to believe that there exists a
threat of such a release. The audits are intended
to be nonconfrontational and positive, such that
information on safety practices, techniques, and
technologies can be identified and shared between
EPA and the facility. Involvement in the CSA
program by Local Emergency Planning Committees
ClEPCs) and State Emergency Response Conmissions
(SERCs) formed under SARA Title III is encouraged
to enhance the goals of both of these programs.
However, as stated above, state and local
government participation in the audit, itself, must
be performed under state and local authorities.
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AUDIT SCOPE
REPORT DISTRIBUTION
The audit consists of interviews with facility
personnel, and on-si re review of various aspects of
facility operations related to the prevention of
accidental chemical releases. Specific topics
addressed include:
Awareness of chemical and process hazards;
Process characteristics;
Emergency planning and preparedness;
Hazard evaluation and release detection
techniques;
Operations arid emergency response training;
FaciIity/corporate management structure;
Preventive maintenance and inspection programs;
and
Community notification mechanisms and
techniques.
Observations and conclusions from audits are
detailed in a report prepared by the audit team.
The report identifies and characterizes the
strengths of specific Chemical Accident Prevention
program areas to allow the elements of particularly
effective programs to be recognized. Copies of the
report are provided to the facility so that weak
and strong program areas may be recognized. The
audit is conducted following the Guidance Manual
for EPA Chemical Safety Audit Team Members, issued
by EPA Headquarters. This guidance contains
recommended actions, as well as mandatory
procedures that must be followed to ensure the
health and safety of program auditors and program
integrity. Each member of the audit team should
have a copy of the manual, and a copy of the manual
is transmitted to the audited facility.
AUDIT TEAM COMPOSITION
An EPA audit team primarily consists of EPA
employees, and other designated representatives
including contractors and the American Association
of Retired Persons (AARP) enrollees. Other
federal, state, and local government personnel may
also be team members. The audit team can vary in
size, depending upon the level of detail of the
audit (e.g., nunber of chemicals and/or processes
under investigation; national significance).
FACILITY SELECTION
At present, there are no established procedures for
selecting a facility for an audit. Each EPA region
has flexibility in identifying facilities. Options
to consider in selecting a facility include:
Previous history of the facility;
SERC and/or LEPC referral;
Proximity to sensitive populations);
Public sensitivity;
Regional accident prevention initiatives;
Opportunity for sharing new technology;
Population density; and
Concentration of industry in the area.
Standard distribution by EPA regional offices of
the audit report will be at a minimun to:
ซ SERC and LEPC in which the facility is located;
Facility owner/operator and facility CEO;
EPA Headquarters; and
Any other federal, state, and local agencies or
departments that assisted in conducting the
audit.
Distribution is available to other EPA offices,
other federal, state, and local agencies or
departments, and other private and public sector
organizations.
ACCOMPLISHMENTS
During the first four years of the CSA program, the
regions have conducted audits at over 150
facilities In 46 states and Puerto Rico. EPA has
analyzed the conclusions and recommendations listed
in the audit reports to identify trends within and
across industries, processes, and chemicals to
assist in the further development of the CSA and
CAP programs, particularly in light of the
accidental release provisions of section 112(r) of
the Clean Air Act. At the same time, follow-up
activities performed by several of the regional
offices indicate that the majority of the
recommendations to improve chemical process safety
practices suggested by the audit teams have been
implemented or are scheduled to be implemented at
audited facilities.
CSA PROGRAM BENEFITS
Identification of effective, field-praven
chemical accident prevention technologies and
practices.
Better understanding of the causes of chemical
releases.
Greater awareness by facilities of chemical
safety and understanding of available
techniques, and specific suggestions for
improved programs.
Identification of problem areas in industry
where more attention is needed.
Cooperation and coordination of chemical safety
programs with other federal and state agencies
through joint audits and training.
For more information on the Chemical Safety Audit
program, contact the Chemical Emergency
Preparedness Program (CEPP) office in your EPA
regional office.
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Attachment 2
CERCLA Provisions Overview and CERCLA Statute
Section KMfa) Removal and Other Remedial Actions
This section provides the federal government with the authority to respond to releases or
threatened releases of hazardous substances, pollutants, or contaminants in certain situations.
Section 104(a) authorizes the EPA Administrator "to act, consistent with the national
contingency plan, to remove or arrange for the removal of, and provide for remedial action relating
to such hazardous substances, pollutants, or contaminants at any time, or take any other response
measure consistent with the national contingency plan which the Administrator deems necessary to
protect public health or welfare or the environment," where:
Any hazardous substance is released;
There is a substantial threat that a hazardous substance will be released into the
environment;
Any pollutant or contaminant is released into the environment "which may present
an imminent and substantial danger to the public health or welfare;" or
There is a substantial threat that a pollutant or contaminant may be released into the
environment "which may present an imminent and substantial danger to the public
health or welfare."
Section 104(b) Investigatory Response
Under Section 104(b), the Administrator is authorized to "undertake such investigations,
monitoring, surveys, testing, and other information gathering" that may be needed "to identify the
existence and extent of the release or threat thereof, the source and nature of the hazardous
substances, pollutants or contaminants involved, and the extent of danger to the public health or
welfare or to the environment." This investigatory response can be initiated whenever the
Administrator can act under Section 104(a) when he has "reason to believe" that:
A release has occurred;
A release is about to occur; or
"Illness, disease, or complaints thereof may be attributed to exposure to a hazardous
substance, pollutant, or contaminant and that a release may have occurred or be
occurring."
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Section 104fe1 Information Gathering and Access
Under Section 104(e), a designated representative of the President or a state or political
subdivision under a contract or cooperative agreement is authorized to obtain information and gain
access to sites and adjacent property "for the purposes of determining the need for response, or
choosing or taking" a response, or to enforce any provision of CERCLA. The authority to enter a
site and to inspect and take samples from a site may only be exercised where "there is a reasonable
basis to believe there may be a release or threat of release of a hazardous substance or pollutant or
contaminant,''
Access to Information. Section 104(e) authorizes any designated official, upon reasonable
notice, to require persons to provide relevant information or documents concerning:
"Identification, nature and quantity of materials which have been or are generated,
treated, stored, or disposed of at the facility;
"The nature or extent of a release or threatened release of a hazardous substance or
pollutant or contaminant at" the facility; and
"Information relating to the ability of a person to pay or perform a cleanup."
In addition, upon reasonable notice, Section 104(e) requires persons to grant access to a
facility to inspect and copy all documents or records, or at their option to provide copies.
Entry. Designated representatives are authorized to enter at reasonable times, any vessel,
facility, establishment, or other place or property:
"Where any hazardous substance, pollutant, or contaminant may be or has been
generated, stored, treated, disposed of, or transported from;"
"From which or to which a hazardous substance, pollutant, or contaminant has been
or may have been released;" and
"Where entry is needed to determine the need for response or the appropriate
response or to effectuate a response action."
Compliance Orders. If consent is not granted for access to information, entry onto the
facility, and inspection or sampling, Section 104(e)(5) authorizes EPA to:
"Issue an order directing compliance with the request," after such notice and
opportunity for consultation;
Ask the Attorney General to commence a civil action to compel compliance with a
request or order; and
Assess civil penalties up to $25,000/day for failure to comply with the order.
Section 104(e) also provides for the right to obtain access or information in any other lawful manner,
which includes warrants.
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Confidentiality of Information. Section 104(e)(7) provides that no person required to provide
information under CERCLA may claim that such information is entitled to protection unless such
person shows each of the following:
The "person has not described the information to any other person, other than a
member of a local emergency planning committee under Title III of SARA," an
officer or employee of the U.S. or a state or local government, an employee of such
person, or a person who is bound by a confidentiality agreement, and such person has
taken reasonable measures to protect the confidentiality of such information and
intends to continue to take such measures;"
"The information is not required to be disclosed, or otherwise made available, to the
public under any other federal or state law;"
"Disclosure of the information is likely to cause substantial harm to the competitive
position of such person;" and
"The specific chemical identity, if sought to be protected, is not readily discoverable
through reverse engineering."
The following information on hazardous substances is not entitled to protection:
Trade name, common name, or generic class or category;
Physical properties;
Hazards to health and the environment, including physical hazards (e.g., explosion)
and potential acute and chronic health hazards;
Potential routes of human exposure;
Disposal location of any waste stream;
Monitoring data or analysis on disposal activities;
Hydrogeologic or geologic data; and
Groundwater monitoring data.
Section 106fa) Abatement Action
This section of CERCLA provides the federal government with the authority to pursue
administrative and judicial action to require responsible parties to respond to actual or threatened
releases of hazardous substances. If the Administrator "determines that there may be an imminent
and substantial endangerment to the public health or welfare or the environment," he has two options
under 106(a):
Request the Attorney General to seek the necessary relief in the federal district court
where the threat occurs. The district court is given jurisdiction to grant relief as the
public interest and the equities of the case may require; or
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After providing notice to the affected state, he may take other action, including, but
not limited to the issuance of orders that may be necessary to protect public health
and welfare and the environment.
Note: Statutory texts of these reviewed CERCLA sections follows.
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COMPREHENSIVE ENVIRONMENTAL RESPONSE,
COMPENSATION AND LIABILITY
(42 U.S.C.A. งง 9601 to 9675)
CHAPTER 103COMPREHENSIVE ENVI-
RONMENTAL RESPONSE,
COMPENSATION, AND LIABILITY
SUBCHAPTER IHAZARDOUS SUBSTANCES
RELEASES, LIABILITY, COMPENSATION
Sec.
9601. Definitions.
9602. Designation of additional hazardous substances
and establishment of reportable released quanti-
ties; regulations.
9603. Notification requirements respecting released sub-
stances.
(a) Notice to National Response Center upon re-
lease from vessel or offshore or onshore
facility by person in charge; conveyance of
notice by Center.
(b) Penalties for failure to notify; use of notice
or information pursuant to notice in crimi-
nal case.
(c) Notice to Administrator of EPA of existence
of storage, etc., facility by owner or opera-
tor, exceptions; time, manner, and form of
notice; penalties for failure to notify; use
of notice or information pursuant to notice
in criminal case.
(d) Recordkeeping requirements; promulgation
of rules and regulations by Administrator
of EPA; penalties for violations; waiver of
retention requirements,
(e) Applicability to registered pesticide product
(f) Exemptions from notice and penalty provi-
sions for substances reported under other
Federal law or is in continuous release, etc.
9604. Response authorities.
(a) Removal and other remedial action by Presi-
dent; applicability of national contingency
plan; response by potentially responsible
parties; public health threats; limitations
on response; exception.
(b) Investigations, monitoring, etc., by President
(c) Criteria for continuance of obligations from
Fund over specified amount for response
actions; consultation by President with af-
fected States; contracts or cooperative
agreements by States with President prior
to remedial actions; cost-sharing agree-
ments; selection by President of remedial
actions; State credits: granting of credit,
expenses before listing or agreement, re-
sponse actions between 1978 and 1980,
State expenses after December 11, 1980, in
excess of 10 percent of costs, item-by-item
approval, use of credits; operation and
Sec,
9604. Response authoritiesCont'd
maintenance; limitation on source of funds
for O & M; recontracting; siting.
(d) Contracts or cooperative agreements by Presi-
dent with States or political subdivisions or
Indian tribes; State applications, terms and
conditions; reimbursements; cost-sharing
provisions; enforcement requirements and
procedures.
(e) Information gathering and access; action au-
thorized, access to information, entry, in-
spection and samples; authority and sam-
ples, compliance orders; issuance and com-
pliance, other authority, confidentiality of
information; basis for withholding.
(f) Contracts for response action; compliance
with Federal health and safety standards,
(g) Rates for wages and labor standards applica-
ble to covered work.
(h) Emergency procurement powers; exercise by
President
(i) Agency for Toxic Substances and Disease
Registry; establishment functions, etc.
(j) Acquisition of property.
9605. National contingency plan; preparation, contents,
etc.
(a) Revision and republication.
(b) Revision of plan.
(c) Hazard ranking system.
(1) Revision.
(2) Health assessment of water contamina-
tion risks.
(3) Reevaluation not required.
(4) New information.
(d) Petition for assessment of release.
(e) Releases from earlier sites.
'(f) Minority contractors.
(g) Special study wastes.
(1) Application.
(2) Considerations in adding facilities to
NPL.
(3) Savings provisions.
14} Information gathering and analysis.
9606. Abatement actions.
(a) Maintenance, jurisdiction, etc.
(b) Pines; reimbursement.
(c) Guidelines for using imminent hazard, en-
forcement and emergency response author-
ities; promulgation by Administrator of
EPA, scope, etc.
9607. Liability.
(a) Covered persons; scope; recoverable costs
and damages; interest rate; "comparable
maturity" date.
(b) Defenses.
(c) Determination of amounts.
467
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42 ง 9601
FEDERAL ENVIRONMENTAL LAW
SUBCHAPTER IVPOLLUTION INSURANCE
See.
9871. Definition*.
(1) Insurance.
(2) Pollution liability.
(3) Risk retention group.
(4) Purchasing group.
(5) State.
9671 State laws: scope of subchapter.
(a) State laws.
(b) Scope of title.
9673. Risk retention groups.
(a) Exemption.
(b) Exceptions.
(1) State laws generally applicable.
(2) State regulations not subject to exemp-
tion.
(c) Application of exemptions.
(d) Agents or brokers.
9674. Purchasing groups..
(a) Exemption.
(b) Application of exemptions.
(c) Agents or brokers.
9675. Applicability of securities laws.
(a) Ownership interests.
(b) Investment Company Act
(c) Blue sky law.
West's Federal Forms
Administrative agency decisions and orders, enforcement and re-
view, see f 851 et seq.
Administrative subpoenas, enforcement, see f 6004 et seq.
Depositions and discovery, see 4f 3271 et teq., 3681 et seq.
Intervention, motion for leave, see f 3111 et seq.
Jurisdiction and venue in district courts, see | 1003 et seq.
Production of documents, motions and orders pertaining to, see
} 3551 et seq.
Sentence and fine, see ง 7531 et seq.
Subpoenas, see ง 3981 et seq.
WESTLAW Electronic Research
See WESTLAW guide following the Explanation pages of this
pamphlet.
SUBCHAPTER IHAZARDOUS SUBSTANCES
RELEASES, LIABILITY, COMPENSATION
ง 9601. Definitions
For purpose of this subchapter
(1) Hie term "act of God" means an unantic-
ipated grave natural disaster or other natural
phenomenon of an exceptional, inevitable, and ir-
resistible character, the effects of which could not
have been prevented or avoided by the exercise of
due care or foresight
(2) The term "Administrator'' means the Ad-
ministrator of the United States Environmental
Protection Agency.
(3) The term "barrel" means forty-two United
States gallons at sixty degrees Fahrenheit
(4) The_term "claim" means a demand in writ-
ing for a sum certain.
(5) The term "claimant" means any person who
presents a claim for compensation under this
chapter.
(6) The term "damages" means damages for
injury or loss of natural resources as set forth in
section 9607(a) or 9611(b) of this title.
(7) The term "drinking water supply" means
any raw or finished water source that is or may
be used by a public water system (as defined in
the Safe Drinking Water Act [42 U.S.C. 300f et
seq.]) or as drinking water by one or more indi-
viduals.
(8) The term "environment" means (A) the nav-
igable waters, the waters of the contiguous zone,
and the ocean waters for which the natural re-
sources are under the exclusive management au-
thority of the United States under the Magnuson
Fishery Conservation and Management Act [16
U.S.C. 1801 et seq,], and (B) any other surface
water, ground water, drinking water supply, land
surface or subsurface strata, or ambient air with-
in the United States or under the jurisdiction of
the United States.
(9) The term "facility" means (A) any building,
structure, installation, equipment pipe or pipeline
(including any pipe into a sewer or publicly owned
treatment works), well, pit, pond, lagoon, im-
poundment ditch, landfill, storage container, mo-
tor vehicle, rolling stock, or aircraft or (B) any
site or area where a hazardous substance has
been deposited, stored, disposed of, or placed, or
otherwise come to be located; but does not in-
clude any consumer product in consumer use or
any vessel.
(10) The term "federally permitted release"
means (A) discharges in compliance with a permit
under section 1342 of Title 33, (B) discharges
resulting from circumstances identified and re-
viewed and made part of the public record with
respect to a, permit issued or modified under
section 1342 of Title 33 and subject to a condition
of such permit (C) continuous or anticipated inter-
mittent discharges from a point source, identified
in a permit or permit application under section
1342 of Title 33, which are caused by events
occurring within the scope of relevant operating
or treatment systems, (D) discharges in compli-
ance with a legally enforceable permit under sec-
tion 1344 of Title 33, (E) releases in compliance
with a legally enforceable final permit issued
pursuant to section 3005(a) through (d) of the
Solid Waste Disposal Act [42 U.S.C. 6925(a) to (d)]
from a hazardous waste treatment storage, or
disposal facility when such permit specifically
472
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ENVIRONMENTAL RESPONSE, ETC,
42 ง 9601
identifies the hazardous substances and makes
such substances subject to a standard of practice,
control procedure or bioassay limitation or condi-
tion, or other control on the hazardous substances
in such releases, (F) any release in compliance
with a legally enforceable permit issued under
section 1412 of Title 33 of1 section 1413 of Title
33, (G) any injection of fluids authorized under
Federal underground injection control programs
or State programs submitted for Federal approval
(and not disapproved by the Administrator of the
Environmental Protection Agency) pursuant to
part C of the Safe Drinking Water Act [42 U.S.C.
300h et seq.], (H) any emission into the air subject
to a permit or control regulation under section
111 [42 U.S.C. 7411], section 112 [42 U.S.C. 7412],
Title I part C [42 U.S.C. 7470 et seq.], Title I part
D [42 U.S.C. 7501 et seq.], or State implementa-
tion plans submitted in accordance with section
110 of the Clean Air Act [42 U.S.C. 7410] (and not
disapproved by the administrator of the Environ-
mental Protection Agency), including any sched-
ule or waiver granted, promulgated, or approved
under these sections, (I) any injection of fluids or
other materials authorized under applicable State
law (i) for the purpose of stimulating or treating
wells for the production of crude oil, natural gas,
or water, (ii) for the purpose of secondary, terti-
ary, or other enhanced recovery of crude oil or
natural gas, or (iii) which are brought to the
surface in conjunction with the production of
crude oil or natural gas and which are reinjected,
(J) the introduction of any pollutant into a public-
ly owned treatment works when such pollutant is
specified in and in compliance with applicable
pretreatment standards of section 1317(b) or (c) of
Title 33 and enforceable requirements in a pre-
treatment program submitted by a State or mu-
nicipality for Federal approval under section 1342
of Title 33, and (K) any release of source, special
nuclear, or byproduct material, as those terms are
defined in the Atomic Energy Act of 1954 [42
U.S.C. 2011 et seq.], in compliance with a legally
enforceable license, permit, regulation, or order
issued pursuant to the Atomic Energy Act of
1954,
(ID The term "Fund" or "Trust Fund" means
the Hazardous Substance Superfund established
by section 9507 of Title 26.
(12) The term "ground water" means water in
a saturated zone or stratum beneath the surface
of land or water.
(13) The term "guarantor" means any person,
other than the owner or operator, who provides
evidence of financial responsibility for an owner
or operator under this chapter.
(14) The term "hazardous substance" means
(A)-any substance designated pursuant to section
1321(b)(2XA) of Title 33, (B) any element, com-
pound, mixture, solution, or substance designated
pursuant to section 9602 of this title, (C) any
hazardous waste having the characteristics identi-
fied under or listed pursuant to section 3001 of
the Solid Waste Disposal Act [42 U.S.C. 6921] (but
not including any waste the regulation of which
under the Solid Waste Disposal Act [42 U.S.C.
6901 et seq.] has been suspended by Act of Con-
gress), (D) any toxic pollutant listed under section
1317(a) of Title 33, (E) any hazardous air pollutant
listed under section 112 of the Clean Air Act [42
U.S.C, 7412], and (F) any imminently hazardous
chemical substance or mixture with respect to
which the Administrator has taken action pursu-
ant to section 2606 of Title 15. The term does not
include petroleum, including crude oil or any frac-
tion thereof which is not otherwise specifically
listed or designated as a hazardous substance
under subparagraphs (A) through (F) of this para-
graph, and the term does not include natural gas,
natural gas liquids, liquefied natural ga3, or syn-
thetic gas usable for fuel (or mixtures of natural
gas and such synthetic gas).
(15) The term "navigable waters" or "naviga-
ble waters of the United States" means the wa-
ters of the United States, including the territorial
seas.
(16) The term "natural resources" means land,
fish, wildlife, biota, air, water, ground water,
drinking water supplies, and other such resources
belonging to, managed by, held in trust by, apper-
taining to, or otherwise controlled by the United
States (including the resources of the fishery con-
servation zone established by the Magmison Fish-
ery Conservation and Management Act [16 U.S.C.
1801 et seq.]) any State or local government, any
foreign government, any Indian tribe, or, if such
resources are subject to a trust restriction on
alienation, any member of an Indian tribe.
(17) The term "offshore facility" means any
facility of any kind located in, on, or under, any of
the navigable waters of the United States, and
any facility of any kind which is subject to the
jurisdiction of the United States and is located in,
on, or under any other waters, other than a vessel
or a public vessel.
(18) The term "onshore facility" means any
facility (including, but not limited to, motor ve-
hicles and rolling stock) of any kind located in, on,
or under, any land or nonnavigable waters within
the United States.
(19) The term "otherwise subject to the juris-
diction of the United States" means subject to the
SM.Em L*w SUts. '87 81.IS
473
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42 ง 9601
FEDERAL ENVIRONMENTAL LAW
jurisdiction of the United States by virtue of
United States citizenship, United States vessel
documentation or numbering, or as provided by
international agreement to which the United
States is a party.
(20XA) The term "owner or operator" means
(i) in the case of a vessel, any person owning,
operating, or chartering by demise, such vessel,
(ii) in the case of an onshore facility or an off-
shore facility, any person owning or operating
such facility, and (iii) in the case of any facility,
title or control of which was conveyed due to
bankruptcy, foreclosure, tax delinquency, aban-
donment, or similar means to a unit of State or
local government, any person who owned, operat-
ed or otherwise controlled activities at such facili-
ty immediately beforehand. Such term does not
include a person, who, without participating in the
management of a vessel or facility, holds indicia of
ownership primarily to protect his security interest
in the vessel or facility.
(B) In the case of a hazardous substance which
has been accepted for transportation by a com-
mon or contract carrier and except as provided in
section 9607(aX3) or (4) of this title, (i) the term
"owner or operator" shall mean such common
carrier or other bona fide for hire carrier acting
as an independent contractor during sueh trans-
portation, (ii) the shipper of such hazardous sub-
stance shall not be considered to have caused or
contributed to any release during such transpor-
tation which resulted solely from circumstances
or conditions beyond his control.
(C) In the case of a hazardous substance which
has been delivered by a common or contract carri-
er to a disposal or treatment facility and except as
provided in section 9607(aX3) or (4) of this title (i)
the term "owner or operator" shall not include
such common or contract carrier, and (ii) such
common or contract carrier shall not be con-
sidered to have caused or contributed to any
release at such disposal or treatment facility re-
sulting from circumstances or conditions beyond
its control.
(D) The term "owner or operator" does not
include a unit of State or local government which
acquired ownership or control involuntarily
through bankruptcy, tax delinquency, abandon-
ment, or other circumstances in which the govern-
ment involuntarily acquires title by virtue of its
function as sovereign. The exclusion provided
under this paragraph shall not apply to any State
or local government which has caused or contrib-
uted to the release or threatened release of a
hazardous substance from the facility, and such a
State or local government shall be subject to the
provisions of this chapter in the same manner and
to the same extent both procedurally and sub-
474
stantively, as any nongovernmental entity, includ-
ing liability under section 960? of this title.
(21) The term "person" means an individual,
firm, corporation, association, partnership, consor-
tium, joint venture, commercial entity, United
States Government, State, municipality, commis-
sion, political subdivision of a State, or any inter-
state body.
(22) The term "release" means any spilling,
leaking, pumping, pouring, emitting, emptying,
discharging, injecting, escaping, leaching, dump-
ing, or disposing into the environment (including
the abandonment or discarding of barrels, con-
tainers, and other closed receptacles containing
any hazardous substance or pollutant or contami-
nant), but excludes (A) any release which results
in exposure to persons solely within a workplace,
with respect to a claim which such persons may
assert against the employer of such persons, (B)
emissions from the engine exhaust of a motor
vehicle, rolling stock, aircraft, vessel, or pipeline
pumping station engine, (C) release of source,
byproduct, or special nuclear material from a
nuclear incident, as those terms are defined in the
Atomic Energy Act of 1954 [42 U.S.C. 2011 et
seq.], if such release is subject to requirements
with respect to financial protection established by
the Nuclear Regulatory Commission under sec-
tion 170 of such Act [42 U.S.C. 2210], or, for the
purposes of section 9604 of this title or any other
response action, any release of source byproduct,
or special nuclear material from any processing
site designated under section 7912(a)(1) or 7942(a)
of this title, and (D) the normal application of
fertilizer.
(23) The term "remove" or "removal" means
the cleanup or removal of released hazardous
substances from the environment, such actions as
may be necessary2 taken in the event of the
threat of release of hazardous substances into the
environment, such actions as may be necessary to
monitor, assess, and evaluate the release or
threat or release of hazardous substances, the
disposal of removed material, or the taking of
such other actions as may be necessary to pre-
vent, minimize, or mitigate damage to the public
health or welfare or to the environment, which
may otherwise result from a release or threat of
release. The term includes, in addition, without
being limited to, security fencing or other mea-
sures to limit access, provision of alternative wa-
ter supplies, temporary evacuation and housing of
threatened individuals not otherwise provided for,
action taken under section 9604(b) of this title,
and any emergency assistance which may be pro-
vided under the Disaster Relief Act of 1974 [42
U.S.C. 5121 et seq.].
(24) The term "remedy" or "remedial action"
means those actions consistent with permanent
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ENVIRONMENTAL RESPONSE, ETC.
42 ง 9601
remedy taken instead of or in addition to removal
actions in the event of a release or threatened
release of a hazardous substance into the environ-
ment, to prevent or minimize the release of haz-
ardous substances so that they do not migrate to
cause substantial danger to present or future
public health or welfare or the environment. The
term includes, but is not limited to, such actions
at the location of the release as storage, confine-
ment, perimeter protection using dikes, trenches,
or ditches, clay cover, neutralization, cleanup of
released hazardous substances or contaminated
materials, recycling or reuse, diversion, destruc-
tion, segregation of reactive wastes, dredging or
excavations, repair or replacement of leaking con-
tainers, collection of leachate and runoff, onsite
treatment or incineration, provision of alternative
water supplies, and any monitoring reasonably
required to assure that such actions protect the
public health and welfare and the environment
The term includes the costs of permanent reloca-
tion of residents and businesses and community
facilities where the President determines that,
alone or in combination with other measures, such
relocation is more cost-effective than and environ-
mentally preferable to the transportation, stor-
age, treatment, destruction, or secure disposition
offsite of hazardous substances, or may other-
wise be necessary to protect the public health or
welfare; the term includes offsite transport and
offsite storage, treatment, destruction, or secure
disposition of hazardous substances and associat-
ed contaminated materials,
(25) The term "respond" or "response" means
remove, removal, remedy, and remedial action, all
such terms (including the terms "removal" and
"remedial action") include enforcement activities
related thereto.
(26) The term "transport" or "transportation"
means the movement of a hazardous substance by
any mode, including pipeline (as defined in the
Pipeline Safety Act), and in the case of a hazard-
ous substance which has been accepted for trans-
portation by a common or contract carrier, the
term "transport" or "transportation" shall include
any stoppage in transit which is temporary, inci-
dental to the transportation movement, and at the
ordinary operating convenience of a common or
contract carrier, and any such stoppage shall be
considered as a continuity of movement and not
as the storage of a hazardous substance.
(27) The terms "United States" and "State"
include the several States of the Unites States,
the District of Columbia, the Commonwealth of
Puerto Rico, Guam, American Samoa, the United
States Virgin Islands, the Commonwealth of the
Northern Marianas, and any other territory or
possession over which the United States has juris-
diction.
(28) The term "vessel" means every description
of watercraft or other artificial contrivance used,
or capable of being used, as a means of transpor-
tation on water.
(29) The terms "disposal", "hazardous waste",
and "treatment" shall have the meaning provided
in section 1004 of the Solid Waste Disposal Act
[42 U.S.C. 6903].
(30) The terms "territorial sea" and "contig-
uous zone" shall have the meaning provided in
section 1362 of Title 33.
(31) The term "national contingency plan"
means the national contingency plan published
under section 1321(c) of Title 33 or revised pursu-
ant to section 9605 of this title.
(32) The term "liable" or "liability" under this
subchapter shall be construed to be the standard
of liability which obtains under section 1321 of
Title 33.
(33) The term "pollutant or contaminant" shall
include, but not be limited to, any element, sub-
stance, compound, or mixture, including disease-
causing agents, which after release into the envi-
ronment and upon exposure, ingestion, inhalation;
or assimilation into any organism, either directly
from the environment or indirectly by ingestion
through food chains, will or may reasonably be
anticipated to cause death, disease, behavioral
abnormalities, cancer, genetic mutation, physio-
logical malfunctions (including malfunctions in re-
production) or physical deformations, in such or-
ganisms or their offspring; except that the term
"pollutant or contaminant" shall not include pe-
troleum, including crude oil or any fraction there-
of which is not otherwise specifically listed or
designated as a hazardous substance under sub-
paragraphs (A) through (F) of paragraph (14) and
shall not include natural gas, liquefied natural
gas, or synthetic gas of pipeline quality (or mix-
tures of natural gas and such synthetic gas).
(34) The term "alternative water supplies" in-
cludes, but is not limited to, drinking water and
household water supplies.
(35)(A) The term "contractual relationship",
for the purpose of section 96Q7(bX3) of this title
includes, but is not limited to, land contracts,
deeds or other instruments transferring title or
possession, unless the real property on which the
facility concerned is located was acquired by the
defendant after the disposal or placement of the
hazardous substance on, in, or at the facility, and
one or more of the circumstances described in
clause (i), (ii), or liii) is also established by the
defendant by a preponderance of the evidence:
475
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ENVIRONMENTAL RESPONSE. ETC.
42 ง 9604
(e) Applicability to registered pesticide product
This section shall not apply to the application of a
pesticide product registered under the Federal In-
secticide, Fungicide, and Rodenticide Act [7 U.S.C.
136 et seq.] or to the handling and storage of such a
pesticide product by an agricultural producer.
(f) Exemption! from notice and penalty provisions for
substances reported under other Federal law or is
in continuoui release, etc.
No notification shall be required under subsection
(a) or (b) of this section for any release of a hazard-
ous substance
(1) which is required to be reported (or specifi-
cally exempted from a requirement for reporting)
under subtitle C of the Solid Waste Disposal Act
[42 U.S.C. 6921 et seq.] or regulations thereunder
and which has been reported to the National
Response Center, or
(2) which is a continuous release, stable in
quantity and rate, and is
(A) from a facility for which notification has
been given under subsection (c) of this section,
or
(B) a release of which notification has been
given under subsections (a) and (b) of this sec-
tion for a period sufficient to establish the
continuity, quantity, and regularity of such re-
lease:
Provided, That notification in accordance with
subsections (a) and (b) of this paragraph shall be
given for releases subject to this paragraph annu-
ally, or at such time as there is any statistically
significant increase in the quantity of any hazard-
ous substance or constituent thereof released,
above that previously reported or occurring.
(Dec. 11, 1980, Pub.L. 96-510, Title I, ง 103, 94 Stat. 2772:
Dec. 22, 1980, Pub.L. 96-561, Title II, ง 238(b), 94 Stat
3300; as amended Oct. 17, 1986, Pub.L. 99-499, Title I,
งง 103, 109(a)(1). (2), 100 Stat 1617, 1632, 1633.)
Library References
Health and Environment 25.5(10), 25.6(3), (9), 25.7(3), (24).
CJ.S. Health and Environment 55 92. 103 et seq.. 106. 113 et
seq.
ง 9604. Response authorities
(a) Removal and other remedial action by President:
applicability of national contingency plan; re-
sponse by potentially responsible parties: public
health threats; limitations on response: exception
(1) Whenever (A) any hazardous substance is re-
leased or there is a substantial threat of such a
release into the environment, or (B) there is a re-
lease or substantial threat of release into the envi-
ronment of any pollutant or contaminant which may
present an imminent and substantial danger to the
public health or welfare, the President is authorized
to act, consistent with the national contingency
plan, to remove or arrange for the removal of, and
provide for remedial action relating to such hazard-
ous substance, pollutant, or contaminant at any
time (including its removal from any contaminated
natural resource), or take any other response mea-
sure consistent with the national contingency plan
which the President deems necessary to protect the
public health or welfare or the environment When
the President determines that such action will be
done properly and promptly by the owner or opera-
tor of the facility or vessel or by any other respon-
sible party, the President may allow such person to
carry out the action, conduct the remedial investiga-
tion, or conduct the feasibility study in accordance
with section 9622 of this title." No remedial investi-
gation or feasibility study (RI/FS) shall be autho-
rized except on a determination by the President
that the party is qualified to conduct the RI/FS and
only if the President contracts with or arranges for
a qualified person to assist the President in oversee-
ing and reviewing the conduct of such RI/FS and if
the responsible party agrees to reimburse the Fund
for any cost incurred by the President under, or in
connection with, the oversight contract or arrange-
ment In no event shall a potentially responsible
party be subject to a lesser standard of liability,
receive preferential treatment, or in any other way,
whether direct or indirect, benefit from any such
arrangements as a response action contractor, or as
a person hired or retained by such a response action
contractor, with respect to the release or facility in
question. The President shall give primary atten-
tion to those releases which the President deems
may present a public health threat.
(2) Removal action
Any removal action undertaken by the Presi-
dent under this subsection (or by any other per-
son referred to in section 9622 of this title)
should, to the extent the President deems practi-
cable, contribute to the efficient performance of
any long term remedial action with respect to the
release or threatened release concerned.
(3) Limitations on response
The President shall not provide for a removal or
remedial action under this section in response to a
release or threat of release
(A) of a naturally occurring substance in its
unaltered form, or altered solely through natural-
ly occurring processes or phenomena, from a loca-
tion where it is naturally found;
(B) from products which are part of the struc-
ture of, and result in exposure within, residential
buildings or business or community structures:
479
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42 ง 9604
FEDERAL ENVIRONMENTAL LAW
(C) into public or private drinking water sup-
plies due to deterioration of the system through
ordinary use.
(4) Exception to limitation!
Notwithstanding paragraph (3) of this subsec-
tion, to the extent authorized by this section, the
President may respond to any release or threat of
release if in the President's discretion, it consti-
tutes a public health or environmental emergency
and no other person with the authority and capa-
bility to respond to the emergency will do so in a
timely manner.
(b) Investigation!, monitoring, etc., by President
(1) Information; studies and investigation!
Whenever the President is authorized to act
pursuant to subsection (a) of this section, or
whenever the President has reason to believe that
a release has occurred or is about to occur, or
that illness, disease, or complaints thereof may be
attributable to exposure to a hazardous sub-
stance, pollutant, or contaminant and that a re-
lease may have occurred or be occurring, he may
undertake such investigations, monitoring, sur-
veys, testing, and other information gathering as
he may deem necessary or appropriate to identify
the existence and extent of the release or threat
thereof, the source and nature of the hazardous
substances, pollutants or contaminants involved,
and the extent of danger to the public health or
welfare or to the environment In addition, the
President may undertake such planning, legal,
fiscal, economic, engineering, architectural, and
other studies or investigations as he may deem
necessary or appropriate to plan and direct re-
sponse actions, to recover the costs thereof, and
to enforce the provisions of this chapter.
(2) Coordination of Investigation*
The President shall promptly notify the appro-
priate Federal and State natural resource trustees
of potential damages to natural resources result-
ing from releases under investigation pursuant to
this section and shall seek to coordinate the as-
sessments, investigations, and planning under
this section with such Federal and State trustees.
(c) Criteria for continuance of obligation* from Fund
over specified amount for response actions; con-
sultation by President with affected States; con-
tracts or cooperative agreements by States with
President prior to remedial actions; coat-sharing
agreements; selection by President of remedial
actions: State credits: granting of credit, expenses
before listing or agreement, response actions be-
tween 1978 and 1980. State expenses after Decem-
ber 11, 1980. in excess of 10 percent of costs,
item-by-item approval, use of credits; operation
and maintenance; limitation on source of funds
for O&M: recontracting; siting
(1) Unless (A) the President finds that (i) contin-
ued response actions are immediately required to
prevent, limit, or mitigate an emergency, (ii) there is
an immediate risk to public health or welfare or the
environment, and (iii) such assistance will not other-
wise be provided on a timely basis, or (B) the
President has determined the appropriate remedial
actions pursuant to paragraph (2) of this subsection
and the State or States in which the source of the
release is located have complied with the require-
ments of paragraph (3) of this subsection, or (C)
continued response action is otherwise appropriate
and consistent with the remedial action to be taken 1
obligations from the Fund, other than those autho-
rized by subsection (b) of this section, shall not
continue after $2,000,000 has been obligated for
response actions or 12 months has elapsed from the
date of initial response to a release or threatened
release of hazardous substances.
(2) The President shall consult with the affected
State or States before determining any appropriate
remedial action to be taken pursuant to the authori-
ty granted under subsection (a) of this section.
(3) The President shall not provide any remedial
actions pursuant to this section unless the State in
which the release occurs first enters into a contract
or cooperative agreement with the President provid-
ing assurances deemed adequate by the President
that (A) the State will assure all future maintenance
of the removal and remedial actions provided for the
expected life of such actions as determined by the
President; (B) the State will assure the availability
of a hazardous waste disposal facility acceptable to
the President and in compliance with the require-
ments of subtitle C of the Solid Waste Disposal Act
[42 U.S.C.A. ง 6921 et seq.] for any necessary off-
site storage, destruction, treatment, or secure dispo-
sition of the hazardous substances; and (C) the
State will pay or assure payment of (i) 10 per
centum of the costs of the remedial action, including
all future maintenance, or (ii) 50 percent (or such
greater amount a3 the President may determine
appropriate, taking into account the degTee of re-
sponsibility of the State or political subdivision for
the release) of any sums expended in response to a
release at a facility, that was operated by the State
or a political subdivision thereof, either directly or
through a contractual relationship or otherwise, at
the time of any disposal of hazardous substances
therein. For the purpose of clause (ii) of this sub-
paragraph, the term "facility" does not include navi-
gable waters or the beds underlying those waters.
The President shall grant the State a credit against
the share of the costs for which it is responsible
under this paragraph for any documented direct
out-of-pocket non-Federal funds expended or obli-
gated by the State or a political subdivision thereof
after January 1. 1978, and before December 11,
1980, for cost-eligible response actions and claims
480
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ENVIRONMENTAL RESPONSE. ETC.
42 ง 9604
vene in any civil action involving the enforcement of
such contract or subcontract.
(4) Where i*vu or more noncontiguous facilities
are reasonably related on the basis of geography, or
on the basis of the threat, or potential threat to the
public health or welfare or the environment, the
President may, in his discretion, treat these related
facilities as one for purposes of this section.
(eV-Information gathering and access; action autho-
rized. access to information, entry, inspection and
samples: authority and samples, compliance or-
ders; issuance and compliance, other authority,
confidentiality of information; basis for withhold-
ing
(1) Action authorized
Any officer, employee, or representative of the
President, duly designated by the President, is
authorized to take action under paragraph (2), (3),
or (4) (or any combination thereof) at a vessel,
facility, establishment, place, property, or location
or, in the case of paragraph (3) or (4), at any
vessel, facility, establishment, place, property, or
location which is adjacent to the vessel, facility,
establishment, place, property, or location re-
ferred to in such paragraph (3) or (4). Any duly
designated officer, employee, or representative of
a State or political subdivision under a contract or
cooperative agreement under subsection (dXl) of
this section is also authorized to take such action.
The authority of paragraphs (3) and (4) may be
exercised only if there is a reasonable basis to
believe there may be a release or threat of release
of a hazardous substance or pollutant or contami-
nant. The authority of this subsection may be
exercised only for the purposes of determining
the need for response, or choosing or taking any
response action under this subchapter, or other-
wise enforcing the provisions of this subchapter.
(2) Access to information
Any officer, employee, or representative de-
scribed in paragraph (1) may require any person
who has or may have information relevant to any
of the following to furnish, upon reasonable no-
tice, information or documents relating to such
matter
(A) The identification, nature, and quantity
of materials which have been or are generated,
treated, stored, or disposed of at a vessel or
facility or transported to a vessel or facility.
(B) The nature or extent of a release or
threatened release of a hazardous substance or
pollutant or contaminant at or from a vessel or
facility.
(C) Information relating to the ability of a
person to pay for or to perform a cleanup.
In addition, upon reasonable notice, such person
either (i) shall grant any such officer, employee, or
representative access at all reasonable times to any
vessel, facility, establishment, place, property, or
location to inspect and copy all documents or
records relating to such matters or (ii) shall copy
and furnish to the officer, employee, or representa-
tive all such documents or records, at the option and
expense of such person.
(3) Entry
Any officer, employee, or representative de-
scribed in paragraph (1) is authorized to enter at
reasonable times any of the following:
(A) Any vessel, facility, establishment, or
other place or property where any hazardous
substance or pollutant or contaminant may be
or has been generated, stored, treated, disposed
of, or transported from.
(B) Any vessel, facility, establishment, or
other place or property from which or to which
a hazardous substance or pollutant or contami-
nant has been or may have been released.
(C) Any vessel, facility, establishment, or
other place or property where such release is or
may be threatened.
(D) Any vessel, facility, establishment, or
other place or property where entry is needed
to determine the need for response or the ap-
propriate response or to effectuate a response
action under this subchapter.
(4) Inspection and samples
(A) Authority
Any officer, employee or representative de-
scribed in paragraph (1) is authorized to inspect
and obtain samples from any vessel, facility,
establishment, or other place or property re-
ferred to in paragraph (3) or from any location
of any suspected hazardous substance or pollu-
tant or contaminant. Any such officer, employ-
ee, or representative is authorized to inspect
and obtain samples of any containers or label-
ing for suspected hazardous substances or pol-
lutants or contaminants. Each such inspection
shall be completed with reasonable promptness.
(B) Samples
If the officer, employee, or representative
obtains any samples, before leaving the premis-
es he shall give to the owner, operator, tenant,
or other person in charge of the place from
which the samples were obtained a receipt de-
scribing the sample obtained and, if requested,
a portion of each such sample. A copy of the
rpซn!ts of any analysis made of such samples
shall be furnished promptly to the owner, oper-
483
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42 ง 9604
FEDEEAL ENVIRONMENTAL LAW
ator, tenant, or other person in charge, if such
person can be located.
(5) Compliance orders
(A) Issuance
If consent is not granted regarding any re-
quest made by an officer, employee, or repre-
sentative under paragraph (2), (3), or (4), the
President may issue an order directing compli-
ance with the request. The order may be is-
sued after such notice and opportunity for con-
sultation as is reasonably appropriate under the
circumstances.
(B) Compliance
The President may ask the Attorney General
to commence a civil action to compel compliance
with a request or order referred to in subpara-
graph (A). Where there is a reasonable basis
to believe there may be a release or threat of a
release of a hazardous substance or pollutant
or contaminant, the court shall take the follow-
ing actions:
(i) In the case of interference with entry
or inspection, the court shall enjoin such in-
terference or direct compliance with orders to
prohibit interference with entry or inspection
unless under the circumstances of the case
the demand for entry or inspection is arbi-
trary and capricious, an abuse of discretion,
or otherwise not in accordance with law.
(ii) In the case of information or document
requests or orders, the court shall enjoin in-
terference with such information or doc-
ument requests or orders or direct compli-
ance with the requests or orders to provide
such information or documents unless under
the circumstances of the case the demand for
information or documents is arbitrary and
capricious, an abuse of discretion, or other-
wise not in accordance with law.
The court may assess a civil penalty not to exceed
125,000 for each day of noncompliance against any
person who unreasonably fails to comply with the
provisions of paragraph (2), (3), or (4) or an order
issued pursuant to subparagraph (A) of this para-
graph.
(6) Other authority
Nothing in this subsection shall preclude the
President from securing access or obtaining infor-
mation in any other lawful manner.
(7) Confidentiality of information
(A) Any records, reports, or information ob-
tained from any person under this section (includ-
ing records, reports, or information obtained by
representatives of the President) shall be avail-
able to the public, except that upon a showing
satisfactory to the President (or the State, as the
case may be) by any person that records, reports,
or information, or particular part thereof (other
than health or safety effects data), to which the
President (or the State, as the case may be) or
any officer, employee, or representative has ac-
cess under this section if made public would di-
vulge information entitled to protection under sec-
tion 1905 of Title 18, such information or particu-
lar portion thereof shall be considered confiden-
tial in accordance with the purposes of that sec-
tion, except that such record, report, document or
information may be disclosed to other officers,
employees, or authorized representatives of the
United States concerned with carrying out this
chapter, or when relevant in any proceeding un-
der this chapter.
(B) Any person not subject to the provisions of
section 1905 of Title 18 who knowingly and will-
fully divulges or discloses any information enti-
tled to protection under this subsection shall,
upon conviction, be subject to a fine of not more
than $5,000 or to imprisonment not to exceed one
year, or both.
CC) In submitting data under this chapter, a
person required to provide such data may (i) des-
ignate the data which such person believes is
entitled to protection under this subsection and (ii)
submit such designated data separately from oth-
er data submitted under this chapter. A designa-
tion under this paragraph shall be made in writ-
ing and in such manner as the President may
prescribe by regulation.
(D) Notwithstanding any limitation contained ,
in this section or any other provision of law, all
information reported to or otherwise obtained by
the President (or any representative of the Presi-
dent) under this chapter shall be made available,
upon written request of any duly authorized com-
mittee of the Congress, to such committee.
(E) No person required to provide information
under this chapter may claim that the information
is entitledhtOprotection under this paragraph un-
less such person shows each of the following:
(i) Such person has not disclosed the infor*
mation to any other person, other than a mem-
ber of a local emergency planning committee
established under title III of the Amendments
and Reauthorization Act of 1986 [42 U.S.C.A.
ง 11001 et seq.]. an officer or employee of the
United States or a State or local government,
an employee of such person, or a person who is
bound by" a confidentiality agreement, and such
484
-------
ENVIRONMENTAL RESPONSE, ETC.
42 ง 9604
person has taken reasonable measures to pro-
tect the confidentiality of such information and
intends to continue to take such measures.
(ii) The information is not required to be
disclosed, or otherwise made available, to the
public under any other Federal or State law.
(iii) Disclosure of the information is likely to
cause substantial harm to the competitive posi-
tion of such person.
(iv) The specific chemical identity, if sought
to be protected, is not readily discoverable
through reverse engineering.
(F) The following information with respect to
any hazardous substance at the facility or vessel
shall not be entitled to protection under this para-
graph:
(i) The trade name, common name, or gener-
ic class or category of the hazardous substance.
(ii) The physical properties of the substance,
including its boiling point, melting point, flash
point, specific gravity, vapor density, solubility
in water, and vapor pressure at 20 degrees
Celsius.
(iii) The hazards to health and the environ-
ment posed by the substance, including physical
hazards (such as explosion) and potential acute
and chronic health hazards.
(iy) The potential routes of human exposure
to the substance at the facility, establishment,
place, or property being investigated, entered,
or inspected under this subsection.
(v) The location of disposal of any waste
stream.
(vi) Any monitoring data or analysis of moni-
toring data pertaining to disposal activities.
(vii) Any hydrogeologic or geologic data.
(viii) Any groundwater monitoring data.
(f) Contract* for response action; compliance with Fed-
eral health and safety standards
In awarding contracts to any person engaged in
response actions, the President or the State, in any
case where it is awarding contracts pursuant to a
contract entered into under subsection (d) of this
section, shall require compliance with Federal
health and safety standards established under sec-
tion 9651(f) of this title by contractors and subcon-
tractors as a condition of such contracts.
(g) Rates for wages and labor standards applicable to
covered work
(1) All laborers and mechanics employed by con-
tractors or subcontractors in the performance of
construction, repair, or alteration work funded in
whole or in part under this section shall be paid
wages at rates not less than those prevailing on
proiects of a character similar in the locality as
determined by the Secretary of Labor in accordance
with the Davis-Bacon Act [40 U.S.C. 276a et seq.].
The President shall not approve any such funding
without first obtaining adequate assurance that re-
quired labor standards will be maintained upon the
construction work.
(2) The Secretary of Labor shall have, with re-
spect to the labor standards specified in paragraph
(1), the authority and functions set forth in Reorga-
nization Plan Numbered 14 of 1950 (15 F.R. 3176;
64 Stat, 1267) and section 276c of Title 40.
(h) Emergency procurement powers; exercise by Presi-
dent
Notwithstanding any other provision of law, sub-
ject to the provisions of section 9611 of this title, the
President may authorize the use of such emergency
procurement powers as he deems necessary to ef-
fect the purpose of this chapter. Upon determina-
tion that such procedures are necessary, the Presi-
dent shall promulgate regulations prescribing the
circumstances under which such authority shall be
used and the procedures governing the use of such
authority.
(i) Agency for Toxic Substances and Disease Registry;
establishment, functions, etc.
(1) There is hereby established within the Public
Health Service an agency, to be known as the
Agency for Toxic Substances and Disease Registry,
which shall report directly to the Surgeon General
of the United States. The Administrator of said
Agency shall, with the cooperation of the Adminis-
trator of the Environmental Protection Agency, the
Commissioner of the Food and Drug Administra-
tion, the Directors of the National Institute of Medi-
cine, National Institute of Environmental Health
Sciences, National Institute of Occupational Safety
and Health, Centers for Disease Control, the Admin-
istrator of the Occupational Safety and Health Ad-
ministration, the Administrator of the Social Securi-
ty Administration, the Secretary of Transportation,
and appropriate State and local health officials, ef-
fectuate and implement the health related authori-
ties of this chapter. In addition, said Administrator
shall
(A) in cooperation with the States, establish
and maintain a national registry of serious dis-
eases and illnesses and a national registry of
persons exposed to toxic substances;
(B) establish and maintain inventory of litera-
ture, research, and studies on the health effects
of toxic substances;
(C) in cooperation with the States, and other
agencies of the Federal Government, establish
485
-------
ENVIRONMENTAL RESPONSE, ETC.
42 ง9606
health or the environment posed by the release
of such hazardous constituents at such faciiity.
This subparagraph refers only to available in-
formation on actual concentrations of hazard-
ous substances and not on the total quantity of
special study waste at such facility.
(31 Saving* provisions
Nothing in this subsection shall be construed to
limit the authority of the President to remove any
facility which as of October IT, 1986 is included
on the National Priorities List from such list, or
not to list any facility which as of such date is
proposed for inclusion on such list
(4) Information fathering and anaJysia
Nothing- in this chapter shall be construed to
preclude the expenditure of monies from the
Fund for gathering and analysis of information
which will enable the President*^ consider the
specific factors required by paragraph (2).
(Dec, 11, 1980, Pub.L. 96-510, title !. f 105, 94 Stat. 2779,
as amended Oct 17, 1986, Pub.L. 99-499, Title I, f 105,
100 Stat. 1625.)
Cod* of Federal
Oil MKj husntau iuIwcucm polluooa eoatmftaey alu, m* 40
CFR 300.1 tt m-
Library Reference*
Hstlth tad Enviroommt "23.1 217.
CJS. Hnltk ud Cbwobibmi || 91 ซt Mq., 10< tt Mq.
ง 9606. Abatement actions
(a) Mainteiwaca. jurisdiction, etc.
In addition to any other action takes by a State or
local government, when the President determine#
that there may be as imminent and substantial
endangerment to the public health or welfare or the
environment because of aa actual or threatened
release of a hazardous substance from a facility, he
may require the Attorney General of the United
States to secure such relief as may be necessary to
abate such danger or threat, and the district court
of the United State* in the district in which the
threat occurs shall have jurisdiction to grant such
relief as the public interest and the equities of the
case may require. The President stay also, after
notice to the afftctad Stfte, take other action under
this section iadodiiif, but not limited to, issuing
such orders aa nay bซ necessary to protect public
health and welfare and the environment
(k> Fines: retฆliniawl
(1) Any person who, without sufficient cause,
willfully violates, or fails or refuses to comply with,
any order of the President under subsection (a) of
this section may, in an action brought in the appro-
priate United States district court to enforce such
order, be fined not more than 125.000 for each day
in which such violation occurs or such failure to
comply continues.
(2KA) Any person who receives and complies
with the terns of any order issued under subsection
(a) of this section may, within 60 days after comple-
tion of the required action, petition the President
for reimbursement from the Fund for the reason-
able costs of such action, plus interest. Any inter-
est payable under this paragraph shall accrue on
the amounts expended from the date of expenditure
at the same rate as specified for interest on invest-
ments of the Hazardous Substance Superfund es-
tablished under subchapter A of chapter 98 of Title
26.
(B) If the President refuses to grant ail or part
of a petition made under this paragraph, the peti-
tioner may within 30 days of receipt of such refusal
file an action against the President in the appropri-
ate United States district court seeking reimburse-
ment from the Fund.
(C) Except as provided in subparagraph (D), to
obtain reimbursement, the petitioner shall
by a preponderance of the evidence that it is not
liable for response costs under section 9607(a) of
this title and that costs for which it seeks reim-
bursement are reasonable in light of the action
required by the relevant order.
(D> A petitioner who is liable for response costs
under section 9607(a) of this title may also recover
its reasonable costs of response to the extent that it
can demonstrate, on the administrative record, that
the President's decision is selecting the response
action ordered was arbitrary and capricious or was
otherwise not in accordance with law. Reimburse-
ment awarded under this subparagraph shall in-
clude all reasonable response costs incurred by the
petitioner pursuant to the portions of the order
found to be arbitrary and capricious or otherwise
not in accordance with law.
(E) Reimbursement awarded by a court under
subparagraph
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Attachment 3
Model Site Safety Plan for Chemical Safety Audits
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SITE SAFETY PLAN FOR
CHEMICAL SAFETY AUDITS
The OSHA Hazardous Waste Site Worker Standards (29 CFR 1910.120), the
EPA Safety Manual, Chapter 9, and other EPA protocols require certain safety
planning efforts prior to field activities. The following format is aligned with
these requirements. Extensive training and certifications, and further planning
in the form of a more extensive Site Safety Plan, may be required in addition to
the following plan.
PROJECT:
Project Coordinator:
Branch Chief:
On Scene Coordinator or
Supervisor: Date:
Health and Safety Manager
Approval: Date:
DESCRIPTION OF ACTIVITY
If any of the following information is unavailable, mark "UA"; if covered in
project plan, mark "PP."
Site Name:
Location and approximate size:
Description of the response activity and/or the job tasks to be performed:
Date:
Date:
Duration of the Planned Employee Activity:
Proposed Date of Beginning the Investigation:
Site Topography:
Site Accessibility by Air and Roads:
-------
HAZARDOUS SUBSTANCES AND HEALTH HAZARDS INVOLVED OR
SUSPECTED AT THE SITE
Fill in any information that is known or suspected
Chemical and Identity of Substance
Areas of Concern Physical Properties and Precautions
Explosivity:
Radioactivity:
Oxygen Deficiency:
(e.g., Confined Spaces)
Toxic Gases:
Skin/Eye Contact ฆ
Hazards:
Heat Stress:
Pathways from site for hazardous substance dispersion:
WORK PLAN INSTRUCTIONS
A. Recommended Level of Protection: A B C
Cartridge Type, if Level C:
-------
Additional Safety Clothing/Equipment:
Monitoring Equipment to be Used;
CONTRACTOR PERSONNEL:
Number of Skills:
CONTRACTOR SAFETY CLOTHING/EQUIPMENT REQUIRED:
Have contractors received OSHA required training and certification?
(29 CFR 1910.120)
(If "yes," copy of training certificate(s) must be obtained from contractor)
B. Field Investigation and Decontamination Procedures:
Decontamination Procedures (contaminated protective clothing, instruments,
equipment, etc.):
-------
Disposal Procedures (contaminated equipment, supplies, disposal items, wash-
water, etc.): '
EMERGENCY CONTACTS
Hospital Phone No.:
Hospital Location:
EMT/Ambulance Phone No.:
Police Phone No.:
Fire Assistance Phone No.:
Regional Health and Safety Manager:
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Attachment 4
Sources of Information
Concerning Hazardous Substance Releases
The Accidental Release Information Program (ARIP). EPA established ARIP to promote safety
initiatives by industry and to develop a national database on the causes of chemical accidents, but
more importantly, to identify methods used to prevent recurrences. The data collected in ARIP are
derived from questionnaires completed by selected facilities that have reported releases to the
National Response Center (NRC), as required by law.
Facilities selected to receive an ARIP questionnaire have experienced a "triggered" release
exhibiting one or more of the following characteristics:
Release quantities in excess of a multiple of the CERCLA reportable quantity for the
chemical involved;
Releases resulting in deaths or injuries;
Releases that are part of a trend of frequent releases from the same facility; or
Releases involving extremely hazardous substances designated under SARA Title in.
State Emergency Response Commissions (SERCs) and Local Emergency Planning Committees
(LEPCs). SERCs and LEPCs established under SARA Title III receive Section 304 reports detailing
accidental releases of hazardous chemicals (those listed under the OSHA Hazard Communication
Standard and CERCLA) and SERCs also received Section 313 reports recording annual releases,
routine and accidental, of hazardous substances by manufacturing facilities.
The National Response Center (NRC). The NRC receives notifications on accidental releases that
are subject to Reportable Quantity requirements of CERCLA The NRC has been notified of
thousands of hazardous substance releases since 1978.
The Emergency Response Notification System (ERNS). ERNS is a recent effort of the Agency to
channel the state, regional, and NRC reports on releases of oil and hazardous substances into one
central database. ERNS is used by EPA for enforcement tracking and program management
purposes.
The Environmental Protection Agency (EPA). Both the national and regional offices of EPA receive
reports and notifications on accidental releases.
The Acute Hazardous Events Data Base (AHE/DB). Designed by EPA, AHE/DB collects a
representative sample of event reports from the above and other sources into a form that is more
convenient for gaining perspective on accidental releases and drawing policy conclusions. Developed
in 1985, it was recently updated and expanded to 6,300 records.
The Section 305(b) Report to Congress on Emergency Systems. Mandated by SARA Title III, the
report was a three-stage process. Information on certain facilities with completed questionnaires is
available. The report and backup information provide a good technical understanding for detecting,
monitoring and preventing releases, as well as for public alert.
-------
The Federal Emergency Management Agency (FEMA). FEMA keeps a record of ail incidents
involving the participation of emergency management personnel.
The Occupation Safety and Health Administration (OSHA) and the National Institute of
Occupational Safety and Health (NIOSH). OSHA and NIOSH have records of accidents in the
workplace.
U.S. Coast Guard Marine Safety Offices (MSO). Local MSOs regularly conduct inspections of
waterfront facilities. These inspection reports are available from the respective MSO, and can
provide useful facility information.
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Attachment 5
Sample First Letter to Facility Owner/Operator
Dear (Facility Owner!Operator):
Through the records retained by the National Response Center pursuant to Section 103(a)
of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as
amended (CERCLA), the U.S. Environmental Protection Agency has identified your facility as a site
where a reportable release of a CERCLA hazardous substance occurred. The EPA is currently
conducting chemical safety audits of particular facilities identified through the Section 103(a)
reporting system for the purpose of identifying technological and managerial mechanisms that might
be implemented to prevent future threatened releases harmful to human health and the environment.
The audit includes an on-site visit during which a review of equipment, procedures, training, and
management techniques is conducted to learn about prevention of accidental chemical releases.
Due to a report filed by the (facility name) under Section 103(a) of CERCLA, [facility name)
has been chosen as a potential candidate for an EPA chemical safety audit The Agency is requesting
your cooperation in an audit of your facility under the authorities of Sections 104(b) and 104(e)
CERCLA, by (names and affiliation of audit team) on (date), or on a date convenient to you. Please
be assured that the audit team will make every effort to minimize any interference with your plant
operations during the actual safety audit.
If you wish to assert a business confidentiality claim for part or all of the information
collected, such a claim must accompany the information when it is received by EPA, or it may be
made available to the public without further notice to you. Information covered by a confidentiality
claim will be disclosed by EPA only to the extent, and by means of the procedures, set forth in EPA
regulations at 40 CFR Part 2. EPA has contracted with (contractor name and contract number) to
obtain information pertinent to conducting the safety audit. (Contractor name) has been designated
as an authorized representative of the Agency. Therefore, (contractor name) is subject to the
provisions of Section 104(e) of CERCLA respecting confidentiality of methods or processes entitled
to protection as trade secrets.
EPA would like to conduct this audit in a constructive and positive manner. The EPA solicits
your prompt response to the above request. If you have any questions about the audit or the
Chemical Safety Audit program, please contact (regional contact) for further information.
Sincerely,
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Attachment 6
Sample Letter to Facility Owner/Operator who has not Responded
or Consented to the Audit
Dear (Facility Owner/Operator):
Through the records retained by the National Response Center pursuant to Section 103(a)
of the Comprehensive Environmental Response, Compensation and Liability Act of 1980, as amended
(CERCLA), the U.S. Environmental Protection Agency has identified your facility as a site where
a reportable release of a CERCLA hazardous substance occurred. The EPA is currently conducting
chemical safety audits of particular facilities identified through the Section 103(a) reporting system
for the purpose of identifying technological and managerial mechanisms that might be implemented
to prevent future threatened releases harmful to human health and the environment. The (facility
name) has been chosen for a chemical safety audit due to its reportable release(s) of (CERCLA
hazardous substance (s)) on (date of release). The audit includes an on-site visit in which a review of
equipment, procedures, training and management techniques is conducted to learn about prevention
of accidental chemical releases. We wish to assure you that we will make every effort to minimize
any interference with your plant operations during the course of the audit.
On (date) EPA sent you a letter requesting your voluntary cooperation in a chemical safety
audit of your facility. [The Agency has not received a reply to that request.] {(By letter dated
,) (/Through a telephone conversation on ,) you indicated that you will not
extend your voluntary cooperation to an audit of your facility.] You should be aware that Sections
104(b) and 104(e)(4)(A) of CERCLA specifically give EPA the right to access private property where
there is a reasonable basis to believe that there has been or may be a release or threat of release of
a hazardous substance or pollutant or contaminant. Failure to grant such access within days
of receipt of this letter, or adequately to justify such failure to grant such access, can result in EPA
enforcing an order requesting entry pursuant to Section 104(e)(5) by seeking a warrant and/or
penalties for noncompliance with the entry order. Section 104(e)(5)(B) of CERCLA permits EPA
to seek the imposition of up to twenty-five thousand dollars ($25,000) for each day that you fail to
grant access to EPA. Please be further advised that provision of false, fictitious, or fraudulent
statements or representations may subject you to criminal penalties under 18 U.S.C. Section 1001.
If you wish to assert a business confidentiality claim for part or all of the information
collected, such a claim must accompany the information when it is received by EPA, or it may be
made available to the public without further notice to you. Information covered by a
confidentiality claim will be disclosed by EPA only to the extent and by means of the procedures set
forth in EPA regulations at 40 CFR Part 2, EPA has contracted with (contractor name and contract
number) to obtain information pertinent to conducting the safety audit. (Contractor name) has been
designated as an authorized representative of the Agency. Therefore, (contractor name) is subject
to the provisions of Section 104(e) of CERCLA respecting confidentiality of methods or processes
entitled to protection as trade secrets.
-------
Due to the legal ramifications of your failure to grant access, EPA strongly encourages you
to give this matter your immediate attention and further consideration within the time specified. If
you have any legal or technical questions relating to this matter, you may consult with the EPA prior
to the time specified above. Please direct legal questions to (Name of ORC Person) of the Office of
Regional Counsel at . Technical questions should be directed to (Name of Program
Person), at the above address, or at .
Sincerely,
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Attachment 7
Standard Report Disclaimer
The contents of this report reflect information concerning the {facility name) facility obtained
during a U.S. Environmental Protection Agency chemical safety audit and from records provided by
the {facility name) facility. The audit was conducted from {audit dates), and observations as presented
in this report provide a snapshot of conditions existing at the facility during the audit time frame.
They do not represent planned or anticipated changes proposed or on-going at the facility. The
recommendations and other report observations contained in this report are not mandatory actions
that the facility must implement. In addition, EPA makes no assurances that if implemented, the
recommendations and other report observations contained in this report will prevent future chemical
accidents, equipment failures, or unsafe management practices, and/or provide protection from a
future enforcement action under any applicable law or regulation.
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Attachment 8
Standard Language for Audit Report introduction
The Chemical Safety Audit (CSA) program has evolved from the efforts of the U.S.
Environmental Protection Agency (EPA) under the Chemical Accident Prevention (CAP) program.
The primary objectives of the CAP program are to learn about the causes of accidental releases of
hazardous substances and the means to prevent such releases from occurring, to promote industry
initiatives in these areas, and to share activities with the community.
The Chemical Safety Audit program is part of this broad initiative, and has been designed to
accomplish the following chemical accident prevention goals:
Visit facilities handling hazardous substances to gather information on safety practices
and technologies;
Heighten awareness of the need for, and promote, chemical safety among facilities
handling hazardous substances, as well as in communities where chemicals are located;
Build cooperation among facilities, EPA, and other authorized parties by coordinating
joint audits; and
Establish a database for the assembly and distribution of chemical process safety
management information obtained from the facility audits.
The audit consists of interviews with facility personnel, and on-site review of various aspects
of facility operations related to the prevention of accidental chemical releases. CERCLA sections
104(b) and 104(e), as amended by SARA in 1986, provide authorities for entering a facility and
accessing information. Specific topics addressed include:
Awareness of chemical and process hazards;
Process characteristics;
Emergency planning and preparedness activities;
Hazard evaluation and release modelling efforts;
Release detection and monitoring techniques;
Training of operators and emergency response personnel;
Facility and corporate management structure;
Preventive maintenance and inspection programs; and
Community notification mechanisms and techniques.
-------
This report contains observations and conclusions and recommendations from an audit
conducted at [facility name, city, and state) from (audit dates). This report identifies and characterizes
the strengths of specific chemical accident prevention program areas to allow the elements of
particularly effective programs to be recognized. Copies of the report are provided to the facility so
that weak and strong program areas may be recognized.
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Attachment 9
Documentation Pertaining to the Processes and
Operations Using Hazardous Substances
The issues contained in sections 6.2.1 and 6.2.2 of the CSA protocol, Overview of Processing
Sleps and Operating Procedures and General Description of Process Equipment, will require members
of the audit team to review processing and operating information. The team should review facility
documentation on the equipment and operating procedures relevant to the audit. Before examining
current practices, the audit team may want to review available technical documentation supporting
the original selection of technology, process chemistry, equipment, and operating parameters for the
process(es) under study. Typical documentation available for current operations include Process Flow
Diagrams (PFDs) and Piping and Instrumentation Diagrams (PIDs). The following questions can
provide a framework for your evaluation of these documents:
Does the facility have documentation on the design and operating parameters of the
equipment and processes using the substance(s) of interest?
Is the documentation for the process(es) complete, accurate, and legible?
Are symbols used uniformly?
Are items such as the location and sizes of nozzles for connection of process lines,
utility tie-ins, relief devices, controls, drains, vents, and blinds included?
Do pieces of equipment have assigned numbers and are descriptions provided?
Are the equipment specifications and operating parameters (e.g., dimensions, capacity,
surface area, temperatures, pressures) specified?
Are equipment spares shown?
For piping, are the items such as rating, diameter, fluid flow direction, insulation and
tracing requirements, and sloping requirements for expansion shown?
For instrumentation, are items such as control parameter, indicating and recording
functions, transmitter, signal type, control valve size, and actuator type shown?
Other issues to keep in mind when examining process documentation include materials of
construction; electrical area classification; design of relief, safety, and ventilation systems; relevant
design codes and standards; and material and energy balances.
PIDs indicate whether or not the crucial operating parameters are being monitored in order
for the operator to be able to respond to upsets in a timely manner. Therefore, the team should
review a PID for the following concerns: monitoring of operating parameters, provisions for
automatic shutdown, presence of alarm systems, interlock systems, overpressure protection, disposal
method of relief stream, and similar information. The audit team may want to compare a portion of
the PID to the systems and equipment in existence at the facility to verify their accuracy.
-------
Attachment 10
Descriptions of Standard Operating Procedure Manuals
Section 7.2.1 of the CSA protocol, Standard Operating Procedures, lists several types of SOP
manuals that should be reviewed, as relevant, by the audit team. In general, the audit team should
consider whether existing facility SOPs are complete -- do they address initial and post-shutdown
startups, normal operations, temporary and emergency operations, normal and emergency shutdowns,
and maintenance. The following descriptions provide a summary of the type of information that
facility SOP manuals typically contain.
Supervisory Operating Manual
ป Feed and product specifications;
PFDs; PIDs; MSDSs;
Process parameters;
Intermediate stream normal operating guidelines;
List of alarms and interlocks;
Equipment and instrumentation settings;
Narrative description of start-up;
Testing practices;
Shutdown; and
ซ Emergency situations.
Operating Procedures Manual
Detailed vaive-by-valve procedures for all operating tasks;
Schematic drawings;
Safety instructions; and
Equipment and systems.
Safety Procedures Manual
Safety systems and equipment;
Safety procedures; and
Instructions.
In addition to comprehensiveness, the audit team should determine whether the SOP manuals
accurately reflect current equipment and current practices and whether they are understood and
implemented by operations personnel. Finally, the audit team should determine whether the manuals
are formally evaluated on a regular basis, whether both operations and management personnel
participate in the review and revision of SOPs, and how information on such changes is provided to
operations and supervisory personnel through training and drills.
Beyond the manuals listed above, there are a variety of other procedural documents (e.g.,
operating logs, shift turnover procedures, and maintenance guidelines) that the audit team may want
to examine, depending on the focus of the audit. Safety, health, and accident prevention topics that
can be investigated through these sources include overtime practices, emergency caliout procedures,
procedures for reporting unusual occurrences, and consistency of equipment handling procedures for
maintenance and operations personnel.
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Attachment 11
Blank CSA Report Profile
-------
CHEMICAL SAFETY- AUDIT PROFILE
Facility Name:
Facility Location:
Date(s) Audit Conducted:
Description of Facility:
SIC Code(8):
Location:
Products manufactured,
produced, or distributed:
Proximity to
sensitive populations:
Reason for Facility Selection:
ARIP Reports:
Focus of Audit:
Hazardous Substances(s)
Examined: .
Physical Area(s) Examined:
fit-nragg and Handling
Storage Systems
Shipping/Receiving
Material Transfer
Process Areafs)
-------
Summary of Audit Findings and Recommendationss
Conclusions:
Facility Background Information
Chemical Hazards
Process Information
Chemical Accident Prevention
Accidental Release Incident Investigation
Facility Emergency Preparedness and Planning Activities
Community and Facility Emergency Response Planning Activities
-------
Public Alert and Notification Procedures
Recommendations:
Facility Background Information
Chemical Hazards
#
Process Information
Chemical Accident Prevention
Accidental Release Incident Investigation
Facility Emergency Preparedness and Planning Activities
-------
Community and Facility Emergency Response Planning Activities
Public Alert and Notification Procedures
Audit Team Member Composition:
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
-------
Follow-up Activities:
By the facility!
By the Regional office:
By State and local authorities:
Regional Contact:
Dates
-------
Attachment 12
Annotated CSA Report Profile
-------
CHEMICAL SAFETY AUDIT PROFILE
Facility Name:
Facility Location;
Date(s) Audit Conducted?
Description of Facility:
SIC Code(s):
Location:
Products manufactured,
produced, or distributed:
Proximity to
sensitive populations:
Reason for Facility Selection:
ARIP Reports:
[provide full name of facility
as ^ well as any corporate
affiliation]
[list city, state, and region]
[list actual days audit team
was on site at facility]
[provide four-digit SIC code]
[describe nature of surrounding
area (e.g., commercial,
industrial, rural, residential,
urban) and indicate direction
and distance to nearest major
city]
[list final products and
intended uses]
[indicate direction and
distance to schools, hospitals,
day care centers, senior
centers, parks, lakes,
wetlands, and other sensitive
environments]
[list all reasons, including
past releases, ARIP
questionnaires, requests from
state and local officials,
regional initiatives, interest
from*facility, public concern,
chemical(s), process(es), or
system(s) of interest]
[list release date and
substance released]
-------
Focus of Audit:
Hazardous Substances(s)
Examined: [list only CERCLA hazardous
substances or Title III
extremely hazardous substances
examined and provide Chemical
Abstract Service (CAS) number]
Physical Area(s) Examined:
Storage and Handling
Storage Systems
[describe all storage systems examined (e.g., rail cars,
tanks, containers, cylinders), including design,
capacity, material of construction, and length of
storage]
Shipping/Receiving
[describe all shipping and receiving systems examined
(e.g., rail car, tank truck, and barge loading/unloading
areas, pipelines), including frequency of
delivery/shipment, design, capacity, and general
loading/unloading procedures]
Material Transfer
[describe all material transfer systems examined {e.g.,
pipelines, conveyor belts, fork lifts, manual), including
design, material of construction, capacity, and general
transfer procedures]
Process Area(a)
[describe each stage in all process(es) examined
involving the hazardous substances (e.g., primary and
secondary manufacturing, recycling and reuse, waste and
waste water treatment and disposal, power generation),
including substances and equipment involved and a general
description of each step in the process]
-------
Summary of Audit Findings and Recommendations:
Conclusions:
[state observations and concerns on facility policies and
practices in a factual manner that refrains from judgments of
adequacy or inadequacy, and ensure that any concerns have been
addressed appropriately in the recommendations section.]
Facility Background Information
Chemical Hazards
Process Information
Chemical Accident Prevention
Accidental Release Incident Investigation
Facility Emergency Preparedness and Planning Activities
-------
Community and Facility Emergency Response Planning Activities
Public Alert and Notification Procedures
Recommendations:
[clearly state recommendations for facility policies and
practices (that are both practical and technologically
feasible at the facility) in a manner that reflects their non-
mandatory nature, as well as the observations and concerns
outlined in the conclusions section.]
Facility Background Information
Chemical Hazards
Process Information
Chemical Accident Prevention
-------
Expertise [characterize the education, training,
and/or professional background of the
auditor (e.g., chemical engineer, public
health officer, hazardous waste
specialist, emergency responder,
emergency planner) ]
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Name and Title
Affiliation
Area of Responsibility
Expertise
Follow-up Activities:
By the facility!
[as appropriate, discuss short and long term plans of facility
to address issues/implement recommendations raised during the
audit]
By the Regional officet
[as appropriate, discuss short and long term plans to follow
up with facility on issues and recommendations raised during
the audit]
-------
CHEMICAL SAFETY AUDIT PROGRAM
RESOURCE GUIDE
Prepared for:
Chemical Emergency Preparedness and Prevention Office
Office of Solid Waste and Emergency Response
U.S. Environmental Protection Agency
Prepared by
ICP Incorporated
April 1991
-------
CHEMICAL SAFETY AUDIT PROGRAM RESOURCE GUIDE
This Chemical Safety Audit (CSA) Resource Guide contains references to
background and resource materials to help support the efforts associated with
the CSA Program. The guide provides audit team members access to additional
information to prepare for and conduct an audit and to write the audit report.
The resources include books, journals, reports, and videos covering many
topics in chemical safety. The guide contains information from various
organizations, associations, and agencies such as the Environmental Protection
Agency, the National Fire Protection Association, the Chemical Manufacturers
Association, the American Institute of Chemical Engineers, the American
Society of Safety Engineers, and the Occupational Safety and Health
Administration.
Each reference lists the resource name, publisher or organizational
sponsor, publication date, a short description of the document, information on
obtaining the resource, and its cost. On the last page of this document is a
list of organizations with frequent publications referenced in the resource
guide. While this guide provides a comprehensive listing of resources, it is
not an exhaustive list.
This guide follows the general format of the protocol found in the
guidance manual of the Chemical Safety Audit Program, The protocol provides
detailed guidance on the types of information that should be reviewed during
an audit and discussed in the subsequent audit report. Resources are
organized by each of the major areas of the protocol to assist audit team
members in locating additional resource materials identified in this document.
Audit team members can consult the resources applicable to specific topics or
a particular focus of the audit. For example, an audit team member
responsible for examining the public alert system in a facility can use the
resources specified in this guide under the topic Public Alert and
Notification Procedures.
This guide can be used at any time in the audit process. Consulting
these resources in preparation for an audit can help the audit team members to
conduct more informed and thorough investigations of the facility. Also, the
resources can be used after an audit to compare facility practices with
standard practices specified in the literature. In addition, the resources
referenced in this guide may help in writing the audit report by validating
facts and bolstering the report's technical credibility.
-------
ii
TABLE OF CONTENTS
Page
1.0 General 1
2.0 Chemical Hazards 4
2.1 Overview of Hazards for Chemical(s) being Audited 4
2.2 Facility Management of Chemical Hazard Data 8
3.0 Process Information for Hazardous Chemical(s) 9
3.1 Storage and Handling 10
3.2 Process Description 14
3.3 Process Hazards 17
4.0 Chemical Accident Prevention 20
4.1 Management Activities 20
4.2 Process Operation and Maintenance 22
4.3 Hazard Evaluation and Modeling 23
4.4 Release Prevention Systems 27
4.5 Mitigation Systems 28
5.0 Accident Release Incident Investigation 30
6.0 Facility Emergency Preparedness and Planning Activities..... 31
6.1 Facility Emergency Response Plan 31
6.2 Emergency Response Exercises and Simulations 33
6.3 Fire, Evacuation, and Rescue Corridors 34
6.4 Emergency Equipment Provisions 37
6.5 Emergency Response Chain of Authority 39
6.6 Emergency Response Management Procedures 39
6.7 Emergency Communication Network Within the Facility... 40
6.8 Emergency Response Personnel Training Requirements.... 41
6.9 Follow-up Release Procedures/Investigation 42
7.0 Community and Facility Emergency Response Planning Activities 43
7.1 Facility Planning and Outreach Activities with Community 43
7.2 Local/Community Emergency Response Plan 45
8.0 Public Alert and Notification Procedures.. 50
Alphabetical Index of Reference Titles 51
Frequently Mentioned Organizations 63
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1.0 GENERAL
Chemical Special Emphasis Program: Final Report. OSHA, March 1987,
OSHA conducted forty Chemical Special Emphasis Program (ChemSEP)
inspections on chemical manufacturing processes. This report indicates
helpful aspects of a cemprehens ive approach to inspections, which
includes management systems.
Available from OSHA/NIOSH as OSHA/RP-87/002. See last page for address
and telephone number.
Conducting Fire Inspections: A Guidebook for Field Use. National Fire
Protection Association, 1989.
This guidebook provides background information and inspection checklists
for all types of occupancy to help ensure thorough inspections.
Available from National Fire Protection Association as Item No. FM-CFI-
89 for $28.00. See last page for address and telephone number.
Inspection for Accident Prevention. First Edition, American Petroleum
Institute, 1984.
This publication provides an overview of inspection methods practiced by
petroleum refineries to prevent accidents at all levels, from the field
to the equipment issue room. 11 pages.
Available from American Petroleum Institute as item # 855-20020 for.
$10.00. See last page for address and telephone number.
NFPA Inspection Manual. National Fire Protection Association, 1989.
This manual covers background facts and practical information' about
building features and NFPA codes and standards.
Available from the National Fire Protection Association as Item No. FM-
IM-89 for $29.95. See last page for address and telephone number.
Plant/Operation Progress: articles on chemical process safety, American
Institute of Chemical Engineers, July and October 1990.
These two monthly issues contain a series of articles on various
strategies, issues, and technologies in chemical safety. Topics include
management practice, process safety audits, public participation in risk
assessment, and accident prevention.
Journal is available commercially or from libraries.
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-2-
Reeomroendations to Chlor-Alkali Manufacturing Facilities for the Prevention of
Chlorine Releases. Edition 1, The Chlorine Institute, Inc., October 1990.
This publication is intended to provide useful information to chlor-
alkali manufacturing facilities to allow the organizations involved in
such production to help comprehensively address the issue of preventing
the occurrence, or minimizing the consequences, of uncontrolled releases
of chlorine. It provides specific guidance in the development of a
comprehensive process safety/risk management program.
Publication is available as publication #86 from the Chlorine Insitute
for $7.00. See last page for address and telephone number.
Review of Emergency Systems. Environmental Protection Agency, 1988.
This document is a report to Congress on facility systems for
monitoring, detecting, and preventing releases of extremely hazardous
substances at facilities that produce, use or store them.
Available free of charge from EPA. See last page for address and
telephone number.
Technical Safety Audit. F. Owen Kubias. Paper presented at Chemical
Manufacturers Association Process Safety Management Workshop, May 5-7, 1985.
This paper describes the Technical Safety Audit process as
designed by Glidden Co. to identify plant conditions, processing
conditions or operating procedures which may lead to accidents.
The audit uses checklists, raw materials evaluations, and "what
if" analysis.
Available from the Chemical Manufacturers Association. See last page
for address and telephone number.
"Total Plant Safety Audit," Jeff Conrad. Chemical Engineering. May 14, 1984,
pp. 83-84, p. 86.
This article describes a hypothetical chemical plant safety audit,
including a thorough evaluation of a plant's design, layout,
appearance and operating procedures. It includes sample
questions, a hypothetical audit team list, and advice on procedure
evaluation and report follow-up.
Journal is available commercially or from libraries.
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-3-
What Went Wrong? Case Histories of Process Plant Disasters. T.A, Kletz. Gulf
Publishing Company, Houston, Texas, 1988.
This book examines the causes and aftermaths of noteworthy process plant
disasters. It centers on recognition of danger signals and
implementation of prevention methods.
Available as ISBN 0-87201-339-1 commercially or from libraries.
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-4-
2.0 CHEMICAL HAZARDS
Flammable and Combustible Lloulds Code Handbook, National Fire Protection
Association, 1990.
This handbook provides guidelines to minimize flammable and combustible
liquids risks, including expert commentary explaining and interpreting
specific requirements.
Available from National Fire Protection Association as Item No. FM-30-
HB90 for $49.50, See last page for address and telephone number.
Liquefied Petroleum Gases* Handbook. National Fire Protection Association,
1989.
This handbook includes the entire text of Storage and Handlins of LP-
Gases . plus commentary and explanations to help apply tequirements.
Available from National Fire Protection Association as Item No. FM-
58HB89 for $49.50. See last page for address and telephone number.
Occupational Safety and Health Guidelines for Chemical Hazards. NIOSH, 1988.
This publication includes a compilation of the 35 occupational safety
and health guidelines developed for the purpose of disseminating the
information to workers, employers, and to professionals in the field of
occupational safety and health.
Available from OSHA/NIOSH as DHHS/PUB/NIOSH-89-118-SUPPL-1-OHG. See
last page for address and telephone number.
2.1 OVERVIEW OF HAZARDS FOR CHEMICAL(S) BEING AUDITED
Air Contaminants -- Permissible Exposure Limits (Title 29 Code of Federal
Regulations Part 1910.1000), Occupational Safety and Health Administration,
1989.
This publication lists the updates of 29 CFR 1910.1000 after study of
industrial experience and available scientific data. The revised
personal exposure limits will protect workers against a wide variety of
health effects. The final regulation includes 600 substances.
Available as OSHA 3112 free of charge from the Occupational Safety and
Health Administration. See last page for address and telephone number.
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-5-
Basic Classification of Flammable and Combustible Liquids. National Fire
Protection Association, 1987.
This publication specifies physical and chemical properties of flammable
and combustible liquids and establishes the classification system.
Available from the National Fire Protection Association as Item No. FM-
321-87 for $13.25. See last page for address and telephone number.
Classification of Class I Hazardous Locations for Electrical Installations in
Chemical Plants. National Fire Protection Association, 1986.
This document lists steps to determine the location, type, and scope of
hazards presented by electrical installations in operations where
flammable or combustible liquids are processed or handled..
Available from the National Fire Protection Association as Item No. FM-
497A-86 for $15.50. See last page for address and telephone number.
Classification of Gases. Vapors and Dusts for Electrical Equipment in
Hazardous (Classified) Locations. National Fire Protection Association, 1986.
This document provides group classifications for selected gases, vapors,
and dusts to aid engineers in specifying the proper electrical equipment
for hazardous (classified) locations.
Available from the National Fire Protection Association as Item FM-497M-
86 for $13.25. See last page for address and telephone number.
A Condensed Guide to Chemical Hazards (CHRIS I). U.S. Coast Guard.
This document provides chemical-specific information on 1,016 chemicals
for hazard assessment and response techniques as applied to marine
environments.
Available from U.S. Coast Guard as COMDTINST M16465.11A/SN#050-012-0024-
0. See last page for address and telephone number.
Dangerous Properties of Industrial Materials. Irving Sax and Richard J. Lewis,
Sr., American Society of Safety Engineers, 1988.
This reference book lists 20,000 chemicals and their exposure standards,
including a Toxic Hazard Review section.
Available from the American Society of Safety Engineers as Order 8809
for $395.00. See last page for address and telephone number.
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-6-
Encyclopedia of Chemical Technology (3rd. Edition), R.E, Kirk and D.F, Othmer,
New York: John Wiley and Sons, 1980.
This encyclopedia consists of articles which describe the
properties and manufacturing process of any substance. Those
articles cross reference one or more articles where the uses of
that substance are described. CAS numbers are included.
Available commercially or from libraries.
Explosive Materials Code. National Fire Protection Association 1990.
This publication identifies reasonable levels of safety for explosive
materials.
Available from the National Fire Protection Association as Item No. FM-
495-90 for $15.50, See last page for address and telephone number.
Fire Hazard Properties of Flammable Liquids. Gases, and Volatile Solids.
National Fire Protection Association, 1984.
This handbook provides a summary of available data on the fire hazard
properties of more than 1,600 substances. Listed alphabetically with
500 synonyms.
Available from the National Fire Protection Association as Item No. FM-
325M-84 for $17.50. See last page for address and telephone number.
Fire Protection Guide on Hazardous Materials. National Fire Protection
Association, 1986.
This document lists hazard information and classification, for most
common hazardous materials.
Available from the National Fire Protection Association as Item No. FM-
SPP-1E for $60.50. See last page for address and telephone number.
Hawlev's Condensed Chemical Dictionary, revised by Irving Sax and Richard J,
Lewis, Sr., American Society of Safety Engineers, 1987.
This publication provides a compendium of technical data on chemicals
and chemical phenomena, chemical manufacturing equipment and components,
energy sources and their potential, pollution, and waste control.
Available from the American Society of Safety Engineers as Order 8706
for $57.95. See last page for address and telephone number.
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-7-
Hazardous Chemical Reactions. National Fire Protection Association, 1986.
This publication describes 3,500 recognized dangerous chemical
reactions.
Available from the National Fire Protection Association as Item No. FM-
491M-86 for $22.50. See last page for address and telephone number.
Hazardous Chemicals Data. National Fire Protection Association, 1987.
This publication specifies life and fire hazard precautions for
chemicals which pose a health hazard, reactivity rating, or fire
fighting problem.
Available from the National Fire Protection Association as Item No. FM-
49-75 for $17.50. See last page for address and telephone number.
Hazardous Chemicals Desk Reference. Irving Sax and Richard J. Lewis, Sr.,
American Society of Safety Engineers, 1987.
This document is a quick-access guide with information on 4700 hazardous
chemicals used in industry. Includes effects, synonyms, exposure
limits.
Available from the American Society of Safety Engineers as Order 8717
for $79.95. See last page for address and telephone number.
NIOSH/OSHA Pocket Guide to Chemical Hazards. NIOSH/OSHA. U.S. Government
Printing Office, 1985.
This book is a tabular-form quick-reference source relating to
general industrial hygiene and medical surveillance practices. It
gives chemical names and pseudonyms, exposure limits and
recommendations, chemical and physical properties, analytical
methods, respiratory and personal protection equipment
recommendations, signs and symptoms of exposure, and procedures
for emergency treatment.
This book is available as DHHS(NIOSH) Publication No. 85-114 from:
Superintendent of Documents
U.S. Government Printing Office
Washington, D.C. 20402-9325
GPO Stock No. 017-033-00342-4
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-8-
Raoid Guide Co Hazardous Chemicals in the Workplace, Irving Sax and Richard J.
Lewis, Sr., American Society of Safety Engineers, 1986.
This document provides an on-the-job guide to 700 hazardous chemicals,
with hazard ratings, exposure standards and workplace control
recommendations.
Available from the American Society of Safety Engineers as Order 8678
for $26.00. See last page for address and telephone number.
2.2 FACILITY MANAGEMENT OF CHEMICAL HAZARD DATA
Guidelines on Technical Management of Chemical Process Safety, the Center for
Chemical Process Safety of the American Institute of Chemical Engineers, 1989.
This book describes twelve basic elements that must be considered in the
development of a management system in the context of plant design,
construction, operation, and management.
Available for $100.00 from the American Institute of Chemical Engineers.
See last page for address and telephone number.
"Industrial Chemical Safety Testing: One Company's Approach," Y.H. Atallah
and D.M. Whitacre. Eeotoxicology and Environmental Safety, vol. 4, No. 4.,
pp. 357-361, 1980.
This article reviews a testing program for the safety of industrial
chemicals. The need for a testing program is discussed and the
development of a three tier system to identify potentially hazardous
chemicals is described. The criteria for defining the tiers are
discussed, including the developmental stage of the product, route and
magnitude of human exposure, magnitude of environmental exposure, and
potential adverse health and environmental effects.
Journal is available commercially or from libraries.
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-9-
3.0 PROCESS INFORMATION FOR HAZARDOUS CHEMICALS
Guidelines on Technical Management of Chemical Process Safety, the Center for
Chemical Process Safety of the American Institute of Chemical Engineers, 1989.
This book describes twelve basic elements that must be considered in the
development of a management system in the context of plant design,
construction, operation, and management.
Available for $100.00 from the American Institute of Chemical Engineers.
See last page for address and telephone number.
Instructional Videotapes on Chemical Process Safety. American Institute of
Chemical Engineers, 1989..
These videotapes provide instruction on the application of safety
procedures in plants and laboratories. The content is highly applicable
to chemical process plants and is deemed useful for industrial training.
Available from AIChE as Pub. V-2 for $1250.00. See last page for
address and telephone number.
Piping Design for Process Plants. Howard F. Rase. New York: John Wiley and
Sons, inc. 1963.
This book describes and illustrates piping designs for various
processes. It also includes standards for piping, pipe
specification, fabrication, and arrangement.
Available at libraries (out of print).
Process-Control Systems: Application/Design/Adiustment. E.G. Shinskey. New
York: McGraw-Hill Book Co., 1979.
This textbook describes theory and applications of chemical
process systems. It centers on control and feedback systems.
Available as ISBN 0-07-0556891-X commercially or from libraries.
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3,1 STORAGE AND HANDLING
Cleaning or Safeguarding Small Tanks and Containers. National Fire Protection
Association, 1987.
This guide describes procedures for the safe removal of flammable
vapors, liquids, gases, or solids from small tanks or containers that
cannot be entered, and other safety measures.
Available from National Fire Protection Association as Item FM-327-87
for $13.25. See last page for address and telephone number.
Fire Protection Considerations for the Design and Operation of Liquified
Petroleum Gas (LPG) Storage Facilities. First Edition. American Petroleum
Institute, 1989.
This publication addresses the design, operation, and maintenance of
liquified petroleum gas (LPG) storage facilities from the standpoint of
prevention and control of releases, fire protection design, and fire
control measures. The history of LPG storage facility failure, facility
design philosophy, operating and maintenance procedures, and various
fire protection and firefighting approaches are presented. The storage
facilities covered are LPG installations (storage vessels and associated
loading/unloading/transfer systems) at marine and pipeline terminals,
natural gas processing plants, refineries, petrochemical plants, and
tank farms. 35 pages.
Available from American Petroleum Institute as item # 855-25105 for
$25.00. See last page for address and telephone number.
Fire Protection in Refineries. Sixth Edition. American Petroleum Institute,
1984.
This document centers on fire protection problems and steps to ensure
the safe storage, handling, processing, and shipping of petroleum and
petroleum products in refineries. The general principles mentioned in
the publication are based in large measure upon composite experience in
a large number of refineries. 31 pages.
Available from the American Petroleum Institute item // 855-20010 for
ง12.00.' See last page for address and telephone number.
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Flammable and Combustible Liquids Code. National Fire Protection Association,
1990.
This document lists updated requirements for storage and handling of
flammable and combustible liquids.
Available from National Fire Protection Association as Item FM-3Q-9Q for
$17.50. See last page for address and telephone number.
General Storage. National Fire Protection Association 1990.
This publication describes requirements for the storage of the broad
range of combustibles (Classes I through IV) and plastics (Groups A, B,
and C),
Available from the National Fire Protection Association as Item No. FM-
231C-186 for $15.50. See last page for address and telephone number.
Guidelines for Safe Storage and Handling of Highly Toxic Hazard Materials.
Arthur D. Little, Inc. & Richard LeVine, American Institute of Chemical
Engineers, 1987.
These guidelines are designed for engineers and technical personnel
concerned with the safe manufacture and use of chemicals. Information
is based on existing regulations, codes and standards in use worldwide
as well as safety requirements developed by individual companies.
Available from AIChE as ISBN 0-8169-0400-6 for $80.00. See last page
for address and telephone number.
Overfill Protection for Petroleum Storage Tanks. First edition. American
Petroleum Institute, 1987
This publication suggests methods of preventing petroleum storage tanks
from being overfilled and covers manual and automatic systems that
provide protection against tank overfills, as well as safety,
environmental protection, optimization of the work place, maintenance,
and installation and training information. 21 pages.
Available from American Petroleum Institute as item # 855-23500 for
$12.00. See last page for address and telephone number.
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Packaeer Training Program, the Chlorine Institute, 1990.
This slide/video program is designed as a training tool for new and
established employees at chlorine packaging plants. It gives a detailed
view of the steps involved with tank car unloading, cylinder and ton
container inspections, and valve reconditioning.
Available as "P-Slides" or "F-Video" from the Chlorine Institute for
ง200.00 (slides) or $175.00 (VHS video). See last page for address and
telephone number.
Production. Storage, and Handling of Liquefied Natural Gas fLNG). National
Fire Protection Association 1990.
This publication describes site selection, design, construction, and
fire protection at LNG facilities.
Available from the National Fire Protection Association as Item No. FM-
59A-90 for $15.50. See last page for address and telephone number.
Refrigerated Liouid Chlorine Storage, edition 1, the Chlorine Institute, July
1984.
This pamphlet provides information applicable to the design,
construction, location, installation, and operation of refrigerated
liquid chlorine storage systems.
Available as publication #78 from the Chlorine Institute for $7.00. See
last page for address and telephone number.
Safe Handling and Storage of Compressed Gases. The Compressed Gas Association.
This audio-visual training program covers procedures for labeling and
storage, precautionary safety warnings, personnel safety equipment,
handling procedures, etc.
The Compressed Gas Association, Inc.
1235 Jefferson Davis Highway
Arlington, VA 22202-3269
703-979-4341
Available from the Compressed Gas Association on VHS, Beta, 3/4 inch, or
slide format as item AV-i for $140.
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Safe Tank Cleaning (Audio-Visual Tape), American Petroleum Institute.
This tape covers the preparation, ventilation, and cleaning procedures
of stationary petroleum and petrochemical storage tanks. Included in
the program are: planning for tank cleaning, necessary permits,
preferred ventilation methods, criteria for tank entry by personnel,
flammability/toxicity hazards, and special considerations dictated by
tank design and tank contents.
Available from American Petroleum Institute as title code 3401. See
last page for address and telephone number.
Storage and Handling of Liquefied Petroleum Gases. National Fire Protection
Association 1989.
This publication includes requirements for the safe storage and handling
of LP-Gases, including systems, liquid transfer, truck transportation,
engine fuel systems, and buildings or structures housing LP-Gas
distribution facilities.
Available from the National Fire Protection Association as Item No. FM-
58-89 for $17.50. See last page for address and telephone number.
Storage and Handling of Liquified Petroleum Gases at Utility Gas Plants,
National Fire Protection Association 1989.
This publication describes safe design, construction, and operation of
LP-Gas equipment at plants supplying LP-Gas/air mixtures for utility
application.
Available from the National Fire Protection Association as Item No. FM-
59-89 for $15.50. See last page for address and telephone number.
Storage of Flammable and Combustible Liquids Within Underground Metal and Non-
Metal Mines (Other than Coal). National Fire Protection Association, 1990.
This publication includes requirements for the safe storage of flammable
and combustible liquids in underground mines other than coal mines.
Includes information on the design, installation, inspection, and
operation of storage facilities and equipment.
Available from the National Fire Protection Association as Item No. FM-
122-90 for $13.25. See last page for address and telephone number.
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Storage Vessels and Other Equipment, Series G: Design of Equipment, Volume 2,
American Institute of Chemical Engineers, 1986,
This book consists of self-study modules designed to be used in
independent study, continuing education courses, and traditional
classes.
Available from AlChE as ISBN 0-816669-0409-X for $40.00. See last page
for address and telephone number.
3.2 PROCESS DESCRIPTION
Atmospheric Monitoring Equipment for Chlorine, edition 4, the Chlorine
Institute, February 1988..
This publication lists known equipment for monitoring chlorine
concentrations at breathing zones and ambient environments.
Available as Publication #73 from the Chlorine Institute for $12.00.
See last page for address and telephone number.
Blower and Exhaust Systems for Dust. Stock, and Vapor Removal or Conveying.
National Fire Protection Association, 1990.
This publication describes safety requirements for fans, ducts, duct
clearances, design, and dust collecting systems for removal or conveying
of flammable vapors, corrosive fumes, dust stock, and refuse.
Available from the National Fire Protection Association as Item No. FM-
91-90 for $15.50. See last page for address and telephone number.
Chlorine Pipelines, edition 2, the Chlorine Institute, April 1982.
This pamphlet contains information on the transportation of gaseous and
liquid chlorine in pipelines.
Available from the Chlorine Institute as publication #74 for $7.00. See
last page for address and telephone number,
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"Emergency Relief System (ERS) Design," Chemical Engineering Progress. August
1985, pp. 53-56.
This article describes a practical approach for estimating vent size and
load requirements for downstream equipment. It is simple enough to be
used by nonspecialist engineers and can be applied to virtually unknown
systems.
Journal is available commercially or from libraries.
Industrial Process Design for Pollution Control, volumes 1-7, American
Institute of Chemical Engineers, 1967-1975.
This series describes various process design strategies to minimize or
control emissions.
Available from AlChE for $18.00 per volume. See last page for address
and telephone number.
Mobile Lidar System Developments and Operating Procedures. George W, Bethke.
EPA Environmental Sciences Research Lab, November 1979.
This report presents complete operating procedures for an improved
system of analysis, presentation, and recording of smoke plume
data.
Available from EPA (as document EPA 600/2-79-197) or NTIS (as PB80-
132715). See last page for address and telephone number.
National Fuel Gas Code. National Fire Protection Association, 1990.
This document updates safety requirements for fuel gas equipment
installations, piping, and venting. Provisions apply to all fuel gas
systems on residential, commercial, and industrial premises using
natural gas and LP-Gas at pressures up to and including 125 psi.
Available from the National Fire Protection Association as Item No. FM-
54-88 for $19.50. See last page for address and telephone number.
Operation of Chlorine Vaporizing Equipment, edition 3, the Chlorine Institute,
May 1987.
This publication contains information intended to assist in the
selection, design, and safe operation of vaporizers.
Available from the Chlorine Institute as publication #9 for $10.00. See
last page for address and telephone number.
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Piping Design for Process Plants. Howard F. Rase. New York: John Wiley and
Sons, inc. 1963,
This book describes and illustrates piping designs for various
processes. It also includes standards for piping, pipe
specification, fabrication, and arrangement.
Available at libraries (out of print).
Piping Systems for Drv Chlorine, edition 5, the Chlorine Institute, March
This booklet contains information on selected pipes, valves, and
fittings suitable for use with dry chlorine (gas or liquid).
Available as publication #6 from the Chlorine Institute for $10 .-00. See
last page for address and telephone number.
Process Instruments and Controls Handbook. D.M, Considine, ed. McGraw-Hill,
1985.
This handbook consists of 83 separate articles in 19 chapters which
cover temperature, pressure, flow, level, force, and other process
systems and instruments. It examines various instruments for systems
indication or control and explains their objectives, methods, and
limitations.
Available as ISBN 0-07-012436-1 commercially or from libraries.
Process Operations. Series G; Design of Equipment, Volume 3, American
Institute of Chemical Engineers, 1987.
This is a self-study module designed to be used in independent study,
continuing education courses, and traditional classes.
Available from AIChE as ISBN 0-8169-0416-6 for $40.00. See last page
for address and telephone number.
Remote Monitoring of Gaseous Pollutants bv Differential Absorption Laser
Techniques. S.A. Ahmed et. al. New York: City University of New York Dept. of
Electrical Engineering. February 1980.
This report describes the single-ended laser radar (LIDAR) system
for detecting pollutants.
Available from EPA (as document EPA 600/2-80-049) or NTIS (as PB80-
179351). See last page for address and telephone number.
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The State-of-the-Art Continuous Enjission Monitoring Systems for Power Plants
J.A, Bamberger, ed., American Society of Mechanical Engineers, 1988.
This publication describes recent developments in Continuous Emission
Monitoring and Systems for power plants.
American Society of Mechanical Engineers
22 Lawn Drive, Box 2300
Fairfield, New Jersey 07007-2300
201-882-1167, ext. 228
Available from ASME as Order No. H00441 for $16.00.
3.3 PROCESS HAZARDS
"Alarm and Shutdown Devices Protect Process Equipment," Edward J. Rasmussen.
Chemical Engineering. May 12, 1975, pp. 74-80.
This article describes operating conditions and suitable
applications for alarm and shutdown devices. It covers devices
.monitoring pressure, flow, level, temperature, and vibration.
Journal is available commercially or from libraries.
Control of Emissions from Seals and Fittings in Chemical Process Industries.
Van Wagenen. Harold. OSHA/NIOSH, 1982.
This book describes methods and equipment to reduce fugitive emissions
from seals and fittings.
Available as publication PB-82-188-988/A04 from NTIS. See last page for
address and telephone number.
"Design for Process Safety," J.H. Tomfohode, Hydrocarbon Processing. December
1985, pp. 71-77.
This article examines a number of design items which frequently become
the precursors of serious incidents. It reviews functional and safety
considerations and potential vulnerabilities. Main topics include
drains and vents, piping and equipment "pockets," small piping systems,
piping and equipment pressure rating specification "breaks," and various
safeguards.
Journal is available commercially or from libraries.
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Eleetrieal Installations in Hazardous Locations. National Fire Protection
Association, 1988.
This publication is a working tool for inspectors, engineers,
manufacturers, and safety professionals evaluating the safety of
hazardous location electrical installations. Provides facts, and
practical advice for solving problems involving for example, the
prevention of ignition from static electricity and/or lightning.
Available from National Fire Protection Association as Item No. FM-HLH-
88 for $49.50. See last page for address and telephone number.
International Symposium on Runaway Reactions. American Institute of Chemical
Engineers, 1989.
This symposium focuses on basic considerations in chemical reactor
stability, evaluating reactor system safety, and design and operating
considerations for safe chemical reactor relief.
Available from AIChE as ISBN 0-8619-0460-X for $100.00. See last page
for address and telephone number.
Plant/Operation Progress: articles on chemical process safety issue, American
Institute of Chemical Engineers, July and October 1990.
These two monthly issues contain a series of articles on various
strategies, Issues, and technologies in chemical safety. Topics include
management practice, process safety audits, public participation in risk
assessment, and accident prevention.
Journal is available commercially or from libraries.
Prevention Reference Manual: User's Guide Overview for ControllinE Accidental
Releases of Air Toxics. D.S. David, G.B. DeWolf, and J.D. Quass. EPA Air and
Energy Engineering Research Lab, July 1987.
The User's Guide, the first in a series of manuals, presents an
overview of available methods for identifying, evaluating, and
controlling hazards in facilities that use, manufacture, or store
acutely toxic chemicals that could be released into the
environment. Hazardous chemicals and their key characteristics
are discussed, followed by a discussion of the potential hazards
in process and physical plant design and in operational
procedures.
Available from EPA (as document EPA 600/8-87-028) or NTIS (as PB 87-
232112). See last page for address and telephone number.
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"Safety-relief-valve malfunction: Symptoms, causes, and cures," William A,
Scully. Chemical Engineering. August 10, 1981, pp. 111-114.
This article examines common problems with safety relief valves
and lists four to twelve items to check in the event of leakage,
chattering, and premature popping of valves.
Journal is available commercially or from libraries.
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4.0 CHEMICAL ACCIDENT PREVENTION
Loss Prevention, volumes 1, 2, 4, 5, 6, 7, and 11, American Institute of
Chemical Engineers, 1967-1977.
These books discuss design strategies to prevent chemical releases.
Available from AIChE for $22.00-$28.00. See last page for address and
telephone number.
Plant/Operation Progress: articles on chemical process safety, American
Institute of Chemical Engineers, July and October 1990.
These two monthly issues contain a series of articles on various
strategies, issues, and technologies in chemical safety. Topics include
management practice, process safety audits, public participation in risk
assessment, and accident prevention.
Journal is available commercially or from libraries.
Review of Emergency Systems. Environmental Protection Agency, 1988.
This document is a report to Congress on facility systems for
monitoring, detecting, and preventing releases of extremely hazardous
substances at facilities that produce, use or store them.
Available free of charge from EPA. See last page for address and
telephone number.
4.1 MANAGEMENT ACTIVITIES
Guidelines on Technical Management of Chemical Process Safety, the Center for
Chemical Process Safety of the American Institute of Chemical Engineers, 1989.
This book describes twelve basic elements that must be considered in the
development of a management system in the context of plant design,
construction, operation, and management.
Available for $100.00 from the American Institute of Chemical Engineers.
See last page for address and telephone number.
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Hazardous Material Spills Conference Proceedings. American Institute of
Chemical Engineers, 1988.
Conference proceedings from a Chicago, Illinois meeting on prevention,
preparedness, and response. Papers deal with current developments in
legislation, regulation, programs, and technology. Topics include
emergency planning, disposal techniques, information management,
computer applications, training, and prevention.
Available from AIChE as ISBN 0-8169-0453-7 for $85.00. See last page
for address and telephone number.
Hazardous Waste and Emergency Response. Occupational Safety and Health
Administration, 1989.
This 20-page publication discusses OSHA's requirements for hazardous
waste operations and emergency response at uncontrolled hazardous waste
sites and TSD facilities and summarizes the steps an employer must take
to protect the health and safety of workers in these environments.
Available as OSHA 3114 free of charge from the Occupational Safety and
Health Administration. See last page for address and telephone number.
"Implementing Process Safety Management Systems," Plant/Operations Progress,
October 1990, p. 236.
This article provides guidelines for putting management procedures to
work for process safety.
Available commercially from the American Institute of Chemical Engineers
or from libraries.
National Occupational Exposure Survey, volume 3: Analysis of Management
Interview Responses, 0SHA/NI0SH. March 1988.
This volume provides analysis of industrial management responses to a
questionnaire regarding occupational safety by industry and plant size.
These analyses provide estimates of the numbers of employee and
facilities in the US operating under specific management policies in the
areas of safety and health.
Available from OSHA/NIOSH as DHHS/PUB/NIOSH-89-103. See last page for
address and telephone number.
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-22-
4.2 PROCESS OPERATION AND MAINTENANCE
Ammonia Plant Safety, volumes 13 through 29, American Institute of Chemical
Engineers, 1971-1989.
This series consists of papers presented at the annual meetings of
AIChE. They center on accidents, safety developments, and technical
improvements pertaining to safety in the ammonia industry.
Available from AIChE for $28.00-$55.00. See last page for address and
telephone number.
Blower and Exhaust Systems for Dust. Stock, and Vapor Removal or Conveying.
National Fire Protection Association, 1990,
This publication describes safety requirements for fans, ducts, duct
clearances, design, and dust collecting systems for removal or conveying
of flammable vapors, corrosive fumes, dust stock, and refuse.
Available from National Fire Protection Association as Item No. FM-91-90
for $15.50. See last page for address and telephone number.
Cleaning or Safeguarding Small Tanks and Containers. National Fire Protection
Association, 1987.
This guide describes procedures for the safe removal of flammable
vapors, liquids, gases, or solids from small tanks or containers that
cannot be entered, and other safety measures.
Available from National Fire Protection Association as Item FM-327-87
for $13.25. See last page for address and telephone number.
"Safety-relief-valve malfunction: Symptoms, causes, and cures," William A.
Scully. Chemical Engineering. August 10, 1981, pp. 111-114.
This article examines common problems with safety relief valves
and lists four to twelve items to check in the event of leakage,
chattering, and premature popping of valves.
Journal is available commercially or from libraries.
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4.3 HAZARD EVALUATION AND MODELING
Engineering Applications of Risk Analysis. F.A, Elia, Jr., and A. Moghissi,
American Society of Mechanical Engineers, 1988.
This book centers on understanding the concept of risk by the
engineering profession, regulatory authorities, and the general public.
Available as Order No. GGQ438 for $20.00 through:
American Society of Mechanical Engineers
22 Lawn Drive, box 2300
Fairfield, New Jersey 07007-2300
201-882-1167, ext. 228
Environmental Fate of Chlorine in the Atmosphere, edition 1, the Chlorine
Institute, April 1990.
This publication describes what happens to elemental chlorine when
released into the air. This report was prepared by Alliance
Technologies, Chapel Hill, North Carolina.
Available as publication #84 from the Chlorine Institute for $20.00.
See last page for address and telephone number.
"Evaluating Emergency Response Models for the Chemical Industry," by Daniel J.
McNaughton, Gary G. Worley, and Paul M. Bodner. Chemical Engineering
Progress. January 1987, p. 46.
This article reviews the evaluation models and identification
databases suitable for validating the models. Vaporization and
dispersion models are among the models discussed.
Available commercially or from libraries.
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Guideline on Air Quality Models (revised). Environmental Protection Agency,
1986.
This guideline recommends air quality modeling techniques that may be
applied to air pollution control strategy evaluation and new source
reviews, including prevention of significant deterioration. It is
intended for use by EPA Regional offices in judging the adequacy of
modeling analyses performed by EPA, by State and local agencies, and by
industry and its consultants. It also identifies modeling techniques
and data bases that EPA considers acceptable.
Available as EPA 450/2-78-027R free of charge from the Environmental
Protection Agency or as PB86-245248 from the National Technical
Information Service. See last page for addresses and telephone numbers.
Guidelines for Chemical Process Quantitative Risk Analysis. Center for
Chemical Process Safety of the American Institute of Chemical Engineers. New
York: American Institute of Chemical Engineers.
This book provides the tools for reducing acute risks in a chemical
plant handling hazardous materials. It enables the manager or engineer
to make quantitative estimates of risk.
Available as ISBN 0-8169-0402-2 from the American Institute of Chemical
Engineers. See last page for address and telephone number.
Guidelines for Hazard Evaluation Procedures, prepared by Batelle Columbus
Division for the Center for Chemical Process Safety of the American Institute
of Chemical Engineers. ISBN # 0-8169-0399-9. New York: American Institute of
Chemical Engineers, 1985.
This book centers on procedures for design, construction, and
operation, including identification and analysis of hazards not
easily identified from past experience. Largely, it lists
qualitative procedures for hazard identification, although some of
the procedures also can be used for quantitative analysis. The
most significant aspect of this book is in helping to apply the
proper hazard evaluation method to each process.
Available from the AIChE. See last page for address and telephone
number.
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Guidelines on Risk Analysis, edition 1, the Chlorine Institute, August 1989,
This publication provides information on the most recent safety concepts
concerning risks posed in the chlor-alkali industry. It also defines
risk analysis and how it is most applicable to the industry.
Available as publication #83 from the Chlorine Institute for $25.00.
See last page for address and telephone number.
Handbook of Chemical Hazard Analysis Procedures. Federal Emergency Management
Agency.
This book describes a wide range of planning activities for
investigating the hazards in using and transporting dangerous chemicals.
It includes methods to investigate local hazards, chemical fire hazards,
probability analysis procedures, and planning for all types of hazardous
materials releases.
Available from the Federal Emergency Management Agency. See last page
for address and telephone number.
Hazardous Materials Incident Analysis. Federal Emergency Management Agency.
This 12-hour audiovisual course introduces a systematic method of
analyzing and assessing the potential effect of hazardous materials
involved in fires and other emergencies. Includes 454 color slides, 4
cassette tapes, 4 overhead transparency masters, and instructor's and
student's guides.
Available for loan by the Chemical Manufacturers Association as Item A
04 at:
NCRIC
Chemical Manufacturers Association
2501 M Street, NW
Washington, DC 20037
Maior Industrial Hazards: Their Appraisal and Control. John Withers, American
Society of Safety Engineers, 1988.
This document presents methods of risk estimation, measurement of
potential hazards against likely benefits, and other aspects of hazard
evaluation.
Available from American Society of Safety Engineers as Order 8803 for
$61.00. See last page for address and telephone number.
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Managlng Risk - Systemic Loss Prevention for Executives. Vernon L. Grose,
American Society of Safety Engineers, 1987,
This publication presents risk analysis and cost with strong emphasis on
bottom line performance.
Available from American Society of Safety Engineers as Order 8715 for
$39.95, See last page for address and telephone number.
Proceedings of the International Conference on Vapor Cloud Modeling. Center
for Chemical Process Safety of the American Institute of Chemical Engineers,
1987.
This book consists of proceedings of a conference held in Cambridge,
Massachusetts from November 2-4, 1987. This book covers field-scale
test modeling, source modeling, dispersion models, fire and explosion
modeling, and other topics.
Available as ISBN 0-8169-0424-3 from the American Institute of Chemical
Engineers. See last page for organization address and telephone number.
Profitable Risk Control: The Winning Edge. William Allison, American Society
of Safety Engineers.
This publication centers on identifying risks to avoid accidents.
Topics considered include performance measurements, hazard
identification, loss control, and cost evaluation. Includes 100 release
case histories, with causes and effective risk controls.
Available from American Society of Safety Engineers as Order 8667 for
$35.00. See last page for address and telephone number.
Risk Assessment and Management: A Framework for Decision-Making. Environmental
Protection Agency, 1984.
This report centers on risk assessment and risk management at EPA. It
gives an overview of EPA's approach to decision-making for environmental
toxic chemical problems.
Available as EPA IMSD/87-0002 from the National Technical Information
Service. See last page for address and telephone number.
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Technical Guidance for Hazards Analysis: Emergency Planning for Extremely
Hazardous Substances. Environmental Protection Agency, 1987.
This guide provides technical assistance on the assessment of lethal
hazards related to potential airborne releases of extremely hazardous
materials. The purpose of the document is to assist local emergency
planners in hazards analysis and specifically with local emergency
planning requirements.
Available free of charge from the Emergency Planning and Community
Right-To-Know Information Services. See last page for address and
telephone number..
4.4 RELEASE PREVENTION SYSTEMS
"Alarm and Shutdown Devices Protect Process Equipment," Edward J. Rasmussen.
Chemical Engineering. May 12, 1975, pp. 74-80.
This article describes operating conditions and suitable
applications for alarm and shutdown devices. It covers devices
monitoring pressure, flow, level, temperature, and vibration.
Journal is available commercially or from libraries.
Explosion Prevention Systems. National Fire Protection Association 1986.
This publication provides requirements for explosion prevention systems
based on reduced concentration of combustible material, as well as inert
gas systems, explosion suppression systems, and pressure containment.
Available from National Fire Protection Association as Item No. FM-69-86
for $15.50. See last page for address and telephone number.
"Safety-relief-valve malfunction: Symptoms, causes, and cures," William A.
Scully. Chemical Engineering. August 10, 1981, pp. 111-114.
This article examines common problems with safety relief valves
and lists four to twelve items to check in the event of leakage,
chattering, and premature popping of valves.
Journal is available commercially or from libraries.
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4.5 MITIGATION SYSTEMS
1990 Emergency Response Guidebook/Guidebook for Hazardous Materials Incidents.
U.S. Department of Transportation. U.S. Government Printing Office, 1990.
This is a guidebook for emergency service vehicles for incidents
with hazardous materials. It includes advice for firefighters on
extinguishing methods and standard procedures for initial actions
to be taken to protect themselves and the public.
Available as DOT P 5800.4 from:
U.S. Department of Transportation
Materials Transportation Bureau, DMT-11
Washington, DC 20590
Evaluation of the Efficiency of Industrial Flares: Background-Experimental
Design-Facility. D. Joseph et. al. Energy and Environmental Research Corp.,
August 1983.
The report summarizes the technical literature on the use of
industrial flares and reviews available emission estimates.
Technical critiques of past flare efficiency studies are provided.
Available from EPA (as document EPA 600/2-83-070) or NTIS (as PB83-
263723) . See last page for address and telephone number.
Guidelines for Vapor Release Mitigation. Richard W. Prugh, American Institute
of Chemical Engineers, 1988.
These guidelines provide information to help development and
communication of improved safety methods, practices, designs, and
procedures in the chemical process industry.
Available from AIChE as ISBN 0-8169-0401-4 for $80.00. See last page
for address and telephone number.
Hazardous Materials Response Handbook. National Fire Protection Association,
1989.
This handbook covers haz-mat standards, expert commentary, and
supplements dealing with haz-mat response plans, decontamination, and
team training.
Available from National Fire Protection Association as Item No. FM-
472HB89 for $49.50. See last page for address and telephone number.
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Installation of Air Conditioning and Ventilating Systems, National Fire
Protection Association, 1989.
This publication specifies installation requirements for air
conditioning and ventilating systems that restrict the spread of smoke,
heat, and fire through duct systems, and minimize ignition sources.
Available from National Fire Protection Association as Item No. FM-90A-
89 for $15.50, See last page for address and telephone number.
Release Containment in Chlorine Plants, edition 1, the Chlorine Institute,
December 1983.
This pamphlet describes methods and techniques which have been commonly
used in the chlorine industry to contain accidental chlorine releases
vhich could possibly occur in chlorine production plants.
Available as publication MIR-147 from the Chlorine Institute for $2.00.
See last page for address and telephone number.
Responding to Hazardous Materials Incidents. National Fire Protection
Association, 1989.
This publication presents procedures and practices for mitigating
incidents. Covers decontamination, methods of mitigation, chemical
protective clothing, and safety.
Available from National Fire Protection Association as Item No. FM-471-
89 for $15.50. See last page for address and telephone number.
"The Use of Water Spray Barriers to Disperse Spills of Heavy Gases," Kieth
Moodie, Plant/Operations Progress. October, 1985, pp. 234-241.
This article describes the performance characteristics of full-scale
water-spray barriers when dispersing accidental spills of heavy gases.
Data from a series of trials establish that water spray barriers can
achieve a worthwhile enhancement of the rate of dispersion and dilution
of heavy gas spills.
Journal is available commercially or from libraries.
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5.0 ACCIDENT RELEASE INCIDENT INVESTIGATION
Accident Investigation for Supervisors. Ted Ferry, American Society of Safety
Engineers.
This is a guide for accident investigation on short notice with limited
resources, and without major study. Includes systems approaches to
accident investigation, organization, interviews, and reports.
Available from American Society of Safety Engineers as Order 8726 for
$20.00. See last page for address and telephone number.
Accident Investigation Techniques. American Society of Safety Engineers, 1988.
This fifteen-minute audio-visual set describes key elements of the
accident investigation process. Includes a leader's guide, script,
cassette tape, point summary, and 70 slides.
Available from American Society of Safety Engineers as Order 8923 for
$135. See last page for address and telephone number.
Investigating Accidents With STEP. Kingsley Hendrick and Ludwig Benner, Jr.,
American Society of Safety Engineers, 1987.
This guide serves as a model for accident investigation from initiation
to follow-up actions.
Available from American Society of Safety Engineers as Order 8701 for
$106.00. See last page for address and telephone number.
Modern Accident Investigation and Analysis. Ted Ferry, American Society of
Safety Engineers, 1988.
This book centers on accident investigation as a management tool.
Available from American Society of Safety Engineers as Order 8502 for
$57.50. See last page for address and telephone number.
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6.0 FACILITY EMERGENCY PREPAREDNESS AND PLANNING ACTIVITIES
A Guide to the Safe Handling of Hazardous Materials Accidents. STP 825.
American Society for Testing and Materials.
This guide discusses Department of Transportation hazard classes, terms
used in describing the classes or the materials, and incident control
tactics. Includes a supplement, "Initial Emergency Assessment Initial
Response Action."
Available from American Society for Testing and Materials as ISBN 0-
803100261-5 or PCN 04-825000-31 for $24.00. See last page for address
and telephone number.
How to Prepare for Workplace Emergencies. Occupational Safety and Health
Administration, 1988.
This 12-page booklet details the basic steps needed to prepare the
handle emergencies in the workplace. It is not intended to serve as an
all-inclusive safety program, but rather to provide guidelines for
planning for emergencies. It includes sections on evaluation, command,
communications, and other topics.
Available as OSHA 3088 free of charge from the Occupational Safety and
Health Administration. See last page for address and telephone number.
6.1 FACILITY EMERGENCY RESPONSE PLAN
Community Awareness and Emergency Response (CAER): The Next Phase. Chemical
Manufacturers Association, 1990.
This document provides approaches and checklists for developing and
implementing local community awareness and emergency response plans.
Contains summaries of various approaches to coordinated emergency
response planning.
Available for ง15.00 from the Chemical Manufacturers Association. See
last page for address and telephone number. Request by title.
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Emergencv Response Plans for Chlorine Facilities, edition 3, the Chlorine
Institute, October 1990.
This publication includes information essential to the preparation or
updating of formal, written emergency control plans applicable to
chlorine-producing, chlorine-packaging, and chlorine-consuming
facilities.
Available as publication #64 for $10.00 from the Chlorine Institute.
See last page for address and telephone number.
"Emergency Response Procedures for Anhydrous Ammonia Vapor Release," Maurice
L. Greiner. Ammonia Plan Safety and Related Facilities. American Institute of
Chemical Engineers CEP Technical Manual v. 24 (1984), pp. 109-114.
This publication provides a detailed review of downwind ammonia
vapor adsorption tactics, developed for firefighters. It includes
a description of ammonia hazards and characteristics, case
histories, and personal protection information.
Available from AIChE. See last page for address and telephone number.
Guide for Development of State and Local Emergency Operations Plans. Federal
Emergency Management Agency, 1985.
This civil preparedness guide provides information for emergency
management planners and for State and local government officials on
FEMA's concept of emergency operations planning under the Integrated
Emergency Management System.
Available as Document number CPG-l/Item #8-0044 free of charge from the
Federal Emergency Management Agency. See last page for address and
telephone number.
Guide for the Review of State and Local Emergency Operations Plans. Federal
Emergency Management Agency, 1988.
This civil preparedness guide provides State Emergency Management Agency
personnel with a practical and uniform means to identify provisions to
be addressed in State and local emergency operations plans. It also
provides FEMA personnel with a standard, comprehensive, and practical
instrument to use in reviewing and determining the consistency of draft
plans.
Available free of charge as CPG 1-8 from the Federal Emergency
Management Agency. See last page for address and telephone number.
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Hazardous Materials Response Handbook. National Fire Protection Association,
1989.
This handbook covers haz-mat standards, expert commentary, and
supplements dealing with haz-mat response plans, decontamination, and
team training.
Available from National Fire Protection Association as Item No. FM-
472HB89 for $49.50. See last page for address and telephone number.
Preparing for Emergency Planning. National Association of Manufacturers, 1986.
This is a guide for plant managers that describes basic provisions of
hazardous substance laws.
Available from the National Association of Manufacturers as Catalog #046
for $21.95. See last page for address and telephone number.
A Primer for Preparedness for Acute Chemical Emergencies. Kathleen J. Tierney.
Columbus: The Disaster Research Center of The Ohio State University, 1980.
This paper integrates social scientific research on planning for
chemical emergencies with general community disaster planning.
The result is a guide for community and facility action.
Available from the Disaster Research Center of The Ohio State
University, Columbus, Ohio 43104.
6.2 EMERGENCY RESPONSE EXERCISES AND SIMULATIONS
Guide to Exercises in Chemical Emergency Preparedness Programs. Environmental
Protection Agency, 1988.
This series of three bulletins provides an overview of the major types
of exercises and describes some resources currently available for
conducting exercises.
Available free of charge from the Emergency Planning and Community
Right-To-Know Information Services. See last page for address and
telephone number.
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Hazardous Materials Exercise Evaluation Methodology (HM-EEM) and Manual.
Federal Emergency Management Agency, 1989.
This two-part document is designed to assist State and local governments
in the comprehensive evaluation of hazardous materials exercises. The
document is the product of a year-long cooperative effort between FEMA
Headquarters and its regional offices. It is a series of modules for
the evaluation of 15 major exercise objectives covered by the plans
prepared using FEMA's Hazardous Materials Emergency Planning Guide, or
NRT-1.
Available as HM-EEM free of charge from the Federal Emergency Management
Agency. See last page for address and telephone number.
Haz-mats! Case Studies for Emergency Responders. National Fire Protection
Association, 1989.
This is a training film that centers on response procedures and
strategies. This film uses four haz-mat emergencies to teach emergency
response teams. Includes Instructor's Guide with reports, lesson plans,
drills, and other materials.
Available from National Fire Protection Association as Item No. FM-FL-73
(Film) for $649.50, or Item No. FM-FL-73V (3/4 ", VHS, or Betamax
videotape) for $549.50. See last page for address and telephone number.
6.3 FIRE, EVACUATION, AND RESCUE CORRIDORS
1990 Emergency Response Guidebook for Hazardous Materials Incidents. U.S.
Department of Transportation. U.S. Government Printing Office, 1990.
This is a guidebook for emergency service vehicles for incidents
with hazardous materials. It includes advice for firefighters on
extinguishing methods and standard procedures for initial actions
to be taken to protect themselves and the public.
Available as DOT P 5800.4 from:
U.S. Department of Transportation
Materials Transportation Bureau, DMT-11
Washington, DC 20590
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Automatic Fire Detectors. National Fire Protection Association 1990.
This publication includes minimum performance, location, mounting,
testing, and maintenance requirements of automatic fire detectors.
Available from National Fire Protection Association as Item No. FM-72E-
90 for $19.50. See last page for address and telephone number.
Evacuation: An Assessment of Planning and Research. Federal Emergency-
Management Agency, 1987.
The purpose of this research was to assess issues and criticism of
evacuation planning for all hazards under an integrated emergency
management concept, and to review research that addresses those issues.
The work identifies gaps in knowledge about evacuation planning issues
and the research that could fill those gaps.
Available free of charge from FEMA as item # 8-0664. See last page for
address and telephone number.
Evaluation of Firefiehting Foams as Fire Protection for Alcohol Containing
Fuels. First Edition. American Petroleum Institute, 1985.
This publication details the results of an API-sponsored study of the
fire protection provided by fire fighting foams on fires containing
alcohol or polar additives. These additives are known to be foam-
destructive. This publication clarifies information on generic foam
classes and application rates required to suppress fires involving these
solvents, which are commonly added to unleaded gasolines. 71 pages".
Available from American Petroleum Institute as publication Publ 2309,
item # 855-2300 for $17.00. See last page for address and telephone
number.
Hazardous Chemicals Data. National Fire Protection Association.
This publication specifies life and fire hazard precautions for
chemicals which pose a health hazard, reactivity rating, or fire
fighting problem.
Available from the National Fire Protection Association as Item No. FM-
49-75 for $17.50. See last page for address and telephone number.
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Ltfe Safety Code. National Fire Protection Association 1988.
This publication describes construction, protection, and occupancy
features necessary to minimize danger to life from fire, smoke, fumes,
and panic. Identifies criteria for the design of egress facilities to
permit prompt escape from buildings, or where desirable, into safe areas
within the building.
Available from National Fire Protection Association as Item No. FM-
10188SB for $24.50. See last page for address and telephone number.
Portable Fire Extinguishers (Audio-Visual Tape), American Petroleum Institute.
This tape covers the design and operation of water, carbon dioxide,
foam, halon, dry chemical, and dry powder extinguishers. Program also
discusses fire-fighting techniques for portable extinguishers.
Available as Title code 3503 through:
Howell Training Company
5201 Langfield Road
Houston, TX 77040
1-800-527-1581
Proceedings of the Conference on In-Place Protection During Chemical
Emergencies: November 30-December 1, 1988, U.S. EPA, FEMA, and Resources for
the Future, 1989.
This book describes discussions and conclusions reached at a conference
on in-place protection (i.e., going indoors and staying in). Results
show that in-place protection may be more appropriate in certain
instances of chemical release. The major aim of the conference was to
begin to identify and develop guidance and training that the federal
government can provide to local planners and responders for use in in-
place protection. Sections discuss field experience, related research,
industry perspective, public planning and preparedness, and emergency
response.
Available for $4.00 from Resources for the Future, 1616 P Street, NW,
Washington, D.C., 20046, or at 202-328-5060.
,1
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6.4 EMERGENCY EQUIPMENT PROVISIONS
"Emergency Response Procedures for Anhydrous Ammonia Vapor Release," Maurice
L. Greiner. Ammonia Plan Safety and Related Facilities, American Institute of
Chemical Engineers CEP Technical Manual v. 24 (1984), pp. 109-114.
This publication provides a detailed review of downwind ammonia
vapor adsorption tactics, developed for firefighters. It includes
a description of ammonia hazards and characteristics, case
histories, and personal protection information.
Available from AIChE. See last page for address and telephone number.
Evaluation of Fireflehting Foams as Fire Protection for Alcohol Containing
Fuels. First Edition. American Petroleum Institute, 1985.
This publication details the results of an API-sponsored study of the
fire protection provided by fire fighting foams on fires containing
alcohol or polar additives. These additives are known to be foam-
destructive. This publication clarifies information on generic foam
classes and application rates required to suppress fires involving these
solvents, which are commonly added to unleaded gasolines. 71 pages.
Available from American Petroleum Institute as publication Publ 2309,
item tf 855-2300 for $17.00. See last page for address and telephone
number.
NFPA 11C: Mobile Foam Apparatus. National Fire Protection Association.
This document outlines the minimum requirements for the design,
approval, testing, inspection, operation, and maintenance of mobile foam
apparatus.
Available from National Fire Protection Association as Item No. FM-11C-
90 for $13.25. See last page for address and telephone number.
NFPA 12: Carbon Dioxide Extinguishing Systems. National Fire Protection
Association.
This document covers design, installation, testing, approval, operation
and maintenance for total flooding, local application, and hose line
systems.
Available from National Fire Protection Association as Item No. FM-11C-
90 for $13.25. See last page for address and telephone number.
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Personal Protective Equipment. Occupational Safety and Health Administration,
1990.
This 18-page booklet discusses those types of equipment most commonly
used for protection of the head, including eyes and ears; the torso;
arms and hands; and feet. The use of equipment to protect against life-
threatening hazards is also discussed.
Available as OSHA 3077 free of charge from the Occupational Safety and
Health Administration. See last page for address and telephone number.
Portable Fire Extinguishers (Audio-Visual Tape), American Petroleum Institute.
This tape covers the design and operation of water, carbon dioxide,
foam, halon, dry chemical, and dry powder extinguishers. Program also
discusses fire-fighting techniques for portable extinguishers.
Available as Title code 3503 through:
Howell Training Company
5201 Langfield Road
Houston, TX 77040
1-800-527-1581
Respiratory Protection. Occupational Safety and Health Administration, 1988.
This 15-page booklet presents information on respiratory equipment that
complements relevant safety and health regulations and manufacturers'
requirements.
Available as OSHA 3079 free of charge from the Occupational Safety and
Health Administration. See last page for address and telephone number.
Standards on Vapor-Protective Suits for Hazardous Chemical Emergencies.
National Fire Protection Association, 1990.
This document lists minimum design, performance, testing, and
documentation requirements for vapor-protective suits for protection
from exposure to specified chemicals in vapor and liquid splash
environments.
Available from National Fire Protection Association as Item No. FM-1991-
90 for $13.25. See last page for address and telephone number.
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6,5 EMERGENCY RESPONSE CHAIN OF AUTHORITY
Hazardous Materials: Managing the Incident, by Gregory G. Noll, Michael S.
Hildebrand, James G. Yvorra, 1988.
This textbook describes each step a command-level emergency responder
must take to manage a haz-mat incident, including coordination with'
various other responders. Volumes available: Textbook ($25.00),
Instructor's Guide ($15.00), and Workbook ($14.00).
Available by title from Fire Protection Publications. See last page for
address and telephone number.
National Interagency Incident Management System: Incident Command System
Position Manuals. 1989.
These booklets describe roles and responsibilities of various actors in
the response to a hazardous materials incident. The volumes cover the
Operations Section, Planning Section, Logistics Section, Command
Section, and Finance Section of a response effort.
Available as a set for $20.00 from Fire Protection Publications. See
last page for address and telephone number.
6.6 EMERGENCY RESPONSE MANAGEMENT PROCEDURES
The CEO's Disaster Survival Kit: a Common-Sense Guide for Local Government
Chief Executive Officers. Federal Emergency Management Agency, 1988.
This book serves to assist CEOs in basic organization planning for an
incident. It encourages the CEO to develop management tools and to plan
for his or her roles and responsibilities in the event of a disaster.
Available as FA-91 free of charge from the Federal Emergency Management
Agency. See last page for address and telephone number.
CHLOREP: Situation Assessment and Planning. National Safety Council.
This 15-minute VHS demonstrates CHLOREP, a procedure for alerting proper
authorities and containing chlorine leaks.
National Safety Council
444 North Michigan Ave.
Chicago, Illinois 60611
Available from the National Safety Council as item No. 19010-2222 for
$350.00.
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"Emergency Response Procedures for Anhydrous Ammonia Vapor Release," Maurice
L. Greiner. Ammonia Plan Safety and Related Facilities. American Institute of
Chemical Engineers CEP Technical Manual v. 24 (1984), pp. 109-114,
This publication provides a detailed review of downwind ammonia
vapor adsorption tactics, developed for firefighters. It includes
a description of ammonia hazards and characteristics, case
histories, and personal protection information.
Available from AlChE. See last page for address and telephone number.
Evacuation: An Assessment of Planning and Research. Federal Emergency
Management Agency, 1987.
The purpose of this research was to assess issues and criticism of
evacuation planning for all hazards under an integrated emergency
management concept, and to review research that addresses those issues.
The work identifies gaps in knowledge about evacuation planning issues
and the research that could fill those gaps.
Available free of charge from FEMA as item # 8-0664. See last page for
address and telephone number.
Hazardous Materials Response Handbook. National Fire Protection Association,
1989.
This handbook covers haz-mat standards, expert commentary, and
supplements dealing with haz-mat response plans, decontamination, and
team training.
Available from National Fire Protection Association as Item No. FM-
472HB89 for $49.50. See last page for address and telephone number.
6.7 EMERGENCY COMMUNICATION NETWORK WITHIN THE FACILITY
Installation. Maintenance, and Use of Notification Appliances for Protective
Signaling Systems. National Fire Protection Association, 1989.
This guide provides recommendations for the performance of notification
appliances that are used with protective signaling systems.
Available from National Fire Protection Association as Item No. FM-72G-
89 for $13.25. See last page for address and telephone number.
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6.8 EMERGENCY RESPONSE PERSONNEL TRAINING REQUIREMENTS
Airport/Community Emergency Planning. National Fire Protection Association
1986.
This publication provides recommendations for emergency planning
procedures, including how to plan for using personnel from all concerned
agencies in an emergency and how to establish adequate emergency
training programs.
Available from National Fire Protection Association as Item No. FM-424M-
86 for $17.50. See last page for address and telephone number.
The Digest of Federal Training Programs in Hazardous Materials. Federal
Emergency Management Agency, 1987.
This document is a catalog of information on all of the Federal training
now available concerning hazardous materials.
Available as Document number FEMA 134/July 1987 free of charge from the
Federal Emergency Management Agency. See last page for address and
telephone number.
Guide for Fighting Fires in and Around Petroleum Storage Tanks. Second
Edition. American Petroleum Institute, 1988.
This is a guide for training employees to successfully attack and
extinguish various types of petroleum storage tank fires. 30 pages-.
Available from American Petroleum Institute as item # 855-20210 for
$8.00. See last page for address and telephone number.
Proceedings of the 1989 National Conference on Hazardous Materials Training.
Federal Emergency Management Agency, 1989.
The purpose of the conference was to facilitate the exchange of ideas
and information about hazardous materials training.
Available free of charge from FEMA as item # 6-0358. See last page for
address and telephone number.
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Professional Competence of Responders to Hazardous Materials Incidents.
National Fire Protection Association, 1989,
This document lists training and capabilities that are required at
various levels of response to hazardous materials incidents, including
the First Responder Awareness and Operational levels; the Technical
level; and the Specialist level. The Appendix deals with management of
an incident.
Available from National Fire Protection Association as Item No. FM-472-
89 for $13.25. See last page for address and telephone number.
6.9 FOLLOW-UP RELEASE PROCEDURES
Accident Investigation for Supervisors. Ted Ferry, American Society of Safety
Engineers.
This is a guide for accident investigation on short notice with limited
resources, and without major study. Includes systems approaches to
accident investigation, organization, interviews, and reports.
Available from American Society of Safety Engineers as Order 8726 for
$20.00. See last page for address and telephone number.
Modern Accident Investigation and Analysis. Ted Ferry, American Society of
Safety Engineers, 1988.
This book centers on accident investigation as a management tool.
Available from American Society of Safety Engineers as Order 8502 for
$57.50. See last page for address and telephone number.
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7.0 COMMUNITY AND FACILITY EMERGENCY RESPONSE PLANNING ACTIVITIES
Community Awareness and Emergency Response (CAER) Resource Disk. Chemical
Manufacturers Association, 1990.
This comprehensive resource guide for implementing the CAER process is
stored on an IBM-compatible computer disk. Provides the CAER
"Responsible Care Code of Management Practices" with examples of
activities for each element, cross-referenced with associated printed
and audio-visual materials, It also includes a database of CAER groups,
SERCs, EPA, and OSHA offices. Specify 5 1/4-inch or 3 1/2-inch disk.
Available for $22.50 from the Chemical Manufacturers Association. See
last page for address and telephone number. Request by title.
Plant/Operation Progress: articles on chemical process safety, American
Institute of Chemical Engineers, July and October 1990.
These two monthly issues contain a series of articles on various
strategies, issues, and technologies in chemical safety. Topics include
management practice, process safety audits, public participation in risk
assessment, and accident prevention.
Journal is available commercially or from libraries.
7.1 FACILITY PLANNING AND OUTREACH ACTIVITIES WITH COMMUNITY
Community Awareness and Emergency Response (CAER) Resource Disk. Chemical
Manufacturers Association, 1990.
This comprehensive resource guide for implementing the CAER process is
stored on an IBM-compatible computer disk. Provides the CAER
"Responsible Care Code of Management Practices" with examples of
activities for each element, cross-referenced with associated printed
and audio-visual materials, It also includes a database of CAER groups,
SERCs, EPA, and OSHA offices. Specify 5 1/4-inch or 3 1/2-inch disk.
Available for $22.50 from the Chemical Manufacturers Association. See
last page for address and telephone number. Request by title.
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Communitv Awareness and Emergency Response (CAER): The Next Phase. Chemical
Manufacturers Association, 1990.
This document provides approaches and checklists for developing and
implementing local community awareness and emergency response plans.
Contains summaries of various approaches to coordinated emergency
response planning.
Available for $15.00 from the Chemical Manufacturers Association. See
last page for address and telephone number. Request by title.
Emergency Response Plans for Chlorine Facilities, edition 3, the Chlorine
Institute, October 1990.
This publication includes information essential to the preparation or
updating of formal, written emergency control plans applicable to
chlorine-producing, chlorine-packaging, and chlorine-consuming
facilities.
Available as publication #64 for $10.00 from the Chlorine Institute.
See last page for address and telephone number.
Plant Manager's Network Guide. Chemical Manufacturers Association, 1990.
This booklet provides facility managers with ideas to develop outreach
activities with their colleagues at nearby plants, or with leaders from
other industries, to help the chemical industry become a visible,
active, and valuable member of the community.
Available free of charge from the Chemical Manufacturers Association.
See last page for address and telephone number. Request by title
A Primer for Preparedness for Acute Chemical Emergencies. Kathleen J. Tierney.
Columbus: The Disaster Research Center of The Ohio State University, 1980.
This paper integrates social scientific research on planning for
chemical emergencies with general community disaster planning.
The result is a guide for community and facility action.
Available from the Disaster Research Center of The Ohio State
University, Columbus, Ohio 43104
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Proceedings of the Conference on In-Place Protection During Chemical
Emergencies: November 30-December 1, 1988, U.S. EPA, FEMA, and Resources for
the Future, 1989.
This book describes discussions and conclusions reached at a conference
on in-place protection (i.e., going indoors and staying in). Results
show that in-place protection may be more appropriate in certain
instances of chemical release. The major aim of the conference was to
begin to identify and develop guidance and training that the federal
government can provide to local planners and responders for use in in-
place protection. Sections discuss field experience, related research,
industry perspective, public planning and preparedness, and emergency
response.
Available for $4.00 from Resources for the Future, 1616 P Street, NW,
Washington, D.C., 20046, or at 202-328-5060.
7.2 LOCAL/COMMUNITY EMERGENCY RESPONSE PLAN
Airoort/Community Emergency Planning. National Fire Protection Association
1986.
This publication provides recommendations for emergency planning
procedures, including how to plan for using personnel from all concerned
agencies in an emergency and how to establish adequate emergency
training programs.
Available from National Fire Protection Association as Item No. FM-424M-
86 for $17.50. See last page for address and telephone number.
Chemical Emergency Preparedness Program: Interim Guidance. Washington, DC:
Environmental Protection Agency. November 1985.
This document provides the public and state and local officials
with information to assist them in planning how to respond to
accidental releases of acutely toxic chemicals. Includes
information on organizing the community, gathering site-specific
information, contingency plan development, and contingency plan
appraisal.
Available from libraries (out of print) as document EPA 560/7-85-012.
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Criteria for Review of Hazardous Materials Emergency Plans. National Response
Team of the National Oil and Hazardous Substances Contingency Plan, 1988.
This document provides guidance that may be used in the review of
emergency response plans.
Available as document NRT-lA from the Emergency Planning and Community
Right-To-Know Information Services. See last page for address and
telephone number.
Developing a Hazardous Materials Exercise Program: a Handbook for State and'
Local Officials fNRT-2). National Response Team, 1990.
This publication describes different types of response and planning
exercises, how they are conducted, how to draw on them, and additional
resources to help in preparing for emergency response. It includes
step-by-step management exercises for decisionmaking.
Available free of charge as NRT-2 from the Emergency Planning and
Community Right-To-Know Information Services. See last page for address
and telephone number.
Evacuation: An Assessment of Planning and Research. Federal Emergency
Management Agency, 1987.
The purpose of this research was to assess issues and criticism of
evacu'ation planning for all hazards under an integrated emergency
management concept, and to review research that addresses those issues.
The work identifies gaps in knowledge about evacuation planning issues
and the research that could fill those gaps.
Available free of charge from FEMA as item # 8-0664. See last page for
address and telephone number.
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Fire Service Emergency Management Handbook. International Association of Fire
Chiefs,
This is a guide for fire chiefs and emergency medical personnel to
strengthen planning and to aid effective emergency management at the
community level. It includes principles of developing, evaluating, and
revising community emergency planning activities; fire and emergency
medical service responsibilities; and effective emergency management
organization are covered. It also covers special problems such as
funding and providing technical resources. Checklists for planning
emergency situations are provided. 228 pages.
Available for ง9.00 through;
International Association of Fire Chiefs Foundation
Suite 10B
101 East Holly Avenue
Sterling, VA 22170
Guide for Development of State and Local Emergency Operations Plans. Federal
Emergency Management Agency, 1985,
This civil preparedness guide provides information for emergency
management planners and for State and local government officials on
FEMA's concept of emergency operations planning under the Integrated
Emergency Management System.
Available as Document number CPG-l/Item #8-0044 free of charge from the
Federal Emergency Management Agency. See last page for address and
telephone number.
Guide for the Review of State and Local Emergency Operations Plans. Federal
Emergency Management Agency, 1988.
This civil preparedness guide provides State Emergency Management Agency
personnel with a practical and uniform means to identify provisions to
be addressed in State and local emergency operations plans. It also
provides FEMA personnel with a standard, comprehensive, and practical
instrument to use in reviewing and determining the consistency of draft
plans.
Available as CPG 1-8 free of charge from the Federal Emergency
Management Agency. See last page for address and telephone number.
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Hazard Identification. Capability Assessment, and Multi-Year Development Plan
for Local Government. Federal Emergency Management Agency, 1987.
This publication lists instructions and forms for completing local
Hazard Identification, Capability Assessment, and Multi-Year Development
Plan.
Available free of charge from FEMA as item # 8-0423. See last page for
address and telephone number.
Hazardous Materials Emergency Planning Guide. National Response Team, 1987.
This book, known as NRT-1, provides local authorities with a detailed
overview of efforts required for selecting and organizing an emergency
planning team, defining the tasks of that team, developing the plan and
individual plan elements, and testing and maintaining the plan.
Available as NRT-1 free of charge from the Emergency Planning and
Community Right-To-Know Information Services. See last page for address
and telephone number.
Hazardous Materials: Managing the Incident, by Gregory G. Noll, Michael S.
Hildebrand, James G. Yvorra, 1988.
This textbook describes each step a command-level emergency responder
must take to manage a haz-mat incident, including coordination with
various other responders. Volumes available: Textbook ($25.00),
Instructor's Guide ($15.00), and Workbook ($14.00).
Available by title from Fire Protection Publications. See last page for
address and telephone number.
Integrated Emergency Management Information System (IEMIS). Federal Emergency
Management Agency.
This computer system combines a resource data base, multiple simulation
models, communications, and color graphics to provide a fully integrated
planning, exercising, and real-time tool for the management of accident
and disaster response.
Available from the Federal Emergency Management Agency. See last page
for address and telephone number.
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National Interagency Incident Management System: Incident Command Svscem
Position Manuals. 1989.
These booklets describe roles and responsibilities of various actors in
the response to a hazardous materials incident. The volumes cover the
Operations Section, Planning Section, Logistics Section, Command
Section, and Finance Section of a response effort.
Available as a set for ง20.00 from Fire Protection Publications. See
last page for address and telephone number.
Technical Guidance for Hazards Analysis: Emergency Planning for Extremely
Hazardous Substances. Environmental Protection Agency, 1987.
This guide provides technical assistance on the assessment of lethal
hazards related to potential airborne releases of extremely hazardous
materials. The purpose of the document is to assist local emergency
planners in hazards analysis and specifically with local emergency
planning requirements.
Available free of charge from the Emergency Planning and Community
Right-To-Know Information Services. See last page for address and
telephone number.
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8.0 PUBLIC ALERT AND NOTIFICATION PROCEDURES
"Alarm and Shutdown Devices Protect Process Equipment," Edward J. Rasraussen.
Chemical Engineering, May 12, 1975, pp. 74-80.
This article describes operating conditions and suitable
applications for alarm and shutdown devices. It covers devices
monitoring pressure, flow, level, temperature, and vibration.
Journal is available commercially or from libraries.
Emergency Warning Systems Guidebook. Chemical Manufacturers Association, 1990.
This guidebook offers generic advice on types of warning systems
available and guidelines for selecting a system. Compiled by industry
representatives experienced in designing and implementing emergency
warning systems and reviewed and approved by FEMA and the EPA.
Available for $7.50 from the Chemical Manufacturers Association. See
last page for address and telephone number. Request by title.
Guide to Preparing Emergency Public Information. Federal Emergency Management
Agency, 1987.
This guide is intended to assist those who prepare public information
documents, and centers on improving the content and distribution of
emergency preparedness messages.
Available as FEMA REP-11 from the Federal Emergency Management Agency,
See last page for address and telephone number.
Installation. Maintenance, and Use of Notification Appliances for Protective
Signaling Systems. National Fire Protection Association, 1989.
This guide provides recommendations for the performance of notification
appliances that are used with protective signaling systems.
Available from National Fire Protection Association as Item No. FM-72G-
89 for $13.25. See last page for address and telephone number.
Review of Emergency Systems. Environmental Protection Agency, 1988.
This document is a report to Congress on facility systems for
monitoring, detecting, and preventing releases of extremely hazardous
substances and to alert the public to a release.
Available from EPA. See last page for address and telephone number.
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ALPHABETICAL INDEX OF REFERENCE TITLES
1990 Emergency Response Guidebook/Guidebook for Hazardous Materials Incidents
4.5 Mitigation Systems -- p. 28, 6.3 Fire, Evacuation, and Rescue Corridors --
p. 34.
Accident Investigation for Supervisors. 5.0 Accident Release Incident
Investigation -- p. 30, 6.9 Follow-up Release Procedures/Investigation -- p.
42.
Accident Investigation Techniques. 5.0 Accident Release Incident Investigation
- - p. 30.
Air Contaminants -- Permissible Exposure Limits (Title 29 Code of Federal
Regulations Part 1910.1000), 2.1 Overview of Hazards for Chemical(s) being
Audited -- p. 4.
Airport/Community Emergency Planning. 6.8 Emergency Response Personnel
Training Requirements -- p. 41, 7.2 Local/Community Emergency Response Plan --
p. 45.
"Alarm and Shutdown Devices Protect Process Equipment", 3.3 Process Hazards --
p. 17, 4.4 Release Prevention Systems -- p. 27, 8.0 Public Alert and
Notification Procedures -- p. 50.
Ammonia Plant Safety. 4.2 Process Operation and Maintenance -- p. 22..
Atmospheric Monitoring Equipment for Chlorine. 3.2 Process Description -- p.
14.
Automatic Fire Detectors. 6.3 Fire,' Evacuation, and Rescue Corridors -- p. 35.
Basic Classification of Flammable and Combustible Liquids. 2.1 Overview of
Hazards for Cheraical(s) Being Audited -- p. 5.
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Blcver and Exhaust Systems for Dust. Stock, and Vapor Removal or Conveying.
3.2 Process Description -- p. 14, 4.2 Process Operation and Maintenance -- p.
22.
The CEO's Disaster Survival Kit: a Common-Sense Guide for Local Government:
Chief Executive Officers. 6.6 Emergency Response Management Procedures -- p.
39.
Chemical Emergency Preparedness Program: Interim Guidance, 7.2 Local/Community
Emergency Response Plan -- p. 45.
Chemical Special Emphasis Program: Final Report. 1.0 General -- p. 1.
CHLOREP: Situation Assessment and Planning. 6.6 Emergency Response Management
Procedures -- p. 39.
Chlorine Pipelines. 3.2 Process Description --p. 14.
Classification of Class I Hazardous Locations for Electrical Installations in
Chemical Plants. 2.1 Overview of Hazards for Chemical(s) Being Audited -- p.
5.
Classification of Gases. Vapors and Dusts for Electrical Equipment in
Hazardous (Classified) Locations. 2.1 Overview of Hazards for Chemical(s>
Being Audited -- p. 5.
Cleaning or Safeguarding Small Tanks and Containers. 3.1 Storage and
Handling -- p. 10, 4.2 Process Operation and Maintenance -- p. 22
Community Awareness and Emergency Response fCAER): The Next Phase. 6.1
Facility Emergency Response Plan -- p. 31, 7.1 Facility Planning and Outreach
Activities with Community -- p. 44.
Community Awareness and Emergency Response (CAER) Resource Disk. 7.0 Community
and Facility Emergency Response Planning Activities -- p. 43, 7.1 Facility
Planning and Outreach Activities with Community -- p. 43.
A Condensed Guide to Chemical Hazards (CHRIS I). 2.1 Overview of Hazards for
Chemical(s) Being Audited -- p. 5.
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Conductine Fire Inspections: A Guidebook for Field Use. 1.0 General -- p. 1.
Control of Emissions from Seals and Fittings in Chemical Process Industries.
3.3 Process Hazards -- p. 17.
Criteria for Review of Hazardous Materials Emergency Plans. 7.2
Local/Community Emergency Response Plan -- p. 46,
Dangerous Properties of Industrial Materials. 2.1 Overview of Hazards for
Chensical(s) Being Audited -- p. 5.
"Design for Process Safety," 3.3 Process Hazards, p. 17.
Developing a Hazardous Materials Exercise Program: A Handbook for State and
local Officials (NRT-2). 7.2 Local/Community Emergency Response Plan -- p. 46.
The Digest of Federal Training Programs in Hazardous Materials. 6.8 Emergency
Response Personnel Training Requirements -- p. 41.
Electrical Installations in Hazardous Locations. 3.3 Process Hazards -- p. 18.
"Emergency Relief System (ERS) Design," 3.2 Process Description -- p. 15.
Emergency Response Plans for Chlorine Facilities. 6.1 Facility Emergency
Response Plan -- p. 32, 7.1 Facility Planning and Outreach Activities with
Community -- p. 44.
"Emergency Response Procedures for Anhydrous Ammonia Vapor Release", 6.1
Facility Emergency Response Plan -- p. 32, 6.4 Emergency Equipment
Provisions -- p. 37, 6.6 Emergency Response Management Procedures -- p. 40.
Emergency Warning Systems Guidebook. 8.0 Public Alert and Notification
Procedures -- p. 50.
Encyclopedia of Chemical Technology. 2.1 Overview of Hazards for Chemical(s)
Being Audited -- p. 6.
Engineering Applications of Risk Analysis. 4.3 Hazard Evaluation and
Modeling -- p. 23.
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Environmental Fate of Chlorine in the Atmosphere. 4.3 Hazard Evaluation and
Modeling -- p. 23.
Evacuation: An Assessment of Planning and Research. 6.3 Fire, Evacuation, and
Rescue Corridors -- p. 35, 6.6 Emergency Response Management Procedures -- p.
40, 7.2 Local/Community Emergency Response Plan -- p. 46.
"Evaluating Emergency Response Models for the Chemical Industry", 4.3 Hazard
Evaluation and Modeling -- p. 23.
Evaluation of Firefighting Foams as Fire Protection for Alcohol Containing
Fuels. First Edition. 6.3 Fire, Evacuation, and Rescue Corridors -- p. 35, 6,4
Emergency Equipment Provisions --p. 37.
Evaluation of the Efficiency of Industrial Flares: Background-Experimental
Design-Facility. 4.5 Mitigation Systems -- p. 28.
Explosion Prevention Systems. 4.4 Release Prevention Systems -- p. 27.
Explosive Materials Code. 2.1 Overview of Hazards for Chemical(s) Being
Audited -- p. 6.
Fire Hazard Properties of Flammable Liquids. Gases, and Volatile Solids, '2.1
Overview of Hazards for Chemical(s) Being Audited -- p. 6.
Fire Protection Considerations for the Design and Operation of Liquified
Petroleum Gas (LPO Storage Facilities. First Edition. 3.1 Storage and
Handling -- p. 10.
Fire Protection Guide on Hazardous Materials. 2.1 Overview of Hazards for
Chemical(s) Being Audited -- p. 6.
Fire Protection in Refineries. Sixth Edition. 3.1 Storage and Handling -- p.
10.
Fire Service Emergency Management Handbook. 7,2 Local/Community Emergency
Response Plan -- p. 47.
Flammable and Combustible Liquids Code. 3.1 Storage and Handling -- p. 11.
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Flaromable and Combustible Liquids Code Handbook. 2.0 Chemical Hazards -- p. 3.
General Storage. 3.1 Storage and Handling -- p. 11.
Guide for Development of State and Local Emergency Operations Plans. 6.1
Facility Emergency Response Plans -- p. 32, 7.2 Local/Community Emergency
Response Plans -- p. 47.
Guide for Fighting Fires in and Around Petroleum Storage Tanks. Second
Edition. 6.8 Emergency Response Personnel Training Requirements -- p. 41.
Guide for the Review of State and Local Emergency Operations Plans. 6.1
Facility Emergency Response Plans -- p. 32, 7.2 Local/Community Emergency
Response Plans -- p. <47.
Guide to Exercises in Chemical Emergency Preparedness Programs. 6.2 Emergency
Response Exercises and Simulations -- p. 33.
Guide to Preparing Emergency Public Information. 8.0 Public Alert and
Notification Procedures -- p. 50.
A Guide to the Safe Handling of Hazardous Materials Accidents. STP 825. 6.0
Facility Emergency Preparedness and Planning Activities -- p. 31.
Guideline on Air Quality Models (revised). 4.3 Hazard Evaluation and
Modeling -- p. 24.
Guidelines for Chemical Process Quantitative Risk Analysis. 4.3 Hazard
Evaluation and Modeling -- p. 24.
Guidelines for Hazard Evaluation Procedures. 4.3 Hazard Evaluation and
Modeling -- p. 24.
Guidelines for Safe Storage and Handling of Highly Toxic Hazard Materials. 3.1
Storage and Handling -- p. 11.
Guidelines for Vapor Release Mitigation. 4.5 Mitigation Systems -- p. 28.
Guidelines on Risk Analysis. 4.3 Hazard Evaluation and Modeling -- p. 25.
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Guidelir.es on Technical Management of Chemical Process Safety. 2.2 Facility-
Management of Chemical Hazard Data -- p. 8, 3.0 Process Information for
Hazardous Chemical(s) -- p. 9, 4.1 Management Activities -- p. 20.
Handbook of Chemical Hazard Analysis Procedures. 4.3 Hazard Evaluation and
Modeling -- p. 25.
Hawlev's Condensed Chemical Dictionary. 2.1 Overview of Hazards for
Chemical(s) Being Audited -- p. 6.
Haz-matsi Case Studies for Emergency Responders. 6.2 Emergency Response
Exercises and Simulations -- p. 34.
Hazard Identification. Capability Assessment, and Multi-Year Development Plan
for Local Government. 7.2 Local/Community Emergency Response Plan -- p. 48.
Hazardous Chemical Reactions. 2.1 Overview of Hazards for Chemical(s) Being
Audited -- p. 7,
Hazardous Chemicals Data. 2.1 Overview of Hazards for Chemical(s) Being
Audited -- p. 7, 6.3 Fire, Evacuation, and Rescue Corridors -- p. 35.
Hazardous Chemicals Desk Reference. 2.1 Overview of Hazards for Chemical (is)
Being Audited -- p. 7.
Hazardous Materials Emergency Planning Guide. 7.2 Local/Community Emergency
Response Plan -- p. 48.
Hazardous Materials Exercise Evaluation Methodology CHM-EEM") and Manual. 6.2
Emergency Response Exercises and Simulations -- p. 34,
Hazardous Materials Incident Analysis. 4.3 Hazard Evaluation and Modeling --
p. 25.
Hazardous Materials: Managing the Incident. 6.5 Emergency Response Chain of
Authority -- p. 39, 7.2 Local/Community Emergency Response Plan -- p. 48.
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Hazardous Materials Response Handbook, 4.5 Mitigation Systems -- p. 28, 6.1
Facility Emergency Response Plan -- p. 33, 6.6 Emergency. Response Management
Procedures -- p. 40.
Hazardous Material Spills Conference Proceedings. 4.1 Management Activities --
p. 21.
Hazardous Waste and Emergency Response. 4.1 Management Activities -- p. 21.
How to Prepare for Workplace Emergencies 6.0 Facility Emergency Preparedness
and Planning Activities -- p. 31.
"Implementing Process Safety Management Systems", 4.1 Management Activities --
p. 21.
"Industrial Chemical Safety Testing; One Company's Approach", 2.2 Facility
Management of Chemical Hazard Data -- p. 8.
Industrial Process Design for Pollution Control. 3.2 Process Description -- p.
15.
Inspection for Accident Prevention. 1.0 General -- p. 1.
Installation. Maintenance, and Use of Notification Appliances for Protective
Signaling Systems. 6.7 Emergency Communication Network Within the Facility --
p. 40, 8.0 Public Alert and Notification Procedures -- p. 50.
Installation of Air Conditioning and Ventilating Systems. 4.5 Mitigation
Systems -- p. 29.
Instructional Videotapes on Chemical Process Safety. 3.0 Process Information
for Hazardous Chemical(s) -- p. 9.
Integrated Emergency Management Information Svstera (IEMIS1. 7.2
Local/Community Emergency Response Plan -- p. 48.
International Symposium on Runaway Reactions. 3.3 Process Hazards -- p. 18.
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Irivestigating Accidents With STEP. 5,0 Accident Release Incident Investigation
-- p. 30.
Life Safety Code. 6.3 Fire, Evacuation, and Rescue Corridors -- p. 36.
Liquefied Petroleum Gases Handbook. 2.0 Chemical Hazards -- p. 4.
Loss Prevention. 4.0 Chemical Accident Prevention -- p. 20.
Major Industrial Hazards: Their Appraisal and Control. 4.3 Hazard Evaluation
and Modeling -- p. 25.
Managing Risk - Systemic Loss Prevention for Executives. 4.3 Hazard Evaluation
and Modeling -- p. 26,
Mobile Lidar System Developments and Operating Procedures. 3.2 Process
Description -- p. 15.
Modern Accident Investigation and Analysis, 5.0 Accident Release Incident
Investigation -- p. 30, 6.9 Follow-up Release Procedures/Investigation -- p.
42.
National Fuel Gas Code. 3.2 Process Description -- p. 15.
National Interagency Incident Management System Incident Command System
Position Manuals. 6.5 Emergency Response Chain of Authority -- p. 39, 7.2
Local/Community Emergency Response Plan -- p. 49.
National Occupational Exposure Survey. 4.1 Management Activities -- p. 21.
NFPA Inspection Manual. 1.0 General -- p. 1.
NFPA 11C: Mobile Foam Apparatus. 6.4 Emergency Equipment Provisions --p. 37.
NFPA 12: Carbon Dioxide Extinguishing Systems. 6.4 Emergency Equipment
Provisions -- p. 37.
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f
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NIOSH/OSHA Pocket Guide to Chemical Hazards. 2.1 Overview of Hazards for
Chemical(s) Being Audited -- p. 7.
Occupational Safety and Health Guidelines for Chemical Hazards. 2.0 Chemical
Hazards -- p. 4.
Operation of Chlorine Vaporizing Equipment. 3.2 Process Description -- p. 15.
Overfill Protection for Petroleum Storage Tanks. First edition. 3.1 Storage
and Handling -- p. 11.
Packager Training Program. 3.1 Storage and Handling -- p. 12.
Personal Protective Equipment. 6.4 Emergency Equipment Provisions -- p. 38.
Piping Design for Process Plants. 3.0 Process Information for Hazardous
Chemical(s) -- p. 9, 3.2 Process Description -- p. 16.
Piping Systems for Dry Chlorine. 3.2 Process Description -- p. 16.
Plant Manager's Network Guide. 7.1 Facility Planning and Outreach Activities
with Community -- p. 44.
Plant/Operation Progress: articles on process safety, 1.0 General -- p. 2, 3.3
Process Hazards -- p. 18, 4,0 Chemical Accident Prevention -- p. 20, 7.0
Community and Facility Emergency Response Planning Activities -- p. 43.
Portable Fire Extinguishers (Audio-Visual Tape), 6.3 Fire, Evacuation, and
Rescue Corridors -- p. 36, 6.4 Emergency Equipment Provisions -- p. 38.
Preparing for Emergency Planning. 6.1 Facility Emergency Response Plan -- p.
33.
Prevention Reference Manual: User's Guide Overview for Controlling Accidental
Releases of Air Toxics. 3.3 Process Hazards -- p. 18.
A Primer for Preparedness for Acute Chemical Emergencies. 6.1 Facility
Emergency Response Plan -- p. 33, 7.1 Facility Planning and Outreach
Activities with Community -- p. 44.
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Proceedtngs of the 1989 National Conference on Hazardous Materials Training.
6.8 Emergency Response Personnel Training Requirements -- p. 41,
Proceedings of the Conference on In-Place Protection Purine Chemical
Emergencies. 6.3 Fire, Evacuation, and Rescue Corridors -- p. 36, 7.1 Facility
Outreach and Planning Activities with the Community -- p. 45.
Proceedings of the International Conference on Vapor Cloud Modeling. 4.3
Hazard Evaluation and Modeling -- p. 26.
Process-Control Systems: Application/Design/Adiustment. 3.0 Process
Information for Hazardous Chemical(s) -- p. 9.
Process Instruments and Controls Handbook. 3.2 Process Description -- p. 16.
Process Operations. 3.2 Process Description -- p. 16.
Production. Storage, and Handling of Liquefied Natural Gas (LNG). 3.1 Storage
and Handling -- p. 12.
Professional Competence of Responders to Hazardous Materials Incidents. 6.8
Emergency Response Personnel Training Requirements -- p. 42.
Profitable Risk Control: The Winning Edge. 4.3 Hazard Evaluation and
Modeling -- p. 26.
Rapid Guide to Hazardous Chemicals in the Workplace. 2.1 Overview of Hazards
for Chemical(s) Being Audited -- p. 8.
Recommendations to Chlor-Alkali Manufacturing Facilities for the Prevention of
Chlorine Releases. 1.0 General --p. 2.
Refrigerated Liquid Chlorine Storage. 3.1 Storage and Handling -- p. 12.
Release Containment in Chlorine Plants. 4.5 Mitigation Systems -- p. 29.
Remote Monitoring of Gaseous Pollutants bv Differential Absorption Laser
Techniques. 3.2 Process Description *- p. 16.
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Respiratorv Protection. 6.4 Emergency Equipment Provisions -- p. 38,
Responding to Hazardous Materials Incidents, 4.5 Mitigation Systems -- p. 29,
Review of Emergency Systems. 1.0 General -- p. 2, 4.0 Chemical Accident
Prevention -- p. 20, 8.0 Public Alert and Notification Procedures -- p. 50,
Risk Assessment and Management: A Framework for Decision-Makinp:. 4.3 Hazard
Evaluation and Modeling -- p. 26.
Safe Handling and Storage of Compressed Gases. 3.1 Storage and Handling -- p.
12.
Safe Tank Cleaning. 3.1 Storage and Handling -- p. 13.
"Safety-relief-valve malfunction: Symptoms, causes, and cures", 3.3 Process
Hazards -- p. 19, 4.2 Process Operation and Maintenance -- p. 22, 4.4 Release
Prevention Systems -- p. 27.
Standards on Vapor-Protective Suits for Hazardous Chemical Emergencies. 6.4
Emergency Equipment Provisions -- p. 38.
The State-of-the-Art Continuous Emission Monitoring Systems for Power Plants.
3.2 Process Description -- p. 17.
Storage and Handling of Liquefied Petroleum Gases. 3.1 Storage and'Handling --
p. 13.
Storage and Handling of Liquified Petroleum Gases at Utility Gas Plants. 3.1
Storage and Handling -- p. 13.
Storage of Flammable and Combustible Liquids Within Underground Metal and Non-
Metal Mines (Other than Coal). 3.1 Storage and Handling --p. 13.
Storage Vessels and Other Equipment. 3.1 Storage and Handling -- p. 14.
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Technical Guidance for Hazards Analysis: Emergency Planning for Extremely
Hazardous Substances. 4.3 Hazard Evaluation and Modeling -- p. 28, 7,2
Local/Community Emergency Response Plan -- p. 49.
Technical Safety Audit. 1.0 General -- p. 2.
"Total Plant Safety Audit", 1.0 General -- p. 2.
"The Use of Water Spray Barriers to Disperse Spills of Heavy Gases," 4.5
Mitigation Systems -- p. 29.
What Went Wrong? Case Histories of Process Plant Disasters. 1.0 General -
p. 3.
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FREQUENTLY MENTIONED ORGANIZATIONS
American Institute of Chemical
Engineers (AIChE)
Publications Sales, Dept. CAT-90
345 East 47 Street
New York, NY 10017
212-705-7657
American Petroleum Institute (API)
1220 L Street, NW
Washington, DC 20005
202-632-8375
American Society for Testing and
Materials (ASTM)
1916 Race St.
Philadelphia, PA 19103-1187
215-229-5585
American Society of Safety Engineers
(ASSE)
Department F
1800 East Oakton Street
Des Plaines, IL 60018-2187
708-692-4121 ext. 18
Chemical Manufacturers Association
2501 M Street, NW
Washington, DC 20037
202-887-1100
The Chlorine Institute, Inc.
2001 L Street, NW
Washington, DC 20036
202-775-2790
Federal Emergency Management Agency
(FEMA)
Publications Office
P.O. Box 70274
Washington, DC 20024
202-646-2500
Fire Protection Publications
Oklahoma State University
Stillwater, Oklahoma 74078-0118
1-800-654-4055
National Association of
Manufacturers (NAM)
Publications Coordinator
1331 Pennsylvania Avenue, NW
Suite 1500 - North Lobby
Washington, DC 20004-1703
National Fire Protection Association
(NFPA)
1 Batterymarch Park
P.O. Box 9101
Quincy, MA 02269-9101
1-800-344-3555
National Technical Information
Service (NTIS)
U.S. Department of Commerce
5285 Port Royal Road
Springfield, VA 22161
703-487-4650
Occupational Safety and Health
Administration
U.S. Department of Labor
OSHA Publications Office, N3101
200 Constitution Avenue, NW
Washington, DC 20210
202-523-9667
U.S. Coast Guard
2100 Second Street, SW
Washington, DC 20593-0001
U.S. Environmental Protection Agency
Public Information Center
401 M Street, SW
Washington, DC 20460
202-382-2080
Emergency Planning and Community
Right-To-Knov Information Service
U.S. Environmental Protection Agency
OS-120
401 M Street, SW
Washington, DC 20460
1-800-535-0202
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United States Office of Solid Waste September 1989
Environmental Protection and Emergency Response OSWER-89-005
Agency (OS-120) Series 5
v>EPA Computer Systems
for Chemical Emergency
Planning
Chemical Emergency
Preparedness and Prevention
Technical Assistance Bulletin #5
Printed on Recycled Paper
-------
ABOUT THIS BULLETIN
EPA is issuing this bulletin to assist local planners with identifying computer systems applicable to
Title III of the Superfund Amendments and Reauthorization Act of 1986 (also referred to as the
Emergency Planning and Community Right-to-Know Act). The purpose of this bulletin is to provide
Local Emergency Planning Committees (LEPCs), State Emergency Response Commissions (SERCs), fire
departments, and other local planners with a checklist of computer system needs and information on
available systems already identified as applicable to local planning.
The first section of this bulletin is an edited version of Appendix K of the Technical Guidance for
Hazards Analysis. This appendix is entitled "Evaluation Guide for Available Computer Applications
Addressing Emergency Response Planning."
The second section of this bulletin is entitled "Preliminary List of Computer Applications and
Systems of Potential Use Under SARA Title III" and contains a list of computer systems applicable to
local planning. The list is not anticipated to be fully comprehensive of the environmental computer
systems market nor is it intended to act as an endorsement for any of the listed systems. The list is only
intended to serve an initial reference source. Vendor names, addresses, and phone numbers have been
provided: it is essential that the vendor be contacted to obtain current cost, capability, availability, and
limitation information for any system of interest.
Updates to the evaluation guide and list of computer applications will be made periodically. If
you have information relevant to future updates, please send the information to:
Chemical Emergency Preparedness and Prevention Office
Environmental Protection Agency
Attn: Software List
OS-120
401 M Street, S.W.
Washington, D.C. 20460
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APPENDIX K OF THE
TECHNICAL GUIDANCE FOR HAZARDS ANALYSIS
EVALUATION GUIDE FOR AVAILABLE COMPUTER
APPLICATIONS ADDRESSING EMERGENCY RESPONSE PLANNING
PURPOSE OF THIS CHECKLIST
This appendix contains a checklist of criteria developed to help local emergency planning
committees (LEPCs), or other groups considering purchasing software, to identify computerized
applications to assist in emergency response planning as outlined in the chapters of the Technical
Guidance for Hazards Analysis, The checklist identifies many of the ways that software applications can
be of assistance. The priorities and needs of the local planning district will dictate which criteria are to
be considered and may require development of additional criteria.
SOURCES OF INFORMATION USED TO DEVELOP THE CHECKLIST
The checklist criteria were developed from information in the National Response Team's
Hazardous Materials Emergency Planning Guide1 (NRT-1) and the Technical Guidance for Hazards
Analysis. NRT-1 was designed to help local communities respond to potential incidents involving
hazardous materials. The Technical Guidance for Hazards Analysis supplements NRT-1 by identifying the
facility and transportation route information necessary for hazards analysis and emergency planning,
providing guidelines for determining vulnerable zones, and outlining the process for analyzing risks.
Understanding the planning processes described in these documents and how the information
being assembled will be used is a prerequisite for determining which computer application will best
address the specific set of needs involved.
STRUCTURE OF THE CHECKLIST
Section 1. Provides a checklist for evaluating the computer hardware (equipment) and additional
software (programs) required to operate the system. The flexibility and ease of use of
the system and the availability of training and other types of vendor support are also
addressed.
The next sections of the checklist are based on the structure of the Technical Guidance for
Hazards Analysis, and include:
Section 2. Hazards Identification (assembling facility, transportation route, and chemical data);
Section 3. Vulnerability Analysis (modeling of releases);
Section 4. Risk Analysis (ranking of hazards); and
Section 5. Emergency Response Planning (assembling hazards, vulnerability analysis, and risk analysis
information).
Section 6. Regulatory Requirements. This section describes a few of the ways that a software
application can explain the requirements under Title III and assist in compliance with
requirements, such as tracking deadlines and responding to requests for information.
1 National Response Team, Hazardous Materials Emergency Planning Guide. NRT-1 (March 1987).
1
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NOTE; This checklist highlights some important user costs to be considered, however the total system
cost is difficult to represent. Some software applications may require the purchase of specialized
hardware or additional software from other manufacturers. Vendors may include fees for
tailoring of the software application to meet a user's needs in the original price. Training,
manuals, technical support services, additional data entry, software updates, and additional copies
of the software may be included or may need to be purchased separately.
In addition to the initial purchase costs of the application, the long-term investment required to
install, maintain, and operate the full working system must be considered. Such costs will include:
assembling the required data; validating and entering the data; training new personnel; purchasing
updated software; and correcting and amending the data as changes occur. These costs will apply
to some extent to any application purchased. Assistance in estimating some of these costs may be
available from data processing professionals within the State government or from computer-
oriented firms located within the district,
SUGGESTED PROCEDURE FOR EVALUATING EMERGENCY RESPONSE PLANNING SOFTWARE
APPLICATIONS
The suggested procedure for LEPCs to use the checklist is as follows:
1. Identify the local district's need to manage emergency response planning information
under NRT-1 and the Technical Guidance for Hazards Analysis. Understanding how the
information is to be used in the planning process is an essential first step to focusing the
evaluation on the needs.
2. Select the criteria on the checklist that most closely represent the local district's needs
and priorities for emergency response planning. It is not expected that all criteria listed
will apply.
3. Develop any additional criteria required to address local needs and priorities (e.g.,
consistency with the type of computer equipment that is already available),
4. Rank the criteria according to levels of importance (e.g., must be met, would be valuable,
can be delayed).
5. Identify vendors and their emergency response software from the available literature,
advertising, and other sources. An initial list of commercial software applications is
included in the second section of this technical assistance bulletin.
6. Request information from the vendors (e.g., sales literature, demonstration software, cost
information, and current users of the application who can be contacted as references).
7. Review the information and complete a checklist for each software application.
8. Contact vendors to request any additional information and to clarify data on the
applications that seem best suited to the need.
CAUTIONS: An evaluation must include the specific priorities and needs of the individual jurisdiction.
Any comparison of the cost of computer applications requires the assessment of many
factors in addition to the purchase price identified by the vendor. (See note above for a
detailed discussion of costs.)
Computer systems are continually being modified and refined. The results of the
evaluation will become out-of-date and should be repeated if the purchase of a system is
delayed.
2
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CRITERIA FOR THE REVIEW OF COMMERCIALLY AVAILABLE
SOFTWARE APPLICATIONS FOR EMERGENCY RESPONSE PLANNING
COMPUTER SYSTEM REQUIREMENTS (Hardware, Software, Support, Etc.)
Objective: Provide a basis to evaluate the functional capabilities, design limitations, and operational
requirements of the system, and to evaluate the vendor's ability and willingness to support the system.
Criteria
Explanation /Examples
Demonstrations of the software application
are available?
Documentation of the software is available
for review?
Software application is available for a trial
evaluation?
Vendor is willing to modify the application?
5. Software is compatible with hardware that is
already available or can be easily obtained?
6. Computer system hardware memory can
be expanded to meet the anticipated needs?
7. Requires additional software to be purchased
from other companies to function?
8. Sold as modular components that are priced
separately?
9. Total system cost is consistent with budget
capabilities of user?
10. Limits hardware and data access by
unauthorized users?
11. User friendly and requires a minimal amount
of user training?
12. Vendor provides additional training that may
be required?
Either a professional sales demo or current user
demo may be available.
User's manuals and other explanatory material
from the vendor.
30-day free trial may be available from the
vendor.
The appEcation may require changes by the
vendor to allow specific community needs to be
addressed.
Microcomputer; monitor; graphics board;
modem; phone line; math co-processor; data
storage space; digitizer; printer or plotter.
Hardware can accept additional memory
required to load the software and modify the
largest data file needed.
Operating system; printer interface; graphics
package.
Modules may be selected and assembled to meet
specific requirements (NOTE: the software may
require purchasing several modules to function
properly.)
Costs of hardware, software, training, and data
input may be hidden.
Access may be limited through passwords and/or
encryption of stored data.
Menu driven; provides help screens; clearly
presented instructions; uses a mouse or touch
screen.
Training classes and materials may be required
when the system is installed and as employees
are hired; cost of training should be considered.
-------
COMPUTER SYSTEM REQUIREMENTS (continued)
Criteria
13. Allows data that was entered by the system
vendor to be updated by the user?
14. Allows new types of data that were not
included in the vendor's application to be
entered by the user?
15. Limits copying or distribution by copyright
or copy protection?
16. Validates data as it is entered or stored in
the application?
17. In addition to using established keywords,
allows searches to be performed with criteria
chosen by the user?
18. Quality data sources were used and updates
will be available as source information
changes?
19. Allows reports or graphs to be designed by
the user?
20. Allows data to be transferred (input and
output) with other types of software packages
and hardware systems?
21. Is in use by others who are willing to
provide information on their experience?
22. Will the system software and data be updated
by the vendor?
23. Vendor provides continued service and
support if the user experiences any type of
difficulties in operating the system?
Explanation/Examples
Allows modification of procedures for handling a
spill or release according to facility or
community practices.
A new field of data can be added to the
database (e.g., new type of chemical information;
facility response procedures).
Some vendors limit the ability to make copies of
the software and require copies to be purchased
for each user.
Tests data against valid ranges (e.g., pH<14) or
lists of acceptable data (e.g., chemical names).
Data can be identified by other than preset
criteria such as through a menu (e.g., user
defined searches).
Chemical data content is current and generally
accepted by science and health agencies such as
EPA, OSHA, NIH, NOAA, U.S. Coast Guard,
DOT, and others; cost and timeliness of updates
should be considered.
User can specify data to be included, physical
layout, and headings for columns of data.
System can communicate with other systems
(e.g., Lotus, dBASE, ASCII, and DIF data
formats; Macintosh and IBM equipment).
Vendors may provide names of current users of
the system who would be willing to discuss their
experience.
New capabilities that are compatible with the
current system may be added.
If this type of service is available, a
maintenance and support fee will probably be
charged.
4
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HAZARDS IDENTIFICATION
Objective: Provide information on the identity, quantity, location, physical properties, and toxicity of
chemicals at sites within the planning district.
Criteria _____
Facilities
1. Accepts data on one or more manufacturing
and storage facilities?
2, Accepts chemical inventory and storage data?
3. Accepts information concerning facility
accident potential or history?
4. Records or describes engineering controls and
safeguards at specific facilities?
Transportation Routes
1, Records shipping routes taken to deliver
materials to facilities (e.g., highway, rail,
and air)?
2, Accepts information on the major safety
characteristics of routes?
3, Logs transportation data, schedules, and
exceptions?
Explanation/Examples
Locations; activities; and inspection records.
Chemical names; quantities; site location(s);
storage methods, temperature, and pressure.
Events that could result in damage; anticipated
damage and consequences; and historical
accident records.
Detection, fire suppression, and security systems;
containment and drainage systems; and utility
shutoffs.
Identifies route taken and materials transported.
Routes may create problems because of width;
access; traffic patterns; and jurisdictions.
Tracks planned cargo shipments for location and
time expected.
Chemical Information
1. Database contains information concerning the
extremely hazardous substances?
2. Contains information about the chemical and
physical properties?
3. Contains the health hazards and risks,
toxicological data, and first aid procedures?
4. Contains methods for the safe handling and
use of the chemical and for emergency
response?
5. Indicates if notification requirements apply
to the chemical released?
As required by the Title III regulations (i.e.,
threshold planning quantities).
Flamm ability; reactivity; corrosivity; vapor
pressures; physical states; boiling and melting
points.
Exposure routes and limits; signs and symptoms;
target organs; and medical conditions aggravated
by exposure.
Identifies the equipment, clothing and procedures
required.
Identifies notification requirements for release of
reportable quantities of chemicals (e.g.,
CERCLA, SARA).
5
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VULNERABILITY ANALYSIS
Objective: Identify geographic zone of the community that may be affected by an airborne release and
populations that may be subject to harm.
Criteria
Explanation/Examples
1. Accepts information on areas around facilities
and routes?
2, Accepts information on the characteristics of
populations located in areas that could be in
the vulnerable zone?
3. Calculates the vulnerability zone based on the
maximum quantity present for screening?
4, Allows site-specific inputs to the calculation
of vulnerability zones and provides release
scenarios?
Drinking water supplies; cropland; sensitive
natural areas.
Location of special populations (e.g., elderly;
handicapped; prisons; and schools) and
population density.
Calculations are based on credible worst case
assumptions identified in the Technical Guidance
for Hazards Analysis.
Calculations are based on site-specific planning
factors such as wind speed, stability class, and
chemical toxicity.
Modeling the Release of Chemicals (predicting the path, the effect, and the area of impact of the
chemical release using mathematical analysis)
Inputs (information that drives the model)
1. Accommodates physical characteristics of the
chemical?
2. Addresses different types of releases?
3. Supports multiple point sources?
4. Addresses releases from any source or only
pre-selected sources?
Accepts data on meteorological conditions?
Allows observed data to be manually
input?
Allows a modem link for direct data
entry?
Requires a meteorological tower for
data input?
Liquids at boiling point or ambient temperature;
powdered solids; solids in solution; molten solids;
gas density.
Instantaneous and continuous releases including
spills, leaks, fires, explosions, and BLEVEs.
Several release sources operating concurrently.
Modeling ability may be limited to a specific set
of pre-established sites or may be capable of
representing releases from any possible location
(e.g., transportation accident).
Wind velocity and direction; temperature;
stability class; precipitation.
Data are typed into the system using the
keyboard.
Accepts data directly from laboratories or
weather stations.
Facility or community meteorologic tower is
required for data collection.
6
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VULNERABILITY ANALYSIS (continued)
Criteria Explanation /Examples
6. Accepts data input for the level of concern? Uses the data entered to calculate the vulnerable
zones.
Algorithms (equation(s) and assumptions used to calculate the results such as the concentration of the
plume of released chemicals)
1. Employs dispersion models that are consistent
with those used in the Technical Guidance for
Hazards Analysis?
2. Identifies the types of assumptions used?
3. Calculates chemical dispersion rates and
routes?
Gaussian dispersion models based on Turner's
Workbook of Atmospheric Dispersion Estimates,
PHS Pub. No. 999-AJP-26. Different air
stabilities and wind speeds are used.
Some models are not documented to provide
information on the assumptions used to perform
calculations and their effect on the model's
results or do not identify the limits of the
model's ability.
Provides information on the plume size, motion,
and concentration over time; and predicts toxic
corridors.
4. Supports terrain modeling and considers
complex terrain?
The ability to accommodate site-specific effects
of terrain can be significant under some
circumstances.
Outputs (the results of the calculations performed)
1. Presents pictorial representation of dispersion
plumes?
2. Produces line, bar, or pie graphs?
3. Retains the results of calculations in final
form for future review or stores the input
parameters to allow the results to be
reproduced?
Presents model output as dispersion plume
overlaid on a map of the area.
Presents model output in graphical format (e.g.,
concentrations experienced at a location over
time).
Systems differ in their ability to re-enact a series
of calculations or to reproduce a specific output.
7
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RISK ANALYSIS
Objective: Provide a basis to judge the relative likelihood (probability) and severity of various possible
events. Risks can be expressed in qualitative terms (high, medium, low) based on subjective, common-
sense evaluations, or in quantitative terms (numerical and statistical calculations).
Criteria
1. Allows judgement to be made concerning
facilities and routes, for probable hazard
and severity of consequences?
2. Assembles quantitative facility information
concerning possible release scenarios?
3. Allows priorities to be recorded according to
community concerns and opinions?
Exnianation/Examples
Judgement may be based on the accident history,
type of facility, storage conditions, control
technologies in place, and other factors.
Recognized systematic approaches include:
hazard operability study (HAZOP); event tree
analysis; fault tree analysis.
Judgement and concerns of the community can
be entered into the ranking and prioritization for
community hazards.
8
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EMERGENCY RESPONSE PLANNING
Criteria Explanation /Examples
Objective: Assemble detailed information concerning hazards, vulnerability, and risk; provide action
outlines for responders and criteria for plan review; present maps of the local area; and provide
simulation capabilities for training.
Provides detailed methods for promptly
identifying the affected area and population
based on release information?
a. Maps facility locations and
transportation routes?
b. Plans routes for hazardous chemical
shipments?
Accepts emergency information and plans
provided by chemical facilities?
a. Records facility emergency contacts?
b. Generates floor plans of facility
storage sites?
c. Indicates location of engineering
controls/safeguards?
3. Provides an action outline for emergency
responders?
4. Identifies the needed emergency response
equipment for various types of emergencies?
5. Stores the inventory of local response
equipment and provides location and
availability information?
6. Stores information on community emergency
procedures and plans?
7. Provides criteria for evaluating existing
emergency response functions?
Mapping; modeling; demographical statistics
worst case release.
Provides details of relative locations of hazards
and vulnerable zones.
Based on characteristics of routes available,
selects the least dangerous route.
Plans; procedures; site diagrams; emergency
checklists.
Provides names, titles, and 24-hr. phone numbers
for emergency purposes.
Shows building layout and chemical locations
graphically.
Identifies safeguards such as emergency shut-offs
graphically or by detailed description of the
location.
Provides a chain of events or considerations that
is based on the site-specific conditions involved.
Provides a decision aid for choosing proper
equipment and required medical supplies based
on the chemicals involved.
Assists in the identification of equipment
available from chemical facilities, local
emergency responders, hospitals, other
communities, and private contractors.
Direction and control; communications;
evacuation and sheltering; medical treatment
facilities; resource management; cleanup and
disposal; decontamination; and documentation.
Identifies the essential elements that should be
present in the plans based on regulatory
requirements and local community priorities.
9
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EMERGENCY RESPONSE PLANNING (continued)
Criteria
8.
9.
10.
Explanation/Examples
Flags information that changes frequently (e.g.,
emergency contacts, telephone numbers, and
addresses).
Provides criteria for evaluation of training
programs and stores information on training
completed per regulatory requirements.
Provides example test emergencies to exercise
the plan and train response personnel.
Prompts for information to update emergency
response plans?
Identifies hazardous material training program
requirements and stores training information
and schedules?
Provides simulation capabilities for training?
10
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IDENTIFICATION OF REGULATORY REQUIREMENTS
Objective: Track regulatory deadlines and assist in the assessment of compliance with reporting
requirements, as well as record the status of required information and log requests for information.
NOTE: These criteria concentrate on planning and response requirements of Title III of SARA. The
following is only a partial list of the possible capabilities applications may possess with regard to
the identification of regulatory requirements.
Criteria Explanation/Examples
1. Tracks deadlines for reporting requirements Deadlines for reporting as required under
under Tide III of SARA? Title III Sections 302, 304, 311-312, and 313.
2. Provides a means to respond to information Report capabilities may include production of
reporting requirements of Title III of SARA? the submission forms or letters or partial
assembly of the needed information.
Data manipulation including cross indexing lists
to identify all facilities using a particular
chemical.
Record type and number of requests and provide
information to answer them.
Identify when a plan was developed and when it
was last updated.
3. Has the capacity to store and manage MSDS
and chemical inventory form data?
4, Addresses public requests for information
under Title III of SARA?
5. Tracks the status of planning in the local
districts?
11
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PRELIMINARY LIST OF COMPUTER APPLICATIONS AND SYSTEMS OF POTENTIAL USE
UNDER SARA TITLE III
PURPOSE AND INTENDED USE OF THE LIST
This section contains a list of computer software applications and has been assembled as a reference
source to assist local emergency planning committees (LEPCs) and others in locating potentially useful
software applications. The list includes systems identified from readily available information sources. The
principal intent is to identify software that is applicable to the information collection, data management,
reporting, planning, or scheduling requirements of Title III of the Superfimd Amendments and
Reauthorization Act of 1986 (SARA). The following list of categories was used in evaluating each of the
systems on Table I (* on the category list indicates that the category addresses an area of concentration
applicable for meeting the requirements of Title III):
* Emergency Response Planning Information (e.g., hazardous materials and facilities: locations,
characteristics, training);
* Air Dispersion Modeling (e.g., releases; gas clouds);
Other Environmental Modeling (e.g., water; groundwater; chemical properties);
* Facility Environmental Monitoring and Other Chemical and Waste Data (e.g., monitoring data;
schedules);
* Facility Chemical or Waste Recordkeeping, Reporting, and Compliance Assistance (e.g.,
manifests, labels, report generation);
* Treatment/Pretreatment Assistance (e.g., recordkeeping);
Facility or Treatment System Design Assistance;
* Cleanup Assistance;
Facility Maintenance and Equipment Monitoring and Repair;
Facility Permit Applications Assistance (e.g., NPDES, RCRA Part B);
Facility Operations and Management Assistance (e.g., budget keeping, management records);
* Chemical and Properties Reference Source (e.g., MSDS information);
* Regulatory Reference Data Source;
* Federal/State Information Source (e.g., historical accident records).
The PURPOSE/DESCRIPTION/REQUIREMENTS column of Table I provides information about
each system pertaining to these areas of apparent concentration. Within Table I, systems that are double
asterisked (**) possess an apparent high degree of usefulness for SARA Title III planning, however this
does not indicate any endorsement of the system's ability. The vendor should be contacted to determine
the extent to which the system addresses specific needs and to verify the system's capabilities.
12
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The names or acronyms given to many applications are not easily recognized for the applications' ability
to meet a particular need. The list therefore includes several types of systems that have no direct
applicability to SARA requirements (e.g., wastewater treatment plant optimization; assistance with ordering
chemicals). The creation of a comprehensive list of environmental applications provides a higher level of
assurance that software that is relevant to Title III has not been overlooked. The list can also be used to
eliminate systems from the review process and reduce the effort needed to identify a system that has the
required capabilities.
SOURCES OF INFORMATION USED TO ASSEMBLE LIST
The list data were collected from a variety of sources, including:
ฆ Published articles, as identified at the end of the list;
ฆ Vendors sales literature, advertisements, and promotions; and
ฆ Accumulated professional knowledge and expertise concerning the systems that have been
developed.
Professional areas of expertise that were investigated included:
ฆ Emergency response (including fire department) actions and planning;
ฆ Occupational Safety and Health data management;
ฆ Chemical information reference sources;
ฆ Facility environmental data management and reporting; and
ฆ Regulatory compliance reporting and data sources.
LIMITATIONS ON INFORMATION QUALITY AND CURRENTNESS
There are many limitations to assembling this type of list. Among the limitations that must be taken
into consideration when the information in the list is used are the following:
1- The information provided to develop the list mav be out-of-date.
Changes to environmental computer applications occur rapidly, therefore, the list cannot remain
current. New systems are being developed, vendors move or go out of business, and identified
systems arc being updated, sold to other vendors, tailored to new markets, or discontinued.
2. System descriptions are not intended to be comprehensive.
The Purpose/Description/Rcquirements column of the table is provided only as a first indicator of
some of the application's capabilities and to assist with modifying criteria that could eliminate the
system from further review (e.g., hardware requirements).
3. Systems listed are not endorsed or approved bv EPA.
Much of the information regarding application capabilities has been taken directly from vendor
sales literature or third party reviews. The information recounted has not been extensively verified
or validated due to time constraints.
13
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IMPORTANT: Vendor contact information, including addresses and phone numbers, is
provided for all systems and has been validated to the extent possible. It is
essential to contact the vendor to obtain current cost, capability, availability,
and limitation information for any systems of interest. The list is only
intended as an initial reference source. Purchase of a system should not be
based on the information provided in the list.
14
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TABI.E I
PRELIMINARY LIST OF COMPUTER APPLICATIONS AND SYSTCMS OIf POTENTIAL USE UNDER SARA Tm.E III
ACRONYM/ADDIU-VIATION SYSTEM NAM I'.
VENDOR
CONTACT
ADDRESS/PI lONIi
PURI'OSE/DESCRII'TION/REQUIREMENTS
ACAI'l*
Aqueous Chemical and
Physical Properties
P S. I oweII & Co., Inc.
8868 Research
Suite 309
Austin, TX 78758
(512) 454-4797
Blvd
Predicts properties and computes chemical ;md sulid-
liquid phase equilibrium for aqueous mixtures. Up
to 20 composition data sets may be handled in
memory at once. Requires 512K memory.
ACT
Techdala
6615 la Mora
Houston, TX 77083
(713) 4984)797
Designs activated sludge systems. Also provides data
data for flow modeling and permits.
ADPM
Automated Defense Priority Roy F. Weston, Inc.
Model Development
Judith Hushon
955 L'Enfant Plaza, SW
6th Floor
Washington, DC 20024
(202) 646-6800
System considers surface waler and groundwater
pathways of exposure in evaluating the potential for
adverse effects. Air and soil pathways will be added
as will numerous built-in error checking routines.
AIRDAS
AMINE-1
Air Quality and
Meteorological Monitoring
Data Acquisition System
Enviroplan, Inc.
TECS Software, Inc.
Michael Abrams
59 Main St.
West Orange, NJ 07052
(201) 325-1544
P.O. Box 720730
Houston, TX 77272
(713) 561-6143
Collects, processes, displays, and reports air quality
and meteorological data. Requires Data General
Corp. MicroBCLIPSE processor.
Performs preliminary design of MGA, 15EA, and
MDEA plants through mass and energy balance
calculations for all major equipment involved.
ANASOFT
Anafaze, Inc.
Mike Jacobs
1041 17th Ave.
Santa Cruz, CA 95062
(408) 479-0415
Records results of environmental monitoring data:
flows, pH, pollution levels, waste disposal areas and
control of pollution.
APR
Air Pollution Emissions
Jerome R. Barta
Jerome R. Barta
1513 White Post
Cedar Park, TX 78613
(512) 258-1812
(Call after 4 PM)
Tracks air pollution emissions. Screen formats for
data input and output in Basic. User can customize
using Basic.
Indicates an apparent high degree of usefulness for SARA Title III (i.e., includes two or more principal areas of use identified on page 12).
All systems require an IBM compatible microcomputer unless otherwise specified.
-------
PAGE 1-2
September 1989
TABLE 1 (continued)
PRELIMINARY LIST OF COMPUTER APPLICATIONS AND SYSTEMS OF POTENTIAL USE UNDER SARA TITLE III
ACRONYM /ABBREVIATION SYSTEM NAME
VENDOR
ADDRESS/PHONE PURFOSE/DESGRIPTION/REOUIREMBNTS
ARCHIE
Automated Resource for
Chemical Hazard Incident
Evaluation
Department of
Transportation
Stacy Gerard
ARCHIE Support
(DHM-15/Room 8104)
U.S. Department of
Transportation
400 7th Street, S.W.
Washington, D,C. 20590
(202) 366-4900
Program created for DOT, EPA, and FEMA to aid
emergency preparedness personnel in assessing the
sequence and nature of events that may follow an
accident. ARCHIE incorporates several estimation
methods that may be used to assess the vapor
discharge, fire, and explosion impacts associated with
episodic discharges of hazardous materials.
ASPER
Activated Sludge
Performance Evaluation
Routines
Cochrane Associates,
Inc.
Jay J. Fink
236 Huntington Ave.
Boston, MA 02115
(617) 247-0444
Evaluates the performance of each unit of a
wastewater treatment plant based on hydraulic
loadings, solid flux loadings, food/microorganism
ratios, sludge age, settleability, and related
parameters.
BASIS
Text Information Management Information Dimensions
System (TIMS)
655 Metro Place South
Suite 500
Dublin, OH 43017
(614) 761-7300
Provides access to textual and numeric data in its
databases for information retrieval and reporting
needs. Features word proximity and phrase
searching; thesaurus and index.
Batchmaster Plus
BEE - SARA
Pacific Micro Software
Engineering
Bowman Environmental
Engineering
35 59th Place
Long Beach, CA 90803
(213) 434-0011
P.O. Box 29072
Dallas, TX 75229
(214) 241-1895
MSDS, HMIS labeling modules.
Dispersion modeling software including EPA
dispersion models, data entry programs,
vulnerability zones, meteorological data
processing programs, and puff-type programs for
modeling gas releases. Uses more than 20 models.
BEESTAR, CRSMET, STAR
WROSE
Bowman Environmental
Engineering
P.O. Box 29072
Dallas, TX 75229
(214) 241-1895
Meteorological data processing. Prepares data in a
suitable format for input in models.
BeSafe
BeSafe Hazardous Substance
Information and Tracking
Module
Azimuth Technologies, Inc.
P.O. Box 5787
Pasadena, CA 91117
(818) 405-0300
Information management system designed to aid in
the creation of MSDSs. Includes packages
containing hazardous materials data for compliance
with "Right to Know" legislation.
"Indicates an apparent high degree of usefulness for SARA Title HI (i.e., includes two or more principal areas of use identified an page 12).
All systems require an IBM compatible microcomputer unless otherwise specified.
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PAGE 1-3
September 1989
TABLE I (continued)
PRELIMINARY LIST OF COMPUTER APPLICATIONS AND SYSTEMS OF POTENTIAL USE UNDER SARA TITLE III
ACRONYM/ABBREVIATION SYSTEM NAME
VENDOR
ADDRESS/PHONE
PURPOSE/DESCRIPTION/REQUIREMENTS
BLUE SKY
BREEZE AIR
BREEZE HAZ
CALS/EWDS
CAMEO II
CAMEO
Computer Automated
Laboratory System/
Environmental Wasic Database
System
Computer-Aided Management
of Emergency Operations,
Version 1.02
Compute r-Aided Management
of Emergency Operations,
IBM Version
Kelon Corporation
Trinity Consultants, Inc.
Trinity Consultants, Inc.
Beckman Instruments Inc.
IIS Department of
Commerce - NOAA/U.S.
Environmental Protection
Agency - Office of Solid
Waste and Emergency
U.S. Department of
Commerce - NOAA/U.S.
Environmental Protection
Agency - Office of Solid
Wasie and Emergency
P.O. Box 64577
Tucson, AZ 85716
(602) 299-5636
12801 N Central Expwy
Suite 1200
Dallas, TX 7S243
(214) 661-8100
12801 N Central Expwy
Suite 1200
Dallas, TX 75243
(214) 661-8100
An integrated package that creates air pollution
permits, calculates and reports on emission inventory
information and individual ait pollution incidents.
Air pollution dispersion models derived from the
UNAMAP6 stationary source models and other
specialized dispersion models. Uses more than 20
models. Requires 512K memory and 132 column
printer.
Models toxic gas releases. Two models available:
SHELL SPILLS and TRPUF (based on EPA
PUFF). Graphical output. Requires 512K memory
and 132 column printer.
Lab. Automation
Operations
160 Hopper Ave.
Waldwick, N.I 07463
(201) 444-8900
Mark Miller
NOAA
HazMat Resp Branch
7600 Sand Point Wy NE
Seattle, WA 98115
(206) 526-6317
John Laumer
National Safety Council
444 N. Michigan Ave.
Chicago, IL 60611
(312) 527 4800 *5606
Mark Miller
NOAA
HazMat Resp. Branch
7600 Sand Point Wy NE
Seattle, WA 98115
(206) 526-6317
CALS combines sample tracking facilities with a
database for management and documentation of
information in the environmental waste monitoring
laboratory. EWD15S provides a reporting format
thai prints data on the N I'D US form.
Emergency planning and response information
including the following: chemical information,
response information, air modeling, mapping,
response resources inventory, facility information,
route information, population information, emergency
recordkeeping, MSDS information, Section 304
release reports, information request records, facility
reports, and planning introduction and assistance.
Requires Apple computer equipment.
Database of chemical data and response information.
"Indicates an apparent high degree of usefulness for SARA Title III (i.e., includes two or more principal areas of use identified on page 12).
All systems require an IBM compatible microcomputer unless otherwise specified.
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PAGE 1-4
September 1989
TABLE 1 (continued)
PRELIMINARY 1.1ST OF COMPUTER APPLICATIONS AND SYSTEMS OF POTENTIAL USE UNDER SARA TITLE Ill
ACRONYM/ABBREVIATION SYSTEM NAME
VENDOR
ADDRESS/PHONE PURPOSE/DESCRIPTION/REQUIREMENTS
CARE
CASH/TRACK
CEMDAS
CENS
*CERS
Computerized Airborne
Release Evaluation
CHARM
Continuous Emission Monitor-
ing Data Acquisition System
Computerized Emergency
Notification System
Computerized Emergency
Response Series
Complex Hazardous Air
Release Mode!
CHART/PC
Environmental Systems
Corporation
Livingston Enterprises
finviroplan, Inc.
Advanced Systems
laboratories, Inc.
Advanced Systems
Laboratories, Inc.
Radian Corp.
Engineering Applications
Specialists, Inc.
Ron Webb
200 Tech Center Dr.
Knoxvtlte, TN 37912
(615) 688-7900
2855 Kifer Road
Santa Clara, CA 95051
(408) 986-8866
Uses mathematical models to assess gas cloud
movements. Uses gas detectors and weather sensors
to alert user of release, and provides plume
dispersion, effects, and response information.
Full inventory chemical tracking system designed to
ejctract Tier I and Tier II information for assistance
in reporting.
Ron Zowan
59 Main Street
West Orange, NJ 07052 provides reports
(201) 325-1544
Data acquisition system for continuous emission
monitoring of ambient air or stack emissions. Also
7137 West Main St.
Lima, NY 14485
(716) 624-3276
7137 West Main St,
Lima, NY 14485
(716) 624-3276
Lou Fowler
8501 Mo-Pac Blvd.
Attn: CHARM
P.O. Box 9948
Austin, TX 78766
(512) 454-4797
5610 Medical Circle
Suite 31
Madison, WI 5371
(608) 273-0065
Can be used with CERS or CMSDS. Determines if
incident requires emergency notification based on
quantity of release. Telephone roster included.
Requires 640K memory and hard disk.
Determines response procedures for incidents based
on data from CMSDS and OHMS. Includes
fire fighting information, personal protective
equipment, emergency first aid procedures, spill and
containment procedures, waste disposal procedures,
and physical and health hazards. Requires 640K
memory and hard disk.
Primarily models chemical releases to the air.
Includes a chemical database and map editor and is
capable of mapping concentration isopleths. Allows
real-time meteorological data input.
Computerized psychometric chart. User provides
two independent properties of moist air and program
calculates the remaining properties.
"Indicates an apparent high degree of usefulness for SARA Title 111 (i.e., includes two or more principal areas of use identified on page 12).
All systems require an IBM compatible microcomputer unless otherwise specified.
-------
PAGE 1-5
September 1989
TABLE I (continued)
PRELIMINARY LIST OF COMPUTER APPLICATIONS AND SYSH'MS OP POTENTIAL USE UNDER SARA TITLE III
ACRONYM/ABnKI '.VI ATI ON SYSlliM NAME
VENDOR
ADDRESS/PHONE
PURPOSE/DESCRtmON/ftEOUlRHMUWS
CI ICS
Computerized Hazard
Compliance Series
Advanced Systems
Laboratories, Inc.
7137 West Main St.
Lima, NY 14485
(716) 624-3276
Provides compliance information including lists of
hazardous substances under SARA, OSHA, and
CERCLA, Her I reports, Tier II reports, emergency
and release reporting. Requires 640K memory and
hard disk.
CHCS Compliance Engine
CHEM MASTER
Version 2.1
CHEM MIJLTI RASE
Advanced Systems
Laboratories, Inc.
ITS Technologies
CHEMASYST
CIIEM Multi BASE, Inc.
1CF Incorporated
7137 West Main St.
Lima, NY 14485
(716) 624-3276
Angela Loundes
9 East Stow Road
Marlton, NJ 08053
(609) 983-7300
(800) 727-2487
P.O. Bo* 350
Mahomet, IL 61853
(217) 586-4131
June Bolstridge
9300 Lee Highway
Fairfax, VA 22031-1207
(703) 934-3208
(800) 283-2243
Assists with SARA Title III compliance. User
inputs information and system provides compliance
status and tasks required for compliance.
Aids in SARA Title III compliance and chemical
inventory tracking. Database of over 3,800 regulated
chemicals. Has capability of tracking and reporting
for multiple facilities. Prints in-house warning labels,
prepares Section 311 reports and facsimiles of Tier 1
and Tier II reports.
Database of 16,000 chemicals with synonyms and
trade names. Government numbers and information
are cross referenced with MSDSs for all DOT
regulated chemicals. Includes tracking and inventory
system.
Manages data needed to comply with SARA Title III
and OSHA HSC Regulations. Provides text,
guidance materials, instructions, and interpretations
of the requirements; forms for reporting; databases
of physical and chemical properties of some
regulated chemicals; lists of chemicals that require
reporting; Section 313 chemical references/sources/
citations; and an approved list of synonyms. Stores
calculations of estimated releases and prints
information onto submittable EPA forms.
CHEMCALC 1, Separations
Calculations
Gulf Publishing Company,
Book Division
P.O. Box 2608
Houston, TX 77252
(713) 520-4444
Programs for use with multi-component mixtures to
determine the conditions and compositions at the
dew point and at the bubble point.
"Indicates an apparent high degree of usefulness for SARA Title III (i.e., includes two or more principal areas of use identified on page 12).
All systems require an IBM compatible microcomputer unless otherwise specified.
-------
PAGE 1-6
September 1989
TABLE I (continued)
PRELIMINARY LIST OF COMPUTER APPLICATIONS AND SYSTEMS OF POTENTIAL USE UNDER SARA TITLE III
ACRONYM/ABBREVIATION SYSTEM NAME
VENDOR
APPRESS/PHONE PURPOSE/DESCRIPTION/REQUIREMENTS
CHEMCALC 7
CHEMCALC 11, AMSIM
CHEMMASTER
CHEMEST
CHEMLINE
Chemical Compound Databank
Amine Gas Treating
Plant Simulator
Chemical Property
Estimation System
Chemical Dictionary Online
Gulf Publishing Company,
Book Division
Gulf Publishing Company,
Book Division
Envirogenics, Inc.
Camp, Dresser, & McKee,
Inc.
National Library of
Medicine
P.O. Box 2608
Houston, TX 77252
(713) 520-4444
P.O. Box 2608
Houston, TX 77252
(713) 520-4444
136 W. Franklin Ave.
Pennington, NJ 08534
(609) 737-3233
Dr. Warren Lyman
1 Center Plaza
Boston, MA 02108
(617) 742-5151 x5711
8600 Rockville Pike
Bethesda, MD 20894
(301) 496-1131
CHEM-PLY
CHEMTOX DATABASE
Environmental Communications
Consultants, Inc.
Resource Consultants
1759 Sharwood Place
Crofton, MD 21114
(301) 858-0332
(301) 793-0622
P.O. Box 1848
Brentwood, TN 37024
(615) 373-5040
Contains (he physical properties of 500 compounds.
Estimates properties at temperature or pressure
within a specified range. Includes OSHA toxicity
data, DOT notations, and directory of manufacturers
for each compound. Requires 2 disk drives.
Models processes for absorption and stripping of
H2S and C02 in a gas stream. For hydrocarbon
gases, also calculates hydrocarbons absorbed and
stripped.
Chemical inventory system for Tier I/II information.
Includes capacity to inventory quantity and location
information. Contains database of 3100 hazardous
chemicals.
Designed to predict environmentally important
properties of organic chemicals. Requires DEC
VAX and IBM PC
Online chemical dictionary with over 500,000 records
on chemical substances found in the TOXLINE,
TOXBACK65, TOXBACK74, RTECS, MEDLINE,
and TDB databases, as well as (he EPA TSCA
Inventory. Search capability by synonyms, CAS
Registry Numbers, and by classes of compounds.
Prime time connect cost is $54 per hour.
Provides brief regulatory information for RCRA,
OSHA, and SARA compliance; also full text.
Access to a 2,700 chemical data base with hazard
information, precautions, and health effects.
Menu-driven software.
Information on 3,500 chemical substances
that are hazardous and of economic
importance. Data include chemical names,
CAS and DOT numbers, properties, exposure
limits, EPA waste information, and spill
response information. Quarterly updates.
Requires 320K memory and lOMeg hard disk.
"Indicates an apparent high degree of usefulness for SARA Title III (i.e., includes two or more principal areas of use identified on page 12).
All systems require an IBM compatible microcomputer unless otherwise specified.
-------
PAGE 1-7
September 1989
TABLE I (continued)
PRELIMINARY LIST OF COMPUTER APPLICATIONS AND SYSTEMS OF POTENTIAL USE UNDER SARA TITLE HI
ACRONYM/ABBREVIATION SYSTEM NAME
VENDOR
ADDRESS/PHONE PURPOSE/DESCRIPTION/REOUIREMBNTS
CHEMTRBC
CII1MS
CHIP
Chemicals in Transportation
Emergency Center
Computerized Hazardous
Inventory Management System
Chemical Manufacturers
Association (CMA)
Advanced Systems
Laboratories, Inc.
Community Hazmal Information Material Safety Data
Platform Systems, Inc.
2501 M Street, NW
Washington, DC 20037
(202) 887-1255
(800) 424-9300
7137 West Main St.
Lima, NY 14485
(716) 624-3276
2674 E. Main St.
Suite C-107
Ventura, CA 93003-2899
(805) 648-6800
Available during a transportation-related
emergency to provide hazard warning and
assistance to response personnel. Modem
allows direct access to HIT, the CMA's
response information database.
Calculates and prints Tier I and Tier II
inventory reports. Also assists with
inventory and chemical storage information
required for Toxic Chemical Release Reports.
Requires 640K memory and hard disk.
Contains four modules that store and
retrieve information: Administrative
Information module for administrative
information for local government;
Emergency Response module for emergency
response information for local
government; Ilazmat Handler Information
module for handler information; and Ilazmat
Information module which contains hazardous
material data for local government and
handlers.
CHIT
Chemical Hazard Identi-
fication and Training
Marcom Marketing Group,
Ltd.
P.O. Uox 9557
4 Denny Road
Wilmington, DE 19809
(800) 651-CHIT
Hazardous chemical information storage and
retrieval for facilities. Modules for:
MSDS, right-to-know requests, spill proce-
dures, training, and labeling.
CHRIS
Chemical Hazard Response
Information System
Chemical Information
Systems, Inc.
Fein-Marquart
7215 York Rd
Baltimore, MD 21212
(800) CIS-USER
Provides chemical information to assist
response to emergencies involving spills of
hazardous materials. Contains chemical,
physical, and biological data, and specific
response-oriented information
(e.g., countermeasures). Developed by the U.S.
Coast Guard.
"Indicates an apparent high degree of usefulness for SARA Title HI (i.e., includes two or more principal areas of use identified on page 12).
All systems require an IBM compatible microcomputer unless otherwise specified.
-------
PAGE 1-8
September 1989
TABLE 1 (continued)
PRELIMINARY LIST OF COMPUTER APPLICATIONS AND SYSTEMS OF POTENTIAL USE UNDER SARA TITLB HI
ACRONYM /ABBREVIATION SYSTEM NAME
VENPOR
ADDRESS/PHONE PURPOSE/DESCRIPTION/REOUIREMBNTS
CHRIS and CHRIS PLUS Chemical Hazard Records
and Inventory Software
Random House
CIS
CMSDS
Chemical Information Service
Computerized MSDS System
Fein-Marquart Associates,
Inc.
Advanced Systems
Laboratory, Inc.
Linda Goldfarb
Jane Rathbun
201 East 50th Street
New York, NY 10022
(800) 733-3000
7215 York Road
Baltimore, MD 21212
(800) CIS-USER
7137 West Main St.
Lima, NY 14485
(716) 624-3276
Primarily recordkeeping system for
individual facilities. Includes information
on chemicals and manufacturers and records
of accidents and training. Chris Plus adds
capability of storing and printing MSDS
information and assists with the preparation of Tier
I and Tier II reports and right-to-know requests.
Both systems contain database of 600 toxic
substances and synonyms.
Collection of databases providing
information that includes chemical
properties, basic effects, and response
techniques. $300 annual subscription fee;
$20 - $95 per computer connect hour.
Software manages and tracks MSDS database
information by chemical ID, supplier,
synonyms, components, registry numbers,
completion status, uses, and hazard classes.
Subscription updating. Requires 640K memory
and hard disk.
COMPLIANCE MANAGER
COPE
CORKES
CoVOCaSc
OSI1A-SOFT Corporation
Metcalf & Eddy, Inc.
Roy F. Weston, Inc.
Dawn Graphics Company
Peter Bragdon
P.O. Box 894
Concord, NH 03301
(603) 672-7230
10 Harvard Mill Sq.
Wakefield, MA 01880
(617) 246-5200
Judith Ilushon
955 L'Enfant Plaza, SW
Washington, DC 20024
(202) 646-6800
19 Edgehil! Road
Winchester, MA 01890
(617) 721-0456
Facility-specific information system that
manages information on the following
modules: MSDS MANAGER, TRAINING
MANAGER and INVENTORY MANAGER.
COPE has 9 modules: PM scheduler,
corrective maintenance, equipment
history, equipment reference listing,
spare parts entry, database integrity
verification, and training.
Provides facility-specific information for
emergency situations.
Spreadsheet template that calculates
expected VOC emissions from use of paints,
inks, and coatings. Prints out EPA data
forms.
"Indicates an apparent high degree of usefulness for SARA Title III (i.e., includes two or more principal areas of use identified on page 12).
AH systems require an IBM compatible microcomputer unless otherwise specified.
-------
PAGE 1-9
September 1989
TARI.fi 1 (continued)
PRELIMINARY 1.1ST OF COMPUTER APPLICATIONS AND SYSTEMS OF POTENTIAL USE UNDER SARA TITLE II!
ACRONYM/ABBKEVIATiON SYSTEM NAME
VENDOR
ADDRESS/PHONB PURPOSE/DESCRIPTION/REQUIREMENTS
CSIN
Chemical Substance
Information Network
CTCRRS
CYCLONE
DATASTREAM
DIALOG
DIPPR
ECMS
Computerized Toxic Chemical
Release Reporting System
Design Institute for
Physical Property Data
Environmental Compliance
Monitoring System
U.S. EPA/Office of
Pesticides and Toxic
Substances
Advanced Systems
Laboratories, Inc.
TECS Software, Inc.
Datastream Systems, Inc.
DIALOG Information
Services
National Bureau of
Standards
Versar Environmental
Systems
Mr. Dalton Tidwell/
Dr. Sidney Siegal
OPTS Chemical
Coordination Staff
(TS-777)
401 M Street, SW
Washington, DC 20460
7137 West Main St.
Lima, NY 14485
(716) 624-3276
P.O. Box 720730
Houston, TX 77272
(713) 561-6143
1200 Woodruff Road
Suite C-40
Greenville, SC 29607
(803) 297-6775
3460 Hillview Ave.
Palo Alto, CA 94304
(415) 858-3785
9200 Rumsey Road
Columbia, MD
21045-1934
(301) 964-9200
Complex switching network that provides user
access to over 400 individual databases.
Necessary to obtain user codes for various
vender databases.
Assists with completion of EPA Form R using
CMSDS and CHIMS information. Also tracks
reporting requirements and emission and
waste treatment. Requires 640K memory and
hard disk.
Does the following calculations for a gas or
air cyclone: sizing, pressure drop, and
fractional and overall efficiency.
System designed for industrial and municipal
wastewater treatment facility data manage-
ment, including key process parameters and
plant evaluation.
Reference system containing information from
all areas of science, technology, and
medicine. $10 - $285 per computer connect
hour.
Data compilation of pure compound
properties.
Facility-specific system including modules
for air emissions, calendar, facility and
agency processes, groundwater, hazardous
waste, incident response, permit tracking,
solid (non-hazardous) waste, work orders,
and wastewater.
"Indicates an apparent high degree of usefulness
for SARA Title III (i.e., includes two or more principal areas of use identified on page 12).
All systems require an IBM compatible microcomputer unless otherwise specified.
-------
PAGE 1-10
September 1989
TABLE 1 (continued)
PRELIMINARY LIST OF COMPUTER APPLICATIONS AND SYSTEMS OF POTENTIAL USE UNDER SARA TITLE III
ACRONYM/ABBREVIATION SYSTEM NAME
VENDOR
ADDRESS/PHONE PURPOSE/DESCRIPTION/REQUIREMENTS
OCOTRAC
EIS/C
Environmental Data
Management System
Emergency Information
System/Chemical
IIAZOX Corporation
Research Alternatives,
Inc.
Daniel Fullerton
12600 W. Colfax Ave.
Suite C420
ljkewood, CO 80215
(303) 237-1065
Maxine Orens
Suite 3
966 HungerfopJ Dr.
Rockville, MD 20850
(301) 424-2803
Provides manifest tracking, permit
tracking, source inventory, environmental
events, TSCA required data management,
waste disposal costs, and groundwater
monitoring.
Primarily an emergency planning and
response system. Records chemical,
facility, transportation, vulnerable
population, and other planning and response
information. Presents information on maps.
Prepares Her I and II reports. Stores MSDS
information.
EMERGENCY CALL SYSTEM
EMERGENCY RESPONSE
COMPUTER PROGRAM
Weith Computer Products
and Services
Ontario Ministry of
Environment
ENFLEX DATA 313
CRM Computer Services,
Inc.
802 Brittany
Suite 101
Bowling Green, OH 43402
(419) 352-8659
Automatically calls emergency response
personnel based on incident specific
information.
Air Resources Branch
880 Bay Street
4th floor
Toronto, Ontario
M5S 1Z8
Terry Percel
855 Springdalc Dr.
Exton, PA 19341
(800) 365-2146
(800) 544-3118
Release modeling system. Contains database
of chemicals and characteristics which may
be modified by user. User selects chemical,
weather conditions and type of release for
simple or heavy gas modeling. Output is
numeric for times and distances with
graphic capabilities.
Calculates releases by four principle methods to
the following media: water, POTW, Underground
Injection, Stack or Point Air, Fugitive, Land,
Waste Offsite, and other processes in the facility.
Also performs a mass balance function around each
process; prints Form R and submits to EPA;
provides for unlimited comments; and stores unused
calculations.
ENFLEX INFO
ERM Computer Services,
Inc.
Terry Percell Provides access to the full text of current
855 Springdalc Dr. federal and state environmental regulations.
Exton, PA 19341 Includes NJ and PA regulations. Provided on
(800) 365-2146 a subscription basis, and furnished on
(800) 544-3118 CD-ROM compact laser disc.
"Indicates an apparent high degree of usefulness for SARA Title III (i.e., includes two or more principal areas of use identified on page 12).
Ail systems require an IBM compatible microcomputer unless otherwise specified.
-------
PAGE 1-11
September 1989
TABLE I (continued)
PRELIMINARY LIST OP COMPUTER APPLICATIONS AND SYSTEMS OF POTENTIAL USE UNDER SARA TITLE III
ACRONYM/ABBREVIATION SYSTEM NAME
VENDOR
ADDRESS/PHONE PURPOSE/DESCRIPTION/REOUIREMENTS
EnviroBase III
Environmental Data
Management System
Enviro Bast Systems
EnviroLab III
ENVIRONMENTAL AIDE
Laboratory Data
Management System (LDMS)
Enviro Base Systems
Odessa Engineering
EHS
FIESTA
Environmental Technical
Information System
Field Slug Test Analyzer
U.S. Army
Roy F. Weston, Inc.
FINANCIAL ANALYSIS OF WASTE
MANAGEMENT ALTERNATIVES
General Electric Company
Corporate Environmental
Programs
Michael II. Freeland
2 Inverness Drive East
Suite 101
Englcwood, CO 80112
(303) 790-8396
Richard L Sayrs, Jr.
2 Inverness Drive East
Suite 101
Englewood, CA 80112
(303) 790-8396
P.O. Bo* 26S37
Austin, TX 7875S
(512) 251-5543
Ron Webster
Construction
Engineering Research
Laboratory
P.O. Box 4005
Champaign, IL 61820
Judith Hushon
955 LEnfant Plaza, SW
6th Floor
Washington, DC 20024
(202) 646-8600
Mr. Richard MacLean
3135 Easton Turnpike
Fairfield, CT 06431
(203) 373-3077
Organizes, analyzes, and generates reports of
laboratory analytic data associated with groundwater,
soils and surface sampling and testing programs.
Written and compiled in Clipper, an extension of
dBase III. Requires DOS 3.0 or greater with at
least 41 OK of free RAM, and a hard disk with at
least 1J megabytes of free storage space.
Organizes analytical laboratory paperwork: sample
log-in and tracking to final analysis reporting and
invoicing, operates on single-CPU or local area
network of IBM PC/XT/AT/80386 or compatible.
Screen oriented, menu driven program that
facilitates data editing, data analysis
and preparation of reports for stack
emissions.
Computerized information retrieval system
that aids the Army and other government
agencies in preparing environmental impuct
statements.
Uses raw data from field tests to compute hydraulic
conductivity, computed value is evaluated by the
expert system for its correctness with regard to these
considerations: site-specific geological characteristics,
validity of test procedures, accuracy of the raw data,
and the computational method. System is written in
Arity-Prolog on a PC.
System calculates the long-term costs,
including liability, associated with
environmental control technologies.
Requires printer with capability of printing
240 columns of width
"Indicates an apparent high degree of usefulness for SARA Title HI (i.e., includes two or more principal areas of use identified on page 12).
All systems require an IBM compatible microcomputer unless otherwise specified.
-------
PAGE 1-12
September 1989
TABLE I (continued)
PRELIMINARY LIST OF COMPUTER APPLICATIONS AND SYSTEMS OF POTENTIAL USE UNDER SARA TITLE III
ACRONYM/ABBREVIATION SYSTEM NAME
VENDOR
ADDRESS/PHONE PURPOSE/DESCRIPTION/REQUIREMENTS
FIND EX
FLAREHDR and FLARESIK
FLOW GEMINI
Environmental Information
Management System and
Occupational Health
Information System
HAZOX Corporation
TECS Software, Inc.
Row General, Inc.
Daniel Fullerton
P.O. Bo* 637
Chadds Ford, PA 19317
(215) 388-2030
(800) 558-6942
P.O. Box 720730
Ilouslon, I X 77272
(713) 561-6143
Indexing and retrieval software for
searching MSDS files.
Two programs, one of which determines header
size based on maximum allowable relief
velocity along the header and the other
program calculates flare tip diameter and
stack height.
Dr. Wanda Rappaport Generates reports, schedules, and
7655 Old Springhouse Rd reminders; summary, detail, and status;
McLean, VA 22102
(703) 893-5900
and inventory, inspection and monitoring
for permits, air and water monitoring,
waste, PCBs and problems and events.
Generates MSDSs, and aids in waste tracking
and environmental audits. Requires DEC
VAX or IBM mini or mainframe.
FRES
GASPROPS
First Responders Expert
System
GEMS
Graphical Exposure
Modeling System
Roy F. Weston, Inc.
Software Systems
Corporation
U.S. EPA
Judith Hushon
955 L'Enfant Plaza, SW
Washington, DC 20024
(202) 6464800
P.O. Box 202017
Austin, TX 78720
(512) 451-8634
Cathy Turner
Pat Harrigan
Office of Toxic Subst.
TS-798
Washington, DC 20460
(202) 382-3929
(202) 382-3397
Provides pollutant toxicity information and
optimal response strategy.
Computes thermodynamic properties of air,
argon, carbon monoxide, carbon dioxide,
hydrogen, nitrogen, oxygen, water vapor, and
products of combustion for hydrocarbons.
Computes all properties from any two
independent properties.
On-line system. Provides support for
exposure assessments of toxic substances.
Includes chemical property estimation
techniques, statistical analysis, multi-
media modeling, and graphics display
(including models).
"Indicates an apparent high degree of usefulness for SARA Title III (i.e., includes two or more principal areas of use identified on page 12).
All systems require an IBM compatible microcomputer unless otherwise specified.
-------
PAGE 1-13
September 1989
TABLE I (continued)
PRELIMINARY I.IST OF COMPUTER APPLICATIONS AND SYSTEMS OF POTENTIAL USE UNDER SARA TITLE 111
ACRONYM/ABBREVIATION SYSTEM NAME
VENDOR
ADDRESS/PHONE PURPOSE/DnSCRIITlON/IUIOUIRItMEMI'S
GLIDE
G ROUNDWATOR/DMS
Geographically Locate
Inventoried Dingers Easily
Groundwater Data
Management System
CSW Data Systems
HAZARD
HAZARDLINE
North American Software,
Inc.
Occupational Health
Services, Inc.
Hazardous Incident
Data Base
Hazardous Material
Document and Package
Verification System
"HazKNOW Know-IT-ALL
U.S. BPA
Bureau of Dangerous
Goods, Ltd.
HazMat Control Systems,
Inc.
Jerome Barta
1513 White Post
Cedar Park, TX 78613
(512) 258-1812
(call after 4 PM)
Provides capability to inventory and
retrieve information on stored hazardous
chemicals and their proximity to central
areas.
One Overlocker Road
Poughkeepsie, NY 12603
(914) 454-0090
George Stephens
P.O. Box 3309
Tustin, CA 92680
(714) 830-6248
John Fee
Suite 2407
450 7th Avenue
New York, NY 10123
(800) 445-6737
(212) 967-1100
Paeita Tibay
Woodbridge Ave.
Edison, NJ 08837
(201) 321-6632
Russell Bowen
Front & Frickson Sts
Essington, PA 19029
(215) 521-0900
Carolyn Husemoller
3409 Lake wood Blvd
Suite 2C
Long Beach, CA 90808
(213) 429-9055
A data management package which tracks the
data associated with a groundwater monitoring
network. The system quantifies and identifies
all forms of data, reports, analyses, corporate and
government standards. Requires 4.6 megs of hard
disk space; 640K RAM, 80286 (80386) processor and
a DOS version of 3.30 or higher.
Database system that is designed to aid in
producing both the EPA Manifest and Drum
Labels. Includes DOT information for
verification.
Online information on hazardous substances.
Includes: response information and medical
effects data with unique search
capabilities. Cost is $120 per hour (1983).
Search and retrieval system designed to
direct the user to documented first-spill
incidents. No charge.
Prepares shipper's declaration and
identifies marking, labeling, and other
packaging requirements.
Stores hazmat information; generates
documents and reports; MSDS document
management.
"Indicates an apparent high degree of usefulness for SARA Title HI (i.e., includes two or more principal areas of use identified on page 12).
All systems require an IBM compatible microcomputer unless otherwise specified.
-------
PAGE 1-14
TABLE I (continued)
PRELIMINARY LIST OF COMPUTER APPLICATIONS AND SYSTEMS OF POTENTIAL USE UNDER SARA TITLE III
September 1989
ACRONYM/ABBREVIATION SYSTEM NAME
VENDOR
ADDRESS/PHONE PURPOSE/DESCRIPTION/REOUIREMENTS
HAZM
HAZMIN
Hazardous Waste Manager
The Hazardous Material
Information Network
Z Micro Systems
Logical Technology, Inc.
HAZOX LABEL PROGRAM
HAZOX EMPLOYEE TRAINING
LEDGER
HAZ/TRAK
IIAZWASTE
HMIS
Hazardous Materials
HAZOX Corporation
HAZOX Corporation
HAWKWA Group, Inc.
HazMat Control Systems,
Inc.
Defense Logistics Agency
Information System
P.O. Box 6634
San Pedro, CA 90734
(213) 831-4888
Vicky Demoss
P.O. Box 3655
Peoria, IL 61614
(309) 677-3303
Kathleen Goddatd
P.O. Box 637
Chadds Ford, PA 19317
(21S) 388-2030
(800) 558-6942
Kathleen Goddard
P.O. Box 637
Chadds Ford, PA 19317
(215) 388-2030
(800) 558-6942
Russ Hannula
P.O. Box 321
Mundelcin, IL 60060
(312) 949-8488
Carolyn Husemoller
3409 Lakewood Blvd
Suite 2C
Long Beach, CA 90808
(213) 429-9055
Rhonda Herns
Rockville, MD
(301) 468-8858
Records and prints waste disposal manifests
on official forms and outputs reports by
waste category, transporter, and disposal
site. Also records MSDSs. Requires 2S6K
memory.
System manages hazardous materials: includes
storage, inventory, compliance, and
training. MSDS based emergency response
data storage and retrieval. Assists with
'Iter I/II reports. Extensive search
capabilities. Requires VAX. PC version
scheduled for release in early 1988.
Prepares labels for containers. User
may copy information from MSDSs or other
text files. May be used in conjunction
with TOXIC ALERT.
Employee recordkeeping system. Tracks
worker training, job location, and
job assignments, as well as employee courses
and qualifications. May be used in
conjunction with TOXIC ALERT.
Computerizes MSDSs in OSIIA-174 format. Also
tracks material use and storage. Requires
448K memory and 2 disk drives.
Hazardous waste data management and
reporting system. Prepares hazardous waste
manifests. Requires 10 Meg hard disk and
132 column printer.
DoD system that stores MSDS information,
quantity and manufacturer, and National
Stock numbers. On-line Database and
microfiche. Cost: $30 - $40 per hour.
For DoD facilities only.
"Indicates an apparent high degree of usefulness for SARA Title HI (i.e., includes two or more principal areas of use identified on page 12).
All systems require an IBM compatible microcomputer unless otherwise specified.
-------
PAGE 1-15
September 1989
TABLE I (continued)
PRELIMINARY LIST OF COMPUTER APPLICATIONS AND SYSTEMS OF POTENTIAL USE UNDER SARA TITLE III
ACRONYM/ABBREVIATION SYSTEM NAME
VENDOR
ADDRESS/PHONE PURPOSE/DESCRIPTION/REQUIREMENTS
HMMS
Hazardous Materials
Management System
Caelus
HWCS
HYCARB
IEMIS
Hazardous Waste
Computer System
INFO (EIIIS)
Integrated Emergency
Management Information
Emergency/Hazmat
Information System
National Safety Council
Software Systems
Corporation
Federal Emergency
Management Agency
Emergency Automation Inc.
Larry Williams
Caelus Inc.
1100 Paulsen Center
W. 421 Riverside
Spokane, WA 99201
(509) 624-8794
or
Craig Van Velzer
Wang Laboratories, Inc.
N1000 Argonne Rd
Suite 100
Spokane, WA 99212
(509) 922-2136
P.O. Box 11933
Chicago, 1L 60611
(800) 621-7619
(312) 527-4800
Donna Schmidt
P.O. Bo* 2606$
Austin, TX 78755-0065
(512) 451-8634
Dr. Bob Jaske
S00 C Street SW
Room 627
Washington, DC 20472
(202) 646-2865
Gary Hill
1401 Wilson Blvd.
Suite 720
Arlington, VA 22209
(703) 522-4550
Integrates both Wang supplied and Caelus
supplied software into a system for managing
data and reporting requirements. Includes:
aliases, trade and industry standard names
and IDs; components of mixtures and compounds;
plant sites, annual usage, and storage
locations; hazardous properties and medical
precautions; approved treatment or remedies;
MSDSs; references; protective equipment and
requirements; approved suppliers and/or
manufacturers; agencies; reporting forms. Can
run stand-alone on any Wang VS computer.
Tracks waste from collection to treatment. Database
of 2,600 common chemicals which provides the EPA
number for each chemical, DOT classification for
hazardous waste transport, and permit information.
Templates for all required forms, labels, and notices.
Computes the thermodynamic and transport
properties of 78 common petroleum and
chemical industry hydrocarbons.
FEMA's database system for emergency response
information for governments. For use in planning,
training, and eventually real-time operational
decision-making for all types of emergencies.
Includes plume dispersion modeling. A wide variety
of access options arc available.
An incident information management tool for
hazardous materials emergency res ponders
"Indicates an apparent high degree of usefulness for SARA Title III (i.e., includes two or more principal areas of use identified on page 12).
All systems require an IBM compatible microcomputer unless otherwise specified.
-------
PAGE 1-16
September 1989
TABLE I (continued)
PRELIMINARY LIST OF COMPUTER APPLICATIONS AND SYSTEMS OF POTENTIAL USE UNDER SARA TITLE III
ACRONYM/ABBREVIATION SYSTEM NAME
VENDOR
ADDRESS/PHONE PURPOSE/DESCRIPTION/REOUIREMENTS
INHEC1
Roy F. Weston, Inc.
INVENTORY MANAGKK
IRIS
Integrated Risk
Information System
OSHA-SOFT Corporation
DIALCOM, Inc.
ISCST
LABSYS
Industrial Source Complex
Short Term
Laboratory Selection
Expert System
Trinity Consultants, Inc.
Roy F. Weston, Inc.
MANGUARD
ManGuard Systems, Inc.
Judith Hushon
955 L'Enfant Plaza, SW
Washington, DC 20024
(202) 646-6800
Peter Bragdon
P.O. Box 668
Amherst, Nil 03031
(603) 672-7230
Mike McLaughlin
600 Maryland Ave, SW
Washington, DC 20024
(202) 4884)550
Shirley Lake
12801 N. Centra! Expwy
Suite 1200
Dallas, TX 75243
(214) 661-8100
Judith Hushon
955 L'Enfant Plaza SW
6th Floor
Washington, DC 20024
(202) 646-6800
Craig Ryiee
25972 Novi Road
Suite 203
Novi, MI 48050
(313) 349-3830
INIIEC1 is a front-end to the HEC-1 model
developed by Hydrologie Engineering Center.
Assists in modeling a watershed and creating the
inputs to HEC-1 for hydrologie simulations.
INHECJ contains information about the
requirements and limitations of HEC-1 and lainfall-
runoff processes.
Tracks hazardous materials in workplace and
inventory for purchasing. Includes
manufacturer listings.
On-line database containing chemical files that
present summaries of hazard and dose-response
assessments for carcinogenic and/or noncarcinogenic
effects and contain information on Office of
Drinking Water Health Advisories, EPA regulations
and guidelines (e.g., Clean Air Act regulations and
Drinking Water Criteria) acute toxicity, and
physical/chemical properties.
Software for dispersion modeling; uses Gaussian
plume model. The system calculates concentration
or deposition values for inputed time periods. May
be used in conjunction with "Breeze Air."
Assists in identifying appropriate analytical
laboratories to evaluate environmental samples (e.g.,
soil, water, sludge, waste, air) for characterizing
hazards at a site. The system factors type of
sample, suspected pollutants, user's needs for on-site
evaluation, and laboratories* locations, capabilities,
and qualifications.
Twelve Modules addressing environmental
activities monitored by EPA, RCRA, OSHA,
CERCLA, and DOT regulations. Includes SARA
reporting module containing MSDS and
production information, SARA reporting
assistance, tracking capabilities.
"Indicates an apparent high degree of usefulness for SARA Title III (fee., includes two or more principal areas of use identified on page 12).
All systems require an IBM compatible microcomputer unless otherwise specified.
-------
PAGE 1-17
September 1989
TABLE I (continued)
PRELIMINARY LIST OF COMPUTER APPLICATIONS ANT) SYSTEMS OF POTENTIAL USE UNDER SARA TITLE III
ACRONYM /ABBREVIATION SYSTEM NAME
VENDOR
ADDRESS/PHONE PURPOSE/DESCRIPTION/REQUIREMENTS
MEDLARS
MESOCHEM
MESOREM Jr.
Medical Literature Analysis
Retrieval System
Chemical Atmospheric and
Hazard Assessment System
National Library of
Medicine
Irnpell Corporation
Impel! Corporation
METROHEALTH
METROSOFT
micro CHRIS
I,amb & Associates, Inc.
Mctrosonics
The HazMat Software Co./
AIA Corporation
Carolyn Tillcy
MEDLARS
Management Section
8600 Rockville Pike
Bethesda, MD 20894
(301) 496 6193
Becky Cropper
300 Tristate Internal'!
Suite 400
Lincolnshire, II. 60069
(312) 940-2090
Becky Cropper
300 Tristate Internal'!
Suite 400
Lincolnshire, 1L 60069
(312) 940-2090
Tommy Roach
P.O. Box 638
Lumberton, NC 28359
(919) 739-3181
Rob Brauch
P.O. Box 23075
Rochester, NY 14692
(716) 334-7300
Rod Nenner
134 Middle Neck Rd
Suite 210
Great Neck, NY 11021
(516) 829-5858
(BOO) 284-6737
Collection of databases containing
toxicological research information and
literature citations.
Software for atmospheric dispersion and
chemical exposure assessment. A plume
dispersion model.
Atmospheric release analysis system that
includes back calculations of source
release rates from field readings, terrain
modeling, meteorological conditions modeling
of multipoint dose and deposition exposures.
Also provides ingestion exposure reports for
atmospheric effluent pathways.
Multi-user safety and health package.
Records data on personnel and MSDS
information. Assists with medical reports
and OS HA forms.
Industrial hygiene information record
system. Utilizes hand held monitoring
system to record exposure data on computer.
Coast Guard CHRIS system. Includes chemical
designations, observable characteristics,
health hazards, responses to discharges,
fire hazards, chemical reactivity, water
pollution, shipping information, hazard
assessment codes, hazard classifications,
and physical and chemical properties.
Requires 640K memory and lOMeg hard disk.
"Indicates an apparent high degree of usefulness for SARA Title HI (i.e., includes two or more principal areas of use identified on page 12).
All systems require an IBM compatible microcomputer unless otherwise specified.
-------
PAGE 1-18
September 1989
TABLE I (continued)
PRELIMINARY LIST OF COMPUTER APPLICATIONS AND SYSTEMS OF POTENTIAL USE UNDER SARA TITLE III
ACRONYM/ABBREVIATION SYSTEM NAME
VENDOR
ADDRESS/PHONE PURPOSE/DESCRIPTION/REOUIREMENTS
microOHM/TADS
The HazMat Software Co./
AIA Corporation
Rod Nenner
134 Middle Neck Rd
Suite 210
Great Neck, NY 11021
(516) 829-5858
(800) 284-6737
Microcomputer version of EPA's Oil and
Hazardous Materials Technical Assistance
Database. Contains emergency response,
physical and chemical properties, and
hazards of 1400 compounds. Requires 640K
memory and lOMeg hard disk.
MIDAS
Meteorological Information
and Dispersion Assessment
System
Pickard, Lowe and
Garrick, Inc.
Mark Abrams
1615 M Street, NW
Suite 730
Washington, DC 20036
(202) 659-1122
Calculates impact of gaseous releases
under routine or accident conditions.
MSDS ALERT
HAZOX Corporation
Kathleen Goddard
P.O. Box 637
Chadds Ford, PA 19317
(800) 558-6942
(215) 388-2030
MSDS database.
MSDS Engine Software
GENIUM Publishing
Corporation
1145 Catalyn St.
Schenectady, NY
12303-1836
(518) 377-8854
Collection of MSDSs. Has capability to
create additional MSDSs and search by name
and CAS#.
MSDS-MAN
MSDS-MAN
Spumifer American, Inc.
Pete Dyke
P.O. Box 3267
St. Augustine, FL 32085
(904) 824-0603
Data base manager for MSDSs.
MSDS MANAGER
OSHA-Soft Corporation
Peter Bragdon
P.O. Box 668
Amherst, NH 03031
(603) 672-7230
Software containing MSDS information in OSIIA
format. Stores and prints MSDSs; assists
with training of employees.
MSDS-PC
JJ. Keller & Associates,
Inc.
145 W. Wisconsin Ave.
P.O. Box 368
Neenah, WI 54957-0368
(800) 558-5011
User created chemical information database.
Includes trade name, manufacturer,
ingredients, CAS Number, and plant location.
Requires 256K memory.
"Indicates an apparent high degree of usefulness for SARA Title III (i.e., includes two or more principal areas of use identified on page 12).
All systems require an IBM compatible microcomputer unless otherwise specified.
-------
PAGE 1-19
TABLE I (continued)
PRELIMINARY LIST OF COMPUTER APPLICATIONS AND SYSTEMS OF POTENTIAL USE UNDER SARA TITLE III
September 1989
ACRONYM/ABBREVIATION SYSTEM NAME
VENDOR
ADDRESS/PI 1QNE PURPOSE/DESCRIPTION/RBOUIREMENTS
MSDSPLUS
MSDSFILF.
OASIS
Operator Assisted Sewer
Information System
OPERATOR 10
Robert EJ, Thomas
& Associates, Inc.
HazMat Control Systems,
Inc.
Public Works Software,
Inc.
Macola Incorporated
ORBIT
Pergamon
OSHA-SOFT CFR
OSHA-SOFT Corporation
Dr. Robert J. Thomas
Woodsboro, Md. 21798
(301) 695-5603
MSDS recording and tracking system. Used
to maintain employee and inventory records.
System also has ability to track location
and first and last date that a chemical was used or
stored at a facility.
Prepares, prints, and stores MSDSs.
reports. Requires lOMeg hard disk.
Creates
Carolyn Husemoller
3409 Lakewood Blvd
Suite 2C
Long Beach, CA 90808
(213) 429-9055
Jerry Cadwell
Harbor Plaza
P.O. Box 580
Port Hueneme, CA
93401
(805) 488-7324
Don Knaur
P.O. Bo* 485
Marion, OH 43301 0485 Process Evaluation for generating process
Database for management of sanitary and
storm wastewater collection systems.
Maintains field operations data including
safety history, engineering data, inspection
records, and work orders. Requires 640K
memory and hard disk.
Assists in the management of wastewater
treatment plants using four programs:
(614) 382-5999
(800) 468-0834
Orbit Action Desk
Infoline, Inc.
8000 Westpark Dr.
McLean, VA 22102
(703) 442-0900
Peter Bragdon
P.O. Box 668
Amherst, NH 03031
(603) 672-7230
equations; Inventory/Maintenance for work
order generation and printouts, preventive
maintenance, and inventory tracking;
Industrial Pollutant Monitoring for record-
keeping and report generation; and Process
Monitoring/Reporting for process reports and
other reports. Each requires 512K memory
and lOMeg hard disk.
Database of information from all areas of
science, technology, and medicine, as well
as business, current affairs, and
humanities, $30 - SIS) per computer connect
hour.
Text of 29 CFR(OSIiA) and 40 CFR(EPA)
regulations on disk. Requires 512K memory
and hard disk.
"Indicates an apparent high degree of usefulness for SARA Title III (i.e., inctudcs two or more principal areas of use identified on page 12).
All systems require an IBM compatible microcomputer unless otherwise specified.
-------
PAGE 1-20
September 1989
TABLE I (continued)
PRELIMINARY LIST OF COMPUTER APPLICATIONS AND SYSTEMS OH POTENTIAL USE UNDER SARA TITLE III
ACRONYM/ABBREVIATION SYSTEM NAME
VENDOR
ADDRESS/PHONE PURPOSE/DESCRIPTION/REQUIREMENTS
PART B OUTLINE
Weith Computer Products
A Services
PART B PERMITTING
Roger Weiter
802 Brittany
Suite 101
Bowling Green, OH
43402-1511
(419) 352-8659
Gerald Rich
17719 Brim Road
Bowling Green, OII 43402
(419) 352-7085
(after 5:30 p.m.)
Assists user with writing Part B
application. Cites regulations by number.
Permit application assistance for hazardous
waste facilities on diskettes.
PCH HAZARD
U.S. Construction
Engineering Research
Laboratory
Attn: Bernie Donahue
P.O. Box 4005
Champaign, IL
61820-1305
(217) 373-6733
Provides guidance on the repair and disposal
of transformers containing 50 ppm or more of
PCB's.
POSSEE
Plant Organizational Software
System for Emissions from
Equipment
Chemical Manufacturers
Association (CMA)
Deborah Stine
2501 M Street, NW
Washington, DC 20037
(202) 887-1176
Supports the organization, entry, and analysis of
plant data and field measurements of fugitive
emissions. A menu-driven system.
PRETRF,
Cochrane Associates, Inc.
, Jay J. Fink
236 Huntington Ave.
Boston, MA 02115
(617) 247-0444
Information management system for wastewater
treatment facilities. Assists with
monitoring compliance, tracking construction
projects, producing reports, and generating letters.
PREXREATMENT
Spica Systems
4921 Seminary Road
Suite 1502
Alexandria, VA 22311
(703) 671-5874
Series of programs for implementing EPA's
categorical pretreatment standards.
Contains data forms for identifying and
collecting information needed for
Applicability, production, special
conditions, and flow.
PSYCHRO
Software Systems
Corporation
Computes properties of air-water vapor
P.O. Box 202017 mixtures for HVAC, combustion, aerodynamic,
Austin, TX 78720 and meteorological applications. Any two
(512) 451-8634 independent properties may be inpuled by
"Indicates an apparent high degree of usefulness for SARA Title HI (i.e., includes two or more principal areas of use identified on page 12).
All systems require an IBM compatible microcomputer unless otherwise specified.
-------
PAGE 1-21
September 1989
TABLE 1 (continued)
PRELIMINARY LIST OF COMPUTER APPLICATIONS AND SYSTEMS OF POTENTIAL USE UNDER SARA TITLE III
ACRONYM ^ABBREVIATION SYSTEM NAME
VENDOR
ADDRESS/PHONE
PURPOSB/DESCRimON/REOUIREMENrS
PTPLU-2
Quantum Software
Trinity Consultants, Inc.
Quantum Software
Solutions, Inc.
Rainbo MSDS-PRO,
SARA, and SAFETY
Regulation Scanning System
Pro Am Safety
Data Rep. Inc.
RESREC
Disposal Alternatives Planning Roy F. Weston, Inc.
and Resource Recovery Systems
RODA
Records and Operations
Management
Metcalf & Eddy, Inc.
Shirley I.ake
12801 N. Central Expwy
Suite 1200
Dallas, TX 75080
(214) 661-8100
Laurie Breck
P.O. Box 640
Ann Aibor, MI
48107-0640
(313) 761-2175
Dispersion modeling software based upon
EPA's UNAMAP. System is upgraded version of
FFMAX; it is a screening model that can be
applied to single sources.
Zoltan Toth
P.O. Box 750
Gibsonia, PA 15044
(412) 443-0410
Robert McCardy
243 West Main St.
Kutztown, PA 19530
(215) 683-5098
Judith Hushon
955 L'Enfant Plaza, SW
Washington, DC 20024
(202) 646-6800
Series of compliance assistance modules
including: Worker Right to Know, Asbestos
Compliance Tracking, Community Right to
Know, Firefighter Right to Know, assistance
with report generation and Underground Tank
Inventory.
Database management system for MSDS
information. Modules include SARA, for
assistance in creating reports for Title
III, and SAFETY for accident and incident record-
keeping.
Hazardous materials transportation
regulations on disk. System displays
text of regulations by chemical name or
number. Also searches by keyword. Updates
to regulations are provided on a monthly
basis.
Assists in planning disposal systems for community
waste. The model accepts appropriate inputs
describing the community's situation and constraints,
performs cost analyses for various scenarios to
account for uncertainties in the input, and provides
the system with heuristic indicators which describe
the results. Interprets the results and provides
advice on planning scenarios to be used as guidelines
for making a study of appropriate alternative
scenarios.
Eric Burman
529 Main Street
Charlestown, MA 02129
(617) 241-8850
Data management system for wastewater
treatment operators.
"Indicates an apparent high degree of usefulness for SARA Title III (i.e., includes two or more principal areas of use identified on page 12).
All systems require an IBM compatible microcomputer unless otherwise specified.
<ป1. jaiMUI >vi|Uiiv. Ill ซป>ซ (.UllllKlllure imUUUJUjpULCl UIIIUM> UtllCIWKC *|>CUMCU,
-------
PAGE 1-22
TABLE 1 (continued)
PRELIMINARY LIST OF COMPUTER APPLICATIONS AND SYSTEMS OF POTENHAL USE UNDER SARA TITLE III
September 1989
ACRONYM/ABBREVIATION SYSTEM NAME
VENDOR
ADDRESS/PHONE PURPOSE/DESCRIPnQN/REQUIREMENrS
RTECS
SAFECHEM II
SAFER
SAM
SARA!
Registry of Toxic Effects
of Chemicals
Management System
System Approach for
Emergency Response
Laboratory Information
Management System
SARA TITLE 111
313 ADVISOR
National Library of Medicine,
Specialized Information
Services
SAFEWARE, INC.
SAFER Emergency Systems,
Inc.
Radian Corporation
OSHA-SOFT Corporation
E.I. I)u Pont de Nemours
& Company Inc.
Environmental Management
Services
Genne Gosloth
8600 Rockville Pike
Building 38A
Bethesda, MD 20894
(301) 496-1131
467? Old Ironsides Dr.
Santa Clara, CA 95054
(408) 727-2436
Darlene Davis
Dave Dillehay
756 Lakefield Road
Westlake Village, CA
91361
(818) 707-2777
Mike McAnally
P.O. Box 9948
8501 Mo-Pac Blvd
Austin, TX 78766
(512) 454-4797
On-line database containing records for more
than 50,000 potentially toxic chemicals.
Source for basic acute and chronic toxicity
information. Prime-time cost is about $5
per hour.
Hazardous chemical management system
implemented on a proprietary database
package.
Facility spill response, tracking of
releases, materials inventory, and training.
Laboratory tracking, scheduling, reporting,
and statistical analysis.
Peter Bragdon Generates inventory and Tier 1 and II
P.O. Box 668 reports required under SARA Title III.
Amherst, Nil 03031-0668 Monitors chemical inventories and locates
(603) 672-7230 hazardous chemicals in the workplace. Emergency
(800) 446-3427 Response version maintains inventories of all hazards
and chemicals in the area for emergency response
personnel.
Barley Mill Plaza
(P27-2125)
Wilmington, DE 19898
(800) 992-0560
Assists with completion of form R. Provides
list of synonyms and copy of regulations in
software. Maintains audit trail.
"Indicates an apparent high degree of usefulness for SARA Title III (i.e., includes two or more principal areas of use identified on page 12).
All systems require an IBM compatible microcomputer unless otherwise specified.
-------
PAGE 1-23
September 1989
TABLE I (continued)
PRELIMINARY LIST OF COMPUTER APPLICATIONS AND SYSTEMS OF POTENTIAL USE UNDER SARA TITLE II!
ACRONYM/ABBREVIATION SYSTEM NAME
VENDOR
ADDRESS/PHONE
PURPOSE/DESCRIPTION/REQUIREMENTS
SARATRAX
ITT Research Institute,
Maryland Technology Center
Dr, Quon Y. Kwan
Sr. Env. Engineer
4600 Forties Blvd
Lanham, MD 20706
(800) 458-1564
(301) 4S9-3711
Assists with determination of facility
reporting responsibilities under Sections
301-303, 304, and 311-3X2. Assists with
notification requirements and definitions
of responsibilities. Maintains lists of
chemicals, quantities, locations, and
properties to assist with the preparation of
Tier I and Tier II reports. Generates
Form R.
SENTRY
SEWER MAINTENANCE SYSTEM
SLUDGE MANAGER
SLUDGE REGULATOR
SOPHIE
Selection of Procedures
for Hazard Identification
and Evaluation
Besserman Corporation
O'Brien & Gere Engineers,
Inc.
Resource Conservation
Services, Inc.
Resource Conservation
Services, Inc.
Battelle
Wes Turner
1702 East Highland
Suite 120
Phoenix, AZ 85016
(602) 264-8000
Trish Anrig
1304 Buckley Road
Syracuse, NY 13221
(315) 451-4700
(315) 451-2060
42 Main Street
Yarmouth, ME 04096
(207) 846-3737
42 Main Street
Yarmouth, ME 04096
(207) 846-3737
Columbus Division
505 King Avenue
Columbus, OH
43201-2693
(614) 424-6424
Records industrial hygiene and health
information. Creates reports, tracks MSDS
information; MSDS information by synonym,
name, mixture name, and CAS #.
Management assistance for sewer line
maintenance and recordkeeping. Database
system that allows monitoring of specific
operations and activities. Requires 640K.
Recordkeeping and database management for
treatment plants and facilities that
produce useful sludge. Requires 312K
memory, 5Meg hard disk, and dBase II.
Designed for state regulatory agencies.
Tracks land spreading operations within the
state. Produces reports, mailing lists and
labels, permit expiration dates, and
generator/material descriptions. Requires
312K memory and 5Meg hard disk.
Assists users with selection of methods to
employ for identifying and evaluating
hazards in chemical and petrochemical
facilities.
"Indicates an apparent high degree of usefulness for SARA Title III (i.e., includes two or more principal areas of use identified on page 12).
All systems require an IBM compatible microcomputer unless otherwise specified.
-------
PAGE 1-24
September 1989
TABLE I (continued)
PRELIMINARY LIST OF COMPUTER APPLICATIONS AND SYSTEMS OF POTENTIAL USE UNDER SARA TITLE III
ACRONYM/ABBREVIATION SYSTEM NAME
VENDOR
ADDRESS/PHONE PURPOSE/DESCR1PTION/REOU1REMENTS
SPCC
Spill Prevention Control
and Countermeasure Data
Base System
U.S. EPA
SI'll.-COM
SUNHEALTH
SWIS
Systems/Services
Engineering
Solid Waste Information
System
Globe International, Inc.
Stewart-Todd Associates,
Inc.
Mathtech The Technical
Research and Consulting
Division of Mathematics,
Inc.
Systems/Services
Engineering
Ms. Jean H. Wright
Office of Emergency
and Remedial Response
WH548B
401 M Street, SW
Washington, DC 20460
(202) 245-30S7
P.O. Bo* 1062
Buffalo, NY 14206
(716) 824-8484
1016 W. 9th Ave.
King of Prussia, PA
19406
(215) 962-0166
Barrett J. Riordan
5111 Lcesburg Pike
Suite 702
Falls Church, VA 22041
(703) 284-7900
P.O. Box 32008
Dayton, OH 45432
(513) 429-2709
Database containing compliance/
noncompliance records of oil facility
discharges. Spill data include amount of
material spilled, rate, response, and
control measures.
Oil spill contingency planning tool intended
to improve notification of federal and state
agencies and improve response and reporting
capabilities.
Manages occupational health records, MSDSs,
chemical information, and employee records.
Aids with emergency release reports.
Inventory and record system designed for the
State of California Solid Waste Management
Board.
Wastewater treatment assistance. Software
includes: Data Handling System, Lab Bench
File, Lab Stock Inventory, Scheduled Work
System, Unscheduled Work System, Facility
Stock Inventory, Tool Record System,
Personnel Record System, Budget Control
System, Equipment Record System, and
Industrial Pretreatment File.
TECJET
Advanced Jet Dispersion Model Technica International
David A. Jones
1400 N. Harbor Blvd
Suite 800
Fullerton, CA 92635
(714) 447-9400
Jet dispersion model for PC.
Indicates an apparent high degree of usefulness for SARA Title III (i.e., includes two or more principal areas of use identified on page 12).
All systems require an IBM compatible microcomputer unless otherwise specified.
-------
PAGE 1-2S September 1989
TABLE I (continued)
PRELIMINARY LIST OF COMPUTER APPLICATIONS AND SYSTEMS OF POTENTIAL USE UNDER SARA TITLE III
ACRONYM/ABBREVIATION SYSTEM NAME
VENDOR
ADDRESS/PHONE PURPOSE/DESCRirnON/REOUIREMBNTS
TI-M
The Environmental Manager
Environmental Information
System
THERMOSIM Module 1:
EQUIL
TOXIC, PUFF, SPILLS.
IN PUFF, AND INPUFF 2.0
'TOXIC ALERT
TOXLINE (non-royalty
based)
TRACE II
Toxicology Information
Online
Toxic Release Analysis of
Chemical Emissions
TRAINING MANAGER
Gulf Publishing Company,
Book Division
Bowman Environmental
Engineering
HAZOX Corporation
National Library of
Medicine
Safer Emergency Systems,
Inc.
OSHA-SOI'T Corporation
Sherida Mock
1101 Capital of Texas
Highway South
Building 8, Suite 212
Austin, IX 78746
(S12) 328-5211
Melissa Beck
P.O. Box 2608
Houston, TX 77252
(713) 520-4444
P.O. Bo* 29072
Dallas, TX 75229
(214) 241-1895
Daniel Fullerton
P.O. Box 637
Chadds Ford, PA 19317
(215) 358-4990
(800) 558-6942
8600 Rockvillc Pike
Bethesda, MD 20894
(301) 496-1131
Darlene Davis
Dave Dillehay
756 Lakefield Road
Westlake Village, CA
91361
(818) 707-2777
P.O. Box 894
Concord, NH 03301
(603) 228-3610
Tracks regulatory requirements; produces reports.
Modules available on Environmental Audits, Permit
Tracking, Groundwater Monitoring, Wastewater
Monitoring, Air Emissions, Task Management, Waste
Manifesting, Chemical Inventory, MSDS
Management, Incident Reporting, and Operational
Journals.
Database of thermodynamic properties of 200
hydrocarbons, 9 non-hydrocarbon gases, carbon,
and sulfur. Requires 512K memory and 2 disk
drives.
In ascending order of data complexity, these systems
address toxic gas releases using models designed for
each type of release, based on emission rate, facility
characteristics and weather data.
Incident management tool with some
emergency planning capability. Modules
for MSDS, incident documentation,
inventory, and Her I/II report generation.
On-line bibliographic database covering the
pharmacological, physiological, and toxicological
effects of drugs and chemicals. Information is taken
from eleven secondary sources.
Models toxic ps and flammable vapor cloud
dispersion. Intended for risk assessment
and planning purposes, rather than real-
time emergencies.
Records employee training information, and
allows classification and tracking of
products and employees by category.
"Indicates an apparent high degree of usefulness for SARA Title III (i.e., includes two or more principal areas of use identified on page 12).
All systems require an IBM compatible microcomputer unless otherwise specified.
-------
PAGE 1-26
September 1989
TABLE 1 (continued)
PRELIMINARY LIST OF COMPl/IBR APPLICATIONS AND SYSTEMS OF POTENTIAL USR UNDER SARA TITLE III
ACRONYM/ABBREVIATION SYSTEM NAME
VENDOR
ADDRESS/PHONE PURPOSE/DESCR1PTION/REOUIREMENTS
TREDAT
TREMAIN
TREPORT
TRI Database
TSAR
Toxic Chemical
Release Inventory
Technology Selector of
Alternative Remedies
Cochrane Associates, Inc.
Cochrane Associates, Inc.
Cochrane Associates, Inc.
National Library of Medicine,
Specialized Information
Services
Roy F. Weston, Inc.
TSDSYS
Treatmenl, Storage and Disposal Roy E Weston, Inc.
Facilities Expert System
Jay J. Fink
236 Huntington Ave.
Boston, MA 02115
(617) 247-0448
Jay J. Fink
236 Huntington Ave,
Boston, MA 02115
(617) 247-0448
lay J. Fink
236 Huntington Ave.
Boston, MA 02115
(617) 217-0444
8600 Rockville Pike
Rethesda, MD 20894
(301) 496-653!
Judith Hushon
955 L'Enfant Plaza, SW
6th Floor
Washington, DC 20024
(202) 646-6800
Judith Hushon
955 L'Enfant Plaza SW
6th Floor
Washington, DC 20024
(202) 646-6800
Data handling and process control software program
for wastewater treatment plants. Requires Apple II.
Equipment and inventory management software
system for wastewater treatment plants. Requires
Apple II.
Data handling and reporting system for wastewater
treatment facilities. Assists with daily calculation of
data and generation of reports.
Contains information on industrial location, storage,
and release to air, water, and land of SARA Section
313 chemicals. Data is divided into the following
categories: facility identification, substance
identification, environmental release of chemical,
waste treatment, and off-site waste transfer.
Assists in selecting appropriate remedial technologies
at waste sites. Using available quantitative and/or
qualitative information the system selects potential
general response actions and eliminates some specific
technologies from further consideration; identifies
additional data required to decide among the
remaining engineering alternatives. The system can
be delivered on Compaq-386 or requires PC HOST
for the PC/AT.
Database containing information on over 400
contractors and the treatment, storage and disposal
methods they offer. Treatment is broken into on-
site and off-site and then by the following
categories: biological, chemical, physical, and
thermal treatment. Menu driven. Available through
cross talk for EPA Regional offices.
"Indicates an apparent high degree of usefulness for SARA Title III (i.e., includes two or more principal areas of use identified on page 12).
All systems require an IBM compatible microcomputer unless otherwise specified.
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PAGE 1-2?
September 1989
TABLE I (continued)
PRELIMINARY I.IST OF COMPUTER APPLICATIONS AND SYSTEMS OF POTENTIAL USE UNDER SARA TTTI.E III
ACRONYM/ABBREVIATION SYSTEM NAME
VENDOR
ADDRESS/PHONE PURPOSE/DESCRIPTION/REQUIREMENTS
UMT
The UNIFORM MANIFEST HAZOX Corporation
TRACKER
VAX DEChealth
VENTDATA
VUI.ZONE.WK1
WASTETRAX
WASTEWATER DATA MANAGEMENT
SYSTEM
water cost
Vulnerability Zone Worksheet
Digital
Hatch Associates Ltd.
New York State Emergency
Management Office
Engineering-Science
WDMS Computer Services
CWC-HDR Inc.
Daniel Fultcrton
P.O. Bo* 637
Chadds Foid, PA 19317
(800) 558-6942
146 Main Street
Maynard, MA 017S4
(617) 897-5111
21 St. Clair Ave. East
Toronto, Ontario,
Canada M4T 1L9
(416) 962-6350
Ed Lipps
Public Security Bldg
State Campus
Albany, NY 12226-5000
(518) 457-9959
Maintains information about hazardous waste
generators, transporters, disposal facilities,
materials shipped, and how they have been shipped.
Assists with Uniform Hazardous Waste Manifest
document required by RCRA. Generates records
and letters. Requires 200K memory plus IK
memory for each record and a printer that can
penetrate a six-part form.
Employee and environmental health data records
system. Maintains medical exposure data of
employees.
Recordkeeping and analytical program for use in
monitoring and maintenance of exhaust ventilation
systems. Requires Apple II.
Calculates mileage of vulnerability zone for
Extremely Hazardous Substances, giving a radial
value to use on a map. Chemicals may he searched
by CAS number; with each search, the system
verifies the chemical name.
For water and wastewater treatment plants.
57 Executive Park S, NE Information management for groundwater
Suite 590
Atlanta, GA 30329
(404) 325-0770
P.O. Box 27561
Tulsa, OK 74149
(918) 241-5755
300 Admiral Way
Suite 204
Edmonds, WA 98020
(206) 774-1947
monitoring, hazardous waste management, and
air quality monitoring. Statistical
capabilities.
Database that allows storage, retrieval, analysis,
and reporting for industrial pretreatment programs.
Requires 512K memory.
Water and wastewater cost estimation software
program. Contains extensive cost data.
"Indicates an apparent high degree of usefulness for SARA Title III (i.e., includes two or more principal areas of use identified on page 12)
AH systems require an IBM compatible microcomputer unless otherwise specified.
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PAGE 1-28
September 1989
TABLE I (continued)
PRELIMINARY LIST OF COMPUTER APPLICATIONS AND SYSTEMS OF POTENTIAL USE UNDER SARA TITLE III
ACRONYM/ABBREVIATION SYSTEM NAME
VENDOR
ADDRESS/PI IONE PURPOSE/DESCRIPTION/REOUIREMBNTS
WATER MASTER
WDC MANIFESTING SYSTEM
Waid and Associates
Waste Documentation
and Control, Inc.
8000 Centre Park Dr.
Suite 270
Austin, TX 78754
(512) 835-6112
P.O. Box 7363
Beaumont, TX 77706
(409) 839-4495
Animated training aid and simulation program for
water and wastewater treatment plant operators.
Produces internal control documentation and
govcrnmcntally required reports. Manifest printing
from files containing information on approved
transporters and disposers, waste materials, and
historical data.
WIIA2AN
World Bank Hazards Analysis Technica International
David A. Jones
1440 N. Harbor Blvd.
Suite 800
Fullerton, CA 92635
(714) 447-9400
Modeling of chemical dispersion and spill behavior.
Database for 30 hazardous substances. 13
mathematical models that predict effects of release
of flammable or toxic chemicals. Hard disk
required.
References
Marsick, Daniel I., Ph.D., "Resources for Right-to-Know Compliance," presented to American Chemical Society, Division of Chemical Health and Safety,
October 6, 1987.
Pollution Engineering, January 1988, "Environmental Software Review - 1988," by Gerald Rich.
Pollution Engineering, January 1987, "Environmental Software Review - 1987," by Nicholas P. Cheremisinoff, Ph.D.
Pollution Engineering, January 1986, *1986 Environmental Software Review," by Jack Blown.
Pollution Engineering, January 1985, "Environmental Software Review,' by Richard Young, Editor.
Fire Command, December 1987, "Cellular Phone Access to Chemical Databases," by Keith T. Linderman.
"Indicates an apparent high degree ot usefulness for SARA Title III (i.e., includes two or more principal areas of use identified on page 12).
All systems require an IBM compatible microcomputer unless otherwise specified.
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CHEMICAL SAFETY AUDIT PROGRAM WORKSHOP
GROUP EXERCISE
CHEMICAL SAFETY AUDIT REPORT
WORKSHEET
1.0 Introduction (Includes an introduction to both the chemical safety audit program AND the
facility audit.)
1.1 Chemical Safety Audit Program:
1.2 Facility X - Pacific Town, Washington, Audit:
11/95
1
Audit Report Worksheet
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2.0 Summary of Findings/Conclusions (Includes a BRIEF description of the major findings
and conclusions of the audit.)
11/95
2
Audit Report Worksheet
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3.0 Background (Includes general facility and audit information, purpose of the audit and the
facility selection process, and audit methodology.)
3.1 General Facility and Audit Information
U/95
3
Audit Report Worksheet
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3.2 Purpose of the Audit and Facility Selection Process
11/95 4 Audit Report Worksheet
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3.3 Audit Methodology
11/95 5 Audit Report Worksheet
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4.0 Facility Background Information (Includes information about the location, size, and
general layout of the facility. Also includes information about sensitive populations in the
area and a brief description of climatic and topological conditions.)
11/95
6
Audit Report Worksheet
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5.0 Chemical Hazards (Includes all chemical hazards that are covered in the scope of the audit,
MAY include material safety data sheets.)
11/95
1
Audit Report Worksheet
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5.0 Chemical Hazards (continued)
11/95 8 Audit Report Worksheet
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6.0 Process Information (Includes storage information, a process description, and process
hazards.)
6.1 Storage Information
11/95
9
Audit Report Worksheet
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6.2 Process Description
11/95 10 Audit Report Worksheet
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6.3 Process Hazards
11/95 11 Audit Report Worksheet
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7.0 Chemical Accident Prevention (Includes management activities, process operation and
maintenance, hazard evaluation and modeling, release prevention systems, and release
mitigation systems.)
7.1 Management Activities
11/95
12
Audit Report Worksheet
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7.1 Management Activities (continued)
11/95 13 Audit Report Worksheet
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7.2 Process Operation and Maintenance
11/95 14 Audit Report Worksheet
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7.2 Process Operation and Maintenance (continued)
11/95 15 Audit Report Worksheet
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7.3 Hazard Evaluation and Modeling
11/95 16 Audit Report Worksheet
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7.4 Release Prevention Systems
11/95 17 Audit Report Worksheet
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7.5 Release Mitigation Systems
11/95 18 Audit Report Worksheet
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8.0 Accidental Release/Incident Investigation
11/95 19 Audit Report Worksheet
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9.0 Facility Emergency Preparedness and Planning Activities
11/95 20 Audit Report Worksheet
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10.0 Community and Facility Emergency Response Planning Activities
11/95 21 Audit Report "Worksheet
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11.0 Public Alert and Notification Procedures
11/95 22 Audit Report Worksheet
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12.0 Conclusions
11/95 23 Audit Report Worksheet
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12.0 Conclusions (continued)
11/95 24 Audit Report Worksheet
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13.0 Recommendations
11/95 25 Audit Report Worksheet
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13,0 Recommendations (continued)
11/95 26 Report Worksheet
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CHEMICAL SAFETY AUDIT
CAPE CORAL REVERSE OSMOSIS
WATER TREATMENT FACILITY
CAPE CORAL, LEE COUNTY, FLORIDA
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
JUNE 1991
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REPORT DISCLAIMER
The contents of this report reflect information concerning the City of
Cape Coral Reverse Osmosis Water Treatment Facility in Cape Coral,
Lee County, Florida obtained during a U.S. Environmental Agency
Chemical Safety Audit and from records provided by the Reverse
Osmosis Water Treatment facility. The audit was conducted on
February 20-21, 1991, and the observations presented in this report
provide a snapshot of conditions existing at the facility during the audit
time frame. They do not represent planned or anticipated changes
proposed or on-going at the facility. The recommendations and other
report observations contained in this report are not mandatory actions
that the facility must implement. In addition, EPA makes no
assurances that if implemented, the recommendations and other
report observations contained in this report will prevent future
chemical accidents, equipment failures, unsafe management practices,
or provide protection from a future enforcement action under any
applicable law or regulation.
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TABLE OF CONTENTS
Page
1.0 INTRODUCTION 1
1.1 Chemical Safety Audit Program 1
1.2 City of Cape Coral Reverse Osmosis Water Treatment Facility,
Cape Coral, Lee County, Florida 3
2.0 SUMMARY OF FIN DINGS/CONCLUSIONS 3
3.0 BACKGROUND 4
3.1 General Facility and Audit Information 4
3.2 Purpose of the Audit and Facility Selection Process 4
3.3 Audit Methodology 5
4.0 FACILITY BACKGROUND INFORMATION 5
4.1 Facility Profile 5
4.2 Site Topography 5
4.3 Special/Sensitive Populations and Environments 5
5,0 CHEMICAL HAZARDS 6
5.1 Overview of Hazards for Chemicals Being Audited 6
5.2 Facility Management of Chemical Hazard Data 7
6.0 PROCESS INFORMATION FOR HAZARDOUS CHEMICALS 8
6.1 Storage and Handling 8
6.1.1 Storage Systems 8
6.1.2 Shipping and Receiving 9
6.2 Process Description 10
6.2.1 Reverse Osmosis Treatment 10
6.2.2 Overview of Chlorination Process 12
6.2.3 Details of the Chlorination Process 12
6.2.4 Chlorine Release Detection 14
7.0 CHEMICAL ACCIDENT PREVENTION 16
7.1 Management Activities 16
7.2 Process Operation and Maintenance 16
7.3 Plant Security 17
' 8.0 ACCIDENT RELEASE INCIDENT INVESTIGATION 17
8.1 History of Accident Releases/Incidents 17
8.2 Hazard Evaluation and Modeling 17
8.2.1 Existing Modeling Programs 17
8.2.2 Modeling/Uses of Modeling 17
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9.0 FACILITY EMERGENCY PREPAREDNESS AND PLANNING
ACTIVITIES
10.0 COMMUNITY AND FACILITY EMERGENCY RESPONSE
PLANNING ACTIVITIES
11.0 PUBLIC ALERT AND NOTIFICATION PROCEDURES
12.0 CONCLUSIONS
13.0 RECOMMENDATIONS
APPENDIX A - MAPS & SKETCHES
APPENDIX B - AUDIT TEAM MEMBERS
APPENDIX C - WASTE PROFILE SHEET
APPENDIX D - FLOWSHEET OF FACILITY PROCESS
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1.0 INTRODUCTION
1.1 Chemical Safety Audit Program
The Chemical Safety Audit (CSA) program has evolved from the efforts of the U.S.
Environmental Protection Agency (EPA) under the Chemical Accident Prevention
(CAP) program. The primary objectives of the CAP program are to identify the
causes of accidental releases of hazardous substances and the means to prevent such
releases from occurring, to promote industry initiatives in these areas, and to share
activities with the community.
The Chemical Safety Audit program is part of this broad initiative and has been
designed to accomplish the following chemical accident prevention goals:
o Heighten awareness of the need for chemical safety among chemical
producers, distributors, and users as well as in communities where
chemicals are located;
o Visit facilities handling hazardous substances to learn and understand
problematic and successful practices and technologies for preventing and
mitigating releases;
o Build cooperation among authorized parties by coordinating joint release
investigations where appropriate;
o Establish a national database for the assembly and distribution of chemical
safety information obtained from facility investigations from other sources.
The audit consists of interviews with facility personnel and on-site review of
various aspects of facility operations related to the prevention of accidental chemical
releases. Comprehensive Environmental Response, Compensation, & Liability Act
(CERCLA) Sections 104(b) and 104(e), as amended by Superfund Amendments &
Reauthorization Act (SARA), provide authorities for entering a facility and
accessing information. Specific topics addressed in the audit include:
o Process characteristics;
o Hazard evaluation and release detection techniques;
o Training of operators and emergency response personnel;
o Management structure (corporate and facility);
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o Preventative maintenance and inspection programs; and
o Community notification mechanisms and techniques.
EPA's June 1988 report to Congress under SARA Title III, Section 305(b) pointed out
many issues and made a number of recommendations on the course of prevention
and preparedness activities by EPA. First, the overall risk awareness of chemical
operations and distributors needs to be raised. Second, the study indicated the need
for new technologies in key areas such a process area monitoring devices, back-up
detectors, mitigation devices, and practices to identify disabled equipment of these
sorts. Third, the report suggested a great degree of caution in using real-time plume
and dispersion models for potential releases. In addition, it was indicated that
employee familiarity with methods of hazard evaluation was limited, which
suggests ineffective and/or improper techniques are being used. Finally,
examination of management practices revealed a failure to place sufficient emphasis
on issues such as standard operating procedures, employee training, preventative
maintenances, post accident investigation, and a general lack of commitment to
safety. Many of the key concerns of the CAP program arise from these
recommendations and findings. Therefore, EPA is working closely with other
federal agencies, states, industry, professional organizations, environmental groups,
and academia to increase awareness of chemical hazards and emergency
preparedness. This joint effort will serve to share information on prevention
technology and practices, and create approaches to increase the state of practice in
chemical safety.
The purpose of the chemical safety audit is to:
o Assess chemical emergency prevention and mitigation systems and
procedures in applicable facilities.
o Conduct a government file review to determine the status of compliance
with local, state, and federal environmental programs and regulations.
o Determine the need for independent media and organization inspections.
o Determine the potential for and consequences of off-site chemical releases.
o Recommend measures to correct safety hazards and increase chemical
emergency preparedness.
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The chemical safety audit serves to investigate the causes of releases at facilities and
the equipment procedures, training, and management practices necessary to
prevent or mitigate accidental hazardous chemical releases. The audits are intended
to enhance chemical safety practices at facilities by providing recommendations to
management and to supplement information acquired through other data gathering
programs. The collected information will be evaluated by EPA and its important
features will be transferred via trade associations and other networks to interested
parties to enhance chemical emergency preparedness and safety.
1.2 City of Cape Coral Reverse Osmosis Water Treatment Facility, Cape Coral,
Lee County. Florida,
This report contains observations, conclusions, and recommendations from an
audit conducted by a team of regional representatives from the United States
Environmental Protection Agency (EPA) and the American Association of Retired
Persons (AARP) at the City of Cape Coral Reverse Osmosis Water Treatment Facility
in Cape Coral, Lee County, Florida, on February 20-21,1991. EPA selected the facility
for an audit because of an accidental release of chlorine gas which occurred at the
plant in February, 1989, resulting in the death of an employee. This report identifies
and characterizes the strengths of specific chemical process safety management
program areas to allow the elements that are particularly effective to be recognized.
Copies of this report have been provided to the facility's corporate management so
that weak and strong program areas may be recognized.
2.0 SUMMARY OF FINDINGS/CONCLUSIONS
Based upon a limited review of the chemical process safety management practices
related to the Reverse Osmosis Water Treatment Method, the audit team has
reached the following conclusions:
o The written emergency plan for the Reverse Osmosis Facility was
incomplete.
o There is no single person on-site in charge of the facility for emergency
purposes; however, on the second and third shifts, the superintendent or
lead operator is on 24-hour call.
o The recent changes to the chlorine distribution system have minimized
the potential for chlorine releases at the Reverse Osmosis Plant.
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o The general housekeeping of the plant is remarkably immaculate which
promotes process safety.
3.0 BACKGROUND
3.1 General Facility and Audit Information
The city of Cape Coral owns and operates the Reverse Osmosis Water Treatment
Plant. The facility address is:
Cape Coral Reverse Osmosis Plant
3300 S.W. 20th Avenue
Cape Coral, FL 33914
The Reverse Osmosis Water Treatment Plant is a very unique plant in the water
treatment industry. The facility treats raw water from an on-site well field to meet
drinking water specifications. The wells are located in the lower part of the
Hawthorn aquifer. The water from this aquifer can be classified as brackish water
due to the high chloride concentration. Treatment consists of filtering, pH
adjustment, and flowing through semipermeable membranes to remove chlorides.
The final treatment step consists of chlorine addition for disinfection. The current
treatment capacity of the plant is fourteen (14) million gallons per day (MGD). The
company has seventeen (17) full-time employees. Due to its Standard Industrial
Category (SIC) code, the plant is exempt from the Section 313 requirements of SARA
Title HI. However, the remaining sections of SARA Title HI do apply. The audit
was conducted on February 20-21,1991, by a team of Regional representatives from
the United States Environmental Protection Agency (EPA). Three members of the
American Association of Retired Persons (AARP) and a Technical Assistant Team
(TAT) member under contract to EPA assisted in the audit. Appendix A provides
the names of the team members and their affiliations.
3.2 Purpose of the Audit and Facility Selection Process
The purpose of the audit was to examine the facility's chemical process safety
management practices associated with the treatment of brackish water. The facility
was selected for an audit because of an accidental release of chlorine gas which
occurred at the plant in February, 1989. The release caused one fatality and two
people were hospitalized-one employee and one emergency responder.
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3.3 Audit Methodology
The audit focused on the chemical treatment used to meet drinking water
specifications. The audit addressed chemical hazards, accident prevention, process
operation and maintenance, and hazard evaluation and modeling. The audit also
addressed accidental release incident investigation, facility emergency preparedness
and planning, and community and facility emergency response planning activities.
4.0 FACILITY BACKGROUND INFORMATION
4.1 Facility Profile
The Cape Coral Reverse Osmosis Plant began operation in 1977. The plant was built
to provide potable water to Cape Coral residents to conserve the water of the upper
Hawthorne aquifer. The plant was designed to treat brackish water drawn from the
lower portion of the same aquifer which suffered from saltwater intrusion.
The initial production capacity was three (3) million gallons per day (MGD). The
plant was expanded in 1980 and 1984. The current capacity of the Reverse Osmosis
Plant is fourteen (14) MGD.
The plant operates as two separate water producing units under the same roof. (See
Appendix D.) One unit is referred to as the Hydranautics Plant. This refers to the
supplier of the semipermeable membrane utilized in the treatment process. The
other water producing unit is the Dow Plant. The Dow membranes in this
treatment unit are quite different from the Hydranautics unit. However, the
chemical treatment requirements are essentially the same for both plants.
4.2 Site Topography
Cape Coral is approximately 106 square miles in size and located on the southern
Gulf Coast of Florida. It is nearly surrounded by water and laced with a one
hundred (100) mile network of navigable saltwater canals plus three hundred (300)
miles of fresh water canals. (See topographic map on following page.)
4.3 Special/Sensitive Populations and Environments
The Reverse Osmosis Plant supplies potable water for drinking and irrigation to
approximately fifty percent (50%) of the 76,000 residents in Cape Coral concentrating
mainly on the more densely populated areas of the city. The facility is located in an
area with the potential for substantial residential development. Projected growth
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estimates are for the population to reach 375,000 residents in the next century, more
than six times the population today. Two schools are located within a one-mile
radius of the plant. The proximity of these schools necessitates implementation of
reliable chemical process safety schemes.
5.0 CHEMICAL HAZARDS
This section of the report will give a brief description of the risks associated with the
chemicals most frequently used in the pre-treatment and treatment of the feedwater
during reverse osmosis. More in-depth information on chemical properties and
hazards may be found on the material safety data sheets (MSDSs) in the appropriate
Appendix. Flocon 100, an anti-scalant used in the initial pre-treatment process,
chlorine (Cl2(g)), sulfuric acid (H2S04), and sodium hydroxide (NaOH), commonly
referred to as caustic soda, will be discussed in this section. The MSDSs are a part of
the plant safety manual which is available to all employees.
5.1 Overview of Hazards for Chemicals Being Audited
Flocon 100, a scale inhibitor used in the pre-treatment of the raw water, serves to
limit the amount of algae or bacteria that can multiply in the process. Flocon 100
enables the bacteria to form a protective film on the surface of the membranes and
prolongs its life.
Sulfuric acid, (H2SO4), is used to lower the pH of the raw water. Raw water enters
the system at a pH of 7.7. Injection of the acid lowers the pH to 6.2, pre verting
precipitation of dissolved solids.
The accidental release of chlorine has the greatest potential of producing a
substantial risk to the surrounding population and personnel within the plant area.
On February 11,1989, there was a release of chlorine resulting in the death of one
worker and injuring two others. There is a minimum of four (4) tons of liquid
chlorine on-site at any one time stored in one ton containers. At the time of the
audit, nine (9) containers were on site. Each container has six (6) fusible plugs
installed on each end set at 120 degrees apart. These plugs are designed to melt from
158ฐF to 165ฐF. If liquid chlorine is released from a container, it will rapidly
vaporize. Chlorine has a vapor density of 2.5 (air = 1.0) so the vapors will tend to
remain at floor level. Chlorine is an acutely toxic substance with a threshold limit
value (TLV) of 1 ppm. Inhalation of chlorine can cause the following symptoms:
6
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3-6 ppm: irritation to the rtose and mucous membrane of the upper
respiratory tract, followed by headache and coughing.
10 ppm: can cause severe irritation of the respiratory tract with 15-20 ppm
causing an intense cough. Other symptoms can include nausea,
vomiting, dizziness, shortness of breath, and chest pains.
Pulmonary edema and pneumonia can develop and may occur
hours after exposure. Prolonged exposure to concentrations above
25 ppm can cause unconsciousness and death.
Liquid contact can cause local irritation and burns to the skin and eyes.
NOTE: Above toxicity data is extracted from the material data sheet issued by
the Chlorine Institute, Inc., Washington, DC.
Chlorine gas, (CIj), is injected into the system via a vacuum to treat both reject
water and product water. The reject (concentrate) water, which is referred to as
brine, is highly concentrated with impurities and will be discharged to the
environment after treatment; chlorine is used in combination with oxygen to
remove hydrogen sulfide (H2S) and raise dissolved oxygen to lessen the
environmental effect.
5.2 Facility Management of Chemical Hazard Data
The management of the Reverse Osmosis facility recognizes the potential hazard a
chlorine release would present to both employees and the surrounding community.
The Reverse Osmosis Water Plant management stated a seminar on chlorine
handling is held for employees every six months. A mandatory workshop on the
application of a chlorine tank repair kit type B is presented by the supplier on an
annual basis. All employees must attend monthly safety meetings which include
discussions on various safety topics, such as chemical hazards, employee safety
precautions, etc. Emergency response requirements are addressed in another
section.
MSDSs for all chemicals used on site are readily available to all employees for
review. Class A personal protection must be used in the event of a release.
Respirators must be readily available in areas where chlorine is used.
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6.0 PROCESS INFORMATION FOR HAZARDOUS CHEMICALS
The City of Cape Coral Reverse Osmosis Water Treatment Facility is a state-of-the-
art facility. Expounding upon already well-documented technology, the audit team
will review the facility's use of chlorine injection, Flocon 100, sodium hydroxide,
and sulfuric acid.
6.1 Storage and Handling
6.1.1 Storage Systems
Flocon 100 [polyacrylic acid (35%) in water], a scale inhibitor, is not a CERCLA or an
extremely hazardous substance. The Hydranautics Plant stores the material in a
twelve hundred (1200) gallon above ground storage tank which is labeled
appropriately as Flocon. It is then transferred to an eighty (80) gallon day tank. For
the Dow plant, the material is stored in the Flocon storage room in the fifty-five (55)
gallon drums in which it is shipped. The material is then transferred to a two
hundred and twenty-five (225) gallon day tank for use.
Two outside bulk storage tanks are used to store the H2SO4 and NaOH for each train
(Dow and Hydranautics) of the Reverse Osmosis Plant. The older Dow section of
the plant has a fifteen thousand (15,000) gallon, lined H2SO4 storage tank and a six
thousand (6,000) gallon lined NaOH storage tank. These chemicals are pumped into
the day tanks located in separate chemical rooms inside the facility. The H2SO4 day
tank has a capacity of six hundred and ten gallons (610) whereas the NaOH tank has
an approximate capacity of two hundred (200) gallons.
There are several safety factors incorporated in the NaOH and H2SO4 handling
systems for the Dow section. The bulk storage tanks for each are located next to each
other on the facility grounds. Each has its own diking system. The Reverse Osmosis
personnel indicated the diked areas will each contain one and one-half times the
full tank volume. Each tank has its own unique fitting to minimize the chance of
cross-loading from the tank truck to the incorrect tank. The day tanks for the H2SO4
and NaOH are located in separate rooms. The pumps for these tanks are controlled
manually through palm switches. The operator must continually press the switch
while observing the tank sight glass to fill each tank. If he releases the switch, the
pump automatically shuts off. This helps to reduce the possibility of tank overflow.
There is no diking in these rooms. In the event of a spill, each room has its own
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individual drain system which allows the chemical to flow to an area where it can
be neutralized.
In 1984, the Reverse Osmosis Plant was expanded. The Hydranautics Section was
added as well as an additional set of outside bulk storage tanks for H2SO4 and NaOH
with capacities of ten thousand (10,000) and four thousand (4,000) gallons,
respectively. Concrete dikes were constructed around each tank. Each diked area is
filled with limestone and has similar containment capacities as the Dow Section.
However, at the time of the audit, both storage tanks were using the same fitting for
unloading which creates the potential for adding incompatible materials to the
system. The audit team recommends the Reverse Osmosis facility use an unloading
system similar to the Dow section.
The Hydranautics Section also has day storage tanks for the NaOH and H2SO4 with
capacities of approximately two hundred (200) gallons and three hundred and eighty
(380) gallons, respectively. These tanks are located in separate rooms similar to the
Dow Section. However, there are some significant differences. The chemicals enter
the appropriate tanks through gravity feed instead of pumps. The operator must
manually open/close a valve while observing the tank sight glass to determine the
fill level. There are manual quick shut-off valves located outside on the large bulk
tanks for both chemicals. Drains are located under each tank as in the Dow Section.
These drains also allow any spilled chemicals to flow into an area where
neutralization can occur. However, these tanks are also located in a three-sided
diked area. The fourth side is open to a common trench. The audit team sees this as
a potential for the mixing of acid and base cross-contamination. However, the
facility does not view this as a problem due to the amount of water normally in the
trench and the availability of the drain system.
6.1.2 Shipping/Receiving
Flocon 100 is supplied by Pfizer Chemicals and is shipped in fifty-five (55) gallon
drums. It is transported by truck but is not regulated by the Department of
Transportation (DOT). Shipments consisting of twenty drums arrive once a month.
Operators remove the material from the trucks using forklifts and transport the
drums via drum grapplers to the appropriate storage areas. Approximately twenty
(20) gallons of material per plant is used during a normal day of operation.
Both NaOH and H2SO4 are shipped to the facility in three thousand (3000) gallon
9
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tank trucks. Approximately six (6) truckloads of ninety-three (93%) H2SO4 and one
and one-half truck loads of fifty (50%) NaOH are received monthly. The truck
operator is responsible for unloading into the respective outdoor storage tanks and
is expected to follow all plant chemical safety rules for acid and caustic handling.
The truck operator is monitored by an employee of the Reverse Osmosis facility.
Chlorine is shipped to the Reverse Osmosis Plant in one ton containers via truck
from the Jones Chemical Company out of Fort Lauderdale, Florida. The
consumption of chlorine will fluctuate according to water demand. Records
indicate 22,000 pounds used for the month of January. The facility receives three to
four shipments of four (4) tons each per month. These containers are unloaded
from the truck onto a deck that is the same height as the truck bed. Containers are
then positioned using a monorail and a three ton electric hoist equipped with a
standard lifting beam.
There is space available in the storage area for as many as ten containers. Eight are
positioned onto roller blocks equipped with load cells. Two additional containers
can be stored using portable chocks to keep them stationary. The rollers allow the
containers to be positioned in the correct attitude to withdraw chlorine gas from the
appropriate valve. There is one set of load cells located between two containers,
each base of the holder cantilevered on a load cell. The load cells are supplied by
PVC Eagle Micro Systems located in Pennsylvania. The readout from the load cells
are located in the control room. The total weight of two containers is continually
indicated.
The storage area is a roofed, three-sided, concrete block building open on the
receiving end and also open between the side of the plant wall and the end of the
north back wall. Access to this area is not limited to anyone who may be on the
premises. Although the containers would not be protected from a driving rain from
the west, the containers are well above the floor level, eliminating the possibility of
the tanks subjected to standing water at any time. Due to the open structure of this
area, storage temperature of these containers will be identical to the outside ambient
air.
6.2 Process Description
6.2.1 Reverse Osmosis Treatment
Water pumped from the lower aquifer (approximately 700 feet) is designated as raw
10
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water. Sulfuric acid is added to lower the pH. Flocon 100, a scale inhibitor, is also
added by injection. Addition of these two chemicals is referred to as "pre-treatment"
and is controlled by the central computer systems. These chemicals are used to
optimize conditions for the reverse osmosis process and prolong the life of the
membranes. The operator takes grab samples each shift to verify computer settings.
The pre-treated feed water passes through a series of cartridge filters which remove
particulates down to five (5) microns. The filtered water is pumped into the reverse
osmosis units at a pressure of 260 psi. The reverse osmesis units, at present, are of
two types: the older Dow design involves hollow-fiber cellulose acetate membranes;
the Hydranautics system uses spiral wound polyamide membranes. A project is
underway to replace the Dow system membranes with spiral wound membranes
with scheduled completion by summer, 1991. There are also plans for updating the
computer system.
When the feed enters the membrane assembly, it is separated into usable (product)
and reject (concentrate) water. Pre-treatment keeps impurities in liquid form during
this separation. The reject is then discharged from the system by way of the brine
line. The brine, treated with chlorine and oxygen to maintain environmental
standards, although highly concentrated with impurities, has a salt concentration
lower than that of the salt water lake into which it empties. The brine is evenly
diffused throughout the lake using an intricate series of submersed spray nozzles.
The combined systems reject an average of twenty percent (20%) of the raw water
taken in from the well field. The original plant rejects approximately twenty-five
percent (25%), and the expansion plant is projected to reject fifteen percent (15%).
This reject water is not potable nor is it suitable for irrigation due to the high salt
and impurity concentration.
After the reverse osmosis units separate the water into product and reject, the
product water is pumped into the clearwell. Prior to entering the clearwell, the
dissolved hydrogen sulfide is removed from the water. Gaseous hydrogen sulfide is
released when the water contacts the air flowing through the degasifiers. The
degasifiers are two upright cylindrical tanks equipped with flow dispersing media.
The product water coming from the plant feeds into the top of these tanks and
cascades down over the media; it is forcibly mixed with air travelling in a counter-
current direction from a blower mounted at the bottom of the tank. The air strips
1 1
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the hydrogen sulfide from the water and the hydrogen sulfide and air is released
through a vent at the top of the unit. The water passes into the elearwell where
chlorine is added for disinfection and removal of any residual hydrogen sulfide.
Caustic (sodium hydroxide) is added to raise the pH of the water to 8.6 to
specifications as per water management regulations. The product flow is computer
controlled with grab samples taken for verification. From the elearwell, the water is
pumped to storage tanks. From this point, it is available for pumping to the
consumer,
6.2.2 Overview of Chlorination Process
At the Reverse Osmosis facility, the treated water as well as the rejected water (brine)
is chlorinated prior to discharge to the storage tanks or the lake receiving the brine
rejects. Since the accident of February 1988, the complete chlorination system was
changed over to an all vacuum system engineered to minimize the risk of further
releases. Vacuum is created at the injectors drawing the chlorine gas from the tanks
through the rotameter and the V-notch variable orifice valve which is manually
operated for controlling the flow. The chlorine gas enters the water flowing
through the injectors. There is a complete chlorination system for each of the two
plants. The chlorinated water is added to the flow of product at the discharge end of
the degasifier where it is then pumped to the storage tanks. There are two locations
where the chlorinated water enters the brine discharge stream. Blending at these
points is achieved using on-line static mixers.
6.2.3 Details of the Chlorination Process
Design of the new system was supplied by the consulting firm of Rostek Services,
Incorporated, with offices in Fort Myers, Florida. Equipment for the chlorination
process was supplied by the Wallace and Tiernen Company of New Jersey.
Water from the municipal supply (storage tanks) is circulated through the
chlorinator injectors creating a negative pressure facilitating the injection of
chlorine into the flow which is directed to the designated points where it is added to
the main stream of product or reject water. The product water for municipal use
has a chlorine residual of 0.8 to 1.00 ppm while the brine can contain a maximum of
0.01 ppm. The purpose of the chlorination of the brine is to remove the hydrogen
sulfide from the water prior to discharge. Chlorine concentration of the brine and
municipal water is dictated by the Florida Department of Environmental
Regulation.
1 2
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The line pressure of the water is 80 psi, and by incorporating a booster pump, the
pressure is increased up to 110 psi into the injectors. The pump is a Robin and
Meyer 5 hp 3500 rpm centrifugal pump and discharges into a two-inch schedule 40
well casing PVC pipe to a manifold feeding the injectors. In the event of a power
outage, the pump may shut down but the existing line pressure will be adequate to
maintain the injector operation. The water is fed to a manifold with six takeoffs.
Three are dedicated to each plant with one line from each injector running to the
discharge point of the degasifier or the entry port of the clearwell. The other two are
dedicated to the chlorination of the brine reject water. The discharge end of the
injector is reduced to a smaller diameter pipe (1 inch). There is a check valve built
in at the gas inlet of the injectors to prevent any suckback of liquid into the gas line.
Both the injector and discharge line is made of Schedule 80 PVC. The team was
informed that all piping not made of this material will be replaced in the very near
future. The injectors, manifold and pump are all mounted along the south wall of
the chlorine tank storage area. The semi-rigid polypropylene tubing carrying the
chlorine to the injectors are fed through a hole in the wall situated above the
injectors at the center point of the manifold. On the reverse side of the wall, the
rotameter, feed rate adjuster, and vacuum gauges are mounted. The chlorinator
control room is also the room where the Flocon (anti-sealant) solution is prepared
for the older Dow Plant. The chlorine enters the room through an opening at a sub-
floor level which is an extension of the trench containing the piping for the
chlorine from the manifold hookup to the one-ton containers. The vacuum created
at the injectors draws the chlorine through the manual feed rate adjuster and the
rotameter indicating the rate of flow. The rotameter indicates the rate drawn from
the containers in pounds of chlorine per twenty-four (24) hours. The gauges
mounted indicate the vacuum in inches of water, and the operating pressures are
approximately 25 to 30 inches. Metering of the chlorine into the injectors is
controlled by a standard V-notch variable orifice common to chlorination
equipment.
The chlorine feeding the injectors is supplied from a manifold which is connected
to an input feed manifold equipped with valves and connectors for the semi-rigid
5/8 inch diameter thickwall polypropylene tubing attached to a pressure valve that
is attached to the yoke and adaptor connector on the chlorine container. The
13
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manifold is made of 3/4 inch CPVC. The pressure valve mounted on each of the
containers is apparently the heart of the safety feature of this revised chlorination
system. The valve is normally in the closed position. There is a switch which
senses the pressure on the outlet side and, if the pressure is negative, the valve will
open. If the pressure is more than or at atmospheric, the valve immediately closes
so, if there is a break in the vacuum, the pressure actuated valve on each container
immediately shuts off the flow of chlorine gas.
6.2.4 Chlorine Release Detection
The report issued by the Florida Bureau of Industrial Safety and Health on the
incident of February 11, 1989, described factors relating to the accident. Quoting from
Page 1 of the report:
"The chlorine supply system is a pressure type and is monitored by two (2) alarm
devices. One is activated when the manifold pressure device senses a low pressure
condition. This could result from a leak on the supply side of the control or a low
volume of chlorine that calls for a switch over the other bank of tanks.
The other alarm device is a chlorine sensor, sampling air approximately three (3)
inches off the floor (chlorine is heavier than air). This device would react to a leak
on either the supply side or the distribution side of the chlorine feed system. In the
event of a leak, as in this occurrence, one device backs up the other.
In examining the chlorine sensor, it was found that the motor driving fan that
draws the air up the tube into the test chamber had seized and, therefore, was not
sampling. The fuse was not blown and the correct fuse, as specified, was in place.
The pressure senor, therefore, activated the alarm. As much as 3000 pounds of
liquid chlorine was released as gaseous chlorine before the alarm sounded. In this
instance, the sensor body had opened up allowing chlorine to leak out. The
eventual loss of pressure then activated the alarm. In examining the
manifold/sensor installation, it was noted the sensor was mounted in an inverted
position (hanging down) rather than upward as the other sensor on the second
manifold is and the way this one was mounted before the piping was reworked on
November 17, 1988. Both manifold systems had been replaced as a precautionary
14
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measure because of their rusted condition. The old sensors were reinstalled,
however, by the service organization."
This description has been discounted by the Reverse Osmosis personnel. They feel
the detector had been checked the Friday before the accident and was in working
order. They feel the motor shaft seized after the incident but before its inspection.
They do not agree with the Florida reports on the quantity of chlorine gas that was
released. They were of the opinion the alarm sounded after much less gas was
released.
When the new system was incorporated, new sensors were installed. There are five
(5) diffusion type sensors currently in operation, three of which are supplied by
Capital Controls, Inc. from Colmar, Pennsylvania. The other two are supplied by
Neutronics, Inc., from King of Prussia, Pennsylvania. Both are conductimetric
diffusion type utilizing a metal oxide semiconductor sensing device. The control
units for the detectors are located in the main control room where the unit activates
an audible as well as visual strobe alarm when the maximum level of 5 ppm is
reached. There are three sensors located in the chlorine storage room. One sensor is
mounted on the south wall and two are located on both ends of the north wall.
There is one located in the chlorination control room and the remaining sensor is
mounted in the hallway adjoining the storage and chlorinator room. All sensors
are mounted approximately one foot above floor level. Maintenance is limited to a
monthly yes/no operation by the on-site instrument technician using a Capitol
chlorine gas sensor test kit (BM-4709). Chlorine gas is produced using boric acid and
sodium-s-triazinetrione. The gas is dispensed by squeezing the plastic bottle
containing the mixture while positioned under the sensor. If the alarm is not
activated, the sensor is replaced. There are two spare sensors of each type on site at
all times. Calibration of these detectors is not possible using this method.
The Reverse Osmosis facility is investigating the acquisition of a calibration device
to ensure the limits of the controller set points are correct. There are no alarms
located on the outside of the building nor are there any detectors mounted to detect
chlorine vapors outside the building. It was recommended Reverse Osmosis install
an alarm on the outside of the building.
1 5
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The current emergency procedure is to run outside and look at the flag to determine
wind direction in the event of a release. It is recommended the Reverse Osmosis
facility install a meteorological station to indicate wind direction and speed with the
readout mounted adjacent to the chlorine detector control units.
There is an elementary school situated less than 1/2 mile south of the Reverse
Osmosis Plant and contact is made by phone only. There will be an increase in
residential construction in the immediate area in the near future so there should be
consideration for additional safeguards to deal with any emergency that may arise
due to an accidental release of chlorine at this plant.
7.0 CHEMICAL ACCIDENT PREVENTION
7.1 Management Activities
The Reverse Osmosis Plant is managed as a division of the City of Cape Coral
Utilities Department. There are written safety and procedure manuals which are
made available to Reverse Osmosis Plant employees. The manuals are a
combination of general utility department guidelines and policies specific to the
Reverse Osmosis Plant. The manuals appear to be out of date. Many corrections are
noted in the policies through handwritten notations. The Reverse Osmosis
management recognizes updating the manuals should be completed. However,
they are awaiting completion of the construction at the facility before this task is
undertaken.
7.2 Process Operation and Maintenance
Seventeen (17) people are employed at the facility; however, most work the day
shift On "off-shifts," as few as two operators may be working. Maintenance is done
during the day shift, when possible, to reduce electrical usage during peak periods. If
an emergency occurs during an "off-shift," it is the "on-shift" duty operator's
responsibility to notify facility management who in turn notify the risk safety
manager. While the facility has an informal emergency plan in place, the formal
written plan is incomplete. It would also appear that little consideration has been
given toward the safety of visitors and contractor employees.
There is an extremely low employee turnover rate at the Reverse Osmosis Plant.
New employees are given the available safety and operating procedure manuals to
review. They also undergo initial health physicals. All employees must attend
1 6
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monthly safety meetings which include discussions on various safety topics, such as
chemical hazards, employee safety precautions, etc. Chlorine is discussed every six
(6) months at these meetings. A mandatory workshop on the application of a
chlorine tank repair kit type B is presented by Jones Chemical on an annual basis.
Also, all operators must review and practice using the safety air packs every three (3)
months. Once per year, an eight (8) hour Occupational Safety and Health
Administration (OSHA) training is required of all plant employees.
7.3 Plant Security
The entire perimeter of the property is protected by an eight-foot, chain-link fence
topped with barbed wire. The front gate is operated by a switch just inside the front
entrance of the building. This gate is kept shut on the off-shifts and on weekends.
The front gate and the immediate grounds are monitored by the operators in the
control room by a single video camera. No perimeter surveillance is conducted.
Since the 1989 accident, a two-way hand-held radio set to the fire department's
frequency is kept in the control room. This radio is to be used in the event of an
emergency situation.
8.0 ACCIDENT RELEASE INCIDENT INVESTIGATION
8.1 History of Accident Releases/Incidents
The Reverse Osmosis facility had an accidental release of chlorine on February 11,
1989, which reportedly occurred when a pressure sensor ruptured on the high
pressure side. The release resulted in one employee fatality and the hospitalization
of an employee and an emergency responder.
8.2 Hazard Evaluation and Modeling
8.2.1 Existing Modeling Programs
The Reverse Osmosis facility does not have a formal hazop or what-if system of
hazard evaluation.
8.2.2 Modeling/Uses of Modeling
Modeling is a tool that may be used for estimating the movement and dispersion of
chemical pollutants through environmental media: air, surface water, and
groundwater. Although models exist for use with each of these media, this report
only addresses the airborne release of EHSs and will limit discussion to vapor
dispersion modeling used to predict the extent, duration, and concentration of a
1 7
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plume or cloud of released toxic gas or aerosol. The results of applying the model
will depend on source information which describes the characteristics of the release,
and on dispersion information which describes the characteristics of the resultant
cloud or plume. The latter is dependent on the physicochemical properties of the
chemical involved and the existing meteorological conditions.
Modeling may be used to predict the effects of various release scenarios and to
estimate which scenarios present the greatest threat to plant personnel and the
surrounding community. The first logical step in this process is representation of
"credible worst case" release conditions to determine whether any problem will
result from such a release. This first approximation is attained through a
"screening" procedure which involves determination of the "zone of vulnerability"
at prescribed concentrations assuming the source to be at ground level in a deep
surface air temperature inversion and stable meteorological conditions. If the
results from such "screening" suggest acceptable conditions, it reasonably can be
assumed no problem is likely to exist. If, however, this first estimate is not
reassuring and concentrations are predicted above acceptable levels, then modeling
should proceed under conditions more carefully and realistically described and be
based on information of greater accuracy.
A zone of vulnerability is any zone of potential human habitation in the vicinity of
the emitting source that experiences a concentration of an EHS that equals or
exceeds a prescribed "level of concern" (LOC). For the purpose of hazards analysis,
the vulnerable zone is defined as:
"An estimated geographical area that may be subject to concentrations of an
airborne EHS at levels that could cause irreversible acute health effects or
death to human populations within the area following an accidental release."
Within the same context, the level of concern is defined as:
"The concentration of an extremely hazardous substance in air above which
there may be serious, irreversible health effects or death as a result of a single
exposure for a relatively short period of time."
1 8
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Credible Worst Case Analysis for Accidental Release
For analysis of the effects of accidental releases under "credible worst case"
assumptions, there is only one that should be considered at the Reverse Osmosis
plant:
Instantaneous release [ten (10) minutes] of chlorine from a two thousand
(2000) pound cylinder. This would result in a layer of chlorine gas which
would spread downwind at ground level with little vertical height.
Since chlorine gas is heavier than air, it will spread only horizontally and move
downwind in a thin blanket along the ground. The vertical height of the chlorine
gas will depend on the amount spilled as well as on the atmospheric mixing
conditions. Under light winds speeds and stable atmospheric conditions (generally
5 PM to 8 AM) the chlorine gas will spread along the ground and fill any low lying
areas. Dispersion under these conditions is poor. When winds are higher than
about 8 MPH and as the atmospheric conditions become more unstable, dispersion
will increase both vertically and horizontally.
Meteorological Patterns in the Vicinity of Reverse Osmosis Plant
The patterns of air flow in the area around the Reverse Osmosis facility is
characterized by east to northeast winds. Wind, temperature, and relative humidity
data obtained from the National Weather Service for the Fort Myers airport are
shown in the table below. Values are presented by month and yearly average.
Twelve month mean values for wind speed, temperature, and relative humidity in
the area were 8.1 mph, 74ฐF, and 76%, respectively.
Table 8.1 Average Monthly Weather Conditions for the Fort Myers Area
Temp.
Wind
Velocity
Relative Humidity
Month
op
Miles/hr
Direction
1:00a.m. 7:00a.m.
1:00p.m. 7:00p.m.
Jan
63.4
8.4
E
85
88
57 72
Feb
64.1
9.0
E
84
88
55 70
Mar
68.8
9.4
SW
84
88
52 67
Apr
73.1
8.9
E
84
88
48 64
May
77.8
8.2
E
85
88
50 66
June
81.1
7.3
E
89
89
59 75
July
82.6
6.8
ESE
89
89
60 76
Aug
82.8
6.8
E
89
90
61 78
Sept
81.7
7.7
E
89
91
62 77
1 9
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Oct
76.5
8.4
NE
88
89
57
74
Nov
69.8
8.3
NE
87
90
56
74
Dec
64 T
8.2
NE
87
89
57
75
Mean
73.9
8.1
E
87
89
56
72
Estimations of Zones of Vulnerability
Basis of Modeling for Purposes of Estimation
The analysis presented in this section utilizes the procedures described above.
Modeling of vulnerable zones is achieved through the use of the CAMEOII
(Computer Aided Management of Emergency Operations) Systems that is standard
within the EPA and is used by many local emergency response organizations. The
methods employed by CAMEOn are described in Appendix G of the Technical
Guidance for Hazards Analysis and are the standard methods adopted by the EPA
since they were formalized by D.B. Turner^.
^Turner, D.B., Workbook of Atmospheric Dispersion Estimates. U.S.
Environmental Protection Agency, Office of Air Programs Publication No.
AP-26, Research Triangle, NC. Revised 1970.
Assumptions for Modeling of "Credible Worst Case" Scenario
Modeling of a "credible worst case" release at the Reverse Osmosis Cape Coral
location is based upon the following assumptions:
Terrain: The area around the plant is flat. The area is characterized as rural
rather than urban due to the land use patterns in the area.
Instantaneous release: A ground-level release of the maximum amount that
could be released from one container or interconnected containers within ten
minutes. At the Reverse Osmosis Cape Coral location, this is represented by the
instantaneous release (ten minutes) of the complete contents of one two
thousand (2000) pound cylinder of chlorine.
Continuous release: A ground-level release of the maximum amount that could
be discharged over a ten (10) minute period from a process-related event giving
rise to an uncontrolled, continuous release incident. There are no processes that
fall into this category at the Reverse Osmosis Cape Coral location.
Atmospheric stability class: "F" stability class. For conservative purposes, the
most stable condition is chosen, which corresponds to strong inversion
conditions. This type of condition is generally found at night when the earth is
cool and dispersants in the air tend to lie close to the ground.
20
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Wind: Wind velocity employed for estimation is designated at 3.4 mph,
corresponding to "low wind speed" recommendations for the most stable
condition.
Level of Concern (LOC): Recommended level is one-tenth of the "Immediately
Dangerous to Life and Health" (IDLH) concentration as published by the
National Institute of Occupational Safety and Health (NIOSH). The LOC for
chlorine is as follows:
o Chlorine 0.0073 gm/m^ (3 ppm)
A summary of the "credible worst case" assumptions for this scenario is presented
in the table below.
Table 8.2 Assumptions for the Credible Worst Case Release Scenario for
Chlorine from the Cape Coral Reverse Osmosis Facility
Release Description Chlorine
Type of Release Instantaneous
Time of Release 10 minutes
Quantity Released 2000 pounds
Wind Speed 3.4 mph
Atmospheric Stability F
Topography Rural
LOC 0.0073 gm/m3
Estimating Zones of Vulnerability
The zone of vulnerability produced by this analysis will be a circle around the
Reverse Osmosis Plant within which the concentration of the released EHS equals
or exceeds the LOC. The greatest threat would be to nearby residences, businesses
and other nearby facilities. Because of the prevailing east and northeast wind flow,
any persons to the west and southwest of the plant would be, on the average, at
greater risk in the case of a release but anyone, regardless of direction from the plant,
are theoretically vulnerable to a given release to the same degree.
Modeling for Credible Worst Case Release
Application of the standard dispersion model for gases as computed by means of the
CAMEOII System yields an estimate of the zone of vulnerability for the "credible
2 1
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worst case" release scenario. The following figure shows the results of vulnerability
screening for chlorine.
Figure 8.1: CAMEOn printout for instantaneous "credible worst case" vulnerability-
screening of chlorine.
Uulnerability/Rislc Screening
V 101
facility id J. 222 name .ft ey *.r sOsmosis Company
Chlorine | cas number 7782505
AVERAGE DAILY QUANTITY ON-SITE (POUNDS)
MAXIMUM DAILY QUANTITY ON-SITE (POUNDS)
MAXIMUM QUANTITY IN ONE VESSEL (POUNDS) I
CONCENTRATION IN WEIGHT PERCENT
physical state: Gas DIKED AREA SO- no
NEAR no
Although the likelihood of a "Credible Worst Case" release of chlorine is Ikov, the
overall risk is considered high due to the magnitude of the vulnerable zone and the
severity of the consequences should such an event occur.
_____
As can be observed, this scenario produces an estimated vulnerable zone that has a
radius greater than ten (10) miles for chlorine. The limits of the vulnerable zone
calculation by CAMEOII is ten (10) miles. Beyond this limit, variables controlling
plume dispersion cannot be adequately accounted for by the model and unacceptable
levels of error are introduced into the calculations. Operation of the model beyond
these limits would produce vulnerable zones that are not realistic depictions of
plume dispersion. The model, therefore, has been "set" with default limits of ten
(10) miles and will not calculate plumes beyond that distance.
In general, the likelihood of the occurrence of a worst case release is low. This
follows from the low probability that all variables surrounding an event would
contribute maximally to the severity of the consequences from the release. Even so,
because of the size of the vulnerable zone created, the risk would be judged high if
such an event were to occur. As a consequence, even with the low probability of
occurrence, the facility should consider response plans for such an event and/or
20001
100
INITIAL SCREENING ZONE BASED ON
CREDIBLE WORST CASE ASSUMPTIONS
RADIUSs >10.0 MILES
SCREENING RISK ANALYSIS'
LOW MED HIGH
LIKELIHOOD OF RELEASE: [x] Q |
CONSEQUENCES OF RELEASE-1 | f~| QjF
OVERALL RISK: f~1 PI [*"
Imm ฆ i i 1 mii I 1 in.
22
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take measures as practical to reduce the likelihood of occurrence.
The result of the screening analysis is significant in that is shows that the "credible
worst case" levels of release could create potentially adverse exposure conditions
over an area beyond ten (10) miles. Although this is an estimate based only on
fixed, worst case conditions, the conclusion is definitive. Further analysis is not
needed to justify additional evaluations using scenarios with higher likelihoods of
occurrence.
Reevaluation of the Vulnerable Zone
Reevaluation of the vulnerable zone provides the opportunity to examine further
the scenarios utilized for the "credible worst case" analysis. In this procedure, each
of the assumptions selected are reassessed relative to the likelihood of occurrence
and revised accordingly. Whereas the "screening" scenarios are designed to present
the most conservative approach to estimating vulnerable zones without regard to
the probability of occurrence, reevaluation includes such considerations. This
process is characterized by a stepwise analysis of the assumptions used, both
individually and in various combinations. Within this process, assumptions are
described and priorities are established and analyzed according to their effects on the
severity of consequences.
It should be emphasized, however, that less conservative assumptions will decrease
the estimated vulnerable zone thereby reducing the area of impact and ultimately
the overall magnitude of damages occurring. However, the severity of
consequences within the redefined vulnerable zone may not be altered or,
depending on the assumptions used, could be increased. Also, certain release
conditions may call for assumptions that would increase the size of the vulnerable
zone. For example, if there were sensitive populations within range of the facility,
such as hospitals, schools, or elderly care homes, an LOC at concentrations less than
one-tenth of the IDLH may be advised. Therefore, considerable caution should be
exercised in the selection of revised assumptions under which reevaluation is
conducted. This is necessary to assure that any vulnerable zones described are based
on plume dispersion models that are realistically depicted.
The following table summarizes the assumptions redefined for use as example
release scenario for chlorine. The assumptions presented are based strictly on our
23
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view of the possible conditions that may exist, and events that potentially could
occur at the Reverse Osmosis facility. Such assumptions are subject to review and
revision by others more familiar with the Reverse Osmosis facility and its
operations and are not presented for purposes other than example.
Table 8.3 Reevaluated Assumptions for the Release Scenario for Chlorine
from the Reverse Osmosis Facility
Release Description Chlorine
Type of Release Instantaneous
Time of Release 10 minutes
Rate of Release 20 Ibm/min
Quantity Released 200 pounds
Wind Speed 8.1 mph
Wind Direction any
Stability Class D
Topography Rural (Flat)
LOC 0.0073 gm/m3
The figure following shows the results of vulnerability analysis for chlorine.
Figure 8.2: CAMEOn printout for the redefined vulnerability zone determination
for chlorine.
Vulnerability/Risk Scenarios
V 1.01 51
FACILITY ID
.,1222 name .ฃeyer3e0.3.mpjij..Comp8n.ii
I Chlorine I ens number
7782505
STABILITY CLASS Qrt Qป Qc (S)d Qe Qf
WIND SPEED I 8.1 ]nrn FROM I IdEGREES TRUE
GROUND ROUGHNESS ฃ) URBAN (#)RURAL
QUANTITY RELENSEd[~
VULNERABLE ZONE
RADIUS ซ
0.5
MILES
200
POUNDS OVER
LEVEL OF CONCERN (LOC)
Q ปLH (3) 1/10 IDLH Q OTHER
PHYSICAL STATE: GiS DIKED AREA
NEAR no
10 Ml*
RISK REEVM-UftTfON>
LOW HEP HIGH
LIKELIHOOD OF RELEASE:
2.5 [PPM
no
CONSEQUENCES OF RELEASE:
OVERALL RISK:
4/2/91
On re-evaluation, this occurence is greater then the "worst case" scenario on the
basis that a slowly leaking valve is more likely then the complete release of the total
contents within 10 minutes.
24
-------
Application of the CAMEO II System yields an estimate of the zone of
vulnerability for the reevaluated release scenarios. Assumptions that were
redefined include the time and rate for product release, stability class, and wind
speed. Changes selected were considered feasible circumstances under which a
release could occur at the pumping stations.
Figures 8.2 shows a significant reduction in the size of the vulnerable zones is
produced under the redefined assumptions. The radius for this vulnerable analysis
using the Cameo model for chlorine is 0.5 miles. It is important to realize other
vulnerability distances can occur depending upon the amount of chlorine released
and the time period. With an alarm system installed to detect chlorine leaks, the 10
minute time period used here should be adequate. The contaminant concentration
of one-tenth the IDLH was maintained constant for both the screening and
reevaluation models thus exposure levels within the vulnerable zones are the same
though the areal extent of exposure is significantly different
Conclusions
The primary reason for conducting a hazard analysis is to provide information
needed for use in preparing local contingency plans for emergency response to the
release of hazardous substances. The ability to predict or determine concentration,
footprints, or plumes for the movement of toxic clouds outward from the source of
release is of paramount importance to making sound decisions concerning public
evacuation and other protective actions. The CAMEOII System provides a rapid
and effective way of assessing the hazards of toxic gas releases and for analyzing
various release scenarios based on realistic conditions that may surround an actual
incident. Using such tools, emergency responders can conduct comprehensive pre-
planning for facilities handling hazardous substances and develop response
capabilities based on realistic needs.
9.0 FACILITY EMERGENCY PREPAREDNESS AND PLANNING ACTIVITIES
The written emergency plan for the Cape Coral Reverse Osmosis plant is
incomplete. The Division of Water Supply for the City of Cape Coral, of which
Reverse Osmosis is a part, has a written policy regarding succession of authority
within the division during emergencies. In this policy, the director delegates
authority and places responsibility for appropriate action on the highest ranking
25
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employee at the site of a water supply emergency. The Reverse Osmosis Plant also
has among its documents detailed instructions for dealing with chlorine arid an
emergency telephone list comprised of home telephone numbers for all facility
personnel plus telephone numbers for the police, the local hospital, and the schools.
In addition, the Reverse Osmosis facility, on another document, maintains the 800
telephone number of Harcross Chemical Company which may be called in case of a
chlorine emergency. The Reverse Osmosis plant has had no emergency response
exercises and simulations. Chlorine, sulfuric acid, and sodium hydroxide are
present at the Reverse Osmosis facility.
The Reverse Osmosis facility is located in a sparsely populated residential area. It is
located within an eighty-acre (80) parcel of land owned by the City of Cape Coral. A
good portion of this land is under security fence. Entry into the property is through
one (1) front gate at 3304 Southwest 20th Avenue. Access into the property may be
controlled from the control room of the facility from which location the control
room operator can open and close the gate electronically. The control room
operator can identify persons arriving at the gate through a television monitor
located in the control room.
Fire department and other emergency agencies which may arrive at the scene of an
emergency have unobstructed access to the vital facilities at the Reverse Osmosis
plant through the front gate. Should a chemical release inside the facility endanger
personnel inside and prevent them from opening the gate, emergency response
agencies are instructed to destroy the gate.
Personal protection equipment at the Reverse Osmosis plant for dealing with
hazardous chemicals on-site includes three (3) breathing apparatus with a thirty (30)
minute supply of oxygen, two (2) apparatus with fifteen (15) minutes of oxygen, two
(2) add suits, ten (10) two-piece chemical resistant suits, face shields, gloves, boots,
and goggles. Personal protection equipment is located at well-labeled points within
the facility including the control room. Safety showers are located in each chemical
room and at each chemical storage tank site.
Reverse Osmosis management indicated that from a plant operational standpoint,
the chain of command goes from the plant superintendent to the chief operator and
then to the control room operator on duty. There are normally nine (9) persons on
26
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duty at the plant during the day shift; usually two (2) persons are on duty during the
second and third shifts. No one has been designated as being in charge of the facility
during second and third shifts.
Reverse Osmosis management has high confidence in their ability to prevent and
control a release of a hazardous chemical at the facility. This confidence is based on
having sensors in the chlorine operations area which will activate both a strobe
light warning in the main operations building and an audible warning signal in the
control room. This early detection of a release would allow Reverse Osmosis
personnel, working in pairs and with protective breathing apparatus, to identify the
leak and stop it There are no detailed written procedures to cover broad emergency
actions which should be taken in the event of an emergency. This does not mean
the Reverse Osmosis fadlity would fail to take all appropriate action to protect plant
personnel and call for outside assistance should it be needed.
For communications within the facility, the Reverse Osmosis plant uses an in-plant
paging system which may be activated from any of the plant telephones. There are
also two (2) portable radios. At night, these portable radios are stored in the control
room of the plant. In addition to their own broadcast channel, these portable radios
have a channel for contacting the Cape Coral Fire Department. Two-way radios are
installed in the plant's sedans and service trucks.
Training at the Reverse Osmosis facility emphasizes chemical dangers and addresses
these dangers in relation to operations rather than to emergency response. Training
of employees during 1990 covered safety and handling of sulfuric acid, chlorine, and
caustic soda. Self-contained breathing apparatus were demonstrated and employees
were required to don equipment. Employees also were acquainted with the new
chlorine alarm system.
On February XI, 1989, the Reverse Osmosis facility had an accidental release of
chlorine estimated by plant management to be four hundred (400) pounds. This
release resulted in the death of one (1) employee. This accident brought about an
intense investigation at the plant. The following changes were made at the plant to
improve safety:
o Weather stripping was replaced.
27
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o Two additional fifteen (15) minute and one additional thirty (30)
minute breathing apparatus was added.
o Air conditioning system was moved to the roof.
o' Pressure regulators for the chlorination systems were replaced with
an all-vacuum system.
o Two chlorine alarms were installed with emergency strobe lights.
o Leak detector was replaced with five new sensing devices.
10.0 COMMUNITY AND FACILITY EMERGENCY RESPONSE PLANNING
ACTIVITIES
Two (2) chemicals, chlorine and sulfuric acid, used at Reverse Osmosis are on lists
contained in federal law that require special emergency planning and notification in
the event a defined amount of these chemicals is accidentally released. Both
chlorine and sulfuric acid are listed as Extremely Hazardous Substances (EHSs)
under the SARA Title III and as hazardous chemicals under the CERCLA. Reverse
Osmosis was found to have complied with the reporting requirements of SARA
Title IH Sections 302, 303, 311, and 312. When approximately four hundred (400)
pounds of chlorine, a reportable quantity, was released on February 11,1989,
notifications to a local warning point defined by the Local Emergency Planning
Committee (LEPC), to the State Emergency Response Commission (SERC), and to
the National Response Center (NRC) were made as required under SARA Title HI
Section 304 and CERCLA 103. No written follow-up report after the accident, as
required under SARA Title III Section 304(b), was found to have been filed.
The management of Reverse Osmosis has invited the Cape Coral Fire Department
to visit the plant and become familiar with chemicals present and their use at the
facility. Complete cooperation was given to a representative of the Lee County,
Florida, Emergency Management Agency in developing a hazardous analysis for the
facility.
The director of the Lee County Emergency Management Agency advised he was
28
-------
familiar with the Cape Coral Reverse Osmosis facility and that provisions for county
response to Reverse Osmosis is incorporated into his county emergency plan. His
agency has produced a hazardous analysis on chlorine and sulfuric acid using
computer modeling. The likelihood of a release of either chlorine or sulfuric acid
was deemed low. A release of sulfuric acid at Reverse Osmosis was projected as
most likely remaining within the facility boundary. In a worst case scenario
projection, a chlorine release might create health effects out to three and one-tenth
(3.1) miles downwind from the facility.
Evacuation routes based on wind direction have been outlined should a release of
chlorine occur at the Reverse Osmosis plant and evacuation become necessary.
The Cape Coral Fire Department would be the initial responding agency to a
chemical release at Reverse Osmosis. The fire department would have the support
of other city response agencies. The Lee County Emergency Management Director
would coordinate county agencies and private resources as needed to support Cape
Coral response.
Emergency response generally is activated by a telephone call through the
Emergency 911 System. Emergency 911 calls are received at the Central Dispatch
Center operated by the Cape Coral Police Department. Hazardous material calls are
directed to the Cape Coral Fire Department for primary response, with other public
safety agencies being put on notice to work under the direction of the senior fire
department officer reporting to the scene. Upon reaching the accident scene, an
evaluation of conditions would be made by the fire department. Should conditions
require it, a command post would be established for response coordination and a
response staging area would be established.
The Cape Coral Fire Department hazardous materials officer noted that should
evacuation be desired it would be commenced by rescue squads and Cape Coral
Police going street to street with loudspeakers. Lee County support would be
requested through the Lee County Emergency Management director.
Cape Coral has a full-time force of one hundred ten (110) professional firemen
located at five (5) stations. The three (3) stations designated for initial response to
the Reverse Osmosis facility are from three (3) to five (5) minutes from the plant.
The fire department has two (2) well-trained and experienced hazardous materials
29
-------
officers. The fire department is currently training an eight-man (8) hazardous
materials response team, and a hazardous materials van is being outfitted for its use.
Of special concern to the fire department in regard to Reverse Osmosis is the Gulf
Elementary School located approximately one-quarter mile from the facility. In-
place shelter is being considered, if conditions permit. Other fire department
concerns relate to the following:
o The need for a second entrance into the property from 20th Avenue.
o The need for training in hazardous materials for facility employees
coordinated with the fire department's hazardous materials section.
o The need for commitment from Reverse Osmosis that early reporting of
releases will be made to the fire department.
11.0 PUBLIC ALERT AND NOTIFICATION SYSTEM
The City of Cape Coral and the Cape Coral Fire Department have public information
officers who are experienced in coordination with the news media. The Lee County
Emergency Management Director indicated initial notification of the public in the
vicinity of Reverse Osmosis would take place as previously indicated. There are no
sirens or other warning systems in place.
Plans and procedures are in place to initiate emergency broadcasts through a twenty-
four-hour (24-hour) Fort Myers, Florida, radio station. Similar arrangements have
been made for furnishing emergency information to local radio and television
stations through FAX transmissions. The emergency broadcast system in Lee
County is tested weekly.
During the week prior to the writer's contact with the Lee County Emergency
Management Agency, shelters were established to protect homeless from cold.
Emergency broadcasts were made to give guidance to homeless on availability and
locations of shelters. In October, 1990, emergency broadcasts were made during
tropical storm Marco.
Contact at Reverse Osmosis revealed that their management has invited public
groups to facility Field Days, Cub Scout Days and other activities.
30
-------
There has been no lack of interaction between Reverse Osmosis and the news
media. Much of this resulted from the February 11, 1989, chlorine accident at the
facility.
12.0 CONCLUSIONS
Significant improvements have been incorporated into the facility's operations
since the 1989 accident, especially in the chlorine supply equipment. Housekeeping
and physical appearance is quite acceptable in view of the plant modifications
currently in progress. Placarding and signs appear adequate. Interior restructured
areas are adequately marked. However, the exterior tank farm and unloading areas
should be better marked with required protective equipment noted. Written safety
and operating practices are available to the operators for use. Many handwritten
modifications have been made that are yet to be incorporated into the typed
documentation.
As a result of the chlorine release, additional internal alarms were added and/or
relocated. However, no exterior visual or audible alarms exist. Sensors as well as
self-contained breathing apparatus (SCBA's) are checked once per week. No written
formalized emergency plan has been prepared.
Hydrogen sulfide gas (H2S(g)) around the degasifiers is quite noticeable. The facility
stated that the state advised the discharge was of no concern. The facility has done
no quantitative study of this discharge.
There is a common drainage trench connecting the sodium hydroxide and sulfuric
acid day tank rooms in the Hydranautics section of the plant Possible mixing of the
acid and caustic could occur.
The outside bulk tank valve fittings for tanker truck unloading on the sodium
hydroxide and sulfuric acid are identical on the Hydranautics section of the plant.
The fittings installed on the tanks in the Dow section are different. Mixing of the
chemicals in the bulk storage tanks on the Hydranautics side could occur during
tanker unloading. Changing the fittings to those used on the Dow system would
eliminate this possibility.
3 1
-------
Reverse Osmosis management appears to be committed to having a safe working
environment for producing potable water for the City of Cape Coral, Florida. Means
are in place to detect chlorine leaks. Alarms have been installed. Trained and
properly equipped plant personnel should be able to control a release under most
conditions. There is concern the Reverse Osmosis plant has no single written
document to guide them in dealing with emergencies. Instead, they rely on
incomplete and fragmented documents. No one has been designated by name or
position to be in charge of the facility during second and third shifts. Telephone
numbers of the State Emergency Response Commission (SERC) and the National
Response Center (NRC), essential points of notification following a release of a
reportable quantity of either sulfuric acid or chlorine, were not immediately
available. Written reports following the February 11,1989, chlorine release were not
filed with SERC or LEPC as required by SARA Title HI. Better understanding and
closer coordination is needed between Reverse Osmosis and the Cape Coral Fire
Department in hazardous materials training and in reporting hazardous materials
releases. Admission of traffic through the front gate could be better controlled.
13.0 RECOMMENDATIONS
The audit team makes the following recommendations for the Reverse Osmosis
facility:
o Incorporate and expand current emergency documents into a more complete
written emergency plan.
o Designate by person or position someone to be in charge of Reverse Osmosis
for emergency purposes on second and third shifts.
o Tighten security by screening of traffic through the front gate.
o Work with the Hazardous Materials Section of Cape Coral Fire Department in
providing another entrance for use in emergencies on the front side of the
property.
o Coordinate with the Hazardous Materials Section of Cape Coral Fire
Department in developing training in hazardous materials for Reverse
Osmosis personnel.
32
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o Work with the Cape Coral Fire Department to ensure that hazardous releases
are reported in a manner that meets the needs of the fire department and the
community.
o Conduct table-top exercises which would include plant personnel, the local
fire department, the local police department, emergency medical services, and
the County Emergency Management Agency.
o Complete the updates of the safety and operating procedures.
o Consider the possibility of cross-contamination between the H2SO4 and
NaOH day tanks in the Hydranautics Section. This mixing of chemicals could
occur due to the common trench shared by both rooms. Methods to prevent
this mixing should be evaluated.
o Change one of the fittings on the outside H2SO4 or NaOH bulk storage tanks
so they are not the same (similar to the ones utilized on the Dow Section bulk
storage tanks). Currently, both use male cam-lock fittings.
o Better marking on required safety equipment should be used in the areas
adjacent to the H2SO4 and NaOH bulk storage tanks.
o Consider installing visual and/or audible exterior chlorine alarms.
o Consider implementation of a monitoring system for emissions of hydrogen
sulfide gas (H2S(g)).
o Consider installing an overflow prevention device for the Hydranautics day
storage tanks.
3 3
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APPENDIX A
-------
LOCATION OF SAFETY AUDIT
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SOUTH
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E.P.A. Region I?
Weston T.A.T. Activity Location
TDD# 04-9102-0004-1328
Reverse Osmosis Water Treatment Plant
Chemical Safety Audit
Cape Coral, Lee County, Florida
ฃ
41
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LOCATION DF CITY DF CAPE CORAL
REVERSE DSMDSIS TREATMENT PLANT
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APPENDIX B
-------
Audit Team Composition
Team Member
Car in DeBenedictis, Team Leader
Connie Landers
Lew Nagler
Thomas Yatabe
Darrell Thomas
Chuck Bruner
Gaines Boone
Dennis Wile
Agency/Affiliation
Environmental Protection Agency (EPA)
EPA
EPA
American Association of Retired Persons (AARJP)
Roy F. Weston, Inc., Technical Assistance Team
AARP
EPA Consultant
AARP
-------
APPENDIX C
-------
U.S. DEPARTMENT OF LABOR
Occupational Safaty and Hsalth Adminiitntion
Poitn Aoo'o.tu
QUI NO, 44-R1JI7
MATERIAL SAFETY DATA SHEET
PFIZER I"SDS " Rปquirปd under USOL Safety ind Hetdh Regulations for Ship Repiifing,
NO. : F005 Shipbuilding, and Shipbrtakino (29 CFR 1915. 1915, 1917)
SECTION 1
MANUfACTURCR** NAME
Pfizer Chemical Division
EMERGENCY TELEPHONE NO,
(718) 780-8456
ADDRESS (Mumber, Street. City, Start, trtd ZJP Code}
ZjS E. 42nd Street, New York. N.Y. 10017
Chemical name and synonyms
Polyacrvlic acid ( 3$%) in water CCAS 9001-01-41
TRADE NAME AND SYNONYMS
FL0C0N Anft sral Rnf 100
chEmiCal Family
Polycarboxylic acid aqueous solution
formula H-(C1H40?)n -H
SECTION II HAZARDOUS INGREDIENTS
PAINTS, PRESERVATIVES. Si SOLVENTS
%
TLV
IUnitป)
ALLOYS AND METALLIC COATINGS
X
TLV
lUm(l)
pigments
BASE METAL
CATALYST
ALLOYS
VEHICLE
METALLIC COATINGS
SOLVENTS
f=ILLEH METAL
PLUS COATING OR CORE FLUX
ADDITIVES
OTHERS
OTHERS
HAZARDOUS MIXTURES OF OTHER LIQUIDS, SOLIDS. OR CASES
%
TLV
CUnifl!
No Hazardous Ingredients
SECTION 11! - PHYSICAL DATA
POILING POINT (8F.|
215
SPECIFIC GRAVITY (HtO-J)
1.15
VAPOR PRESSURE {mm Hซ.J
'-24
PERCENT, VOLATILE
BY VOLUME (X)
65
VAPOR DENSITY tAlfl-H
EVAPORATION RATE
{ *1!
SOLUBILITY IN WATdR
7 99
PH
2-2.5
appearance ANDOOOR Pale yellow viscous liquid; faint bland odor
SECTION IV .
FIRE AND EXPLOSION HAZARD DATA
FLASH POINT (Mtuiod UI.OI
flammaole limits
Lปl
uซi
EXTINGUISHING MEOIA
No Fire
special fine riQHTiNa procedures
or
Explosion Hazard
UNUSUAL, f IRE AMD EXPLOSION HAZAflOS
-------
SECTION V - HEALTH HAZARD DATA
TMซtSHOUO Liwir VALUE
No TLV established
testers of Qvttฃ*cosuซt
May be aild akin and eve Irritant
[MtDCtNCV AND rIRST AIQ HHOCฃOUซฃ5
Flush Stein .contact with watec 3nd flush eve contort *f^y vf f*H
plenty of water. Get medical care for
eyes.
SECTION VI - REACTIVITY DATA
STABH.1TV
UNSTABLE
CONDITIONS TO AVOIO
STABLE
X
iNCOMPATABiLirv (Aiaienati to arOKJf
Usual incompatibilities of oraanic acid*
MAZAnCQUS DECOMPOSITION phqoucts
None establ l.shed
HAZARDOUS
MAY OCCUK
CONOITIONS TO AVOIO
POLYMERIZATION
WtUU. NOT OCCU*
X
SECTION VII - SPILL OR LEAK PROCEDURES
IN CASE MATERIAL iS RELEASED OH SPILLEO
~5TEIปC TO BE TAKEN
This material is not a hazardous waste according to RCRA. and thrmlrf
disposed of in conformance with sound disposal practices.
WASTE Oli-PCSAU METHOD
Spills of this product are not covered bv FPA rpgitliiMnnc Dllurf with water and
dispose of.by any normal liquid disposal method which conforms with applicable
state and local regulations.
SECTION VIII
- SPECIAL PROTECTION INFORMATION
R[inm*rosv protection {Sptiijy typr/
None
VENTILATION
LOCAL EXHAUST
SPECIAL """"
mechanical (Central)
Nnrtp
OTHER
PROTECTIVE GLOVES Stan(Jard work gloves
EVE PROTECTION
Safety classes
OTMEB PBOTtCTlVE EQUIPMENT
SECTION IX - SPECIAL PRECAUTIONS
CRCCAuVlONS TO BC TAKEN IN
handling aho stohinu
None normally required
OTMCn PBECAUTIOMS
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-------
APPENDIX D
-------
CITY DP CAPE CORAL FLORIDA
REVERSE OSMOSIS
WATER TREATMENT FACILITY
-------
Hydranautics Plant
PAGE 7
Raw Water Supply:
Pre-treatment:
Membrane Type:
Number of Trains/Skids:
Recovery:
Lower Hawthorn Aquifer, Brackish Water
12 Wells (approx. 700 feet)
600 Gallons per Minute Each (approx.)
2400 ^mhos/cm conductivity
600 ppm Chlorides
Sulfuric Acid for Carbonate Scale Prevention
pH of 6.0 - 6.2
Flocon 100 Scale Inhibitor for Sulfate Scale Prevention
3.0 ppm
5 micron cartridge filters
Polyamid Spiral Wound
8
85% @ 260 feed psi
240 TDS
18:8 array
Dow Plant:
Raw Water Supply Lower Hawthorn Aquifer, Brackish Water
10 Wells (approx. 700 feet)
600 Gallons per Minute Each
2200 umhos/cm conductivity
500 ppm Chlorides
Pre-treatment: Sulfuric Acid for Carbonate Scale Prevention
pH of 5.8 - 5.9
Flocon 100 Scale Inhibitor for Sulfate Scale Prevention
5 PPM
5 Micron Cartridge Filters
Membrane Type: Cellulose Triacetate Hollow Fine Fiber
Number of Trains/Skids: 10
Recovery: 75% @ 260 feed psi
140 TDS
16:8 array
-------
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-------
CHEMICAL SAFETY AUDIT DATABASE
USER'S MANUAL
EPA Regional Edition
May 1993
-------
TABLE OF CONTENTS
Section Page
I. INTRODUCTION AND PURPOSE 1
II. OVERVIEW AND SYSTEM OBJECTIVES
Goals of Chemical Safety Audit (CSA) Program 1
Goals of Chemical Safety Audit (CSA) Database 2
Specific Uses and Benefits of CSA Database 2
Organization of Audit Information in CSA Database 4
Information Contained in CSA Database 4
III SYSTEM STRUCTURE
Software 6
Hardware and Equipment Required 6
Loading the Program onto Your Computer's Hard Disk 6
IV. OPERATION OF THE SYSTEM
Starting the Program Each Time 8
The Main Menu 8
Browse Profiles 9
Search for Profiles of Interest 13
Print Profiles 22
Configure 22
Exiting from the System 23
Attachment I: Chemical Safety Audit Database Profile Printout
Attachment 2: Protocol Outline from CSA Guidance Manual
Attachment 3: Codes for Audit Report Recommendations and Conclusions
Attachment 4; Codes Summarizing the Reasons for Selecting Facility for Audit
-------
I. Introduction and Purpose
This user's manual is intended to assist EPA regions in using the Chemical Safety
Audit (CSA) database. First, the manual includes an overview of the CSA program and
outlines the objectives and uses of the database. Second, it describes the system (both
hardware and software) needed to run the computer program and to access the database.
Finally, the manual provides detailed instructions on how to operate the system, and
provides a few suggestions for potential data searches of interest to EPA regions.
EE. Overview and System Objectives
Goals of Chemical Safety Audit Program
The Environmental Protection Agency's (EPA) Chemical Safety Audit program is
part of a broad initiative designed to prevent accidental chemical releases by:
o Visiting facilities handling hazardous substances to gather information on
chemical process safety practices and technologies;
o Heightening awareness of the need for, and promote, chemical safety at
facilities handling hazardous substances, as well as in communities where
chemicals are located;
o Building cooperation among facilities, EPA, and other authorized parties by
coordinating joint audits; and
o Establishing a database for the assembly and distribution of chemical safety
information obtained from facility audits.
The audit itself consists of interviews by EPA regions with facility personnel and an on-
site review of various aspects of facility operations related to the prevention of accidental
chemical releases. Although the CSA program is not a compliance or regulatory
program, EPA does have legal authority to enter a facility and conduct a chemical safety
audit. The primary authority is provided by CERCLA sections 104(b) and 104(e), as
amended by SARA. EPA regions may select facilities for an audit based on a number of
factors, including a specific chemical release or history of releases at the facility; a
referral by the state or local government; public concern or interest about the facility; or
other reasons. Specific topics addressed in the audit include:
o Awareness of chemical and process hazards;
o Process characteristics;
o Emergency planning and preparedness activities
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o Hazard evaluation and release detection techniques;
o Release detection and monitoring techniques;
o Training of operators and emergency response personnel;
o Facility and corporate management structure;
o Preventive maintenance and inspection programs; and
o Community notification mechanisms and techniques.
Observations and conclusions from the audits are detailed in a report prepared by the
audit team. The report identifies and characterizes the strengths and weaknesses of
specific chemical process safety management practices and allows the elements of
particularly effective programs to be recognized. Copies of the report are provided to
the facility so that wealf and strong program areas may be recognized.
Goals of the Chemical Safety Audit Database
One of the primary goals of the CSA program is to establish a database for the
assembly and distribution of chemical process safety management information obtained
from the facility audits. This computerized database implements that objective by
providing EPA headquarters and regional offices with information collected from final
audit reports and organized in a uniform format. The database has been designed to
enable EPA staff to:
o Access and use chemical process safety management information quickly;
o Browse through information about specific chemical safety audits;
o Analyze audit information for patterns or trends in chemical process safety
management;
o Disseminate chemical process safety management information; and
o Provide data for agency- and region-wide reviews of the audit program.
Specific Uses and Benefits of the CSA Database
For EPA Regional Offices
The information contained in the database can be useful to the EPA regional
offices in a variety of ways.
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ฆ3-
o Regional audit staff who are planning to conduct an audit of a facility in a
certain industry, but lack the relevant expertise, can use the database to
identify field experts throughout the country that could be contacted for
advice in conducting the audit or even participation in the audit.
o Regional audit staff may want to refer to information collected during
earlier audits in order to better examine successful and problematic safety
practices for similar facilities or processes. For example:
Audit team members could examine the storage and handling,
training, maintenance, or other chemical process safety practices and
techniques in use at previously audited facilities that handle chlorine
to prepare for an audit at a waste water treatment facility.
Audit team members could examine the on-site availability of health
and safety as well as emergency response equipment at previously
audited agricultural chemical facilities to prepare for an audit at a
pesticides manufacturer.
Audit team members could examine the processing observations,
conclusions, and recommendations made in reference to previously
audited facilities that use a state-of-practice processing technology to
prepare for an audit at a facility using the same technology.
For EPA Headquarters
The CSA computerized database will provide headquarters with select audit
information organized in a uniform format consistent with the CSA protocol
outlined in the CSA Guidance Manual. Using the database, EPA headquarters
will be able to;
o Identify successful and problematic chemical process safety management
practices and technologies at the audited facilities;
o Assemble and distribute the audit information and findings on chemical
process safety management and chemical accident prevention issues; and
o Assess the implementation of the CSA program in terms of the number of
audits conducted, the number of audit reports completed, and the types of
information contained in the reports.
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Oreanizatinn of the Audit Information in the CSA Database
As a first step in incorporating audit information into the CSA Database, each
chemical safety audit report was first summarized and then placed in a standardized
format called a profile (see Attachment 1). The profile contains background material,
such as the facility name, location, primary processes and products, hazardous substances
examined for the audit, storage, shipping, and handling practices, and name, title, and
expertise of each audit team member. Also, the profile provides a summary of the
chemical process and storage information and includes the conclusions and
recommendations made by the audit team.
The organization of the profile information is based on the protocol provided in
the Guidance Manual for EPA Chemical Safety Audit Team Members. This protocol,
referred to as the CSA Protocol, is a topic outline intended to guide the scope and
content of the audit and to provide the organizational structure for the preparation of
the audit report (see Attachment 2). Consequently, the protocol provides a convenient
way to organize and structure the chemical safety audit database so that profile
information can be directly entered into, and accessed from, the database. The database
is updated on a regular basis as final audit reports are received by EPA headquarters.
In the database, each audit team conclusion and recommendation is categorized
and assigned a three-digit code corresponding to the headings in the protocol outline (see
Attachment 3 for a listing of these codes). For instance, a recommendation by an audit
team suggesting that the audited facility should consider implementing a more formal
employee training recordkeeping system would be assigned the code 722 (corresponding
to section 7.2.2 in the CSA protocol) - 'Training Practices."
Information Contained in CSA Database
The database contains the following audit profile information:
o Background information, including the facility name, address, EPA region,
and SIC code(s); the dates of the audit, and the proximity of the facility to
sensitive populations. In addition, the reasons for selecting the facility for
the audit are provided in the form of standardized numerical codes (see
Attachment 4).
o The name and telephone number of the primary EPA contact person on
the audit team.
o Confirmation as to whether the facility has completed an Accidental
Release Information Program (ARIP) questionnaire.
o A list of the extremely hazardous substances or CERCLA hazardous
substances that are the focus of the audit.
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Facility information describing the chemical process(es), the storage
methods, the snipping and receiving procedures, and the material trans;er
methods in use at the facility.
The detailed audit observations (conclusions) of the audit team on the
facility, its processes, and its policies. These conclusions are divided into
the following six sections; process information, chemical accident
prevention, accidental release incident investigation, facility emergency
preparedness and planning activities, community and facility emergency
response planning activities, and public alert and notification procedures.
Each conclusion is classified by a three-digit code (see Attachment 3) that
corresponds to the appropriate section of the CSA protocol.
The recommendations suggested by the audit team for the facility are also
separated according to the six sections listed for the conclusions. In
addition, each recommendation is also categorized by a three-digit code
(see Attachment 3) corresponding to the appropriate section of the CSA
protocol.
The follow-up activities, conducted after the audit has been completed, by
the facility, the EPA regional offices, or state or local authorities,
A list of the names, agency/organizational affiliation, areas of audit
responsibility, and expertise for each member of the audit team.
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IIL System Structure
Software
The Chemical Safety Audit database is a user-friendly program that allows you to
enter and access a variety of information concerning the facilities in EPA's program of
chemical process safety audits. The system software consists of two parts: the computer
program and the Chemical Safety Audit data. The computer program provides the
mechanism to store, enter, and access the data. The program is written in the language
called Clipper. The Chemical Safety Audit data are stored in dBase III files. The
operator does not need to know how to use dBase III or Clipper in order to input the
data or access the data. Instead, the user-friendly program guides you with easily
understandable menus.
Hardware and Equipment Required
The computer program will run on an IBM or IBM-compatible computer with
DOS 2.0 or greater disk operating system; the program will not run on an Apple
computer. A variety of printers (e.g., Hewlett-Packard laser, Epson dot matrix) may be
used to obtain a hard copy of the profile information -- the general printout format is
specified in the computer program and displayed in Attachment 1. If a color monitor is
used, the screens will appear in several colors. Although the computer program itself
can be stored on one 3.5 or 5,25 inch diskette, several additional diskettes may be
needed to store the large quantities of data contained in the Chemical Safety Audit
profiles. In order to minimize the number of diskettes, the database's electronic files
have been compressed to temporarily reduce the storage space required. Instructions for
expanding these files are provided in the next section on loading the computer program.
Loading the Program onto Your Computers Hard Disk
Accompanying this User's Manual, you should have received one or more 3.5-inch
or a 5.25-inch diskette(s) labeled "CSA Database." All of the files necessary to run the
computer program are on this diskette. As the database grows, you will receive
additional "CSA Database" diskettes with appropriate installation instructions.
To load the program into your computer hard disk (drive C), follow these steps;
1. To start, turn on the computer. Exit from any program or menu to the
DOS operating system. If the e:> prompt does not appear, follow the
appropriate instructions listed below to get to this prompt.
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o If your prompt appears as A:>, B:>. D:>. or E:>, type c: and press
.
or
o If your prompt appears as cMirectoty namo, type cd\ and press
2. The next step is to copy all files on the diskettes into a directory of the
computer's hard disk. First, make a CSA directory (a special computer
folder) to house all of the CSA files by typing md\csa at the c: prompt and
pressing . Then, go into.this CSA directory by typing the
command cd\csa and press . The prompt should now read
c:\csa >.
Note: If you have installed a previous version of the CSA database on
your computer, you must first remove all of the earlier files prior to
installing this version of the database. To remove the files in the CSA
directory, at the c:\csa> prompt type delete c:\csa\*.* and press .
3. Next, type a:unzip. The database has now been installed in the directory
labeled "csa" on your c: (hard disk) drive. Save the diskette as a backup in
case the files on your hard disk are lost or damaged.
4. Begin the computer program by typing the command csa at the c:\csa >
prompt and press . The CSA introductory screen will now appear.
Press any key to access the main menu, or to leave the program.
You are now ready to use the CSA database.
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IV. Operation of the System
Starting the Program Each Time
After the first time you loaded the CSA computer program onto your computer's
hard disk, you no longer need the diskettes. Any time you want to start the CSA
computer program, follow these steps;
1. Switch to the hard disk drive that contains the CSA database. Do this by
getting to the c:> prompt by first exiting from any program or menu to the
DOS disk operating system. If the correct prompt does not appear, follow
the appropriate instructions.
o If your prompt appears as A:>, B:>, D:>, or E:>, type c: and press
,
or
o If your prompt appears as c-^directory name>, type ed\ and press
< enter >
2. Change to the CSA directory, the section of your computer's hard disk that
contains the CSA database. At the c:> prompt, type cd\csa and press
.
3. Start the computer program by typing csa and pressing < enter >. The CSA
introductory screen will now appear. Press any key to access the main
menu, or to leave the program.
The Main Menu
The main menu lists the following six options:
ฆ Browse Profile
Displays a list of all of the profiles in the database. You can access any of
these profiles and page through the data.
ฆ Search for Profiles of Interest
Displays the search menu so that you can generate a list of profiles meeting
any combination of the following parameters: EPA region, facility SIC
code(s), chemicals examined during the audit, key words in the profile, and
the recommendations and conclusions made by the audit team. In addition,
you can browse and print selected profiles with the search option.
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ฆ Calculate Statistics
Computes frequencies for a number of database elements, including facility
SIC code, reason for facility selection, chemical examined, audit team
recommendations, presence of sensitive populations, and length of audit.
ฆ View Most Recent Statistics
Displays the statistics generated the last time the "calculate statistics" option
was selected. You may print these statistics using the key.
ฆ Print Profiles
Prints a copy of one or more of the profiles in the database.
ฆ Configure
Enables you to designate the appropriate computer port for printing CSA
database information on your computer network (see below).
On your computer screen, you will see the menu displayed in Exhibit 1. Using the
t and * keys, you may move the highlighted box over the desired option and select it by
pressing < enter>. Another helpful key function is < escape>, which allows you to exit
the computer program from the main menu. Also, pressing repeatedly will
return you to the main menu from any point in the program. Once into the program,
PgUp and PgDn enable you to page up and page down through the audit information.
Each of the mam menu options, except for the "calculate statistics" and "view most recent
statistics" functions, are described below.
ฆ Browse Profile Option
The BROWSE PROFILES option allows the user to page through a profile or
profiles. When you select BROWSE PROFILES. the program will display an
alphabetical list of all of the facility names in the audit database (see Exhibit 2). Use * *
or PgUp and PgDn to move through the list. To browse a profile, move the lighted box
over the requested profile number and press . This will put you at the first page
of the requested profile in the database. Exhibit 3 provides page number references to
find quickly specific profile information on the computer screens.
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Exhibit 1
Main Menu
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Exhibit 2
List of Facilities
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-11-
Exhibit 3
Quick Reference
to Contents of CSA Computer Screens
Information
Page
Facility Name and Address
1
SIC Codefs)
1
Regional Contact Name
I
Audit Dat.es
1
Sensitive Population Description
1
Reason for Selecting Facility
1
Hazardous Chemical(s)
2
Processes Used
3 & 4
Storage Systems
5
Shipping and Receiving
6
Material Transfer
7
Conclusion - Chemical Hazards/Process Information
8 &
Conclusion - Chemical Accident Prevention
10 & 11
Conclusion Accident Release Incident Investigation
12 & 13
Conclusion - Facility Emergency Preparedness and Planning Activities
14 & 15
Conclusion - Community and Facility Emergency Response Planning Activities
16 & 17
Conclusion Public Alert and Notification Procedures
18 & 19
Recommendation Chemical Hazards/Process Information
20 &. 21
Recommendation' Chemical Accident Prevention
22 & 23
Recommendation - Accident Release Incident Investigation
24 & 25
Recommendation Facility Emergency Preparedness and Planning Activities
26 & 27
Recommendation - Community and Facility Emergency Response Planning Activities
28 & 29
Recommendation - Public Alert and Notification Procedures
30 & 31
Audit Team Members
32-34
Follow-up Activities
35
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Moving Through the Profile:
PgUp and PgDn allows you to thumb through a profile page-by-page; a
status line at the top of the screen tells you which
profile you are browsing'and the page number.
F8 allows you to jump back or ahead to any page in the
profile; you can thereby browse the profile information
listed in Exhibit 3 in any order your choose.
Accessing Open-ended Descriptions
Several profile headings (e.g., "Population Description," "Processes Used,"
"Storage Systems," "Conclusions," and "Recommendations") contain open-
ended desjcriptions that may be longer than space on the computer screen
permits. Only a few sentences of the descriptions can be seen initially;
instructions to view the full description appear on the computer screen.
Follow these steps to expand the text window to see the full descriptions
for specific profile headings:
"Population Description" shows the first two lines of the open-ended
description; to see the full description, press F4.
"Processes Used" shows a brief heading-and the first lines of each
open-ended description. Press F4, F5, or F6 to display the first,
second, or third full description, respectively. On the next page,
press F4, F5, and F6 to see the full description for the fourth, fifth,
and sixth process, respectively.
"Storage Systems," "Shipping and Receiving," and "Material Transfer"
show the first two lines of each open-ended description. Press F4,
F5, or F6 to display the first, second, or third full description,
respectively.
"Conclusions" shows the three-digit code and corresponding heading
(see Attachment 3). Under the code and heading, the screen shows
the first few lines of the open-ended conclusion description. Press
F4, F5, or F6 to display the first, second, or third conclusion
description, respectively. On the next page, press F4, F5, and F6 to
see the full description for the fourth, fifth, and sixth conclusion,
respectively.
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"Recommendations" shows the three-digit code and corresponding
heading (see Attachment 3). Under the code and heading, the
screen shows the first few lines of the open-ended recommendation
description. Press F4, F5, and F6 to display the first, second, and
third full recommendation description, respectively. On the next
page, press F4, F5, and F6 to see the full description for the fourth,
fifth, and sixth recommendation, respectively.
"Follow-up Activities" describes actions taken by the facility, by state
and local government, and by the appropriate EPA regional office
after the audit has been conducted. Again, the first two lines of
each open-ended description are shown, and you can press F4, F5,
and F6 to display the corresponding full descriptions.
To exit from the expanded text windows, press . When you are finished
browsmgL.pressing again will bring you back to the main menu.
ฆ Search for Profiles of Interest Option
The computer program enables you to search for specific profiles of interest. By
selecting specific parameters (e.g., facilities using chlorine in EPA Region 6), you can
access those profiles that meet your needs. You may search using any combination of
the following parameters:
o EPA region
o SIC code(s)
o Chemical
o Key words in open-ended descriptions
o Recommendation code(s) (see Attachment 3)
o Conclusion code(s) (see Attachment 3)
On the computer screen, you will see the display in Exhibit 4.
Entering Information for a Search:
To conduct a search, type in your search specifications and then press .
o For the EPA region, enter a number from 1 to 10.
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Exhibit 4
Search Screen
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-15-
o For the SIC code(s). enter 4-digit numbers. This allows you to find profiles
in a 4-digit SIC code or in a range of SIC codes. If you choose a 2- or 3-
digit SIC code, you must add placeholders to the end of the SIC code. For
example, if you wanted to search for all profiles in the chemical
manufacturing industry (SIC code 28), you would enter 2800-2899. the
range of codes associated with that industry. If you wanted to limit the
search to the agricultural chemicals industry (SIC 287), you would enter
2870-2879. Additionally, you could search for profiles in a 4-digit SIC code
(the nitrogenous fertilizer industry) by entering the same SIC code twice
(e.g., 2873-2873). Exhibit 5 provides a sample list of two-digit SIC codes.
To determine industry definitions associated with other SIC codes, consult
the Standard Industrial Classification Manual 1987, located in most libraries.
o For the paramter CHEMICAL, the program will search for the chemical
name that you enter in the hazardous substance entry.
o For the parameter KEY WORD, the program will search for the word(s)
that you enter, up to twenty characters, in every profile memo entry.
o For both the recommendations and conclusions code, type in 3-digit
numbers from the list in Attachment 3, The search option allows you to
find profiles that have one type of recommendation/conclusion or any one
of a range of recommendations/conclusions. The recommendations and
conclusions in Attachment 3 are organized into a numeric outline so that
you could capture categories and/or subcategories of recommendations and
conclusions by specifying a range of codes. For example, you may want to
find all the profiles that have recommendations about storage and handling
practices. This search will encompass all of the recommendations relating
to storage and handling, including "General Storage and Handling" (code
610), "Storage Systems" (code 611), "Shipping/Receiving" (code 612), and
"Material Transfer" (code 613). Consequently, you would enter (610-613)
to capture all of the "Storage and Handling" recommendations. If you
wanted to find the recommendations only in Material Transfer, you would
enter the corresponding code twice (e.g., 613-613). For any
recommendation/conclusion code range specified,- a profile need only have
one code within a specified range to be selected.
o For parameters you do not wish to specify, just press .
Conducting a Search:
After you enter the last search specification (the conclusions code), another search
screen will appear. This screen asks you to choose between a high speed search and a
longer, more detailed search. On the computer screen, you will see the display in
Exhibit 6. Both searches will look for the key words and codes that you specified. Both
searches will tell you what page/section of the profile to find a key word/code. However,
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Exhibit 5
Quick Reference to Select Two-Digit SIC Codes
SIC CODE INDUSTRY
20
Food and kindred products
21
Tobacco products
22
Textile mill products
23
Apparel and other products made from fabrics
24
Lumber and wood products, except furniture
25
Furniture and fixtures
26
Paper and allied products
27
Printing, publishing, and allied industries
28
Chemicals and allied products
29
Petroleum refining and related industries
30
Rubber and miscellaneous plastics products
32
Stone, clay, glass, and concrete products
33
Primary metal industries
34
Fabricated metal products, except machinery and
transportation equipment
35
Industrial and commercial machinery and computer
equipment
36
Electronic and other electrical equipment and components,
except computer equipment
39
Miscellaneous manufacturing industries
49
Electric, gas, and sanitary services
50
Wholesale trade -- durable goods
51
Wholesale trade - nondurable goods
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Exhibit 6
High-Speed Detailed Search
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-18-
o a high speed search will provide you with the location of only the
first appearance of the key word/code in the profile. This search
method is relatively quick and should be used if you are performing
many exploratory searches;
o a longer, more detailed search will provide you with the location of all
appearances of the key words/codes in the profile. This method should be
used if you are performing searches in order to thoroughly review the
profiles and reference the key words/codes.
The Profiles Selected
When the search is activated, the database will select the appropriate profiles and
list their profile number, facility name, and address (see Exhibit 7). The profiles selected
by the database will satisfy every condition entered. For instance, if you enter the
chemical CHLORINE and EPA Region 6, the database will list only facilities that are in
EPA Region 6 and use chlorine as a hazardous chemical. However, if you have specified
codes for both conclusions and recommendations, the search mode does not require that
a profile match the specifications for both conclusions and recommendations. Matching
either a conclusion code or a recommendation code will be sufficient to select the profile.
Also, for any recommendation/conclusion code or SIC code range specified, a profile
need only have one code within a specified range to be selected. If the search does not
select any profiles, the program will display 'No records match criteria'. To conduct
another search, simply press < escape> once and enter new search specifications.
Locating Key Words/Codes in the Selected Profiles
At the top of the screen listing the profiles selected in the search (see Exhibit 7),
a table tells you where to find the key words/codes mentioned in the profile. This table
gives the profile page number and the profile section where you can find a reference to
one of the key words/codes you specified. If you highlight a different profile (using 4t),
the look-up table will change to correspond to the new profile. If there are more page
numbers than the table can display, you can browse all key word/code locations by
pressing . When you are finished browsing, you can return to the profile list by
pressing again. You should record the page numbers or profile sections so you
can quickly find the key word/code using the browse routine in the search mode.
Browsing the Profiles Selected in the Search Mode
When the computer program lists the profiles that meet your specifications, you
can browse any of these selected profiles by using H or PgUp and PgDn to move
through the list and by pressing over the desired profile. This will put you at
the first page of the desired profile in the database. Follow the same directions in the
above section on BROWSE PROFILES.
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Exhibit 7
List of Selected Facilities
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-20-
Prindng the Profiles Selected in the Search Mode
You can print one or more profiles selected from the search mode. You may
select the ones you want to print by moving the lit box over them and pressing the
. The profiles you have selected will have a check mark next to them. You
may select all the profiles by pressing <*>, or unmark all the profiles by pressing <->.
When you have marked all the profiles you want to print, press F10 to print them. Note:
Before you can you print within the SEARCH option, you need to follow the directions in
the section called CONFIGURE. If you have already configured your printer, you can
print from the search mode. After printing, press once to return to the search
menu and press several times to return to the main menu.
Suggestions for Searches
The following are three examples of searches you could perform:
1. Looking for Common Safety Problems or Patterns
For instance, an EPA Region 5 audit team member wants to use the search
option to look for common safety problems. As a technical person, audit team
veteran, and expert about accidental release incidents, he suspects industry-wide
safety problems in storage tank equipment that handle chlorine. Several EPA
Region 5 audits have indicated that problems exist in this area. Consequently, he
decided to run the following search of all profiles conducted across the nation to
see if other audit team members made conclusions or recommendations about
storage systems for chlorine:
o Selected SEARCH option from the main menu
o Entered CHLORINE as the chemical
o Entered the Recommendation code for storage systems (611-611)
o Entered the Conclusions code for storage systems (611-611)
To complete the search specification, he chose a high speed search because he
plans to make other exploratory searches with different specifications. The search
uncovered quite a few profiles. This may indicate that a chlorine storage system
problem may exist. However, the audit team member decided to conduct another
more specific search before examining the conclusions/recommendations in so
many profiles. Suspecting a specific problem in the organic chemical
manufacturing industry, he adds the SIC code range for this industry (2860-2869)
to the above search specifications. Anticipating fewer selected profiles and
interested in the content of the profile recommendations, he opts to conduct the
option of a detailed search. From the results of the search, he uses the key
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-21-
word/code location information to quickly browse through the recommendations of
interest in each profile selected, looking for common safety management problems
and successful practices regarding chlorine storage systems.
2. Looking for Audit Experts
An EPA Region 6 audit team member is planning to conduct an audit of a
fertilizer facility but knows little about fertilizer production and the risks of
ammonia releases from process equipment. She could search all profiles to
identify field experts on fertilizer/ammonia facilities that could be contacted for
advice in conducting the audit or even could participate in the audit.
o Select SEARCH option from the main menu
o Enter AMMONIA as the chemical
o Enter SIC codes 2871-2875 corresponding to the fertilizer industry
To complete the search specification, the audit team member chose a high speed
search because she is interested only in identifying profiles with information about
fertilizer field experts. In the profiles selected, she can browse the section of the
profile on audit team members and expertise. If she desires, she could search for
experts located close to her region by adding a region specification in another
search.
3. Genera! Search Using a Key word:
An audit team member is interested in seals in pressurized systems and the
occurrences of accidental releases from seals. Here, a key word search may be
helpful. The computer can search for a key word in all profile memo entries
including population description, processes used, storage systems, shipping and
receiving, material transfer, conclusions, and recommendations. If he wanted to
know which facility audit profiles made reference to seals, he would:
o Select the SEARCH option from the main menu
o Enter SEALS as a key word
The computer system would search all memo fields and list the profiles that
contained the word SEALS.
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-22-
ฆ Print Profiles Option
The PRINT PROFILES option from the Main Menu enables you to make a hard
copy of one or more profiles. Although the computer program has been programmed to
be compatible with your type of printer, you need to follow the directions in the next
section called CONFIGURE before you can print. On choosing the PRINT PROFILES
option, the computer screen will list ali the profiles in the database (Exhibit 2). You may
select the ones you want to print by moving the lit box over them and pressing the
< space bar>. The profiles you have selected will have a check mark next to them. You
also may unmark a selected profile by pressing the . You may select all the
profiles by pressing <*>, or unmark all the profiles by pressing <->. When you have
marked all the profiles you want to print, you may press FIO to print them, and press
< escape > to return to the main menu. Attachment 1 is a sample printout.
ฆ Configure Option
The CONFIGURE option allows you to designate a computer port. The port
specifies the path needed to direct the print information to your printer. (Specifying the
type of printer is not handled through this option.) The configure option allows for
several different 'hook up' options that are specific to certain computer network systems.
For example, the current default port setting is 'LPT1' which enables proper hook up on
all EPA computer networks. Other computer networks may require other port hook ups.
A person familiar with your computer system (e.g., data management division personnel)
may know which port code is appropriate. Before you print a profile, the port option
should be properly configured to your computer network system. Select CONFIGURE
from the main menu and choose from the following codes and press .
Port Codes
LPTl (default)
LPT2
LPT3
COM1
COM2
The computer will save this configuration, so you will not need to configure again as long
as you use the same computer network system. Thereafter, you can skip this
configuration step any time you send a profile to your printer.
Exiting from the System
You can exit from any point in the program by pressing repeatedly.
-------
Attachment 1
Attachment 2
Attachment 3
Attachment 4
LIST OF ATTACHMENTS
Audit Profile Printout
Protocol Outline in CSA Guidance Manual
Codes for Audit Report Recommendations and Conclusions
Codes Summarizing the Reasons for Selecting Facility for Audit
-------
Attachment i
Facility Name:
CHEMICAL SAFETY AUDIT PROFILE
Rhone - Poulenc -- Silver Bow Plant:
Facility Location:
Audit Start Date:
Days to Complete Audit:
Description of Facility:
SIC Code(s):
Region:
Proximity to sensitive
Butte, MT
05/27/92
2
2813,
8
population:
Reasons for Facility
Selection:
The town of Ramsey, home to 50 families and
an^elementary school, and the Port of
Montana, a truck and rail transportation
exchange, are both located within 0.75
miles of the plant. The 20-family town of
Rocker is 3.5 miles northeast.'
01 - ARIP Questionnaire
02 - History of Releases
Focus o"f Audit:
Hazardous Substance(s)
Examined: Phosphorus
Sulfuric Acid
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Facility Activities
Storage :
o Elemental phosphorous (P4) is stored under a water blanket in
pressurized carbon steel storage tanks to prevent contact
with air. Nitrogen or carbon dioxide could also be used to
blanket the Pi. Railcars provide additional storage when
necessary. Because winter weather can interrupt mining
operations, the facility normally stockpiles a nine-month
supply of phosphate ore, a two- to three-month supply of
silica rock, and a four-week supply of coke on site during
the summer. Stockpiles are watered to suppress dust
emissions. Sulfuric acid is stored in a 12,000 gallon tank
with secondary containment.
Shipping and Receiving;
o Coke "and phosphate ore- are deli-vered by rail car and unloaded
by car tipples. Natural gas is delivered by pipeline.
Sulfuric acid is delivered by truck and silica by rail, P4
is shipped in specially designed railcars under a water and
nitrogen blanket. The cars are first filled with water,
which is then displaced by molten P4. On average, one
railcar of P4 is shipped daily.
Material Transfer:
o Molten P4 is transported in stainless steel lir.as that .are
insulated and heated to prevent the molten material frcm
solidifying inside the lines. Carbon monoxide (CO) is piped
from the P4 condenser to the phosphate ore nodulizing kilns,
where it is consumed as fuel. When kilns are out of service,
excess CO is, vented to a flare. Phosphate ore is transferred
by conveyors from the storage area to the nodulizing kiln,
and then to the furnace feed bin. The feed burden is
transferred by skip hoist. Sludge from the filtering process
in the P4 handling area is transported in corrosion resistant
stainless steel lines to the roaster.
Process Area(s):
o Phosphorus production
The phosphate ore is dried, calcined, and nodulized by
incipient fusion in one of two rotary kilns fueled by a
mixture of CO from the P4 furnace and natural gas. Gaseous
emissions from the kilns are treated in water spray towers
and wet electrostatic precipitators to remove particulate
-------
matter. Emissions also include hydrogen fluoride, formed
when fluorides driven from the phosphate ore in the furnace
contact water vapor in the atmosphere. The nodules are
cooled on oscillating grace coolers and screened to remove
oversize and undersize nodules before being conveyed to the
furnace feed proportioning silo. Oversize nodules are
crushed and conveyed to the kiln feed proportioning silo.
Fines are returned to the kiln feed silos or used for
processing sludge in the roaster.
Silica and coke are blended with the phosphorus nodules prior
tc entry into the furnace. The furnace reaction results in
ferrophos, slag, CO, and P4. The gaseous P4 is condensed,
filtered to remove sludge, and then pumped in the molten
state to storage tanks. The CO is pumped to the nodulizing
kilns for use as fuel. Excess CO is vented to a flare. The
ferrophos and slag are tapped out from the furnace four to
five times a shift. Some ferrophos is sold for vanadium
recovery; a small amount of the slag is sold for paving and
construction material. The remainder is stored on-site in
large piles. Sludge and kiln fines from the kilns are used
in the roaster, which removes remaining P4. Process water
from the P4 condenser and the P4 handling system is treated
in a clarifiar and then pumped to a large clay-lined settling
pond to remove the fines. Tailings and the tailings pond
occupy 240 acres.
-------
Conclusions:
Hazards Process Information:
520 - Facility Management of Chemical Hazard Data
KSDS information is available for review by plant personnel.
Process modification proposals are thoroughly reviewed at
facility and corporate levels to ensure the modification will
not present any unreasonable health and safety risks. A
comprehensive industrial hygiene monitoring program is
administered by the Safety and Industrial Hygiene Supervisor.
However, there is no medical monitoring program to reveal
possible acute or chronic toxic effects of hazardous
cnemicals at the plant.
611 - Storage Systems
Flow lines and vessels containing molten P4 are labeled,
although some of the labels inside the furnace building were
difficult to read due to their locations. Confined areas
where CO could accumulate are identified by warning placards.
622 - General Description of Process Equipment Capacity
All piping and vessels which come into contact with molten P4
are constructed of stainless steel. The furnace bed and
electrodes are constructed of carbon.
623 - Back-ups and Redundancy
The facility has diesel-powered auxiliary generators which
would allow critical equipment such as water pumps, electrode
lift hoists, facility lighting, and telephone systems to
remain in operation. Approximately 10,000 gallons of diesel
fuel for the backup generator is kept on site, for which the
facility has developed an SPCC plan. The facility also has
auxiliary generators for the backup water supply wells and
pumps to ensure that fire fighting and deluge systems are
always operational.
624 - Process Parameter Monitoring
Parameters are monitored using a combination of analog and
digital readouts. Process parameters monitored in the
nodulizing process include raw material feed rates, air flow
rates, natural gas and CO usage rates, pressure, temperature,
kiln speed, and scrubber inlet and effluent pH, Pressure,
temperature, and material flow rates are monitored hourly the
P4 operators. Operators check the pH of the tap hole fume
scrubber effluent every shift and record the' results.
625 - Environmental Monitoring
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Scruceer opacity is also monitored continuously as required
by zr.e facility's permit. Rhone - Pouier.c is required to
demonstrate their compliance with che state air quality
perrr.it cy conducting quarterly stack sampling for particulate
. emissions. They are also required to perform monthly
sampling cf forage in the area during the summer months to
ensure that fluoride levels do not exceed the allowable
limits. In addition to the continuous opacity monitors on
the scrubber stacks, three plant employees are certified to
read opacity per U.S. EPA Test Method 9. Finally, personnel
entering process areas that may contain dangerous levels of
CO are required to wear personal CO monitors to ensure that
they are not exposed to hazardous levels-of the gas.
Chemical Accident Prevention:
o 710 - Management Activities
From 1983 to 1986, ownership of the plant changed four times
and there was little or no investment in the plant.
Management and technical staff have experienced significant
turnover. Rhone-Poulenc requires each subsidiary to develop
and implement a Process Hazard Management Program (PHMP),
reviewed at the corporate .level prior to acceptance and
implementation. Corporate level assistance is available if
needed. Facility HA20P evaluation teams include a corporate
representative. Rhone-Poulenc has established minimum
requirements to be covered in each Safe Job Analysis manual,
and has established company-wide construction and operation
standards for facilities that handle P4 in its "P4 Manual."
The Pi Manual covers training, equipment, and the safe
handling of elemental phosphorus. Rhone-Poulenc issues a
handbook to each employee defining corporate health, safety,
and environmental practices. Rhone-Poulenc, Inc. policy
requires each facility to aduit each process unit subject to
OSHA regulation once every three years. Audits are done to
ensure P&XDs are current and that HAZCPs have been performed
for all process units that have undergone modifications since
the last audit.
o 722 - Training Practices
Company-wide regional PHMP training sessions are held for
employee training and understanding of the PHMP. Training
sessions are held for technicians and mechanics to emphasize
the importance of accurately documenting maintenance
procedures. P4 Manual training is held twice a year for all
employees. In addition to the PHMP training, each new
employee must undergo six hours of safety
training/orientation. Opon completion, the new employee's
process area supervisor will guide the employee in one day of
in-plant orientation and one day of SJA review of procedures
-------
related to the process area where he or she will work. The
employee will then be allowed to perform "lightly supervised"
work and have daily feedback sessions with the process
supervisor. Upon transfer to a new process area, the
employee must undergo process-specific orientation for the
new process. Maintenance personnel, department heads, and
supervisors hold daily safety meetings. The facility
conducts monthly safety/training meetings attended by all
personnel. Contract workers are required to undergo a
separate safety training/orientation program, after which
they are assigned to the supervision of the process engineer
for the area in which they will work. Contractors are
instructed to report any accidents or near misses to the
engineer, and are identified with stickers on their hard
hats. The facility is currently preparing a slide
presentation to ensure uniformity in the contractor
orientation program and a quiz to verify the contractor's
comprehension of the material.
72 3 - Equipment Maintenance Procedures
Unit supervisors are required to review Safe Job Analysis
manuals with maintenance personnel prior to work on major
pieces of equipment. The facility has a preventative
maintenance schedule for key equipment based on historical
failure frequencies. A separate environmental equipment
maintenance team completes a daily checklist for all
environmental control equipment, A paper work-order system
is currently used to initiate maintenance. . The facility is
planning to convert this system to computerized system to
improve maintenance recordkeeping. Rhone-Poulenc uses a
pyrometer to check for irregularities in the block
temperature of the furnace to help predict a "tap-out" -- the
uncontrolled release of molten slag and ferrophos. The
maintenance department uses the lockout/tagout system. The
kiln ESPs are cleaned weekly or more often if the scrubber
opacity or ESP voltage-drop monitors indicate poor
performance. The maintenance department works the day shift,
with designated personnel on-call for emergency repairs.
Opacity monitors are automatically recalibrated daily.
731 - Hazard Evaluation
HA20P analysis is the primary method of hazard evaluation
used at this facility, although causal tree and what-if
methods axe scenetimes used. The HAZQP team, made up of three
engineers, one corporate executive, and a team leader, is
responsible for developing equipment specific pre-startup
safety reviews. HAZOP evaluations are conducted every five
years, or when process modifications are made. HAZOP
analysis for the on-site P4 handling operation, which the
facility has identified as the area having the greatest
-------
potential for a hazardous release, has been completed. HAZOP
evaluations for the furnaces and kilns are scheduled to be
completed by year-end 1992 and 1993, respectively;
evaluations for off-site P4 handling and the mining operation
have not yet been scheduled. Release modeling is not
performed at the facility; however, the capability to do
modelling is available at the corporate level.
o 740 - Release Prevention Systems
The facility has upgraded its tap hole fume scrubber system
three times since 1977. The latest modification was made in
1989, when a new tap hole fume scrubber, a kiln scrubber, and
continuous emission monitors were installed. There are three
furnace scrubbers at the facility; bcrabber maintenance can
be performed on one of the units without shutting down the
furnaces.
o 750 _ - Mitigation Systems
The sulfuric acid and diesel storage areas are surrounded by
concrete secondary containment barriers. Spills outside the
containment will be captured before leaving the property by
the runoff collection system and pumped to the settling pond.
Soda ash is kept at each sulfuric acid storage and
loading/unloading area to neutralize small spills. The P4
handling area is equipped with a water deluge system
automatically activated by heat; it can also be activated
manually. Each P4 line flange has a gasket guard screen that
prevents molten material from being sprayed over a large area
should a line flange gasket fail.
Accident Release Incident Investigation;
o 810 - History of Accidental Releases/Incidents
The facility has reported 10 chemical releases since 1990,
eight involving phosphorus, totaling 284 pounds. One
accident resulted in 1,500 pounds of sulfuric acid spilling
into the secondary containment area when a tank overflowed.
The tenth release was a continuous emission of radionuclides
from the phosphate ore.
o 810 - History of Accidental Releases/Incidents
A gasket failure caused a fatal accident in 1982. The gasket
had been pressure tested shortly before it failed; the test
apparently failed to indicate that the gasket was about to
fail.
o 82 0 - Facility Procedures - Accident Investigation
Incident release forms are completed for spills and releases
as well as for injuries. Copies of these reports are
distributed to the plant manager and health, safety, and
-------
environmental supervisor. Tne supervisor initiates
corrective action. Corporate management reviews results of
some of the incident investigations. Results of incident
investigations are conspicuously posted on bulletin boards
tr.roughout the plant. Causual tree analysis is applied to
the more serious incidents to understand their root causes.
Employees and contractors are trained in complying with
release reporting requirements.
Facility Emergency Preparedness and Planning Activities:
o 913 - Facility Emergency Response Plan
The facility is in the process of revising its emergency
response plan. The new plan will outline possible chemical
release scenarios and recommended response techniques, as
well as update the call-out list and the guidelines for media
interaction.
o 930 Fire, Evacuation, and Rescue Corridors
Although fire and man-down drills are conducted periodically,
evacuation drills are not regularly conducted, and evacuation
routes are not posted. Evacuation reassembly points were
identified, but no secondary assembly points were designated
if the primary assembly point was downwind of a chemical
release. The facility has no formal way of accounting for
its personnel.
o 94 0 - Emergency Equipment Provisions
There are ten fire-hose houses, portable fire extinguishers,
two SCBA units near the furnaces, and eye-wash stations and
emergency showers throughout plant operating areas. There is
also a first-aid station near the P4 handling department.
The facility relies on outside ambulance service to evacuate
the injured.
o 950 - Emergency Response Chain of Authority
During one incident, outside emergency responders were called
and had to wait outside the gate for quite some time before
the plan manager arrived from home.
o 970 - Emergency Communication Network within the Facility
An alarm sounds if an emergency shower is activated or if
anyone enters the first-aid station. Plant personnel can
communicate by personal two-way radios. A system of steam
whistle blasts identifies the area of the plant where the
emergency respone team assembles in response to a fire. An
oscillating siren indicates a man down and a whistle and
siren is the evacuation alarm.
o 980 - Emergency Response Personnel Training Requirements
-------
The facility has five-man emergency response teams on"each
snift, made up of people who can safely leave their jobs in
tne event of an emergency. These people are trained and
drilled m CPR, SCBA use, fire suppression and emergency
rr.edical assistance.
Community and Facility Emergency Response Planning Activies:
o 101 - Facility planning and Outreach Activities with
Community
Rhone-Poulenc belongs to the Chemical Manufacturers
Association, the Phosphorus Emergency Response Team (another
industry group), and the Chemtrec Emergency Response System.
o 102 - Lccal/Community Emergency Response Plan
Although the facility is a member of LEPC, community
involvement and awareness activities on the part of
Rhone-Poulenc has been minimal in the past. Current
management is considering having an open house to improve
community relations and awareness. No exercises that involve
the community have been held.
Public Alert and Notification Procedures:
o 111 - Procedures for Public Notification of Releases
Plant personnel are responsible for notifying regulatory
agencies, the plant manager, and any neighbors who might need
to be evacuated. The on-site supervisor makes this
notification if Silver Bow Plant personnel cannot be reached.
o 114 - Community and Facility Contacts
The facility has a list of seven alternate facility contacts
in order of notification to be used in case one or more of
the people cannot be contacted.
o
115 - Facility and Media Interaction
Rhone -Poulenc's policy is to notify the media of a chemical
accident through its corporate office.
-------
Recommendations:
Chemical Hazards - Process Information:
510 - Overview of Hazards for Chemical Is) being Audited
Rhone-Poulenc should provide regular dental examinations for
employees who frequently work m P4 handling areas.
Elemental phosphorus accumulation in the body will first show
up in a dental exam.
625 - Environmental Monitoring
Because phosphate.ore contains numerous trace metals such as
arsenic that could contaminate the ground water,
Rhone-Poulenc should consider monitoring the groundwater to
provide early detection and remediation of amy contamination
which might occur.
Chemical Accident Prevention:
o 721 - Standard Operating Procedures
The SJA and P&ID revisions should be completed as soon as
possible, and the SJA manual should be updated to meet all of
OSHA's requirements. The manual should cov'er initial process
start up, temporary operations, confined space entry, etc.
Accident Release Incident Investigation:
Facility Emergency Preparedness and Planning Activities:
o 93 0 - Fire, Evacuation, and Rescue Corridors
The facility should designate secondary assembly points and
post evacuation routes in all operating areas. A
sign-in/check-in system should be established to verify the
number of people inside the plant at amy time, including
contractors and visitors. Evacuation drills should be held
to train employees in evacuation procedures.
o 940 - Emergency Equipment Provisions
In addition to existing shower stations, water tanks should
be provided in P4 handling areas for P4 decontamination.
o 950 - Emergency Response Chain of Authority
The new emergency response plan should include an emergency
response chain-of - command. It should define and assign
functions to individuals from the plant management team, such
as determining the extent and type of incident, whom to
notify, determining what plant areas are involved or
threatened, establishing control of the situation, isolating
-------
the area, calling for help, establishing security,
interacting with the media and families of plant personnel,
etc.
o 950 - Emergency Response Chair, of Authority
Rhone-Poulenc should designate an on-site coordinator and a
backup for each shift to serve as a contact point and work
with outside emergency respcnders in the event of an accident
requiring outside assistance.
Community and Facility Emergency Response Planning Activities:
o 101 - Facility Planning and Outreach Activities with
Community
Rhone -Poulenc should increase its efforts to promote
community involvement and awareness. The facility should
work with local emergency responders and the 911 emergency
notification network to create & level-of-response ranking
system to facilitate emergency response.
o 102 - Local/Community Emergency Response Plan
Rhone-Poulenc should work in conjunction with the LEPC to
develop a table-top exercise involving an on-site chemical
accident scenario before the end of 1992.
o 102 - Local/Community Emergency Response Plan
Because of the chemical hazards of P4, the company should
also verify that local hospital personnel are properly
trained in the treatment of phosphorus burns and offer
additional training for hospital staff, if needed.
o 102 - Local/Community Emergency Response Plan
Rhone Poulenc and the LEPC should conduct a full-scale
simulated emergency response exercise in which a P4 train
derails to improve their joint 'preparedness to respond to
such an incident. This simulation could be staged during the
summer of 1993.
Public Alert and Notification Procedures:
o 112 - Schedule of Testing for Procedures - Public Alert
Because no exercises have been held, public notification
procedures, particularly the development of a mechanism for
notifying persons at nearby facilities and communities in the
event of a release, need further attention.
o 114 - Community and Facility Contacts
The facility should develop a schedule or procedure for
ensuring that the list of community and facility contacts is
current at all times.
-------
c 115 - Facility and Media Interaction
Media interaction procedures should Se included m
Rhone-Poulenc's emergency action checklist.
-------
Audit Team Members:
1: Name:
Due Nguyen
Affiliation:
US EPA Region 8
Responsibility;
Team Leader
Expertise:
Chemical Engineer
2: Name:
John McCambridge
Affiliation:
US EPA Region 9
Responsibility:
Deputy Team Leader
Expertise:
Chemist
3: Name:
Robert Litchford
Affiliation:
TAT US EPA Region 8
Responsibility:
Technical Reviewer
Expertise:
Geologist
4: Name;
Paul Schnitz
Affiliation:
TAT US EPA Region 8
Re spons ibility:
Technical Reviewer
Expertise:
Chemical Engineer
5: Name:
Jerry Goedert
Affiliation:
TAT US EPA Region 8
Responsibility:
Technical Reviewer
Expertise:
Chem/Petroleum Engineer
6: Name:
Bob Armstrong
Affiliation:
Silver Bow Fire Dept
Responsibility:
Observer
Expertise:
Emerg Planning Expertise
Follow-up Activities:
By facility:
By Regional Office:
By State and Local Authorities:
Regional Contact:
Due Nguyen
(303) 293-1867
Region 8
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Attachment 2
outline of Protocol/Report Preparation Guidance
1.0 INTRODUCTION
2.0 SUMMARY OF FINDINGS/CONCLUSIONS
3.0 BACKGROUND
3.1 General Facility and Audit Information
3.2 Purpose of the Audit and Facility Selection Process
3.3 Audit Methodology
4.0 FACILITY BACKGROUND INFORMATION
4.1 Site and Surrounding Area Description
4.1.1 Facility Profile
4.1.2 Site Topography and Meteorological Conditions
4.1.3 Site Access
4.1.4 Special/Sensitive Populations and Environments
4.1.5 Regional Demographics
4.1.6 Identification of Vulnerable Zones
5.0 CHEMICAL HAZARDS
5.1 Overview of Hazards for Chemical(s) Being Audited
5.2 Facility Management of Chemical Hazard Data
6.0 PROCESS INFORMATION FOR HAZARDOUS CHEMICALS
6.1 Storage and Handling
6.1.1 Storage Systems
6.1.2 Shipping/Receiving
6.1.3 Material Transfer
6.2 Process Description
6.2.1 Overview of Processing Steps and Operating
Procedures
6.2.2 General Description of Process Equipment
Capacity
6.2.3 Back-ups and Redundancy
6.2.4 Process Parameter Monitoring
6.2.5 .Environmental Monitoring
6.3
Process Hazards
-------
7.0 CHEMICAL ACCIDENT PREVENTION
7.1 Management Activities
7.1.1 'Corporate Role m Facility Process Safety
Management;
7.1.2 Facility Role in Process Safety Management
7.1.3 Audit Activities and Procedures
7.2 Process Operation and Maintenance
7.2.1 Standard Operating Procedures
7.2.2 Training Practices
7.2.3 Equipment Maintenance Procedures
7.2.4 Instrument Maintenance
7.3 Hazard Evaluation and Modeling
7.3.1 Hazard Evaluation
7.3.2 Modeling
7.4 Release Prevention Systems
7.5 Mitigation Systems
8.0 ACCIDENT RELEASE INCIDENT INVESTIGATION
8.1 History of Accidental Releases/Incidents
8.2 Facility Investigation Procedures
9.0 FACILITY EMERGENCY PREPAREDNESS AND PLANNING ACTIVITIES
9.1 Facility Emergency Response Plan
9.2 Emergency Response Exercises and Simulations
9.3 Fire, Evacuation, and Rescue Corridors
9.4 Emergency Equipment Provisions
9.5 Emergency Response Chain of Authority
9.6 Emergency Response Management Procedures
.9.7 Emergency Communication Network within the Facility
9.8 Emergency Response Personnel Training Requirements
9.9 Follow-up Release Procedures
10.0 COMMUNITY AND FACILITY EMERGENCY RESPONSE PLANNING
ACTIVITIES
10.1 Facility Planning and Outreach Activities with
Community
10.2 Local/Community Emergency Response Planning
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11. C FUEL.-.: .-.1ERT AND NOTIFICATION rr.C CEDURES
11.1 Procedures for Public Notification of Releases
11.2 Schedule for Testing Procedures
11.2 History of Notification Procedures and Evaluation
11.4 Cc-r,unity and Facility Contacts
11.5 Facility and Media Interaction
12.0 CONCLUSIONS
13.0 RECOMMENDATIONS
APPENDICES
-------
410
411
412
413
414
415
416
510
520
610
611
612
613
620
621
622
623
624
625
630
710
711
712
713
720
721
722
723
724
730
731
732
740
750
810
820
Attachment 3
Codes for Audit Report Recommendations and Conclusions
Tome of Recommendations and Conclusions
Site and Surrounding Area Description
Facility Profile
Site Topography and Meteorological Conditions
Site Access
Special/Sensitive Populations and Environments
Regional Demographics
Identification of Vulnerable Zones
Overview of Hazards for Chernical(s) Being Audited
Facility Management of Chemical Hazard Data
Storage and Handling
Storage Systems
Shipping/Receiving
Material Transfer
Process Description
Overview of Processing Steps and Operating Procedures
General Description of Process Equipment Capacity
Back-ups and Redundancy
Process Parameter Monitoring
Environmental Monitoring
Process Hazards
Management Activities
Corporate Role in Facility Process Safety Management
Facility Role in Process Safety Management
Audit Activities and Procedures
Process Operation and Maintenance
Standard Operating Procedures
Training Practices
Equipment Maintenance Procedures
Instrument Maintenance
Hazard Evaluation and Modeling
Hazard Evaluation
Modeling
Release Prevention Systems
Mitigation Systems
History of Accidental Releases/Incidents
Facility Investigation Procedures
-------
930
y40
950
960
970
980
990
101
102
111
112
113
114
115
Topic of Recommendations and Conclusions
Facility Emergency Response Plan
Emergency Response Exercises and Simulations
Fire, Evacuation, and Rescue Corridors
Emergency Equipment Provisions
Emergency Response Chain of Authority
Emergency Response Management Procedures
Emergency Communication Network within the Facility
Emergency Response Personnel Training Requirements
Follow-up Release Procedures
Facility Planning and Outreach Activities with Community
Local/Community Emergency Response Planning
Procedures for Public Notification of Releases
Schedule for Testing Procedures
History of Notification Procedures and Evaluation
Community and Facility Contacts
ฆFacility-^rFd MediaJnteraction
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Attacnment 4
Codes Summarizing the Reasons for Selecting Facility for Audit
Code
Reason for Conducting Audit
01
ARIP Questionnaire
02
History of Releases
03
History of Violations
04
Invitation by Facility Management
05
Unique Facility (e.g., state-of-the-art equipment or practices, extensive
management involvement)
06
Process or Chemicals of Interest
07
Concern from Public or Chance of Potential Release
08
Request from State or Local Authority
09
Proximity to Sensitive Populations
10
Special Regional Focus
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Instructions for Installing CSA Database: July 1995
Please Note: You must have at least 15 MB of free space on your computer's hard drive in order
to install the latest version of the CSA database.
The complete system comes on three 3.5-inch, 1.44-megabyte diskettes.
1. Exit from any applications to the DOS prompt.
2. Remove any existing files (e.g., old versions of the CSA database) from the directory in
which you intend to keep the CSA database.
3. Place CSA Database Diskette ti\ in the high-density diskette drive (e.g., A:).
4. Type A: [enter] to switch to the high-density diskette drive.
5. Type install [enter] to begin installation of the database.
6. Indicate your preference for the drive (e.g., C) and directory (e.g., CSA) when prompted
by the installation program.
7. During the initial setup, place CSA Database Diskette #3 in the diskette drive when prompted
by the installation program and type [enter],
8. Then, replace CSA Database Diskette #1 in the diskette drive when prompted by the
installation program and type [enter] to begin the actual installation.
9. Place CSA Database Diskette #2 in the diskette drive when prompted by the installation
program and type [enter],
10. Place CSA Database Diskette #3 in the diskette drive when prompted by the installation
program and type [enter].
11. Type csa [enter] at the C:\CSA prompt to run the program. The first time the program is
run, there will be a short delay as the database files are indexed.
12. Type [escape] repeatedly to exit from the program at any time.
-------
PREAUDIT QUESTIONNAIRE
The U.S. Environmental Protection Agency (EPA) has been performing Chemical
Safety Audits for several years. The following questionnaire has been designed to
assist you in preparing for the audit. It is not necessary that a formal response be
prepared. However, it would be helpful if you would indicate (handwritten is fine)
where the information to particular questions can be found in the material you supply.
For a thorough audit to be conducted, it is essential that adequate data be furnished
to the audit team.
FACILITY BACKGROUND INFORMATION
Please provide a diagram of the facility layout.
Describe the facility's location (cite surveys, township, range, etc.)
When was the facility founded?
Describe the history of ownership of the facility.
When were major process additions or modifications implemented?
What is the total acreage of the site?
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Preaudit Questionnaire
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How many of these acres are used by facility operations (e.g., how many acres are occupied by
process or storage areas, laboratories, administration buildings, transportation facilities, surface
runoff impoundments, and water and wastewater treatment facilities)?
What are the principal finished products?
Describe the disposition of the finished products (e.g., sold to bulk distributors, industrial or
agricultural users, or retail sale).
What raw materials are used?
What is the prevailing wind direction?
Describe the use of the lands surrounding the site (e.g., residential, commercial, hospitals, or
schools). Also, please provide the approximate distance to the nearest occupied structure or building
for each direction:
North
East
South
West
Preaudit Questionnaire
2
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What are the major departments and processing areas of the facility? Give a brief description of the
function(s) of each department or processing area.
How deep is the water table at the facility?
Is the groundwater in hydraulic communication with any surface bodies of water? If so, please
identify those water bodies:
Is groundwater in the area used for irrigation or human or livestock consumption?
CHEMICAL HAZARDS
List the hazardous chemicals used, produced, stored, transported, or handled at the site, including
process intermediates and auxiliary facilities such as water pretreatment processes, wastewater
treatment processes, and warehouses.
Chemical name
Average
quantity
Maximum
quantity
Location on site
How is chemical used
or produced?
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Preaudit Questionnaire
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What mechanisms are in place at the facility for identification and evaluation of chemical hazards,
for updating hazardous chemical information, and for documenting incidents involving hazardous
chemicals? Are computer models used to predict or track releases (or potential releases) to the air,
soil, or groundwater?
Which onsite chemicals does facility management consider to be the most hazardous?
Describe the hazards associated with these chemicals.
How is information concerning these hazards communicated to workers? Where are the material
safety data sheets (MSDS) kept? Who updates the MSDS?
How are tanks, vessels, pipes, or other equipment that could contain potentially hazardous chemicals
identified (e.g., labels, placards, color codes, or symbols)?
Preaudit Questionnaire
4
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STORAGE, SHIPPING, AND PROCESS INFORMATION
Describe chemical storage systems. Include capacities, materials of construction, separation of
incompatible substances, and identification of tank contents (e.g., placards, signs, and labels).
How are tank inventories monitored? What measures, alarms, level-activated shutoff devices, or
other instruments are used to prevent overfilling of tanks?
Describe any early leak detection systems to alert personnel in case of leaks at storage areas (e.g.,
air monitoring systems, falling-level or falling-pressure alarms, high level alarms in containment area
sumps, etc.).
Describe any corrosion prevention measures used for storage tanks and associated equipment.
Describe any secondary containment structures provided for storage areas, truck or railcar unloading
areas, flowing networks, process areas, and other areas where hazardous chemical spills could occur.
Please provide the appropriate dimensions and/or volume of the containment area and its materials
of construction.
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How are spilled materials, rainwater, snowmelt, etc. removed from the secondary containment areas?
Describe shipping and receiving modes (e.g., truck, rail, barge or pipeline), and material transfer
methods (e.g., piping networks, tote-bin, drums on pallets, etc.) in use for hazardous chemicals used
or produced at the site:
What individuals perform loading and/or unloading of hazardous chemical shipments? Do these
individuals have any special training for this?
How often are shipments of the chemical of concern received? Approximately how much of the
chemical is typically received in a shipment?
Please provide a copy of the bulk chemical loading/unloading procedures for the chemical (or
chemicals) of concern.
Describe highway and rail access corridors used to transport hazardous products, raw materials or
auxiliary materials.
Preaudit Questionnaire
6
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Does the local/county emergency preparedness plan specify hazardous cargo routes? If so, what
routes are specified? Are these routes used for hazardous shipments to or from the facility?
Please describe the piping system, or systems, used for flow-streams containing the chemical of
concern: (i.e., piping and gasket materials; types of fitting used and connections (welded or
screwed, combination); labelling, color-coding or other means of identification; protection of pipes
from vehicular traffic and other hazards; secondary containment of piping systems.
Describe any corrosion protection methods used to protect piping networks.
What types of leak detection systems are used for piping networks?
Describe the type (or types) of pump used, their design capacity (capacities), discharge pressures,
pump locations, location and access to starter and shutoff controls.
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For the most hazardous chemicals, briefly describe the major processing steps, including principles
of operation, range of operating parameters (pressures, temperatures, flow rates, and concentrations)
and equipment capacities. Please include block diagrams.
Briefly describe process parameter monitoring (i.e., which parameters are monitored, and why) in
the processes which use or produce the most hazardous chemicals. Describe any process alarms,
automatic shutoff systems, or redundant control systems used to maintain operating parameters within
these ranges.
What process parameter deviations could trigger an emergency shutdown of the process?
Is there a written procedure for emergency shut-down of the process? If so, please provide a copy
of the procedure.
Are drills, simulators, oral or written exams, or other training mechanisms used to verify that all
personnel who may be required to perform an emergency shutdown are familiar with the procedure?
If so, which employees receive this training and how often is refresher training given?
Preaudit Questionnaire
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Describe any backup or redundant process control system components such as; redundant sensors
or transmitters, redundant alarms, on-line back-up pumps, back-up electrical power supplies, back-up
instrument air supplies, manual control override systems, emergency standby equipment, safety
interlocks, redundant emergency shutdown systems, etc.
Describe any hazards, other than chemical, related to the processes of concern.
PROCESS SAFETY MANAGEMENT
Describe the role of corporate management in promoting process safety and environmental
compliance. What type of safety and regulatory guidance is provided to facilities by corporate-level
management?
Describe the oversight role of corporate departments in monitoring the safety and environmental
performance of individual facilities. Does the corporate office require all facilities to submit periodic
safety and regulatory performance reports? What is the corporate office's role in initiating corrective
action when results of these performance reports are deemed unsatisfactory?
Does the corporate office provide assistance to facility management in response to specific problems
or areas of concern?
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Describe the role of facility management in promoting process safety and environmental compliance.
What types of internal safety and regulatory performance reports are prepared by facility
management for its own use?
Who are the designated points of contact between facility and corporate management, with respect
to safety and environmental issues?
Are internal performance audits conducted by corporate and/or facility management? If so, what
types of audits are they? Are these regularly scheduled? How are the results used? Is corrective
action required if audit findings are unsatisfactory? When was the last such audit held at this
facility?
Briefly describe any other safety-related audits or inspections performed by outside parties such as;
state OSHA or environmental audits, insurance audits, fire marshals, etc. How often are these audits
performed? What process area or equipment is addressed by each?
What types of environmental monitoring such as; stack gas or effluent monitoring, perimeter air
quality monitoring, groundwater monitoring, are conducted at the facility?
Do employees undergo periodic physical examinations to monitor possible effects of exposure to
onsite chemical and non-chemical hazards? If so, what possible health effects are monitored?
Preaudit Questionnaire
10
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STANDARD OPERATING PROCEDURES, TRAINING, AND MAINTENANCE
List all safety-related Standard Operating Procedures (SOPs) and/or checklist used at the facility.
A copy of the SOP manual table of contents may be used to provide this. Examples of safety-related
SOPs include such procedures as initial startup, normal operations, emergency shutdown, emergency
operations, normal shutdown, and startup following a turnaround or emergency shutdown, confined
space entry procedures, equipment decontamination procedures, how work permit procedures, and
lock-out/tagout procedures.
How often are SOPs reviewed and updated? Who is responsible for reviewing and updating SOPs?
What departments or employees have input into the SOP reviews? Who has final approval authority
for SOPs?
Prior shift changes, do operators and/or supervisors review any abnormal operational conditions
experienced during the shift being relieved? How is this accomplished? (e.g., review of operator's
logs, checklists, etc.)
For the process for processes') of concern only, please provide a copy of SOPs for initial startup,
normal operations, emergency shutdown, emergency operations, normal shutdown, and startup
following a turnaround or emergency shutdown, confined space entry procedures, equipment
decontamination prior to entry, how work permit procedures, and lock-out/tagout procedures. If any
other these SOPs are supplemented by operator checklists, please provide a blank copy of the
checklist also.
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Preaudit Questionnaire
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Which areas, if any, have been identified as permit-required confined spaces or hot-work areas? Are
these areas identified by signs? If not, where can employees go to find a listing of these areas?
Are new or revised SOPs provided to operators prior to the introduction of any new processes, or
modifications to existing processes?
What types of operational training are provided to facility employees? How and when arc employees
trained in SOPs that are specific to their job functions? How are employees trained with respect to
other safety procedures, such as confined space entry, hot work permits, etc.? How often is
refresher training provided?
Who is responsible for scheduling training and ensuring that all affected employees receive safety
training? What training media are used? (e.g., in-house or contract instructors, videotapes, self-
paced modules, etc.) How often are training materials reviewed to verify whether they are up-to-
date? Who updates the training materials?
How is retraining accomplished prior to start-up of new processes or implementation of new
procedures?
What is the approximate employee turnover rate? (last 1-3 years or so) What is the average
experience level (i.e., years of service) of operations and maintenance personnel?
Preaudit Questionnaire
12
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Which maintenance or operations positions require certification?
Describe the mechanism used to document that affected employees have received training that
satisfies the regulatory requirements of 29 CFR Part 1910.120; 1910.1200; and if applicable, 29
CFR 1910.119. How is employee competency in these areas documented?
Describe the safety orientation training provided to contractor employees. Does this include a
discussion of fire and evacuation procedures, evacuation routes, hot-work and lock-out/tagout
procedures, confined space entry procedures, and accident and spill reporting requirements?
Are formal procedures in place at the facility to fully evaluate hazards of new products, materials,
and processes introduced at the facility, and take appropriate action to mitigate or eliminate those
hazards? If so, describe the review process, the individuals and/or departments involved, and
procedure for resolving issues of concern identified during the process.
Explain how the maintenance work order system functions. Who initiates work orders? How are
work orders prioritized? How is the status of maintenance jobs tracked? How is job status
communicated between Maintenance and Operations/Production?
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Preaud.it Questionnaire
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What is the typical maintenance response time for "routine" and "emergency" repairs?
Which equipment is subject to preventative maintenance? How frequently is preventative
maintenance performed? Is preventative maintenance performed by company or contract employees?
Does the Maintenance Department keep historical records of repairs and/or maintenance for major
pieces of equipment? If so, how long has it been doing this?
Who specifies replacement parts (materials, rated capacity, etc.)? Who is responsible for ensuring
that proper replacement parts are used?
Is a formal apprenticeship program utilized for training maintenance personnel? If so, please give
a brief description of the program.
How frequently are instruments calibrated and sensors, alarms, and interlocks tested?
Does the facility have its own maintenance personnel trained in instrument maintenance, calibration
and testing? How may instrument technicians are at this facility?
Preaudit Questionnaire
14
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Which instruments are considered most critical? What backup measures have been taken for use if
these instruments fail?
Which departments can request instrumentation upgrades? What is the review process for changes
to or addition of instruments?
Have any major upgrades to process instrumentation been made recently? What were these?
What types of methods of Hazard Evaluation, if any, have been used at the facility? Which
processes or operations have undergone Hazard Evaluations? When were these performed? Are
additional Hazard Evaluations planned? How were the results used?
Has modeling been performed to predict potential consequences of hazardous chemical releases? If
so, what model was used? What were the results?
RELEASE PREVENTION AND MITIGATION SYSTEMS
Describe the major release prevention and mitigation systems in place at the facility.
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Preaudit Questionnaire
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ACCIDENT RELEASE INCIDENT INVESTIGATION
Describe any accidental releases or incidents, including facility and corporate investigative roles and
follow up procedures:
HEALTH AND SAFETY INFORMATION
Are there any requirements at the facility for employee use of personal protective equipment, other
than a hard hat, safety glasses, and steel toed boots? Are visitors or contractors subject to any of
these requirements?
Is the facility located within an area having the 911 telephone emergency dialing system? If the 911
system is not in place, please provide both the emergency and non-emergency telephone numbers
for the police and fire departments.
What is the name, location and telephone number of the nearest hospital? Please provide directions
from the facility to the hospital.
Does the hospital have chemical trauma capability? If not, what is the location of the nearest backup
hospital? Please provide directions.
FACILITY EMERGENCY PREPAREDNESS AND PLANNING ACTIVITIES
Please provide a copy of the facility emergency response plan and answer any questions below which
are not addressed in the plan.
Preaudit Questionnaire
16
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How often are emergency exercises or simulations conducted? Give a brief description of these
exercises, including participants, exercise evaluation and follow-up procedures.
Does the facility have an evacuation plan?
Are evacuation drills held? If so, how frequently are they held? When was the latest evacuation
drill held.
Are facility evacuation maps posted within the facility? If yes, where?
What type of training is required for facility emergency response personnel?
What types and amount of emergency equipment and personal protective equipment, such as fire
extinguishers, SCBAs, protective suits, sorbents, neutralizing agents, and portable pumps are kept
onsite?
What types of fire extinguishing agents (i.e., water, foam, C02, halon, dry chemical, etc.) are used
in each process area? What quantity of these agents are kept onsite?
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Preaudit Questionnaire
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What is the extinguishing agent discharge capacity of the fire fighting system?
What is the power source for the firefighting pumps?
Describe any backup firefighting equipment, such as backup pumps or alternate power supplies.
Please provide an organizational chart illustrating the emergency response chain of authority, and
briefly describe emergency response management procedures.
Describe the emergency communications network within the facility.
Is the facility involved in any local community emergency response planning? If so, please describe
the extent of the facility's involvement.
Preaudit Questionnaire
18
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Is the facility involved in any mutual assistance agreements with other facilities nearby? If so, please
describe each facility's role in the agreement (i.e., will the facilities be able to provide personnel,
equipment, technical expertise, etc.)
Briefly discuss procedures for public notification of releases. How often are procedures tested?
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Preaudit Questionnaire
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vvEPA
United States Office of Solid Waste 550-F-96-002
Environmental Protection and Emergency Response May 1996
Agency {5101)
RISK MANAGEMENT PLANNING:
ACCIDENTAL RELEASE PREVENTION
Final Rule: Clean Air Act section 112(r)
Fa
ET
Preventing accidental releases of hazardous chemicals is the shared
responsibility of industry, government, and the public. The first steps
toward accident prevention are identifying the hazards and assessing the
risks. Once information about chemicals is openly shared, industry, gov
ernment, and the community can work together toward reducing the risk
to public health and the environment. Important new provisions in the
Clean Air Act advance the process of risk management planning and pub-
lic disclosure of risk. These requirements will affect facilities that pro-
duce, handle, process, distribute, or store certain chemicals. The final rile
for risk management planning was promulgated on 20 June 1996.
Managing
Chemicals
Safely
Section 112(r) of the
amended Clean Air
Act (CAA), signed into
law on 15 November
1990, mandates a new federal focus on the preven-
tion of chemical accidents. The objective of section
112(r) is to prevent serious chemical accidents that
have the potential to affect public health and the
environment. Under these requirements, industry
has the obligation to prevent accidents, operate
safely, and manage hazardous chemicals in a safe
and responsible way. Government, the public, and
many other groups also have a stake in chemical
safety and must be partners with industry for acci-
dent prevention to be successful.
The risk management planning requirements of
CAA section 112(r) complement and support the
Emergency Planning and Community Right-to-
Know Act of 1986 (EPCRA). A milestone in federal
actions, EPCRA helps local communities prepare
for and respond to chemical accidents. It requires
communities to develop emergency response
plans, based on information from industry con-
cerning hazardous chemicals. Under the new
CAA requirements, stationary sources (facilities)
must identify and assess their chemical hazards
and carry out certain activities designed to reduce
the likelihood and severity of accidental chemical
releases. Information summarizing these activities
will be available to state and local governments,
the public, and all other stakeholders. Using this
information, citizens will have the opportunity to
work with industry to reduce risks to the commu-
nity from chemical accidents.
In the broadest sense, risk management planning
relates to local emergency preparedness and
response, to pollution prevention at facilities, and
to worker safety. In a more focussed sense, it forms
one element of an integrated approach to safety
and complements existing industry codes and
standards. The risk management planning require-
ments build on OSHA's Process Safety
Management Standard, the chemical safety guide-
lines of the Center for Chemical Process Safety of
the American Institute of Chemical Engineers, and
Chemical Emergency Preparedness mtil Prevention Office
Printed on recycled paper
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2
Risk Management Plantting Fhul Rule
May 19%
similar standards of the American Petroleum
Institute and Chemical Manufacturers
Association, as well as the practices of many
other safety-conscious companies.
works, ammonia refrigeration systems, utilities,
and federal facilities. Sources with at least one
covered process must comply with the rule by
June 20,1999.
It's the Law...
CAA section 112{r) mandates that EPA pub-
lish rules and guidance for chemical acci-
dent prevention. These rules must include
requirements for sources to develop and imple-
ment risk management programs that incorpo-
rate three elements: a hazard assessment, a pre-
vention program, and an emergency response
program. These programs are to be summarized
in a risk management plan (RMP) that will be
made available to state and local government
agencies and the public.
Who's Covered
Any source with more than a threshold quan-
tity of a listed "regulated substance" in a
single process must comply with the regulation.
"Process," in terms of the regulation, means
manufacturing, storing, distributing, handling,
or using a regulated substance in any other way.
Transportation, including pipelines and vehicles
under active shipping orders, is excluded. On 31
January 1994, EPA promulgated a final list of 139
regulated substances: 77 acutely toxic sub-
stances, 63 flammable gases and volatile liquids,
and Division 1.1 high explosives as listed by
DOT. The final list rule established threshold
quantities for toxics ranging from 500 to 20,000
pounds. For all listed flammables, the threshold
quantity is 10,000 pounds. EPA proposed modifi-
cations to the final list on 15 April 1996. These
modifications would exclude facilities handling
explosives, exploration/production facilities for
oil and gas, and gasoline.
EPA estimates that approximately 66,000 sources
will be covered by the rule, assuming the pro-
posed list amendments are adopted. The uni-
verse includes chemical manufacturers, other
manufacturers, certain wholesalers and retailers,
drinking water systems, wastewater treatment
Three Levels of
Compliance
The final risk management planning regula-
tion (40 CFR part 68) defines the activities
sources must undertake to address the risks
posed by regulated substances in covered
processes. To ensure that individual processes
are subject to appropriate requirements that
match their size and the risks they may pose,
EPA has classified them into three categories
("Programs").
Program 1 requirements apply to processes for
which a worst-case release, as evaluated in the
hazard assessment, would not affect the public.
These are sources or processes that have not had
an accidental release that caused serious offsite
consequences. Remotely located sources and
processes using listed flammables are primarily
those eligible for this program.
Program 2 requirements apply to less complex
operations that do not involve chemical process-
ing (e.g., retailers, propane users, non-chemical
manufacturers, and other processes not regulat-
ed under OSHA's PSM Standard).
Program 3 requirements apply to higher risk,
complex chemical processing operations and to
processes already subject to the OSHA PSM.
RMP Basics
Sources with processes with a regulated sub-
stance above a threshold quantity will be
required to carry out the following elements of
risk management planning:
~ An offsite consequence analysis that
evaluates specific potential release scenar-
ios, including worst-case and alternative
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3
Ri.tkMimngcnxnl Planning final Rule
Mny 2 90S
scenarios
~ A 5-year history of certain accidental
releases of regulated substances from covered
processes
~ An integrated prevention program to man-
age risk
~ An emergency response program
~ An overall management system to supervise
the implementation of these program elements
~ A risk management plan (RMP), revised at
least once every five years, that summarizes
and documents these activities for all covered
processes
Based on their limited potential for serious offsite
consequences, sources are not required to imple-
ment a prevention program, an emergency
response program, or a management system for
Program 1 processes. Sources with processes in
Program 2 and Program 3 must address each of
the above elements.
Links
The OSHA PSM Standard (29 CFR 1910.119)
reflects the key elements that the petrochemical
industry, trade associations, and engineering soci-
eties have deemed essential to safe management of
hazardous substances for complex, chemical-pro-
cessing operations. EPA has adopted OSHA's PSM
requirements as the Program 3 prevention pro-
gram, with only minor changes in terminology.
With few exceptions, processes assigned to
Program 3 are already subject to the OSHA PSM
Standard; the remaining Program 3 processes are in
industry sectors that have a significant accident
history.
EPA has also worked closely with other regulatory
programs that focus on risk management issues for
hazardous chemicals in order to foster co-ordina-
tion and reduce burden. EPA and the National
Response Team have prepared Integrated
Contingency Plan Guidance to assist sources sub-
ject to multiple regulations in preparing a consoli-
dated emergency response plan. Further, EPA
believes that many of the prevention program
requirements for Program 2 processes and the
emergency response program requirements can be
satisfied without additional effort because of exist-
ing compliance with other federal and state regula-
tions, industry standards and codes, and good
engineering practices.
Making It Work
To document compliance with the rule and pro-
vide risk information, all sources must submit
to a central location a risk management plan that
includes a registration, an executive summary, a 5-
year accident history, and offsite consequence
analysis information. Sources with Program 2 and
3 processes also must submit information in the
RMP regarding compliance with requirements for
the prevention program and the emergency
response program.
EPA is developing a reporting mechanism and
form to collect RMPs in a way that encourages elec-
tronic submission. This will make risk management
planning information available far more widely to
the public and at a far lower cost than would tradi-
tional reporting. To support electronic submission
and reduce the reporting burden, EPA has stan-
dardized the RMP requirements. With the excep-
tion of the executive summary, data elements will
be primarily check-off boxes, yes/no answers, or
numerical entries.
An "implementing agency" will oversee these
requirements and receive the RMPs. It will audit
and inspect a percentage of sources each year and
require whatever revisions to the RMPs are neces-
sary. Under CAA section 112(1), states may request
that EPA delegate the authority to serve as the
implementing agency to a state or local agency
with the appropriate expertise, resources, and
authority. States may implement their own pro-
grams, although the law demands that program
requirements must be as stringent as EPA's and
must include all EPA-reguIated substances and
processes. Approximately 30 per cent of the
sources subject to the risk management program
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4
Risk Management Planning Fhuil Rule
May/1996
requirements must also comply with Title V of the
Clean Air Act, which requires permits for emis-
sions of air pollutants. Section 112(r) is an applica-
ble requirement for Title V permits.
Help for Small
Business
Small and medium-sized enterprises may receive
information about CAA section 112(r) through
the Small Business Assistance Program in each
state, through the Federal Small Business
Assistance Program, through the network of Small
Business Development Centers across the country,
through the EPCRA Hotline, and through a range
of electronic outlets.
through a variety of educational outlets.
Workshops, in co-operation with industry and
engineering societies, will also be presented around
the country, as well as teleconferences to introduce
the new risk management planning requirements
to a diversity of stakeholders.
~~~
With risk management planning as the basis for
accident prevention, everybody wins.
Industry has an opportunity to demonstrate excel-
lence in safety. Government can show effective,
efficient leadership in developing sensible require-
ments. And communities will have a powerful
right-to-know tool, as citizens work together
toward reducing chemical risks to public health
and the environment.
To make compliance easier for small businesses,
EPA is working with industry groups to develop
model risk management programs. Initially, these
model programs will be developed for ammonia
refrigeration, propane handling, and water treat-
ment operations. The RMP Offsite Consequence
Analysis Guidance will eliminate the need for cov-
ered small operations to invest in computer model-
ing programs and to answer complex technical
questions (e.g., how to model liquefied gases) relat-
ed to this element of the hazard assessment.
Looking Ahead...
As this final rule is implemented, EPA plans to
publish general technical guidance, guidance
for states on implementation, guidance for Local
Emergency Planning Committees on ways to use
RMP information in the community, and additional
model plans for certain industry sectors and regu-
lated substances. In addition, the Agency will pro-
duce training packages and disseminate training
For More Information...
Contact the Emergency Planning and
Community Right-to-Know Hotline
(800) 424-9346 OR (703) 412-9810
TDD (800) 553-7672
Monday-Friday, 9 AM to 6 PM, eastern time
~~~
Visit the CEPPO Home Page on the World
Wide Web at:
http://www.epa.gov/swercepp/
Ciwmicn! Enrrpiicy Ptrjximlum nrrf Pretention Office
-------
United States Office of Solid Waste and May 1996
Environmental Protection Emergency Response 550-F-96-003
Agency (5101)
ซEPA LIST OF SUBSTANCES FOR
ACCIDENTAL RELEASE
PREVENTION
CLEAN AIR ACT section 112(r)
Fa
The purpose of the
CAA provisions
for accident prevention
is to ensure that facili-
ties reduce the likeli-
hood and severity of
accidental chemical
releases that could
harm the public and
the environment. These
provisions also ensure
that the public and state
and local governments can receive facility-specific
information on potential hazards and the steps
being taken to prevent accidents.
Regulatory Background
Community
law.
EPCRA improves the ability of communities to
prepare for and respond to chemical accidents.
Under EPCRA, communities must develop
emergency response plans, based on information
that facilities must provide on the hazardous
chemicals they handle. In the 1990 amendments to
the Clean Air Act, Congress included requirements
for accidental release prevention regulations in
section 112(r). Congress also mandated that the
Occupational Safety and Health Administration
(OSHA) adopt a process safety management
standard to protect workers from the workplace
effects of chemical accidents; the standard was
issued on 24 February 1992.
On 31 January 1994, EPA promulgated a final rule under provisions of the Clean
Air Act (CAA) Amendments s.112(r) for the prevention of accidental releases of
hazardous substances. The rule establishes a list of chemicals and threshold
quantities that identify facilities subject to subsequent accident prevention
regulations. The listed substances have the potential to pose the greatest hazard
to public health and the environment in the event of an accidental release. On 15
April 1996, EPA proposed several amendments to the final rule. The list
constitutes the first of two necessary elements for the prevention of chemical
accidents under EPA's CAA mandate. The second element is the requirement for
risk management planning. A facility that handles more than a threshold quantity
of a listed substance in a process is subject to the risk management planning
requirements of CAA section 112(r).
Characteristics of
the Final Rule
Under the CAA, EPA must develop an initial
list of at least 100 substances that, in the event
of an accidental release, could cause death, injury,
or serious adverse effects to human health or the
environment.
If a facility has more than a threshold quantity
of these substances in a process, then it must
develop and implement a risk management
program. That program must include a hazard
assessment, prevention program, and an
emergency response program. Summary risk
management plans will be submitted to a central
location and will be made electronically available to
state and local authorities as well as the public. The
final rule for risk management planning was
promulgated on 20 June 1996.
The statutory criteria EPA considered in selecting
substances for the list include severity of acute
adverse health effects, likelihood of release, and
Chemical Emergency Preparedness ami Prevnithm Office
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2
Lint of Substancesfor Accidental Release Prevention
May 1996
potential magnitude of human exposure. EPA
set threshold quantities for each regulated
substance based on its toxicity, reactivity,
volatility, dispersibility, and flammability, as well
as the amount known or anticipated to cause
effects of concern.
The list EPA promulgated in 1994 includes 77
acutely toxic chemicals, 63 flammable gases and
volatile flammable liquids, and Division 1.1 high
explosive substances as listed by DOT in 49 CFR
172.101. The final rule establishes threshold
quantities for toxic substances ranging from 500
to 20,000 pounds. For all listed flammable
substances, the threshold quantity is 10,000
pounds, while all explosive substances have a
threshold quantity of 5,000 pounds. The rule sets
forth the procedures for determining whether a
threshold quantity of a regulated substance is
present at a stationary source. Specific
exemptions to the threshold determination are
also included for mixtures, articles, and certain
uses and activities. The rule also specifies the
requirements for petitions to the Agency to add
substances to, or delete substances from, the list.
Proposed Changes
Following EPA's promulgation of the final list
rule, some members of the regulated
community raised questions about certain
provisions they felt were inconsistent with the
intent EPA expressed in the preamble and other
documents supporting the final rule. In response,
EPA published proposed amendments to the
final rule on 15 April 1996.
The first proposed modification would be to
delete the category of Division 1.1 explosives.
The Agency also proposes to exempt from
threshold quantity determinations regulated
flammable substances in gasoline used as fuel
and in naturally occurring hydrocarbon mixtures
prior to initial processing. Further, the Agency
proposes clarification of the provision for
threshold determination of flammable
substances in a mixture. Modifications to the
definition of "stationary source" are proposed to
clarify the exemption of transportation and
storage related to transportation and to clarify
that naturally occurring hydrocarbon reservoirs
are not stationary sources or parts of stationary
sources. In addition, EPA proposes to clarify that
40 CFR part 68 does not apply to sources located
on the Outer Continental Shelf. EPA believes
these proposed changes will focus accident
prevention more appropriately on stationary
sources with high hazard operations and reduce
duplication with other similar requirements.
For those provisions of the list rule that EPA is
proposing to amend, the Agency has finalized a
stay of effectiveness until it takes final action on
the proposed modifications. Thus, owners and
operators of processes and sources that EPA has
proposed not be subject to risk management
planning requirements would not have to
comply with CAA section 112(r) until EPA has
determined whether to finalize the proposed list
rule amendments.
Affected Universe
T7 PA estimates that approximately 66,000
ฆ*-J facilities will be affected by the list and risk
management planning rules, if the proposed list
amendments are adopted. The facilities include
chemical and many other manufacturers, cold
storage facilities with ammonia refrigeration
systems, public water treatment systems,
wholesalers and distributors of these chemicals,
propane retailers, utilities, and federal facilities.
Conclusion
According to the risk management planning
requirements of the Clean Air Act, facilities
that handle certain hazardous substances must
act to prevent chemical accidents. They must also
share information about their prevention efforts
with the public, workers, and government. EPA
expects these new partnerships among
stakeholders in prevention activity to prove a
dynamic force in reducing the number and
severity of chemical accidents.
For More Information
Contact the Emergency Planning and
Community Right-to-Know Hotline
(800) 424-9346 OR (703) 412-9810
TDD (800) 553-7672
Monday-Friday, 9AM to 6PM, eastern time
Visit the CEPPO Home Page
http://www.cpa.gov/swercepp/
CUennca! Emergency Pnytuvtlnex* ami Pmvntion Office
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United States Office of Solid Waste 550-F-96-004
Environmental Protection and Emergency Response May 1995
Agency (5101)
wEPA CHEMICAL ACCIDENT PREVENTION
AND THE CLEAN AIR ACT
AMENDMENTS OF 1990
Fa
The Clean Air Act
(CAA) makes it
clear that facilities that
handle hazardous
substances bear the
primary responsibility
for ensuring their safe
use. The CAA section
112(r)(l) general duty
clause outlines the basic
statutory principle that
facilities fire responsible
for designing and
maintaining a safe plant,
identifying their hazards, and minimizing the
consequences of accidental chemical releases. This
clause applies to any facility that handles any
hazardous substance, regardless of the quantity
on site.
CAA SECTION 112 (r):
Basic Requirements
Preventing accidental releases of hazardous chemicals is the shared
responsibility of industry, government, and the public. The first steps toward
prevention are identifying the hazards and assessing the risks. Once information
about chemicals is openly shared, stakeholders can work together toward
reducing chemical risks to public health and the environment. Important new
provisions in the Clean Air Act of 1990 advance the process of risk management
planning and public disclosure of risk. The amendments, which cover a wide
range of air pollution issues, include specific provisions addressing accidental
releases of hazardous chemicals. These requirements will affect facilities that
produce, handle, process, distribute, or store certain chemicals.
u
nder CAA s.l!2(r), EPA must:
Publish a list of at least 100
substances and associated threshold
quantities that determine who must
comply with the new regulations
~ Develop regulations and guidance for the
response, prevention, and detection
of accidental releases associated with these
regulated substances.
Certain facilities must:
~ Prepare risk management plans that
include a hazard assessment, accident
prevention program, and emergency
response program
~ Comply with other accidental release
regulations that EPA may adopt.
One of the other key provisions of section 112(r) is
a mandate for OSHA to establish a chemical
process safety management standard for the
workplace.
Chemical Emergency Prepari'ihw>;; and Prevention Office
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Cheniiail Accident Prevention unci theClemi Air Act Anwndmenta n/1990
Mny 1996
The CAA, under s.507, also requires that each
state set up programs to provide small
businesses with technical assistance on the CAA
and to help them comply with the Act's
regulations. By statute, these small business
programs must include assistance related to
accidental release prevention and detection.
These programs provide information on
alternative technologies, process changes,
products, and methods of operation that help
reduce air pollution.
Background: Chemical
Accident Prevention
Before 1990
Public awareness of the potential danger
from accidental releases of hazardous
substances has increased over the years as
serious chemical accidents have occurred around
the world. Public concern intensified following
the 1984 release of methyl isocyanate in Bhopal,
India, which killed more than 2,000 people. A
subsequent chemical release in Institute, West
Virginia, sent more than 100 people to the
hospital and made Americans aware that such
incidents can and do happen in the United
States.
EPA's Response to Bhopal
In response to this public concern and the
hazards that exist, EPA began its Chemical
Emergency Preparedness Program (CEPP) in
1985. CEPP was a voluntary program to
encourage state and local authorities to identify
hazards in their areas and to plan for potential
chemical emergencies. This local planning
complemented emergency response planning
carried out at the national and regional levels by
the National Response Team and Regional
Response Teams.
The following year, Congress enacted many of
the elements or CEPP in the Emergency Planning
and Community Right-to-Know Act of 1986
(EPCRA), also known as Title III of the
Superfund Amendments and Reauthorization
Act of 1986 (SARA). This law requires states to
establish State Emergency Response
Commissions and Local Emergency Planning
Committees to develop emergency response
plans for each community. EPCRA also requires
facilities to make information available to the
public on the hazardous chemicals they have on
site. EPCRA's reporting requirements foster a
valuable dialogue between industry and local
communities on hazards to help citizens become
more informed about the presence of hazardous
chemicals that might affect public health and the
environment. According to OSHA requirements,
workers on site also have a right to know about
the hazardous chemicals to which they could be
exposed.
Milestone Report on
Systems for Prevention
EPCRA did not require facilities to
establish accident prevention programs.
However, under EPCRA section 305(b), EPA was
required to conduct a review of emergency
systems to monitor, detect, and prevent chemical
accidents at facilities across the country. The
final report to Congress, Rcviexo of Emergency
Systems (EPA, 1988), concluded that the
prevention of accidental releases requires an
integrated approach that considers technologies,
operations, and management practices, and it
emphasized the importance of management
commitment to safety.
EPA's Prevention
Program Takes Shape
EPA recognized that prevention,
preparedness, and response form a safety
continuum. Therefore, in 1986, EPA established
its Chemical Accident Prevention Program,
integrating it with the Chemical Emergency
Preparedness Program. The first initiative was to
begin collecting information on chemical
accidents. Then EPA began working with other
stakeholder groups to increase knowledge of
prevention practices and encourage industry to
improve safety at facilities.
Under the Chemical Accident Prevention
Program, EPA developed the Accidental Release
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May 1996
Chemical Accident Prevention and lite Clean Air Act Amendments of 1990
3
Information Program (ARIP) to collect data on
the causes of accidents and the steps facilities
take to prevent recurrences. EPA also
developed its Chemical Safety Audit Program to
gather and disseminate information on
successful practices to mitigate and prevent
chemical accidents. The audit program also
points out problematic practices and ways to
improve them. Through the program, EPA has
trained its regional staff as well as state officials
on process safety and auditing techniques.
Another significant component of EPA's
Chemical Accident Prevention Program
involves outreach to small and medium-sized
enterprises, which the section 305(b) study
indicated are generally less aware of risks than
larger facilities. EPA has worked with a broad
spectrum of stakeholder groups to determine
the best ways to reach these smaller operations.
All these efforts are based on the premise that
while industry bears the primary responsibility
for preventing and mitigating chemical
accidents, many other groups also have a role to
play. Workers, trade associations, environ-
mental groups, professional organizations,
public interest groups, the insurance and
financial community, researchers and academia,
the medical profession, and governments at all
levels can help facilities that use hazardous
chemicals identify their hazards and find safer
ways to operate. A number of stakeholder
groups have now developed programs and
guidance to assist facilities in the management
of chemical hazards. Many of these safety
measures can make businesses more efficient
and productive.
Clean Air Act
Requirements:
What Chemicals are
Covered?
Under CAA 112(r)(3)(5), EPA must develop
and publish an initial list of at least 100
substances that, in an accidental release, could
cause death, injury, or serious adverse effect to
human health or the environment.
To build its list, EPA considered the severity
of any acute adverse health effects, the
likelihood of an accidental release, and the
potential magnitude of human exposure. The
threshold quantities for each chemical (which
determine the facilities subject to the RMP
requirements) reflect toxicity, reactivity,
volatility, flammability, explosivity and
dispersibility as well as the amount known or
anticipated to cause effects of concern.
On January 31,1994, EPA promulgated a final
rule on the substances and thresholds: 77
acutely toxic chemicals, 63 flammable gases and
volatile flammable liquids, and Division 1.1
high explosive substances as listed by DOT. On
April 15,1996, based on concerns raised by the
regulated community, EPA proposed
modifications to the final rule. The
modifications would clarify "flammables" so
that gasoline and crude oil would not be
covered; clarify "stationary source"; and make
clear the exclusion of facilities handling
explosives, exploration and production facilities
for oil and gas, and gasoline.
It is important to note that the threshold
quantity is determined by the maximum
amount of a substance in a proccess, not the
maximum quantity on site. The list rule also sets
forth the requirements for petitions to the
Agency to add substances to, or delete
substances from, the list.
Risk Management
Planning
For industry, chemical accident prevention
has become an important way of doing
business. More and more plant managers,
whether they are subject to regulation or not,
recognize chemical safety management as an
integral part of running an efficient operation.
At the same time, new CAA regulations ensure
that the public can be properly informed about
chemical risks in their neighborhoods, and
community organizations, states, and the
federal government all have become active
players in helping to lower these risks.
RMP Basics
EPA proposed its regulation on risk
management planning on October 20,1993. Its
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4
Chemical Accident Prevention mid the Clean Air Act Amendments of 1990
May 1996
requirements apply to facilities that have more
than a threshold quantity of a regulated
substance in a process. As mandated by the
CAA, the final rule requires facilities to develop
and implement a risk management program that
includes a hazard assessment of the off-site
consequences of releases under worst case and
alternate scenarios, a prevention program, and
an emergency response program. Information
about the program must be documented in a risk
management plan that is submitted to a central
location and made available electronically to
states and local planning agencies as well as the
public.
Building on Chemical
Process Safety Management
These new risk management planning
requirements are not unique. Rather, they form
one element of an integrated approach to safety
and complement closely related industry
standards and practices. In the broadest sense,
risk management planning relates to local
emergency preparedness and response, to
pollution prevention at facilities, and to worker
safety. In a more focussed sense, these
requirements build on OSHA's Process Safety
Management Standard (issued on February 24,
1992). They also draw from the chemical safety
guidelines of the Center for Chemical Process
Safety of the American Institute of Chemical
Engineers and similar standards of the American
Petroleum Institute and Chemical Manufacturers
Association, as well as the practices of safety-
conscious chemical companies. In addition, four
states-New Jersey, California, Nevada, and
Delaware-also have regulations on accidental
release prevention.
For facilities to comply with the new risk
management planning rule, EPA is encouraging
them to incorporate these existing industry
standards and approaches that many already
practice for chemical safety management.
Prevention Program Requirements
The elements of the
prevention program include the
following:
~ Review and documentation
of the plant's chemicals,
processes, and equipment
~ Detailed process hazard
analysis to identify hazards,
assess the likelihood of
accidental releases, and
evaluate the consequences
of such releases
~ Development of standard
operating procedures
~ Training of employees on
procedures
~ Implementation of a
preventive maintenance
program
~ Management of changes in
operation that may impact
the safety of the system
~ Reviews before initial start-
up of a process and before
start-up following a
modification of a process
~ Investigation and
documentation of accidents
~ Periodic safety audits to ensure
that procedures and practices
are being followed
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Mfly 1996
Chemical Accident Prevention ami the Clean Air Act Amendments of 3 990
5
Affected Universe
EPA estimates that approximately 66,000
facilities will be affected by the risk
management planning requirements, if
proposed amendments to the list rule are
adopted. These facilities include manufacturers
in the chemical and petrochemical and refining
industries, other manufacturers in many
manufacturing sectors (e.g., manufacturers of
pulp and paper; organic and inorganic
chemicals; manufacturers and handlers of chlor-
alkalis, plastics and resins, nitrogen fertilizers,
and agricultural chemicals), cold storage
facilities that use ammonia as a refrigerant
including food processors and distributors and
refrigerated warehouses, public water treatment
systems, chemical retailers, federal facilities, and
some service industries.
Many other stakeholder groups will also be at
least indirectly affected by the new 112(r)
requirements. These include federal agencies
and departments (especially OSHA, DOT, DOD,
DOE, SBA, FEMA , and Coast Guard) and state
and local representatives (particularly State
Emergency Response Commissions and Local
Emergency Planning Committees, state air
offices, local fire departments, emergency
management agencies, environmental protection
and public health departments, land use
planning officials, and natural resource planning
and management offices).
Other interested stakeholders will be public
interest groups and the environmental
community, insurance companies, labor
organizations, and international bodies such as
the Organisation for Economic Co-operation and
Development.
RMP Registration and
Submittal
Facilities covered by the rule will comply by
submitting to a central location a registration
form along with a risk management plan that
describes their risk management program.
Facilities will submit their plans electronically,
selecting options to be spelled out in guidance.
The information will be available immediately
to state and local authorities as well as to the
general public and all other stakeholders who
may be interested.
The final rule with the requirements for risk
management planning was promulgated on
June 20,1996. Submittals of registration forms
and risk management plans are due from
facilities by June 20,1999, with updates required
every five years.
Should EPA add to the list of regulated
substances, the regulations would take effect for
newly covered facilities three years after the
date on which a substance is first listed.
Other CAA Provisions
Presidential Review
The CAA requires the President to conduct a
review of the current authority of various
federal agencies regarding chemical release
prevention, mitigation, and response and to
report the findings to Congress. The purpose of
the review is to clarify and co-ordinate
responsibilities and to identify any gaps and/or
overlaps that may exist. The President delegated
this authority to the EPA Administrator in 1993.
Hydrofluoric Acid Study
As required by the CAA, EPA conducted a
study on the potential hazards of hydrofluoric
acid (HF). Transmitted to Congress in the fall
of 1993, the study investigates the physical and
chemical properties of HF, its hazards in
commercial and industrial use, and the types
and numbers of facilities in which HF is
handled. The document also describes accidentr
that have resulted in the release of HF, as well as
any public and environmental impacts that
resulted from these releases. An analysis of
scenarios using atmospheric dispersion models
investigates potential impacts on the public
from a range of worst-case accidental releases.
The study also describes the current industry
and government controls to prevent accidental
releases of HF and to mitigate the potential
consequences of accidents through emergency
preparedness and response efforts.
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6
Chanicai Accident Prevention and the Clean Air Act Amendments of 1990
May 1996
Research Programs
Under the CAA, EPA must establish a
program of long-term research on methods
and techniques for conducting detailed hazard
assessments. The CAA also requires EPA to
test substances at the Liquefied Gaseous Fuels
Spill Test Facility in Nevada. These tests
would develop and validate improved
predictive models for atmospheric dispersion,
evaluate existing dispersion models, and
evaluate technology for mitigation and
emergency response.
New OSHA Standard
On February 24,1992, OSHA adopted a
standard for chemical process safety
management in the workplace as required
under the CAA 1990 amendments, just as
CAA s,112(r) protects public health and the
environment, the OSHA standard is designed
to protect workers from accidents involving
hazardous chemicals. The OSHA standard
applies to facilities that handle certain acutely
toxic, highly flammable, and reactive
substances.
Requirements of the standard cover safety
information on chemicals and processes, a
workplace process hazard analysis, periodic
audits, standard operating procedures,
training, maintenance, pre-startup safety
reviews, management of change, emergency
response, and accident investigation.
In formulating the regulatory requirements for
risk management planning, EPA incorporated
OSHA's Process Safety Management Standard
nearly verbatim into the prevention program
requirements of CAA s.ll2(r) for higher risk
facilities.
Natural Evolution
Since the mid-1980s, EPA has been
working closely with the whole gamut of
prevention stakeholders to help reduce the
likelihood and severity of chemical accidents.
Beginning with the voluntary Chemical
Emergency Preparedness Program in 1985,
extending to the SARA Title III regulations in
1986, and now culminating in the new Clean
Air Act, these efforts address the entire safety
continuum from emergency response to
preparedness to prevention. In this way, a new
partnership involving government, business,
and the public is being forged. Working
together, each of these groups is playing a key
role in preventing accidental releases of
hazardous chemicals.
For more information.
Contact the Emergency Planning and Community Right-to-Know Hotline
(800) 424-9346, OR (703) 412-9810, OR TDD (800) 553-7672
Monday through Friday, 9:00 am to 6:00 pm, eastern time
On the World Wide Web, visit the home page of EPA's Chemical Emergency Preparedness
and Prevention Office at:
http://www.epa.gov/swercepp/
Chemical Emergency Preparedness an J Prevention Office
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vO/EPA
United States
Environmental Protection
Agency
Office of Solid Waste
and Emergency Response
{5101)
550-F-96-0Q5
May 1996
ri CAM AID ATT
ULCMIM Ml ft Ml# I
SECTION 112(r)
Excerpts from Statute
Fa
Clean Air
Act
Section 112 (r)
Excerpts
(r) Prevention of
Accidental
Releases
Section 112(r) of the amended Clean Air Act deals with the preven-
tion and detection of accidental releases of hazardous chemicals.
EPA has promulgated the two regulations that the Act calls for con-
cerning risk management planning. As a reference document to
accompany those rules, this fact sheet sets forth relevant portions
excerpted from the statute.The Clean Air Act is codified in the U.S.
Code at 42 U.S.C. 7401 et seq.; section 112{r) may be found at
U.S.C. 7412.
(1) Purpose and General Duty
It shall be the objective of the regulations and pro-
grams authorized under this subsection to prevent
the accidental release and to minimize the conse-
quences of any such release of any substance listed
pursuant to paragraph (3) or any other extremely
hazardous substance. The owners and operators
of stationary sources producing, processing, han-
dling, or storing such substances have a general
duty in the same manner and to the same extent as
section 654 of Title 29 to identify hazards which
may result from such releases using appropriate
hazard assessment techniques, to design and main-
tain a safe facility taking such steps as are neces-
sary to prevent releases, and to minimize the con-
sequences of accidental releases which do occur.
For purposes of this paragraph, the provisions of
section 7604 of this title shall not be available to
any person or otherwise be construed to be applic-
able to this paragraph. Nothing in this section
shall be interpreted, construed, implied or applied
to create any liability or basis for suit for compen-
sation for bodily injury or any other injury or prop-
erty damages to any person which may result from
accidental releases of such substance:/..
(2) Definitions
(A) The term "accidental release" means an unan-
ticipated emission of a regulated substance or
other extremely hazardous substance into the
ambient air from a stationary source.
(B) The term "regulated substance" means a sub-
stance listed under paragraph (3).
(C) The term "stationary source" means any build-
ings, structures, equipment, installations or sub-
stance emitting stationary activities (i) which
belong to the same industrial group, (ii) which are
located on one or more contiguous properties, (iii)
which are under the control of the same person (or
persons under common control), and (iv) from
which an accidental release may occur
Chemical Emergency Prepit redness ami Prevenlhin Office
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2
CAA $.lt2(r) F.xci-rjiis
May 1996
(3) List of Substances
The Administrator shall promulgate not later
than 24 months after enactment of the Clean Air
Act Amendments of 1990 an initial list of 100
substances which, in the case of an accidental
release, are known to cause or may reasonably
be anticipated to cause death, injury, or serious
adverse effects to human health or the environ-
ment. For purposes of promulgating such list,
the Administrator shall use, but is not limited to,
the list of extremely hazardous substances pub-
lished under the Emergency Planning and
Community Right-to-Know Act of 1986 [42
U.S.C. fs 11001 et seq.], with such modifications
as the Administrator deems appropriate. The
initial list shall include chlorine, anhydrous
ammonia, methyl chloride, ethylene oxide, vinyl
chloride, methyl isocyanate, hydrogen cyanide,
ammonia, hydrogen sulfide, toluene diiso-
cyanate, phosgene, bromine, anhydrous hydro-
gen chloride, hydrogen fluoride, anhydrous sul-
fur dioxide, and sulfur trioxide. The initial list
shall include at least 100 substances which pose
the greatest risk of causing death, injury, or seri-
ous adverse effects to human health or the envi-
ronment from accidental releases. Regulations
establishing the list shall include an explanation
of the basis for establishing the list. The list may
be revised from time to time by the
Administrator on the Administrator's own
motion or by petition and shall be reviewed at
least every 5 years. No air pollutant for which a
national primary ambient air quality standard
has been established shall be included on any
such list. No substance, practice, process, or
activity regulated under subchapter VI of this
chapter shall be subject to regulations under this
subsection. The Administrator shall establish
procedures for the addition and deletion of sub-
stances from the list established under this para-
graph consistent with those applicable to the list
in subsection (b) of this section.
(4) Factors to be Considered
In listing substances under paragraph (3), the
Administrator shall consider each of the follow-
ing criteria,
(A) the severity of any acute adverse health
effects associated with accidental releases of the
substance;
(B) the likelihood of accidental releases of the
substance; and
(C) the potential magnitude of human exposure
to accidental releases of the substance.
(5) Threshold Quantity
At the time any substance is listed pursuant to
paragraph (3), the Administrator shall establish
by rule, a threshold quantity for the substance,
taking into account the toxicity, reactivity,
volatility, dispersibility, combustibility, or flam-
mability of the substance and the amount of the
substance which, as a result of an accidental
release, is known to cause or may reasonably be
anticipated to cause death, injury or serious
adverse effects to human health for which the
substance was listed. The Administrator is
authorized to establish a greater threshold quan-
tity for, or to exempt entirely, any substance that
is a nutrient used in agriculture when held by a
farmer.
(7) Accident Prevention
(A) In order to prevent accidental releases of
regulated substances, the Administrator is
authorized to promulgate release prevention,
detection, and correction requirements which
may include monitoring, recordkeeping, report-
ing, training, vapor recovery, secondary contain-
ment, and other design, equipment, work prac-
tice, and operational requirements. Regulations
promulgated under this paragraph may make
distinctions between various types, classes, and
kinds of facilities, devices and systems taking
into consideration factors including, but not lim-
ited to, the size, location, process, process con-
trols, quantity of substances handled, potency of
substances, and response capabilities present at
any stationary source. Regulations promulgated
pursuant to this subparagraph shall have an
effective date, as determined by the
Administrator, assuring compliance as expedi-
tiously as practicable.
(B)(i) Within 3 years after November 15,1990,
the Administrator shall promulgate reasonable
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3
CAA*Al2(r) Exli n>ft
M/fjf 1996
regulations and appropriate guidance to provide,
to the greatest extent practicable, for the prevention
and detection of accidental releases of regulated
substances and for response to such releases by the
owners or operators of the sources of such releases.
The Administrator shall utilize the expertise of the
Secretaries of Transportation and Labor in promul-
gating such regulations. As appropriate, such reg-
ulations shall cover the use, operation, repair,
replacement and maintenance of equipment to
monitor, detect, inspect, and control such releases,
including training of persons in the use and main-
tenance of such equipment and in the conduct of
periodic inspections. The regulations shall include
procedures and measures for emergency response
after an accidental release of a regulated substance
in order to protect human health and the environ-
ment. The regulations shall cover storage, as well
as operations. The regulations shall, as appropri-
ate, recognize differences in size, operations,
processes, class and categories of sources and the
voluntary actions of such sources to prevent such
releases and respond to such releases. The regula-
tions shall be applicable to a stationary source 3
years after the date of promulgation, or 3 years
after the date on which a regulated substance pre-
sent at the source in more than threshold amounts
is first listed under paragraph (3), whichever is
later.
(ii) The regulations under this subparagraph shall
require the owner or operator of stationary sources
at which a regulated substance is present in more
than a threshold quantity to prepare and imple-
ment a risk management plan to detect and prevent
or minimize accidental releases of such substances
from the stationary source, and to provide a
prompt emergency response to any such releases in
order to protect human health and the environ-
ment. Such plan shall provide for compliance with
the requirements of this subsection and shall also
include each of the following;
(I) a hazard assessment to assess the potential
effects of an accidental release of any regulated
substance. This assessment shall include an esti-
mate of potential release quantities and a determi-
nation of downwind effects, including potential
exposures to affected populations. Such assess-
ment shall include a previous release history of the
past 5 years, including the size, concentration, and
duration of releases, and shall include an evalua-
tion of worst case accidental releases;
(II) a program for preventing accidental releases of
regulated substances, including safety precautions
and maintenance, monitoring and employee train-
ing measures to be used at the source; and
(III) a response program providing for specific
actions to be taken in response to an accidental
release of a regulated substance so as to protect
human health and the environment, including pro-
cedures for informing the public and local agencies
responsible for responding to accidental releases,
emergency health care, and employee training
measures.
At the time regulations are promulgated under this
subparagraph, the Administrator shall promulgate
guidelines to assist stationary sources in the prepa-
ration of risk management plans. The guidelines
shall, to the extent practicable, include model risk
management plans.
(iii) The owner or operator of each stationary
source covered by clause (ii) shall register a risk
management plan prepared under this subpara-
graph with the Administrator before the effective
date of regulations under clause (i) in such form
and manner as the Administrator shall, by rule,
require. Plans prepared pursuant to this subpara-
graph shall also be submitted to the Chemical
Safety and Hazard Investigation Board, to the State
in which the stationary source is located, and to
any local agency or entity having responsibility for
planning for or responding to accidental releases
which may occur at such source, and shairbe avail-
able to the public under section 7414(c) of this title.
The Administrator shall establish, by rule, an
auditing system to regularly review and, if neces-
sary, require revision in risk management plans to
assure that the plans comply with this subpara-
graph. Each such plan shall be updated periodical-
ly as required by the Administrator, by rule.
(C) Any regulations promulgated pursuant to this
subsection shall to the maximum extent practica-
ble, consistent with the subsection, be consistent
with the recommendations and standards estab-
lished by the American Society of Mechanical
Engineers (ASME), the American National
Standards Institute (ANSI) or the American Society
of Testing Materials (ASTM). The Administrator
shall take into consideration the concerns of small
business in promulgating regulations under this
subsection.
(D) In carrying out the authority of this paragraph,
the Administrator shall consult with the Secretary
of Labor and the Secretary of Transportation and
shall coordinate any requirements under this para-
graph with any requirements established for com
-------
4
CAA s.212(rj Excepts
May 1996
parable purposes by the Occupational Safety and
Health Administration or the Department of
Transportation. Nothing in this subsection shall be
interpreted, construed or applied to impose
requirements affecting, or to grant the
Administrator, the Chemical Safety and Hazard
Investigation Board, or any other agency any
authority to regulate (including requirements for
hazard assessment), the accidental release of
radionuclides arising from the construction and
operation of facilities licensed by the Nuclear
Regulatory Commission.
(E) After the effective date of any regulation or
requirement imposed under this subsection, it shall
be unlawful for any person to operate any station-
ary source subject to such regulation or require-
ment in violation of such regulation or require-
ment. Each regulation or requirement under this
subsection shall for purposes of sections 7413,7414,
7416, 7420, 7604, and 7607 of this title and other
enforcement provisions of this chapter, be treated
as a standard in effect under subsection (d) of this
section.
(F) Notwithstanding the provisions of subchapter
V of this chapter on this section, no stationary
source shall be required to apply for, or operate
pursuant to, a permit issued under such subchap-
ter solely because such source is subject to regula-
tions or requirements under this subsection.
(G) In exercising any authority under this subsec-
tion, the Administrator shall not, for purposes of
section 653(b)(1) of Title 29, be deemed to be exer-
cising statutory authority to prescribe or enforce
standards or regulations affecting occupational
safety and health.
(9) Order Authority
(A) In addition to any other action taken, when the
Administrator determines that there may be an
imminent and substantial endangerment to the
human health or welfare or the environment
because of an actual or threatened accidental
release of a regulated substance, the Administrator
may secure such relief as may be necessary to abate
such danger or threat, and the district court of the
United States in the district in which the threat
occurs shall have jurisdiction to grant such relief as
the public interest and the equities of the case may
require. The Administrator may also, after notice
to the State in which the stationary source is locat-
ed, take other action under this paragraph includ-
ing, but not limited to, issuing such orders as may
be necessary to protect human health. The
Administrator shall take action under section 7603
of the title rather than this paragraph whenever the
authority of such section is adequate to protect
human health and the environment.
(B) Orders issued pursuant to this paragraph may
be enforced in an action brought in the appropriate
United States district court as if the order were
issued under section 7603 of this title.
(C) Within 180 days after enactment of the Clean
Air Act Amendments of 1990, the Administrator
shall publish guidance for using the order authori-
ties established by this paragraph. Such guidance
shall provide for the coordinated use of the author-
ities of this paragraph with other emergency pow-
ers authorized by section 9606 of this title, sections
311(c), 308,309 and 504(a) of the Federal Water
Pollution Control Act, sections 3007, 3008,3013,
and 7003 of the Solid Waste Disposal Act, section
1445 and 1431 of the Safe Drinking Water Act, sec-
tion 5 and 7 of the Toxic Substances Control Act,
and section 7413,7414, and 7603 of this title.
For More Information...
Contact the Emergency Planning and
Community Right-to-Know Hotline
(800) 424-9346 OR (703) 412-9810
TDD (800) 553-7672
Monday-Friday, 9 AM to 6 PM, eastern time
~ ~~
Visit the CEPPO Home Page on the World
Wide Web at:
http://www.epa.gov/swercepp/
Cfwuical Emergency Prqxw'druss aiui Prcii'ntion Office
-------
CHEMICAL SAFETY AUDITS (165.19)
WORKBOOK
CONTENTS
EXERCISES:
Group Exercises 1
Exercise 1 5
Exercise 2 13
Exercise 3 23
Exercise 4 37
Technical Information About Facility X 43
Facts About Facility X 45
Incident Review 53
Material Safety Data Sheet: Chlorine 55
ARIP Questionnaire 63
Chlorine Release Model 81
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GROUP EXERCISES
OBJECTIVES
1. Organize a chemical safety audit team using U.S. EPA audit protocol.
2. Fill out the EPA-required and/or standard entries found in the following sections of a
chemical safety audit report:
a. Report Disclaimer.
b. Introduction (Section 1).
c. Background (Section 3).
d. Facility Background Information (Section 4).
3. Prepare the remainder of a chemical safety audit report using U.S. EPA protocol. The report
will address all 13 required sections and include at least 1 conclusion and 1 recommendation
for each of the following sections:
a. Process Information (Section 6).
b. Chemical Accident Prevention (Section 7),
c. Accidental Release/Incident Investigation (Section 8).
d. Facility Emergency Preparedness and Planning Activities (Section 9),
e. Community/Facility Emergency Response Planning Activities (Section 10).
f. Public Alert and Notification Procedures (Section 11).
OVERVIEW
There are four interlocking exercises in this course that will provide practice in the various phases
of a chemical safety audit. The exercises are based on a mock chemical safety audit conducted at
Facility X.
Facility X treats water for the surrounding community. It consists of two very similar water
treatment processes that include chlorine delivery systems. The chemical safety audit was triggered
by a recent release of 50 pounds of chlorine vapor.
PROCEDURE
Participants will be randomly divided into groups of five to seven individuals to form chemical safety
audit teams. After conducting a chemical safety audit, each team will create a chemical safety audit
report. This report will be presented orally on Friday.
5/96
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Group Exercises
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GENERAL INFORMATION
Exercise 1 (Tuesday)Facility X Overview followed by team assignment, role selection, and
technical information review. During this exercise, students will review and complete the EPA-
required and/or standard entries found in the Report Disclaimer and Sections 1, 3, and 4 of a
chemical safety audit report (page 5).
Exercise 2 (Wednesday)Facility X Tour followed by team interviews of Facility X Operations,
Maintenance, and Emergency personnel and an Interviewing Techniques Critique. During this
exercise, each team will complete Section 5 - Chemical Hazards, Section 6 - Process Information,
and Section 9 - Facility Emergency Preparedness and Planning Activities (page 13).
Exercise 3 (Thursday)Team Interviews of Facility X Safety, Training, and Management
Personnel. During this exercise, each team will complete Section 7 - Chemical Accident Prevention,
Section 8 - Accidental Release/Incident Investigation, Section 10 - Community and Facility
Emergency Response Planning Activities, and Section 11 - Public Alert and Notification Procedures
(page 23).
Exercise 4 (Friday)Team Audit Report Presentation. During this exercise, each team will prepare
and present Section 12 - Conclusions, and Section 13 - Recommendations (page 37).
Note: The conclusions and recommendations will be based on factual information acquired during
the exercises. For example:
Factual information (from Section 9 - Facility Emergency Preparedness and Planning
Activities)Facility volunteer fire brigade personnel training meets Washington State
training requirements for Firefighters and both OSHA 1910.120 Part Q and
Washington State requirements for HAZMAT technician-level responders.
ConclusionFacility volunteer fire brigade training meets the appropriate Washington
State and OSHA 1910.120 Part Q training requirements for fire fighters and
HAZMAT technician-level responders.
RecommendationFacility X should consider continuing its practice of providing
appropriate training for its volunteer fire brigade.
This factual information, conclusion, and recommendation set cannot be used to meet the exercise
requirements of this course.
Homework will be assigned as part of this course. The homework will be reading and evaluating
the technical information about Facility X to extract information that will be used to complete the
team's chemical safety audit report.
The following information about Facility X is provided in Exercise 1 of the manual:
1. Facts about Facility X and maps of the facility and the surrounding community.
2. A diagram of a Facility X chlorine delivery system.
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Group Exercises
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3. Material safety data sheet (MSDS) information covering chlorine.
4. A Facility X Incident Review report covering the chlorine release.
5. A copy of the Accidental Release Information Program (ARIP) report submitted to
EPA as a result of the chlorine release.
6. Chlorine release information, including a computer model of the chlorine plume and
an incident investigation report for the last chlorine release.
Note: Appropriate sections of the Chemical Safety Audit Program Worksheet have been included
with the first three exercises. A complete copy of the worksheet to be used in Exercise 4 is located
in Section 6 of the manual.
Additional information will be provided during the exercises.
5/96
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Group Exercises
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EXERCISE 1
OBJECTIVES
1. Organize a chemical safety audit team using U.S. EPA audit protocol.
2. Identify report topics to be covered using U.S. EPA protocol.
3. Assign report sections to be covered by the various chemical audit team members.
4. Using the material provided, fill out the required and/or standard entries found in the
following sections of a chemical safety audit report:
a. Report Disclaimer.
b. Introduction (Section I).
c. Background (Section 3).
d. Facility Background Information (Section 4).
OVERVIEW
This exercise starts with a Facility X Overview presented by a Facility X Public Relations Specialist.
The overview is followed by a team organization meeting. The purpose of the exercise is to allow
each team to establish roles for each team member, to complete sections 1, 3, and 4 of the audit
report, and to review the written information about Facility X.
EXERCISE TASKS
1. Establish roles (Team Leader, etc.) for all team members. Each team member will select
a role based on the audit team roles shown in Section 3 - Role of Audit Team Members in
the Guidance Manual for EPA Chemical Safety Audit Team Members (CSA manual).
2. Review the examples of Chemical Safety Audit required and/or standard entries provided for
this exercise. Using the Facts about Facility X found in the technical information, fill in the
blanks to complete the following sections of the chemical safety audit report on the Chemical
Safety Audit Program Worksheet (Worksheet) provided in the student manual:
Section 1 - Introduction
Section 3 - Background
Section 4 - Facility Background Information
3. Using the Guidance Manual for EPA Chemical Safety Audit Team Members, Exhibit 2 -
Annotated Protocol/Report Preparation Guidance, assign team members to take charge of
completing each remaining section of the audit report.
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Exercise 1
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HOMEWORK
1. Review the technical information about Facility X to acquire information needed to complete
the remaining sections of the team's chemical safety audit report.
Note: The technical information does not include all the information required to complete
the audit report.
2. As much as possible, identify the additional information needed to complete the report as
well as the sources of the needed information (such as Facility X personnel to be
interviewed).
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Exercise 1
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REPORT DISCLAIMER
The contents of this report reflect information concerning Facility X obtained during a U.S.
Environmental Protection Agency (EPA) Chemical Safety Audit and from records provided by
Facility X. The audit was conducted from February 5, 19XX. through February 8. 19XX. and
the observations as presented in this report provide a snapshot of conditions existing at the facility
during the audit time frame. They do not represent planned or anticipated changes proposed or
ongoing at the facility. The recommendations and other report observations contained in this report
are not mandatory actions that the facility must implement. In addition, EPA makes no assurances
that if implemented, the recommendations and other report observations contained in this report will
prevent fiiture chemical accidents, equipment failures, unsafe management practices, or provide
protection from a future enforcement action under any applicable law or regulation.
5/96
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Exercise 1
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1.0 INTRODUCTION
1.1 Chemical Safety Audit Program
The Chemical Safety Audit (CSA) program has evolved from efforts of the U.S. Environmental
Protection Agency (EPA) under the Chemical Accident Prevention (CAP) program. The primary
objectives of the CAP program are to identify the causes of accidental releases of hazardous
substances and the means to prevent such releases from occurring, to promote industry initiatives in
these areas, and to share activities with the community.
The CSA program is part of this broad initiative and has been designed to accomplish the following
chemical accident prevention goals:
Heighten awareness of the need for chemical safety among chemical producers,
distributors, and users, as well as in communities where chemicals are located
Visit facilities handling hazardous substances to learn and understand problematic and
successful practices and technologies for preventing and mitigating releases
Build cooperation among authorized parties by coordinating joint accidental release
investigations where appropriate
Establish a national database for the assembly and distribution of chemical safety
information obtained from facility investigations and from other sources.
The audit consists of interviews with facility personnel and onsite review of various aspects of facility
operations related to the prevention of accidental chemical releases. CERCLA Sections 104(b) and
104(e), as amended by SARA, provide authorities for entering a facility and accessing information.
Specific topics addressed in the audit include:
Process characteristics
Hazard evaluation and release detection techniques
Training of operators and emergency response personnel
Management structure (corporate and facility)
Preventive maintenance and inspection programs
Community notification mechanisms and techniques.
5/96
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Exercise 1
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1.2 Facility X -- Pacific Town, Washington, Audit
This report contains observations, conclusions, and recommendations from an audit conducted at
.... ฆฆ i. ฆ - .. . ป
from . The
facility was selected for an audit because of a series of releases of chlorine, the last one of
approximately pounds. This report identifies and characterizes the strengths of specific
chemical process safety management program areas to allow the elements that are particularly
effective to be recognized. Copies of this report have been provided to the facility's corporate
management so that weak and strong program areas may be recognized.
3.0 BACKGROUND
3.1 General Facility and Audit Information
Facility X is owned by , the
parent company. operates at the following address:
Brief Description
. The audit was conducted from ,
by a team of regional representatives from the EPA. EPA was assisted by representatives from the
. The names of the team
members, their affiliations, their responsibilities in the audit, and their expertise are provided in
Appendix A.
3.2 Purpose of the Audit and Facility Selection Process
The purpose of the audit was to examine the facility's chemical process safety management practices
associated with chlorine. The facility was selected for an audit based on an analysis of chemical use
in the region, and the facility's release history. Region 11 identified ammonia and chlorine as the
two chemicals used in the highest volume in the region. Based on the facility's release history, the
5/96
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Exercise I
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Regional Office decided that a CSA be conducted. There was a series of accidental releases of
chlorine occurring over the past year, the last one of approximately pounds.
3.3 Audit Methodology
The audit centered around the process areas related to the use of ammonia in the urea manufacturing
process. Because of time and resource constraints, the audit team did not review the production of
ammonia from natural gas in the ammonia/carbon dioxide unit. The audit addressed ammonia
hazards, chemical accident prevention, process operation and maintenance, hazard evaluation and
modeling, release prevention systems, accidental release incident investigation, facility emergency
preparedness and planning, and community and facility emergency response planning activities.
However, the audit is limited in that is does not attempt to make comparisons or otherwise
distinguish between the safety systems used only for urea manufacturing processes and those used
for other chemical processes at the facility.
4.0 FACILITY BACKGROUND INFORMATION
General description
5/96
10
Exercise 1
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Surrounding area description
5/96 11 Exercise 1
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EXERCISE 2
OBJECTIVES
1. From personal or team experience, describe the effectiveness of at least one interviewing
technique used for group interviews.
2. Evaluate information obtained from interviews AND select factual information required for
a chemical safely audit report.
3. Complete the factual information for audit report Section 5 - Chemical Hazards, Section 6 -
Process Information, and Section 9 - Facility Emergency Preparedness and Planning.
OVERVIEW
This exercise begins with a facility tour by Facility X Staff. The photographic tour will be presented
to the class as a whole and questions are allowed.
The tour is followed by a group interview of Facility X operating and maintenance staff, including
the maintenance foreman, the operator who was on duty at the time of the chlorine release, and the
Facility X Fire Brigade Commander.
EXERCISE TASKS
1. Tour Facility X (Note: questions are permitted).
2, Conduct Facility X employee interviews with the following:
a. The maintenance foreman.
b. The operator on duty at the time of the chlorine release.
c. The Fire Brigade Commander.
Possible interview topics include (but are not limited to):
a. Facility standard operating procedures.
b. Response activities relating to the chlorine release.
c. Maintenance philosophy and procedures.
d. Maintenance activities relating to the chlorine release.
e. Emergency response procedures.
Interviewing procedure:
a. Interviews with each Facility X employee will be conducted in front of the entire
class.
b. Each Facility X employee will be interviewed by members of each team. Selection
of team members to conduct the interviews and the questions to be asked are entirely
up to the team. However, please arrange the questioning to allow each student a
chance to participate in the interviewing process.
5/96
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Exercise 2
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c. To ensure maximum fairness during the exercise, interviews will be conducted in
rounds. Each audit team will be allowed three questions plus one follow-up question
per round. The rounds will continue until there are no further questions.
Upon completion of questioning, a short critique will be conducted. The critique will focus
on interviewing technique strengths and weaknesses displayed during the interviews.
3. Reassemble the team to evaluate the information obtained from the facility tour and the
interviews, and select factual information required to complete Section 5 - Chemical Hazards,
Section 6 - Process Information, and Section 9 - Facility Emergency Preparedness and
Planning of the audit report.
4. Complete the factual information for audit report Sections 5, 6, and 9.
Note: Factual information for EPA Chemical Safety Audits should avoid descriptions of adequacy
or inadequacy. Words such as good, bad, sufficient, and insufficient should be avoided for a number
of reasons, four of which are as follows:
1. They tend to be qualitative and therefore not easily defended.
2. They are often general in nature and do not lead to clear conclusions and achievable
recommendations.
3. They often appear to be the audit team members' opinions rather than observable
facts.
4. They may appear to be prejudicial.
Examples: Statement based on adequacy: "The facility emergency response plan is weak and
should be improved."
Questions created: "How is this statement verified?"
"Where is the plan weak?"
"What repairs are required to improve the plan?"
Statement based on fact: "The facility emergency response plan does not
contain a section addressing decontamination as
required by OSHA 1910.120 Part Q."
This statement is easily verified, defines exactly where the plan does not meet the
OSHA standard, and gives the facility a clearly defined repair requirement.
5/96
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Exercise 2
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5.0 Chemical Hazards (Includes all chemical hazards thai are covered in the scope of the audit;
MAY include material safety data sheets.)
5/96
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Exercise 2
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5.0 Chemical Hazards (continued)
5/96 16 Exercise 2
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6.0 Process Information (Includes storage information, a process description, and process
hazards.)
5/96
17
Exercise 2
-------
6.1 Storage Information
-------
6.2 Process Description
5/96 19 Exercise 2
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6.3 Process Hazards
5/96 20 Exercise 2
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9.0 Facility Emergency Preparedness and Planning Activities
5/96 21 Exercise 2
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EXERCISE 3
OBJECTIVES
1. Describe, from personal or team experience, the effectiveness of at least one interviewing
technique used for individual interviews.
2. Evaluate information obtained from individual interviews to select factual information
required for a chemical safety audit report.
3. Compare the following information to verify its factual nature:
Information obtained from the individual interviews.
Previously acquired information.
4. Complete the factual information for audit report Section 7 - Chemical Accident Prevention,
Section 8 - Accidental Release/Incident Investigation, Section 10 -Community and Facility
Emergency Response Planning, and Section 11 - Public Alert and Notification Procedures.
OVERVIEW
Each team will conduct individual interviews with Facility X management staff, including the facility
manager, the safety supervisor, and the process engineer. Information gathered will be verified
through comparisons and corrections made on the factual information previously supplied, and audit
report Sections 7, 8, 10, and 11 will be completed.
INTERVIEW PREPARATION
Each team will select team members to conduct the individual interviews for each of the following:
a. Facility manager.
b. Safety supervisor (also handles training).
c. Process engineer (also handles hazard evaluation).
These interviews will be held in various assigned locations.
Possible interview topics include, but are not limited to:
a. Safety and accident investigation procedures and records.
b. Incident investigation findings for the chlorine leak.
c. Staff and management training needs and availability.
d. Hazards evaluation techniques.
e. Emergency response planning.
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Exercise 3
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EXERCISE TASKS
1. Perform Facility X management staff interviews.
2. Reassemble the team and evaluate the information obtained during the interviews.
3. Re-interview Facility X management staff as needed.
4. As a team, compare the information obtained during individual interviews with previously
acquired information to verify the factual nature of the information in each section of the
report. Correct the factual information listed in previously prepared sections of the report
as appropriate.
5. Complete the factual information for Section 7 - Chemical Accident Prevention, Section 8 -
Accidental Release/Incident Investigation, Section 10 - Community and Facility Emergency
Response Planning, and Section 11 - Public Alert and Notification Procedures.
5/96
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Exercise 3
-------
7.0 Chemical Accident Prevention (Includes management activities, process operation and
maintenance, hazard evaluation and modeling, release prevention systems, and release
mitigation systems.)
5/96
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Exercise 3
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7.1 Management Activities
5/96 26 Exercise 3
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Exercise 3
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Exercise 3
-------
7.2 Process Operation and Maintenance (continued)
5/96 29 Exercise 3
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7.3 Hazard Evaluation and Modeling
5/96 30 Exercise 3
-------
7.4 Release Prevention Systems
5/96 31 Exercise 3
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7.5 Release Mitigation Systems
5/96 32 Exercise 3
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8.0 Accidental Release/Incident Investigation
5/96 33 Exercise 3
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10.0 Community and Facility Emergency Response Planning Activities
5/96 34 Exercise 3
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11.0 Public Alert and Notification Procedures
51% 35 Exercise 3
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EXERCISE 4
OBJECTIVES
1. Prepare at least one conclusion and one recommendation for each of the following sections:
a. Process Information (Section 6).
b. Chemical Accident Prevention (Section 7),
c. Accidental Release/Incident Investigation (Section 8).
d. Facility Emergency Preparedness and Planning Activities (Section 9).
e. Community/Facility Emergency Response Planning Activities (Section 10).
f. Public Alert and Notification Procedures (Section 11).
2. Complete Summary of Findings/Conclusions (Section 2), Conclusions (Section 12), and
Recommendations (Section 13).
3. Complete any other section that was not finished earlier.
4. Prepare the oral audit report.
OVERVIEW
In this exercise, each audit team will finish preparing a chemical safety audit report for Facility X.
Complete Summary of Findings/Conclusions (Section 2), Conclusions (Section 12), and
Recommendations (Section 13), including at least one conclusion and one recommendation for
Process Information (Section 6), Chemical Accident Prevention (Section 7), Accidental
Release/Incident Investigation (Section 8), Facility Emergency Preparedness and Planning Activities
(Section 9), Community and Facility Emergency Response Planning Activities (Section 10), and
Public Alert and Notification Procedures (Section 11).
EXERCISE TASKS
1. Prepare at least one conclusion and one recommendation for each of the following sections:
a. Process Information (Section 6).
b. Chemical Accident Prevention (Section 7).
c. Accidental Release/Incident Investigation (Section 8).
d. Facility Emergency Preparedness and Planning Activities (Section 9).
e. Community/Facility Emergency Response Planning Activities (Section 10).
f. Public Alert and Notification Procedures (Section 11).
2. Complete Summary of Findings/Conclusions (Section 2), Conclusions (Section 12), and
Recommendations (Section 13).
3. Complete any other section that was not finished earlier.
4. Prepare and present the team's oral audit report.
Limited re-interviews of various Facility X personnel will be allowed during this exercise.
5/96
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Exercise 4
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2.0 Summary of Findings/Conclusions (Includes a BRIEF description of the major findings
and conclusions of the audit.)
5/96
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Exercise 4
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12.0 Conclusions
5/96 39 Exercise 4
-------
12.0 Conclusions (continued)
5/96 40 Exercise 4
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13,0 Recommendations
5/96 41 Exercise 4
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Exercise 4
-------
TECHNICAL INFORMATION
ABOUT
FACILITY X
5/96
43
Facts About Facility X
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FACTS ABOUT FACILITY X
1. Facility X is located in the northwest United States along the Pacific Coast. It is a water
treatment facility owned by XYZ Manufacturing, Inc., 1 Industry St., Pacific Town, WA
99999. Some relevant weather data are:
2. The facility is 20 years old and employs 45 persons. Facility X has a design capacity of 10
million gallons of treated water per day. Currently, it is operating at 70-percent capacity.
3. The audit was triggered by a series of releases of chlorine, the last one being approximately
50 lbs. (The reportable quantity of chlorine is 10 lbs.) The most recent chlorine release
occurred because of a chlorine delivery tubing rupture. The tubing was ruptured during a
chlorine ton container transfer operation.
4. The corporate safety person (a Vice President) is responsible for 22 plants located at various
locations within the United States.
5. The plant safely supervisor maintains records of the personnel who have attended training
programs at the facility. Training programs include courses on employee safety, emergency
response, and equipment operator certification.
This person also maintains all records of accident investigations, including accidental
releases, and follows up each incident with the plant manager within 30 days to gather full
details of investigations along with recommendations for improvement of safety.
In addition, this person instituted an employee suggestion program to encourage safety-related
suggestions accompanied by monetary rewards.
6. The corporate policy on hazards analysis requires that cause-consequences analyses of
HAZOP be conducted on an annual basis. However, because of budget constraints, only
50% of such analyses have been carried out at this plant.
7. Equipment maintenance at this plant is done using a preventive and predictive maintenance
program installed about 6 months ago. The plant also conducts regular equipment inspections
and testing, as well as comprehensive investigations of equipment failures.
8. As an active member of CAER, emergency response plans at this facility are revised and
updated every 6 months.
9. The plant has its own fully equipped fire brigade.
5/96 45 Facts About Facility X
Average temperature:
Average relative humidity:
Mean wind speed:
53-F
73%
7.9 miles per hour from ESE
-------
FIGURE 1. Facility X
Old Process
New Process
Clarifier
Clarifier
Chlorine
Storage
Area
Evaporator
Room
Filter
Evaporator
Room
Filter
Parking:
Offices
j
Highway 1
5/96
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Facts About Facility X
-------
FIGURE 2. Communities Around Facility X
Arnie's Golf
Course
Elemental7^^
<^School
4 Mi es
2.5 Miles
3.5 Miles
Lake Golden
Shopping Center
5/96
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Facts About Facility X
-------
FIGURE 3. Chlorine Delivery System
Expansion
Tank
Relief
Valve
Chlorine Ton
Container
Chlorine Ton >c'<ฐ""
Container
Delivery
Tubing
Manifold
Pressure
Reducing
Flow Cutoff
Valve
Fail Closed
Evaporator
Chlorinator
5/96
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Facts About Facility X
-------
INCIDENT REVIEW
LOCATION
Old Chlorine Delivery System
DEPARTMENT/DIVISION
Old Water Treatment Process
DATE OF ACCIDENT/INCIDENT
December 12, 19XX
DATE OF REVIEW
December 13, 19XX
NATURE OF LOSS
NATURE AND EXTENT OF ACTUAL OR POTENTIAL LOSS TO PERSONS OR PROPERTY
(INCLUDE COSTS OF PROPERTY LOSS)
Approximately 50 pounds of chlorine lost offsite.
Z
c
ฃ
2
u
<*>
k
a
DESCRIPTION OF ACCIDENT/INCIDENT (WHO, WHAT, HOW)
The chlorine delivery system operator was transferring a ton container of chlorine in the old chlorine
delivery system evaporator room using the overhead, hand-controlled hoist. As the container was being
moved, it hit and jarred the in-use chlorine container. The impact ruptured the chlorine discharge tubing
that connected the in-use container with the chlorine manifold. In accordance with facility policy, no
other chlorine containers were supplying chlorine to the manifold at the time of the incident. The
ruptured tubing released liquid chlorine into the evaporator room for approximately 13 minutes when the
operator shut off the supply of chlorine from the container. The liquid chlorine immediately vaporized,
and when the concentration of chlorine at floor level reached 1 ppm, the chlorine release alarm and the
chlorine vapor evacuation system automatically activated initiating, the facility chlorine release emergency
response procedure. The 13-minute time delay in shutting off the chlorine supply occurred while the
operator donned proper protective equipment and waited for emergency responders for support and "back-
up." The chlorine container weigh scale and computer modeling both indicate that about 50 pounds of
chlorine was lost into the atmosphere.
CAUSES
WHY DID THE ACCIDENT,'INCIDENT OCCUR?
1. The operator did not allow proper clearance between containers while transferring a container
using the overhead, hand-controlled hoist.
2. Investigation showed that corrosion inside the discharge tubing contributed to the rupture. The
discharge tubing had not been replaced in 2 years, although Facility X maintenance policies state
that chlorine discharge tubing is to be replaced annually.
1
**
2
3
ACTION TO PREVENT RECURRENCE: INFORMATION FOR ORGANIZATION - WIDE ATTENTION
1. The operator was disciplined and required to repeat a hoist refresher training course prior to
future operation of the hoist.
2. All remaining chlorine discharge tubing in the facility is to be checked and replaced as needed.
3. Facility X maintenance policies for annual replacement of chlorine discharge tubing will be
enforced.
MEMBERS
REVIEW MEMBERS
Mr. Checkvalve, Chlorine Delivery System Operator; Mr. Do-it, Operations Supervisor; Mr. Do-
right, Safety Supervisor; Mr. Goodwrcnch, Maintenance Supervisor; Mr. Hotshot, Process
Engineer.
REVIEW CHAIRMAN DATE
MANAGER DATE
5/96
53
Incident Review
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MATERIAL SAFETY DATA SHEET
PRODUCT NAME: chlorine gas
24-HOUR EMERGENCY PHONE: 1-800-100-0000 OR 888-100-0000
1. PRODUCT IDENTIFICATION
HEALTH HAZARD 3
HAZARD RATINGS
FIRE HAZARD 0
REACTIVITY 1
MANUFACTURER'S f*"Y7 . ฆ Ci .
NAMF AND 1 Manufactunnง Street
Pacific Tower, Washington 99999
(1-800-100-1000)
CHEMICAL NAME: Chlorine CAS NUMBER: 7782-50-5
SYNONYMS/COMMON NAMES: Chlorine Gas
CHEMICAL FORMULA: C12
PRODUCT USE: Water Purification, Chemical Processes, Plastic manufacture
DOT PROPER SHIPPING NAME: Chlorine
DOT HAZARD CLASS: 2.3
DOT I.D. NUMBER: UN1017
DOT HAZARDOUS SUBSTANCE: RQ = 10 lbs.
DOT MARINE POLLUTANT: Chlorine
ADDITIONAL DESCRIPTION REQUIREMENT: Poison Inhalation Hazard.
Zone B
I. PRODUCT IDENTIFICATION
PROPER NAME: Chlorine
COMMON NAME: Chlorine
PRODUCT ID NUMBER: UN 1017
CAS NUMBER: 7782505
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Material Safety Data Sheet: Chlorine
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Page 2 of 7
04-01-96
CHLORINE GAS
II. HEALTH HAZARD INFORMATION
EMERGENCY AND FIRST ATP PROCEDURES
EYES:
IMMEDIATELY flush eyes with plenty of water for at least 15 minutes holding lids apart
to ensure flushing of entire eye surface. Washing eyes within several seconds is essential to
achieve maximum effectiveness. SEEK MEDICAL ATTENTION IMMEDIATELY.
SKIN:
Treat for inhalation first. Remove contaminated clothing under safety shower. Flush exposed
skin with water,. Wash with soap and water. If irritation is present after washing, GET
MEDICAL ATTENTION.
INHALATION:
Remove to fresh air. Administer oxygen until victim breathes easily. Keep warm and at
rest. In mild cases, give milk to relieve irritation. DO NOT INDUCE VOMITING. GET MEDICAL
ATTENTION AS SOON AS POSSIBLE.
INGESTION:
NEVER GIVE ANYTHING BY MOUTH TO AN UNCONSCIOUS PERSON. If swallowed, DO NOT
INDUCE VOMITING. Give large quantities of water. (If available, give several glasses of milk.) If
vomiting occurs spontaneously, keep airway clear and give more water. SEE MEDICAL ATTENTION
IMMEDIATELY.
EFFECTS OF OVEREXPOSURE
ACUTE:
Liquid contact with skin or eyes may cause burns. Vapors may cause severe irritation to skin,
eyes and respiratory tract. Inhalation of large concentrations may cause pneumonitis and pulmonary
edema.
CHRONIC:
There are no known chronic effects from exposure to chlorine vapors at or below the accepted
occupational limits for exposure. Repeated exposure to chlorine above the TLV may result in
reduced pulmonary capacity and dental erosion.
TOXICOLOGY DATA:
Chlorine gas is a primary irritant of the respiratory tract.
Severe exposure to vapor can be fatal. Exposure to liquid can cause burns on contact. Prompt
treatment is important to minimize effects.
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Material Safety Data Sheet: Chlorine
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Page 3 of 7
04-01 -96
CHLORINE GAS
II. HEALTH HAZARD INFORMATION (Continued)
TOXICOLOGY DATA continued
The hazard at different concentrations is reported to be as follows:
0.2-0.5 ppm = No toxic, long term effect
1 -3 ppm = Definite odor; irritation of eyes and nose
5-8 ppm = Throat, eye, and mucous membrane irritation
30 ppm = Intense coughing fits
34-51 ppm = Lethal in 1 to 1.5 hours exposure
40-60 ppm = Exposure for 30-50 minutes without effective respiration may cause bronchitis,
pulmonary edema or bronchopneumonia
100 ppm = May be lethal after 50 minutes of exposure (estimated)
430 ppm = Lowest concentration known to cause lethality after 30 minutes of exposure
1000 ppm = May be fatal with a few deep breaths
NOTES TO PHYSICIAN:
Treatment is symptomatic. Because there is no known antidote for chlorine gas inhalation,
effective and immediate relief of symptoms is the primary goal. Steroid therapy, if given early, has
been reported effective in preventing pulmonary edema.
SYNERGISTIC MATERIALS:
None known.
HI, IMPORTANT COMPONENTS
CAS NUMBER / NAME
7782505 Chlorine
EXPOSURE LIMITS PERCENTAGE
PEL: 0.5 ppm; 1.5 mg/m3 TWA VOL ND
STEL 1 ppm; 3 mg/m3 WT 99.50-100
TLV: 0.5 ppm; 1.5 mg/m3, TWA
STEL 1 ppm; 2.9 mg/m3
IV. FIRE AND EXPLOSION DATA
FLASH POINT: Not applicable AUTOIGNITION TEMPERATURE: Not applicable
FLAMMABLE LIMITS IN AIR % BY VOLUME - UPPER: Nonflammable
LOWER: Nonflammable
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Material Safety Data Sheet: Chlorine
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Page 4 of 7
04-01-96
CHLORINE GAS
IV. FIRE AND EXPLOSION DATA (Continued)
EXTINGUISHING MEDIA:
Use water to keep fire-exposed containers cool. If it is necessary to stop the flow of gas, use
water spray to direct escaping gas away from persons effecting the shut-off. Wear full protective
clothing. Use extinguishing media as appropriate for surrounding fire.
SPECIAL FIRE FIGHTING PROCEDURES:
In case of fire, chlorine containers should be removed from fire zone immediately. Tank cars
or barges should be disconnected and pulled out of the danger area. If no chlorine is escaping,
water should be applied to cool containers that cannot be moved. All unauthorized persons should
be kept at a safe distance. Fire fighters must use self-contained breathing apparatus, eye protection
and full protective clothing.
UNUSUAL FIRE AND EXPLOSION HAZARD:
Chlorine gas or liquid, is nonexplosive and nonflammable. However, like oxygen, it is
capable of supporting combustion of certain substances. Reacts explosively, or forms explosive
compounds, with many chemicals, such as acetylene, turpentine, ether, ammonia gas; hydrogen,
and finely divided metals.
SENSITIVITY TO MECHANICAL IMPACT:
Non sensitive.
SENSITIVITY TO STATIC DISCHARGE:
Non sensitive.
V. SPECIAL PROTECTION
VENTILATION REQUIREMENTS:
Provide general and local exhaust ventilation to meet OSHA ceiling exposure limit of 1 ppm.
Provide venting for low-lying areas. Use closed systems when possible.
SPECIFIC PERSONAL PROTECTIVE EQUIPMENT
RESPIRATORY:
Use a NIOSH/MSHA approved respirator following manufacturer's recommendations where
gas leaks may occur. Use supplied air respirator in positive mode following ANSI Zt 17.1 for tank
and confined space entry.
EYE:
Face shield and chemical goggles should be worn.
GLOVES:
Impervious gloves should be worn. Natural rubber or latex have been used. Contaminated
gloves should be discarded.
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CHLORINE GAS
Page 5 of 7
04-01-96
V. SPECIAL PROTECTION (Continued)
OTHER CLOTHING AND EQUIPMENT:
Standard work clothing. Wash contaminated clothing with soap and water and dry before
reuse. Emergency shower and eyewash facility should be in close proximity.
VI. PHYSICAL DATA
BOILING POINT @ 760 MM hG: -34'C (-29.3ฐF)
FREEZING POINT: -101 ฐC (-150ฐF)
VAPOR PRESSURE: 2748MM hG @ 0ฐC
SPECIFIC GRAVITY (H20 = 1): 1.4 @ 15.4ฐC
SOLUBILITY IN H20 % BY WRT: 0,7% @ 20ฐC
VAPOR DENSITY (Air = 1): 2.5
APPEARANCE AND ODOR: Amber color liquid. Greenish-yellow gas,
Pungent irritating odor.
ODOR THRESHOLD (ppm): Approximately 2 ppm
pH: 0.7% solution has pH 5.5
% VOLATILES BY VOL.: 100%
EVAPORATION RATE: Not applicable; gas under atmospheric conditions.
COEFFICIENT WATER/OIL DISTRIBUTION: Not available.
VII. REACTIVITY DATA
CONDITIONS CONTRIBUTING TO INSTABILITY:
Chlorine is stable. Avoid the release of chlorine to the atmosphere. Do not place chlorine
containers near heat or fire. Never use water on the source of the chlorine leak. Water spray may
be used to direct the flow of escaping chlorine gas.
INCOMPATIBILITY:
Reducing agents, combustible materials. Keep away from materials such as acetylene,
turpentine and other hydrocarbons, ammonia, hydrogen, ether, powdered metals, sulfur and
aluminum. Reacts with hydrogen sulfide and water forming hydrochloric acid. Combines with
carbon monoxide and sulfur dioxide forming phosgene and sulfuryl chloride. Moist chlorine is highly
corrosive to most metals. Chlorine reaction to some organic compounds can be explosive. Strong
oxidizer.
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Material Safety Data Sheet: Chlorine
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Page 6 of 7
04-01-96
CHLORINE GAS
VII. REACTIVITY DATA (Continued)
HAZARDOUS DECOMPOSITION PRODUCTS:
None.
CONDITIONS CONTRIBUTING TO HAZARDOUS POLYMERIZATION:
None.
VIII. HANDLING AND STORAGE
HANDLING AND STORAGE PRECAUTIONS:
Store chlorine containers in a well ventilated area of low fire potential and away from
incompatible materials (acetylene, turpentine, other hydrocarbons, ammonia, hydrogen, ether,
powdered metals, sulfur, aluminum, reducing agents and combustible materials}. Keep away from
heat and source of ignition. Protect container from weather and physical damage. Follow safety
procedures for containers of compressed gases. Provide special training to workers handling
chlorine. Regularly test and inspect piping and containment used for chlorine service. Liquid levels
should be less than 85% of tank or cylinder capacity.
IX. ENVIRONMENTAL PROCEDURES
STEPS TO BE TAKEN IF MATERIAL IS RELEASED OR SPILLED:
If a material is spilled or released to the atmosphere, keep up-wind, provide ventilation, wear
full protective equipment and shut off supply at source. Exclude non-essential personnel. Contain
liquids and prevent discharges to streams or sewer systems; and control or stop the loss of volatile
materials to the atmosphere. Large leaks may require environmental consideration and possible
evacuation. Do not apply water to leak.
Spills or releases should be reported, if required, to the appropriate local, state and federal
agencies.
NEUTRALIZING CHEMICALS:
Chlorine can be absorbed into an alkaline solution, i.e., caustic soda (NaOH), caustic potash
(KOH), lime, etc.
WASTE DISPOSAL METHOD:
Move leaking container to isolated area. Position to release gas, not liquid. Absorb in
alkaline solution of caustic soda, soda ash or hydrated lime.
Dispose in accordance with all federal, state, and local health and pollution regulations.
Depending upon the particular situation involved, special equipment may be required. Consult your
chlorine supplier.
X. ADDITIONAL INFORMATION
Spills of chlorine of 10 or more pounds must be reported to the National Response Center,
1-800-424-8802.
60 Material Safety Data Sheet: Chlorine
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Page 7 of 7
04-01-96
CHLORINE GAS
ADDITIONAL INFORMATION (Continued)
Chlorine is contained on a list as required under Sec 101{14) of CERCLA, which includes
substances designated pursuant to SEC 311 of the Clean Water Act. Hazardous Wastes under SEC
3001 of RCRA, Toxic Pollutants under SEC 307 of the Clean Water Act. Hazardous Air Pollutants
under Sec 112 of the Clean Air Act. Imminently hazardous Chemicals under Sec 7 of TSCA.
Chlorine is designated a hazardous substance by 29 CFR Sec 1910. Subpart Z. The Federal
insecticide, Fungicide and Rodenticide Act (FIFRA) is applicable if chlorine is used as a pesticide or
in water or sewer treatment applications.
OSHA Standard 29 CFR 1910.1200 requires that information be provided to employees
regarding the hazards of chemicals by means of a hazard communication program including labeling,
material safety data sheets, training and access to written records. We request that you, and it is
your legal duty to, make all information in this Material Safety Data Sheet available to your
employees.
This product contains a toxic chemical or chemicals subject to the reporting requirements
of SECTION 313 of TITLE III of the SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF
1986 and 40 CFR PART 372. (See Section III. List Legend 02)
XI. PREPARATION INFORMATION
For additional non-emergency health, safety or environmental information telephone or write to:
Facility Y
Chlorine Information Service
1 Manufacturing Street
Pacific Tower, WA 99999
For Emergencies: 24 HOUR EMERGENCY PHONE
To request an MSDS: 1 -888-100-1100
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Material Safety Data Sheet: Chlorine
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U.S. ENVIRONMENTAL PROTECTION AGENCY
ACCIDENTAL RELEASE INFORMATION PROGRAM
QUESTIONNAIRE
INITIAL REPORT
SECTION I. FACILITY PROFILE
FACILITY NAME: Facility X
Dunn & Bradstreet Number: ( ] |- [ | j j- ( [
FACILITY MAILING ADDRESS:
1 Industry St.
Street
Pacific Town
City
WashinEton
State
99999
Zip Code
b. Facility physical address:
1 Industry St,
Street
Pacific Town
City
Washington
Slate
99999
Zip Code
4, Latitude Longitude
1.
2.
3a.
DEG
1
MIN
i
DEG
1
1
MIN
S/% 63 ARIP Questionnaire
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5. NAME AND ADDRESS OF
OWNER OR CHIEF Bill Smith
EXECUTIVE OFFICER: Name
1 Industry St.
Street
Pacific Town
City
Washington
State
99999
Zip Code
6a. RESPONDENT: Virginia Williams
Name
Vice President. Safety
Title
1 Industry St.
Street
Pacific Town
City
Washington
State
99999
Zip Code
(206) 555-6666
Telephone
b. DATE QUESTIONNAIRE
COMPLETED: February 19. 19XX
7. Indicate the total number of employees typically at the facility (include all full-time and part-time
employees, all employees on paid sick leave, paid holidays, paid vacations, managers, and corporate
officers at the facility). 45
8. Identify the four-digit Standard Industrial Classification (SIC) that best describes your facility
operations and the primary product or service of this facility.
a. SIC code: 9 5 II
b. Primary product or service: Treating water for residential and industrial use.
c. For facilities with multiple SIC codes, please identify the additional SIC codes.
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SECTION II. HAZARDOUS SUBSTANCE RELEASE PROFILE
The following section asks several questions concerning the accidental release of hazardous substances. If
exact responses cannot be provided, please provide estimates using your best professional judgment,
9. Indicate the date release began,
12 - 12 - XX
(month) (day) (year)
Indicate the date release ceased.
11 - 11 - XX
(month) (day) (year)
10. Indicate time of day release began.
1 0:40
X A.M.
_ P.M.
Indicate time of day release ceased,
10:52
X A.M.
_ P.M.
11a. Check the item below that best describes the status of the process line where the event occurred at
the time of release.
1. X In operation
2. _ Temporarily inactive
3. _ Testing/trial run
4. _ Scheduled startup
5. _ Scheduled shutdown
6. _ New construction
7. _ During maintenance
8. _ Production changeover
b. Check the item below that best describes the current status of the process line where the event
occurred.
1. X In operation
2. _ Temporarily inactive
3. _ Permanently closed
If item 2 or 3 is marked, answer Question 11c; otherwise go to Question 12.
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c. Is the shutdown of operations at the process line related to the accidental release of hazardous
substances?
_ Yes
_ No
12a. Were federal authorities notified?
X Yes
_ No
b. If yes, please indicate which federal authorities were notified:
1. X National Response Center Telephone number called (800) 424-8802
2. _ Coast Guard Telephone number called
3. _ EPA Telephone number called
4. _ Other (specify)
c. Indicate the date and time of day federal authorities were notified.
12 - 12 - XX (Date)
(month) (day) (year)
11:15
X A.M.
_ P.M.
13a. Were state authorities notified?
X Yes
_ No
b. If yes, identify all state authorities notified concerning the release. (If more than one, please attach
list on separate page.)
(Name) (Title)
Washington Emergency Response Commission
(Agency)
Olvmpia
(City)
Washington
(Slate)
f80ffl 633-7585
(Telephone)
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c. Indicate the date and time of day state authorities were notified.
12 - 12 - xx (Date)
(month) (day) (year)
I 1:1 0 (Time)
X A.M.
_ P.M.
14a. Were local authorities notified?
X Yes
_ No
b. If yes, identify all local authorities notified concerning the release. (If more than one, please attach
list on separate page.)
(Name)
(Title)
Pacific Town Fire Deoartment
(Agency)
Pacific Town
(City)
Washington
(Slate)
(206) 555-9111
(Telephone)
c. Indicate the date and time of day local authorities were notified.
12-12 -XX (Date)
(month) (day) (year)
10:55 (Time)
X A.M.
_ P.M.
15a. Was the general public notified?
_ Yes
X No
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b. If yes, indicate the person that notified the general public of the release. (If more than one, please
attach list on separate page.)
(Name) (Title)
(Agency)
(City)
(State)
^Telephone)
16. For this particular release, what type(s) of communication technologies were used by the facility to
alert and notify the public to evacuate or take other safety measures?
a. _ Door-to-door notification
b. _ loudspeakers/public address system
c. __ Tone alert radio/pagers
d. _ Sirens/alarms
e. _ Modulated power lines
f. _ Aircraft
g. _ Radio
h. _ Television
i. _ Cable override
j. _ Telephone
k. X None
I. _ Other (please describe)
17a, Were members of the general public evacuated? b. Were members of the general public
sheltered in place?
_ Yes _ Yes
X No X No
If yes, please indicate number evacuated. If yes, please indicate
number sheltered in place.
5/96 68 ARIP Questionnaire
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18.
To the best of your ability, indicate weather conditions at the time of release for each item below.
Approximations are acceptable.
a. Wind speed (miles per hour) _ T 9
b. Wind direction ESE
c. Humidity (percent) _ 7 3
d. Temperature (Fahrenheit) _ 5 3
e. Precipitation? __ Yes X_ No
19. Briefly describe the circumstances that led up to the release (if helpful include a sketch).
The release involved a 50-pound discharge from the old chlorine delivery system. The release
occurred when chlorine discharge tubing connecting a 1-ton chlorine container to the chlorine
manifold ruptured, releasing liquid chlorine. The tubing ruptured when the ton container was hit and
jarred bv another container. At the time of the incident, the second ton container was being moved
bv the chlorine delivery system operator using a hand-controlled overhead hoist.
20. Please check the one item below that best describes the location of the release within your facility.
a. _ Process vessel
b. _ Storage vessel
c. _ Valves on process vessel
d. _ Valves on storage vessel
e. _ Piping on process vessel
f. _ Piping on storage vessel
g. _ Pumps
h. _ Joints
i. _ Unknown
j. X Other (please describe)
Chlorine delivery system, evaporator room.
21. How was the release first discovered? (Check as many as apply.)
a. _ Indication by process control device (gauge or monitor)
b. X Chemical-specific detector
c. X General operator observation
d. _ Observation by foreman or supervisor
e. _ Injury/death
f. _ Explosion/fire
g. _ Major environmental damage
h. _ Third-party notification (i.e., POTW, community, other facility)
i. _ Other (describe below)
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22.
Please check the one item below that best describes the primary cause of the release event. (Check
only one item.)
a. X Equipment failure
b. _ Operator error
c. _ Bypass condition
d. _ Upset condition (explain below)
e. _ Fire
f. _ Maintenance activity
g. _ Unknown
h. _ Other (please describe)
23. Please check any items below that describe additional causes of the release event. (Check as many
items as apply.)
a. _ Equipment failure
b. X Operator error
c. _ Bypass condition
d. _ Upset condition (explain below)
e. _ Fire
f. X Maintenance activity
g. _ Unknown
h. _ Other (please describe)
24. Check the items that describe the end effects of the release event. (Check as many as apply.)
a
b
Spill
e
d
c
X Vapor release
_ Explosion
_ Fire
_ Other (describe)
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25a. In the table below, please estimate the quantity of each substance released to each media. Be sure
to specify the measurement unit.
Chemical
la. Name
b. CAS #
c. Physical State
d. Concentration
2a. Name
b. CAS #
c. Physical State
d. Concentration
3 a. Name
b. CAS it
c. Physical State
d. Concentration
4a. Name
b. CAS ง
c. Physical State
d. Concentration
Chlorine
7782-50-5
Gas
100%
Media
Air
Surface Water
Land
Sewer to Treatment
Facility
Air
Surface Water
Land
Sewer to Treatment
Facility
Air
Surface Water
Land
Sewer to Treatment
Facility
Air
Surface Water
Land
Sewer to Treatment
Facility
Quantity
50
Unit
pounds
5196
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ARIP Questionnaire
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b. Please check the items below that describe your methods or the source(s) of information for your
responses in Question 25a. (Check as many as apply.)
X Physical properties and ambient conditions
X On-line instrument
_ Engineering estimate
X Tank/system inventory
_ Chemical analysis
_ Effluent measured
_ Inventory check
X Computer simulation
X Process records
_ No release to media
_ Other (please describe)
26a. Did any substances identified in Question 25 migrate beyond the legal boundaries of your facility
(for example, was a vapor release carried by prevailing wind beyond the fence line of your facility)?
X Yes (If yes, please answer Questions 26b and c)
_ No (If no, skip Question 26b and answer Question 26c)
b. In the following table, specify the quantities of substances that migrated beyond your facility
boundaries.
Chemical
Media
Quantity
Unit
1. Name:
2. Name
Physical state:
3. Name
Physical state:
4. Name
Physical state:
Chlorine
Physical state: Gas
Air
Surface Water
Land
POTW
Air
Surface Water
Land
POTW
Air
Surface Water
Land
POTW
Air
Surface Water
Land
POTW
50
pounds
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ARJP Questionnaire
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c. Please check the items below that describe your methods or sources of information for your
responses in Question 26b.
X Physical properties and ambient conditions
_ On-line instrument
_ Engineering estimate
_ Tank system inventory
_ Chemical analysis
_ Effluent measured
_ Computer simulation
_ Inventory check
_ Process records
_ Assumed
_ Other (please describe)
27. Did injuries occur among facility employees or contractors as a result of the event?
_ Yes
X No
a. If yes, please indicate number of injuries.
b. How many of these received hospital treatment?
Number treated unknown
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Did deaths occur among facility employees or contractors as a result of the event?
.... Yes
X No
If yes, please indicate number of deaths.
Did injuries occur among the general public as a result of the event?
_ Yes
X No
_ Don't know
If yes, please indicate number of injuries.
How many of these received hospital treatment?
_ Number treated unknown
Did deaths occur among the general public as a result of the event?
_ Yes
X No
Don't know
If yes, please indicate number of deaths.
Please indicate the environmental effects that occurred as a result of the release:
a. _ Fish kills
b. _ Vegetation damage
c. _ Soil contamination
d. _ Groundwater contamination
e. _ Wildlife kills
f. X None
g. _ Other (please specify)
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ARIP Questionnaire
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SECTION III. CLEANUP AND PREVENTION PROFILE
30. Please describe the immediate response activities taken to contain or minimize the release.
The chlorine evacuation system automatically activated, removing most of the chlorine vapor from
the room. The chlorine delivery operator activated the chlorine release alarm and left the room to
don proper PPE. Then, when backup resoonders arrived (within 1-2 minutes), the operator returned
to the room and closed the container outlet valve, stopping the leak. Draeger tube readings were
taken at the facility boundary and no elevated readings were obtained. However, the proximity of
the room to the facility boundary and the wind conditions at the time of the release led to the
conclusion that the chlorine had been released beyond the facility boundary.
31. Did your facility undertake cleanup of the release?
_ Yes (If yes, skip Question 32a.)
X No (NA)
32a. Please supply the name and address of the party responsible for cleanup.
(Name)
(Title)
(Agency)
(City)
(
(State)
)
(Telephone)
b. Has cleanup of the release been completed?
_ Yes (If yes, please answer Question 32c.)
_ No (If no, please answer Question 32d.)
c. Indicate the date cleanup activity ceased.
(month) (day) (year)
d. Please indicate the approximate date completion of cleanup activity is expected.
(month) (day) (year)
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ARIP Questionnaire
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33. How did you dispose of the waste generated during the spill and cleanup?
Ons ite N/A
Qffsite N/A
34a. Prior to this release event, which types of formalized hazard assessments were performed? (Check
as many items as apply.) For those items checked, please indicate the frequency performed (i.e.,
quarterly, annually, one time, or on occasion).
X Cause-consequence analysis
_ Dow and Mond hazard indices
_ Event tree analysis
_ Failure modes, effects, and criticality analysis
_ Fault tree analysis
X HAZOP/hazard and operability studies
_ Human error analysis
_ Probabilistic risk assessment
_ "What if" analyses
_ None
_ Other (please describe)
b. What is your opinion of the effectiveness of each of the assessment techniques used?
Both HAZOP and cause-consequence have been used with great success. HAZOPs. although
expensive to conduct, are particularly valuable for identifying hazards.
SI96 76 ARIP Questionnaire
Frequency
annually
annually
-------
35. Prior to this release event, which of the following prerelease controls have been employed
specifically to identify or prevent the type of release that occurred? (Check as many items as apply.)
a. X Preventive maintenance
b. X Regular equipment inspections and testing
c. X Hazard assessment
d. _ Comprehensive audit
e. _ Regular assessment of equipment designs
f. X Process controls for operations monitoring and/or warning
g. _ Regular upgrading of equipment
h. _ Comprehensive investigation of similar equipment failure
i. X Standard operating procedures
j. _ Release prevention equipment
k. _ Equipment installation checks
1. _ Other (please describe)
36. Prior to this release, what management activities related to safety and loss prevention have been
employed? (Check as many as apply.)
a.
X Employee safety training (e.g., OSHA training program)
b.
X Emergency response training
c.
X Employee testing
d.
X Certification of operators on equipment/system
e.
X Membership in CAER or other similar programs
f.
X Release control program
g-
X Accident investigation reports
h.
_ Research/conferences
i.
X Safety loss prevention office/officer
k.
_ Program to improve system design
1.
_ None
m.
_ Other (please describe)
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ARIP Questionnaire
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37. For this particular release, what method(s) of prerelease protection equipment (systems to capture,
neutralize, or destroy a toxic chemical before it is released into the environment) is used by the
facility? (Check as many items as apply.)
a. _ Containment (i.e., diking, dump tank - explain below)
b. _ Neutralization
c. _ Scrubber
d. _ Flares/incineration
e. _ Adsorbers
f. _ Spray curtain
g. X Emergency equipment (i.e., firefighting)
h. _ None
i. _ Other (please describe)
38. For this particular release, what systems or procedures were employed by the facility to minimize
accident potential? (Check all that apply.)
a. _ Backup systems
b. _ Redundant systems
c. _ Minimize inventory
d. _ Valve lock out
e. _ Automatic shut off
f. _ Bypass and surge systems
g. Manual override
h. _ Limit capacity of equipment
i. X Standard operating procedures (logs, checklists)
j, X Alarms
k. _ Interlocks
1. _ None
m. _ Other (please describe)
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ARIP Questionnaire
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In response to this release, which of the following prerelease controls have been implemented or
modified to identify/prevent future potential releases? (Check as many as apply.)
a. X Preventive maintenance
b. X Regular equipment inspections and testing
c. X Hazard assessment
d. _ Comprehensive audit
e. _ Regular evaluation of equipment designs
f. _ Increase process controls for operations monitoring and/or warning
g- _ Upgrading equipment
h. _ Revised standard operating procedures
i, _ Follow accident report investigation recommendations
j. _ Develop or refine emergency response planning
k. _ Other (please describe)
Describe the changes in the content of your training programs as a result of this release.
Increased overhead hoist training will help prevent this type of incident.
Describe the immediate equipment repairs and/or replacements, management practices, operational
changes, etc. made as a result of the release.
The operators and maintenance crew replaced the chlorine connecting tubing and conducted a check
on the proper operation of the system.
What additional long-term preventive measure(s) will be taken to minimize the possibility of
recurrence?
The plant conducts more frequent inspection of chlorine connecting tubing and increased overhead
hoist training.
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ARIP Questionnaire
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TEXT SUMMARY
SITE DATA INFORMATION:
Location: PACIFIC TOWN, WASHINGTON
Building Air Exchanges Per Hour: 0.38 (Sheltered double storied)
Date and Time: Using internal Macintosh clock
CHEMICAL INFORMATION:
Chemical Name: CHLORINE GAS
Molecular Weight: 70.9 kg/kmol
TLV-TWA: 0.50 ppm
IDLH: 30.00 ppm
Footprint Level of Concern: 1.00 ppm
Boiling Point: -29 * Fahrenheit
Vapor Pressure at Ambient Temperature: Greater than 1 atm
Ambient Saturation Concentration: 1,000,000 ppm or 100.0%
ATMOSPHERIC INFORMATION: (MANUAL INPUT OF DATA)
Wind: 8 mph from ESE
No Inversion Height
Stability Class: B
Air Temperature: 53 "F
Relative Humidity; 75%
Ground Roughness: Open country
Cloud Cover: 7 tenths
SOURCE STRENGTH INFORMATION:
Pipe Diameter: 0.50 inches
Pipe Length: 800 feet
Pipe Temperature: 73 "F
Pipe Press: 150 lbs/in.2
Pipe Roughness: Smooth
Hole Area: 0.150 in.2
(Unbroken end of the pipe is closed off)
Release Duration: 13 minutes
Max Computed Release Rate: 3.85 pounds/min
Max Average Sustained Release Rate: 3.85 pounds/min
(average over a minute or more)
Total Amount Released: 50 pounds
FOOTPRINT INFORMATION:
Dispersion Module: Heavy gas
User Specified LOC: 1.00 ppm
Max Threat Zone for LOC: 1204 yards
Max Threat Zone for IDLH: 192 yards
For more detailed information, check the time-dependent
conc/dose information at specific locations
TIME DEPENDENT INFORMATION:
Concentration/Dose Estimates at the Point:
Downwind: 1000 yards
Off Centerline: 10 yards
Max Concentration:
Outdoor: 1.62 ppm
Indoor: 0.383 ppm
Max Dose:
Outdoor: 4.8 (ppm/min)
Indoor: 1.18 (ppm/min)
Note: Indoor graphs are shown with a dotted line.
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Chlorine. Release Model
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FOOTPRINT WINDOW
Chemical Name: CHLORINE, GAS
Model Run: Heavy gas
Wind: 8 mph from ESE
FOOTPRINT INFORMATION:
Dispersion Module: Heavy gas
User specified LOG: 1.00 ppm
Max TTireat Zone for LOC: 1204 yards
Max Threat Zone for IDLH: 192 yards
For more detailed information, check the time-dependent
conc/dose information at specific locations
500
300
00
ฆo
k.
100
300
500
0 200 400 600 800 1,000 1,200 1,400
yards
5/96
82
Chlorine Release Model
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CHEMICAL SAFETY AUDIT
FACILITY X
PACIFIC TOWN, WASHINGTON
(FEBRUARY 5 - FEBRUARY 8, 19XX)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 11
MAY 19XX
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REPORT DISCLAIMER
The contents of this report reflect information concerning Facility X obtained during a U.S.
Environmental Protection Agency (EPA) Chemical Safety Audit and from records provided by
Facility X. The audit was conducted from February 5, 19XX, through February 8, 19XX, and the
observations as presented in this report provide a snapshot of conditions existing at the facility during
the audit time frame. They do not represent planned or anticipated changes proposed or ongoing at
the facility. The recommendations and other report observations contained in this report are not
mandatory actions that the facility must implement. In addition, EPA makes no assurances that if
implemented, the recommendations and other report observations contained in this report will prevent
future chemical accidents, equipment failures, unsafe management practices, or provide protection
from a future enforcement action under any applicable law or regulation.
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TABLE OF CONTENTS
Eige
1.0 INTRODUCTION 1
1.1 Chemical Safety Audit Program
1.2 Facility X - Pacific Town, Washington, Audit
2.0 SUMMARY OF FINDINGS/CONCLUSIONS 2
3.0 BACKGROUND 3
3.1 General Facility and Audit Information
3.2 Purpose of the Audit and Facility Selection Process
3.3 Audit Methodology
4.0 FACILITY BACKGROUND INFORMATION 4
5.0 CHEMICAL HAZARDS 4
6.0 PROCESS INFORMATION FOR CHLORINE 7
6.1 Storage and Handling
6.2 Process Description
6.3 Process Hazards
7.0 CHEMICAL ACCIDENT PREVENTION 11
7.1 Management Activities
7.2 Process Operation and Maintenance
7.3 Hazard Evaluation and Modeling
7.4 Release Prevention Systems
7.5 Release Mitigation Systems
8.0 ACCIDENTAL RELEASE/INCIDENT INVESTIGATION 13
9.0 FACILITY EMERGENCY PREPAREDNESS AND PLANNING
ACTIVITIES 14
10.0 COMMUNITY AND FACILITY EMERGENCY RESPONSE
PLANNING ACTIVITIES 14
11.0 PUBLIC ALERT AND NOTIFICATION PROCEDURES 15
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12,0 CONCLUSIONS 15
13,0 RECOMMENDATIONS 16
Figure 1 - Facility X 5
Figure 2 - Communities Around Facility X 6
Figure 3 - Chlorine Delivery System 9
iv
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1.0 INTRODUCTION
1.1 Chemical Safety Audit Program
The Chemical Safety Audit (CSA) program has evolved from efforts of the U.S. Environmental
Protection Agency (EPA) under the Chemical Accident Prevention (CAP) program. The primary
objectives of the CAP program are to identify the causes of accidental releases of hazardous
substances and the means to prevent such releases from occurring, to promote industry initiatives in
these areas, and to share activities with the community.
The CSA program is part of this broad initiative and has been designed to accomplish the following
chemical accident prevention goals:
Heighten awareness of the need for chemical safety among chemical producers,
distributors, and users, as well as in communities where chemicals are located.
Visit facilities handling hazardous substances to learn and understand problematic and
successful practices and technologies for preventing and mitigating releases.
Build cooperation among authorized parties by coordinating joint accidental release
investigations where appropriate.
Establish a national database for the assembly and distribution of chemical safety
information obtained from facility investigations and from other sources.
The audit consists of interviews with facility personnel and onsite review of various aspects of facility
operations related to the prevention of accidental chemical releases. CERCLA Sections 104(b) and
104(e), as amended by SARA, provide authorities for entering a facility and accessing information.
Specific topics addressed in the audit include:
Process characteristics.
Hazard evaluation and release detection techniques.
Training of operators and emergency response personnel.
Management structure (corporate and facility).
Preventive maintenance and inspection programs.
Community notification mechanisms and techniques.
1.2 Facility X -- Pacific Town, Washington, Audit
This report contains observations, conclusions, and recommendations from an audit conducted at
Facility X, a water treatment plant in Pacific Town, Washington, from February 5 through
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February 8, 19XX. The facility was selected for an audit because of a series of releases of chlorine
from a water filtration unit, the last one of approximately fifty pounds. This report identifies and
characterizes the strengths of specific chemical process safety management program areas to allow
the elements that are particularly effective to be recognized. Copies of this report have been
provided to the facility's corporate management so that weak and strong program areas may be
recognized.
2.0 SUMMARY OF FINDINGS/CONCLUSIONS
Based on a limited review of the chemical process safety management practices related specifically
to the handling of chlorine, the audit team has reached the following conclusions:
Facility X management actively sponsors and provides training for emergency
response, maintenance, and operations; has reduced the chlorine operating inventory;
and has documented operating and maintenance procedures, checklists, and standard
safety rules for all tasks and operations.
Facility activities to prevent catastrophic chlorine leaks include using flow cutoff
valves and earthquake protection measures.
Facility X is conducting hazard evaluations in accordance with OSHA Process Safety
Management, 29 CFR 1910.119, and the task is about 50-percent complete.
Corporate policy calls for evaluations to be performed annually, but because of
budget constraints, this task has not been completed.
The facility began performing preventive and predictive maintenance and maintaining
appropriate records about 6 months ago at the direction of corporate management.
Records for equipment inspection, testing, and repair are incomplete except for the
last 6-month period.
The facility has evaluated a chlorine perimeter monitoring system and elected not to
install such a system. However, the facility is currently investigating the use of
additional chlorine detectors at certain potential release points.
The facility added a chlorine scrubbing system to the new water filtration unit when
it was built. The facility has plans to add a scrubbing system to the old filtration unit
as well.
The facility management conducts incident investigations for all deviations from
standard conditions and identifies problems in the investigation reports. However,
there is no systematic follow-up to correct those problems.
The facility incident investigation of the last chlorine release found that chlorine
discharge tubing connecting a 1-ton chlorine container to the chlorine manifold
ruptured, releasing approximately 50 pounds of liquid chlorine.
2
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The facility notified the local fire department rather than the local emergency
planning committee (LEPC) of its chlorine releases. This was done at the LEPC's
request.
The fire brigade, responsible for handling all emergency situations, meets regularly
but has not conducted a drill in nearly 15 months.
3.0 BACKGROUND
3.1 General Facility and Audit Information
Facility X is owned by XYZ Manufacturing, Inc., the parent company. Facility X operates at the
following address:
Facility X
1 Industry St.
Pacific Town, WA 99999
The facility has five sections and is located north of Interstate Highway 1 and west of County
Highway. The facility provides drinking water for the Pacific Town area using a multistep process
that includes water clarification, filtration, and chlorine addition. The audit was conducted from
February 5 through February 8, 19XX, by a team of regional representatives from EPA. EPA was
assisted by representatives from the Occupational Safety and Health Administration (OSHA), the
State Emergency Response Commission (SERC), and the LEPC. The names of the team members,
their affiliations, their responsibilities in the audit, and their expertise are provided in Appendix A.
3.2 Purpose of the Audit and Facility Selection Process
The purpose of the audit was to examine the facility's chemical process safety management practices
associated with chlorine. The facility was selected for an audit based on an analysis of chemical use
in the region, referral from the SERC, and the facility's release history. Region 11 identified
chlorine and ammonia as the two chemicals used in the highest volume in the region. The SERC
requested that the Regional Office conduct a CSA based on the facility's release history. There was
a series of accidental releases of chlorine that occurred over the past year, the last one of
approximately 50 pounds.
3.3 Audit Methodology
The audit centered around the process areas related to the use of chlorine in the water treatment
process. The audit addressed chlorine hazards, chemical accident prevention, process operation and
maintenance, hazard evaluation and modeling, release prevention systems, accidental release incident
investigation, facility emergency preparedness and planning, and community and facility emergency
response planning activities. However, the audit is limited in that is does not attempt to make
3
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comparisons or otherwise distinguish between the safety systems used only for water treatment
processes and those used for other chemical processes at the facility.
4.0 FACILITY BACKGROUND INFORMATION
Facility X is located approximately 100 miles west of Seattle on the Pacific coast in an area known
as Pacific Town. This facility is located north of Interstate Highway 1 and west of County Highway.
Figures 1 and 2 are maps of the area, provided to the audit team by the facility. The facility is
bounded on the north side by the railroad tracks. There are five units on the property: the old
filtration unit, the old clarifying unit, the new filtration unit, the new clarifying unit, and the offices.
There is also a parking lot. The facility can be accessed from either the main gate off the Interstate
Highway or from the railroad spur. Hazardous and extremely hazardous substances are transported
both by highway and rail. The facility is 20 years old and employs 45 persons.
The facility occupies 100 acres in a relatively sparse area approximately 2.5 miles from the nearest
community shopping mall. An elementary school is within 3 miles, and a lake, critical to the town's
water supply, is within 3.5 miles of the plant. The shopping mall, the school, and the lake are
considered by the facility to be sensitive populations and environments in the event of a major
chlorine release. Both the County Highway and the Interstate Highway are heavily traveled routes.
Pacific Town experiences the heavy spring rains and high humidity associated with a Northwest
Pacific coastal city. Other relevant weather data include an average temperature of 53'F, an average
relative humidity of 73 percent, and a mean wind speed of 7.9 miles per hour from east-southeast
direction. The facility is situated near a flood plain, and minor flooding often occurs in the area
during the spring months. The coastal area also is susceptible to earth tremors from nearby
earthquake-prone zones. In April 1965, before this facility was built, an earthquake with an
epicenter in Puget Sound-Taeoma caused extensive building and property damage to the coastal
region. In response to this potential for damage, the facility owners designed and constructed the
chemical process buildings with lateral bracing and strong connections to guard against the dangerous
horizontal motions that can be caused by an earthquake.
The design capacity for the water treatment plant is 10 million gallons of treated water per day.
Currently, it operates at a 70-percent capacity. Within the last year, the facility had seven chlorine
releases, which were reported to the National Response Center (NRC) and have been documented
in internal incident investigation reports.
5.0 CHEMICAL HAZARDS
According to the facility safety supervisor, chlorine, if released accidentally, poses the greatest threat
to the community. The facility has two chlorine delivery systems, one in each of the two filtration
units. A chlorine delivery system includes two 1-ton containers of chlorine. One of the containers
is in use, and the second container is available as a spare. The second container is connected to the
delivery system and shut off at the container. Because one container is always shut off, a
catastrophic failure of a chlorine delivery system could cause no more than a 1-ton release.
4
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FIGURE 1. Facility X
New Process
Old Process
Clarifier
Evaporator
Filter
Room
Clarifier
Chlorine
Storage
Area
Evaporator
Room
Filter
Offices
Parking
Highway 1
5
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FIGURE 2. Communities Around Facility X
Arnie's Golf
Course
Elementary
<^School
3 Miles
Facility X
2.5 Miles
3.5 Miles
Lake Golden
Shopping Center
6
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A chlorine scrubbing system was installed in the new filtration unit when it was built. The scrubbing
unit has the capacity to neutralize 2 tons of chlorine. Plans exist to build a similar scrubbing unit
in the old filtration unit, but the scrubbing system had not been installed at the time of the audit.
Within the last year, the facility has had seven chlorine releases that were above the 10-pound
reportable quantity. They were reported to the NRC, the SERC, and the LEPC. The releases have
been documented in internal incident investigation reports.
A Material Safety Data Sheet (MSDS), which includes the National Institute of Occupational Safety
and Health (NIOSH) Immediately Dangerous to Life and Health (IDLH) levels for chlorine, is
provided in Appendix B. In the chlorine delivery areas, large bright signs indicate the presence of
chlorine.
A mini-library of reference materials is mounted on the wall outside each chlorine delivery system.
The library includes information on the hazards associated with chlorine and includes MSDSs,
accidental investigation reports, a folder describing worker rights and responsibilities under OSHA
regulations, and a document summarizing SARA Title III Community Right-to-Know provisions.
Employees are encouraged to use the mini-library; however, most employees interviewed were not
aware of these resources.
6.0 PROCESS INFORMATION FOR CHLORINE
6.1 Storage and Handling
Storage Systems
Chlorine is stored in 1-ton containers located in a shed outside the chlorine room for the old chlorine
delivery system. No more than six full containers are stored in the shed by facility policy. Clearly
marked empty ton containers are also stored in the shed.
In the past, 10 or more full chlorine ton containers were stored at the facility. Hazard analysis
conducted by the facility indicated a very small possibility of catastrophic release from these
containers during a natural disaster such as a major earthquake. To reduce the possibility of this
type of release, a facility policy was created that reduced the maximum number of containers to six.
Shipping and Receiving
Chlorine ton containers are generally shipped to the facility once a month by truck. By facility
policy, they are only received between 3:30 p.m. and sunset. This policy was established to eliminate
transportation-related releases when the local elementary school is in session or after dark when it
is harder to identify and track chlorine releases.
Chlorine can be shipped to the facility by rail. Rail shipping procedures for ton containers exist, but
no chlorine has been shipped to the facility by rail in the past 5 years.
7
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Materia/ Transfer
Chlorine ton containers are transferred from the storage shed to the chlorine delivery systems as
needed. They are moved individually to a chorine delivery system evaporator room by crane and
truck. Each of the two chlorine delivery systems has an evaporator room that houses two chlorine
ton containers. In the evaporator room the containers are moved using overhead-mounted, hand-
controlled hoists. No more than two ton containers are held in a chlorine room at any time.
6.2 Process Description
Overview of Processing Steps
The water treatment process consists of clarifying and filtering the water and then treating it with
chlorine to eliminate any infectious agents. The major components of the process are clarifiers,
filters, and chlorination systems. Facility X has two water treatment processes: the old process and
the new process. Both contain the same components; the primary difference between the processes
is their size. The old process is designed to treat 3 million gallons of water a day, and the new
process is designed to treat 7 million gallons. A second difference is that the chlorination system
in the new process contains a chlorine scrubber that traps and neutralizes some chlorine releases.
In the processes, an alum-based flocculent is added to untreated water as it is pumped to the clarifier.
A clarifier removes suspended solids from the water. Flocculent clumps suspended solids together
to form floe. The resultant floe is large enough to settle out of the water in the clarifier.
From the clarifier, the water flows through a sand and anthracite coal filter. The filter removes any
remaining solids from the water. The water is then pumped out of the facility to water storage tanks.
Chemical additives in either the clarifier or filter remove color and odor-causing compounds from
the water. Chlorine is also added to the water, both in front of and after the filter, to kill disease-
causing organisms.
Details of Chlorine Flow in the Water Treatment Processes
In both processes, liquid chlorine flows from a discharge valve in a ton chlorine container through
steel discharge tubing to a chlorine manifold. The chlorine runs through the tubing and manifold
at ton container pressure which is approximately 85 to 140 psi. Chlorine flow is shown in Figure 3.
Two containers are connected to the manifold. Both containers are located on weigh scales that
continuously indicate the weight of the chlorine in the containers. To eliminate the possibility of
both containers emptying if the manifold ruptures, only one container is open at any time. The
remaining container is closed at the container's discharge valve.
From the manifold, the liquid chlorine flows to a chlorine evaporator. In the evaporator, the
chlorine is converted from a liquid to a gas using heat supplied by warm water. The chlorine and
the water never come in direct contact with each other in the evaporator.
8
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FIGURE 3. Chlorine Delivery System
Expansion
Tank
Chlorine Ton
Container
Manifold
Chlorine Ton ฃฃ*
Container
Delivery
Tubing
Evaporator
Relief
Vaive
Pressure
Reducing
Flow Cutoff
Valve
Fall Closed
Chlorinator
9
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The vaporized chlorine flows out of the evaporator past a cylindrical container called an expansion
tank. The tank serves as a gas expansion and collection area. The collected gas reduces variations
in the chlorine gas pressure which, at this point in the system, is usually in excess of 75 psi.
Color-coded chlorine gas piping directs the chlorine gas through a pressure relief valve, a pressure-
reducing flow cutoff valve, and a chlorinator, In Facility X, chlorine gas lines are a distinctive
pinkish color.
The pressure-relief valve prevents gas overpressure that could rupture the evaporator or the gas
chlorine lines. At a chlorine gas pressure of 160 psi, it opens and releases chlorine to reduce the
pressure. In the old chlorine delivery system, the released chlorine is vented into the atmosphere
above the roof of the system. In the new system, the chlorine is vented into the scrubber.
The pressure-reducing flow cutoff valve serves two functions. It reduces chlorine gas pressure to
50 psi, and if a chlorine gas pressure drop occurs, the valve closes, stopping the flow of chlorine
gas. A drop in chlorine gas pressure indicates a break in the chlorine piping. When the pressure
downstream of the valve drops below 15 psi, the valve closes, cutting off the flow of chlorine to the
chlorinator.
The chlorinator delivers controlled amounts of gas chlorine to six separate water streams. The
chlorine mixes with the water in the water streams and is carried to the rest of the water in the
treatment process. Two water streams are injected into the water in front of the filters and four
streams enter the water after the filters. The water is continuously monitored to make sure there is
enough residual chlorine in the treated water to kill disease-causing organisms. A loss of pressure
in any of the six water streams will close the pressure-reducing flow cutoff valve.
Major parts of both the old and new chlorine systems are housed in evaporator rooms. Each room
houses 2-ton containers, connecting tubing, a manifold, container weigh scales, and evaporators.
The old system evaporator room also houses the chlorinator. The new system chlorinator is located
in a separate room adjacent to the new evaporator room. A catastrophic release from the containers,
the tubing, the manifold, or the evaporators in either room will not be stopped by the pressure-
reducing cutoff valves.
Both the old and new chlorine delivery systems contain vapor evacuation systems that ventilate the
chlorine rooms. In an emergency, the evacuation systems reduce the concentration of chlorine in
the rooms to assist emergency response activities. The evacuation systems vent out the roof.
The new chlorine delivery system contains a chlorine scrubbing system capable of neutralizing 4000
pounds (2 tons) of chlorine. When activated, the scrubbing system removes chlorine vapor from the
new evaporator room and neutralizes it with a caustic soda solution. This action reduces the
concentration of chlorine in the new chlorine room and prevents the release of chlorine to the
environment. When the scrubbing system is activated, the vapor evacuation system automatically
shuts off.
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Chlorine Release Detection
Each chlorine room contains a wall-mounted chlorine detector. Inlets for the detectors are mounted
at the floor level. Because chlorine is heavier than air, the first traces of chlorine from a leak are
most likely to be detected at floor level. The detectors are set to sound an alarm at 1 part per
million chlorine in air. An alarm by the new system detector also starts the scrubbing system and
automatically closes all entry doors to the new chlorine room.
According to facility operators, another method for detecting chlorine leaks is by visual observation
using a weak ammonia solution. A white vapor that appears when a weak ammonia solution is used
is a positive indication of a chlorine leak. The thicker the white cloud, the larger the leak. An
ammonia spray is usually used when chlorine lines are being connected or when a chlorine leak is
suspected.
The facility examined the feasibility of purchasing a perimeter monitoring system to measure the
presence of chlorine. Rather than installing this system, the facility is investigating installing
additional monitors at potential leak points, such as the chlorine storage area and the vents from the
chlorinator rooms, for early detection of leaks.
6.3 Process Hazards
The moderately high pressure levels in the ton containers and the chlorine delivery system's piping
present an increased potential for an accidental release.
7.0 CHEMICAL ACCIDENT PREVENTION
7.1 Management Activities
A corporate safety person (a Vice President) is responsible for 22 plants located at various locations
within the United States. All environmental regulatory compliance, safety, and health issues are the
responsibility of the corporate safety person.
At the plant, the safety/loss prevention supervisor has the primary responsibility for safety, health,
and the environment. He or she maintains records of all incident investigations, including accidental
releases, and prepares a report for the plant manager within 30 days of each incident that provides
the full details of the investigation along with recommendations for improvements of safety. The
Safety Supervisor is also in charge of the employee suggestion program that encourages safety-related
suggestions with nonmonetary rewards.
The Safety Supervisor maintains records of personnel who have attended training programs at the
facility. Training programs include courses on employee safety, emergency response, and equipment
operation certification.
Facility X is an active participant in the Chemical Manufacturers Association's Community
Awareness and Emergency Response (CAER) program and is a member of the Industry Mutual Aid
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Association, a group of local industries that combine resources to address emergency responses to
catastrophic chemical releases. The facility is in regular communication with the corporate safety
office, and formal meetings are scheduled monthly.
7.2 Process Operation and Maintenance
Management has coordinated the development of training courses on emergency response,
maintenance, and operations. Classes include employee safety, chemical hazards, emergency
response, certification of operators on equipment, employee retesting, equipment replacement,
completing release investigation forms, and an on-the-job buddy system program for new hires.
All operators in charge of the water treatment process, including the area in which the last chlorine
release occurred, are given a 1-week, 4-part training course covering (1) process operation, (2)
process hazards, (3) problem solving, and (4) emergency procedures. Part one informs the operator
about the reactions in the process and the steps in startup, operation, and shutdown of the process.
Operators are provided with routine operations checklists to follow as part of standard operating
procedures. These have been developed and revised by both the process design engineers and the
operators. Part (2) (process hazards) is covered in lecture format, and Part (3) (problem solving)
is conducted in a discussion format. Emergency procedures, Part (4), is addressed in actual
simulation tests. The goal of the course is to familiarize and educate the operators about the process
and proper procedures so that supervisory involvement can be minimized.
As a result of the latest chlorine accident, the facility management is designing a mini-course for
water treatment operators. The course will review and strengthen knowledge and skills in problem
solving and in following emergency procedures.
Preventive maintenance at this plant is performed in accordance with manufacturers' specifications.
The plant conducts regular instrument and equipment inspections and testing. Inspections and testing
are supposed to be conducted daily for the chlorine detectors; monthly for the automatic shutdown
systems, pressure gauges, and flow indicators; and every year, during scheduled shutdowns, for
relief valves, excess flow devices, and transfer hoses. Records of all equipment inspection, testing,
and replacement are kept in the maintenance department office and the process control room.
Scheduled shutdown for repair of the units in the water treatment processes occurs every 12-16
months.
7.3 Hazard Evaluation and Modeling
Corporate policy requires that cause-consequence analysis or HAZOP evaluations be conducted
annually. An ongoing HAZOP evaluation of the Urea Unit was about 50-percent complete at the
time of the 50-pound chlorine release. The facility has worked with the LEPC and used the
CAMEO/ALOHA modeling program and EPA's Technical Guidance for Hazards Analysis to
perform screening modeling of chlorine releases. This model and the HAZOP evaluation led to
inventory reductions as mentioned in Section 6.1 of this report. The facility has not conducted any
modeling techniques for evaluating the consequences of releases other than catastrophic vessel
failure.
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7.4. Release Prevention Systems
The relief valves and low-pressure cutoff valves in the chlorine systems are designed to reduce the
potential for a catastrophic release. A scrubbing system that is part of the new chlorine delivery
system is designed to mitigate a catastrophic release of chlorine in the new chlorine room. The
system is described in Section 6.2 of this report.
7.5 Release Mitigation Systems
Tf a release occurs at the Facility X new chlorine delivery system, a chlorine scrubbing system
automatically activates to neutralize the chlorine. The scrubbing system is capable of neutralizing
4000 pounds (2 tons) of chlorine. When activated, the scrubbing system removes chlorine vapor
from the new chlorine room and neutralizes it with a caustic soda solution. When the scrubbing
system is activated, the air evacuation system automatically shuts off. Facility X has plans to install
a similar chlorine scrubbing system in the old chlorine delivery system. However, the chlorine
scrubbing system's old chlorine delivery system was not installed or under construction at the time
of this audit.
8.0 ACCIDENTAL RELEASE/INCIDENT INVESTIGATION
Facility X has had seven releases of chlorine over the past 2 years. All were from one of the two
evaporator rooms and above the reportable quantity (10 pounds) for chlorine. The last release
involved a 50-pound discharge from the old system chlorine room. The release occurred when
chlorine discharge tubing connecting a 1-ton chlorine container to the chlorine manifold ruptured,
releasing approximately 50 pounds of liquid chlorine. The four other releases occurred because of
gasket failures in the discharge tubing connections. The releases ranged from 10 to 20 pounds.
An incident investigation report of the tubing gasket leaks recommended that a different type of
gasket be installed in theses devices. The new gaskets seem to have stopped the leaks. Maintenance
has begun use of a standard gasket replacement manual for all equipment and processes to prevent
reoccurrence of improper gasket replacement.
The last chlorine release occurred during a transfer in the old chlorine delivery system when a ton
container that was being moved into position in the system struck a ton container that was in use.
The impact ruptured a chlorine discharge tube at the manifold. Investigation showed that corrosion
inside the discharge tube contributed to the rupture. The discharge tube had not been replaced in
2 years, although Facility X maintenance policies state that chlorine discharge tubes are to be
replaced annually.
As a result of the incident investigation, the operator that was moving the container that ruptured the
tubing was required to repeat a hoist operating course. The container being moved should not have
struck the other container. Additionally, corrosion of the discharge tubing indicated that the tubing
should be checked and replaced on a regular basis. The investigation report recommended that all
the tubing in both systems be removed, checked, and replaced as needed and that the tubing be
replaced every year as required by facility procedures. Recently installed, computerized preventive
and predictive maintenance programs should solve the tubing replacement problem.
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For accidents reported to the NRC, facility policy requires completion of an Accident Release
Information Program Report. Hie report is usually assembled by operator/maintenance staff with
the assistance of the plant safety supervisor. Training is offered to properly teach how to write such
a release report. Recommendations from the report are discussed with the plant manager and
worthwhile changes are addressed in a follow-up memorandum by the safety supervisor and
distributed to the appropriate facility staff.
According to the plant safety supervisor, all of the accident reports are annually reviewed to identify
common problems and a comprehensive investigation is conducted for each identified problem, such
as gasket failure. Accident reports that are filed with state or federal authorities are prepared by the
Corporate Vice President for Safety.
9.0 FACILITY EMERGENCY PREPAREDNESS AND PLANNING ACTIVITIES
Facility X has evacuation instructions that are posted inside each building. These instructions were
clear and corridors were well marked and accessible. Employee training records and interviews with
facility employees show that the employees have been trained and understand the Facility X
evacuation procedures.
As an active participant in the local CAER program, Facility X revises its emergency response plans
at the facility are revised and updated every 6 months. The plan covers the facility's release
response and reporting procedures, emergency equipment provisions, and evacuation routes. In the
event of an emergency, Facility X currently has a fire brigade for responding to facility emergencies,
including chlorine releases. Equipment for response to chlorine releases includes Level A and B
suits and respirators, hand-held chlorine monitors, two-way radios, and chlorine "B" kits for stopping
chlorine ton container leaks.
The fire brigade staff at the facility received training at the State University Fire Academy to learn
firefighting, search and rescue techniques, and HAZMAT training, including chlorine leak detection
and mitigation. The fire brigade consists of a Fire Brigade Chief, six operators or maintenance
persons per shift (all volunteers), and the Operations Shift Supervisors, who are on duty at the
facility. Each shift has its own shift fire brigade.
The Shift Supervisors are in charge of all emergency responses until the Fire Brigade Chief arrives
on the scene. Shift supervisors have several other responsibilities. They are responsible primarily
for ensuring the proper operation of the process, including monitoring operator performance,
coordinating operations and maintenance duties, and performing other management duties. The fire
brigade is responsible for handling all emergency situations. The brigade meets regularly, but it has
not conducted a drill with the community in nearly 15 months.
10.0 COMMUNITY AND FACILITY EMERGENCY RESPONSE PLANNING ACTIVITIES
The management of Facility X has coordinated emergency efforts with the LEPC and the local
Industry Mutual Aid Association. This includes conducting monthly meetings to discuss common
hazards, pooling resources, and conducting simulation exercises. In these meetings, facility
responsibilities have been designated and formalized in a mutual aid agreement.
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As an active participant in the local CAER program, the facility has established a relationship with
the LEPC in planning for chemical releases. According to the SERC and LEPC, facility
management has provided all information required under Title III. Also, the management has given
facility tours to LEPC members and other local emergency response personnel.
The facility plans to improve its accidental release notification procedures with the community,
including possible use of short-wave radios to notify the LEPC and local fire department personnel.
Also, the facility plans to hold a joint training program with the Pacific Town hospital to review
various types of medical problems such as chemical burns and inhalation. Because the LEPC does
not have a full-time emergency coordinator or 24-hour emergency coverage, they have requested that
the facility contact the local fire department in an emergency.
11.0 PUBLIC ALERT AND NOTIFICATION PROCEDURES
The facility follows CAER's public notification procedures outlined in the "Community-Industry
Emergency Notification System." These procedures call for the LEPC to notify the public in the
case of a Facility X chlorine release. Plant policy is for the operations supervisor to make a decision
to notify the LEPC. Once a decision to notify the LEPC is made, the procedure calls for the main
gate security guard to contact the local fire department by telephone or radio. The exact wording
of the notification is stated in the facility's emergency response plan and at the main gate. Current
telephone numbers for the community, the SERC, and the National Response Center (NRC) are
maintained in the Fire Brigade Chiefs office, the Operations Supervisors' offices, and at the main
gate. There has been no testing of the LEPC public notification procedures.
For each of the seven chlorine releases, the facility notified the NRC and the SERC and, at the
LEPC's request, the local fire department. According to SARA Title III, a release need not result
in actual exposure to persons offsite in order to be subject to release reporting requirements, and in
the absence of an operational LEPC, notifying the local fire department meets the local notification
requirement.
12.0 CONCLUSIONS
Based on a review of the chemical process safety management practices related specifically to the
handling of chlorine, the audit team has reached the following conclusions:
The facility has incorporated earthquake protection measures to prevent releases.
The facility has evaluated perimeter monitoring systems and is in the process of
evaluating specific process monitoring for early leak detection in certain high leak
rate areas. Operators are trained in the use of portable monitors for locating chlorine
leaks.
Facility X management sponsors and provides training on emergency response,
maintenance, and operations.
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The facility's release prevention and mitigation equipment related to chlorine leaks
include relief valves to prevent catastrophic releases caused by overpressurizing and
rupturing chlorine equipment, and pressure-reducing flow cutoff valves to stop the
flow of chlorine when a leak occurs downstream from the valves.
A chlorine scrubbing system has been installed in the new chlorine delivery process.
A similar scrubbing system installed in the old chlorine delivery process may have
mitigated or prevented the release of chlorine to the environment during the facility's
last chorine leak. Plans exist to install a scrubbing system in the old process.
However, the system had not been installed at the time of the audit.
The facility has documented operating and maintenance procedures, checklists,
standard safety rules, and procedures for all tasks and operations.
Facility X has conducted hazard evaluations as required by corporate policy, which
calls for evaluations to be performed annually.
The facility performs preventive maintenance in accordance with manufacturers'
specifications. It has records on equipment inspection, testing, and replacement.
However, several releases involved equipment that failed in service.
The facility management conducts incident investigations for all deviations from
standard conditions and attempts to follow-up on problems identified in the
investigation reports. However, no formal follow-up procedures for implementing
investigation recommendations exist.
The fire brigade is composed of a Fire Brigade Chief, volunteer operators and
maintenance personnel, and Operations Shift Supervisors. The fire brigade meets
regularly, but has not conducted a drill with the local community in nearly 15
months. In addition, there has been no testing of public notification procedures by
the facility or the LEPC.
At the LEPC's request, the facility notifies the local fire department, rather than the
LEPC, of chlorine releases.
13.0 RECOMMENDATIONS
Based on the audit team's observations and conclusions, audit team recommendations to the
management of Facility X include the following:
The facility should consider installing additional detectors and alarms to monitor for
chlorine leaks at locations where leaks could appear (such as the chlorine storage area
and the air evacuation systems roof vents).
The facility should consider expediting the installation of the scrubbing system in the
old process. The scrubbing system may have mitigated or prevented the release of
chlorine to the environment during the facility's last chorine leak.
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The facility should consider establishing a predictive maintenance and testing program
to repair or replace equipment subject to chlorine exposure, and to prevent failures
and releases from critical equipment such as chlorine delivery tubing. The practice
of preventive maintenance based on manufacturers' specifications may be contributing
to equipment failure and resultant releases.
The facility should consider developing formal follow-up procedures, including time
schedules, to ensure that incident investigation recommendations are evaluated and
implemented, if appropriate.
The facility and the LEPC should consider conducting an emergency response drill
simulating a chlorine release from the facility, including a test of the LEPC public
notification procedures.
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EXERCISE 1 - ANSWER SHEETS
REPORT DISCLAIMER
The contents of this report reflect information concerning Facility X obtained during a U.S.
Environmental Protection Agency (EPA) Chemical Safety Audit and from records provided by
Facility X. The audit was conducted from February 5. 19XX. through February 8, 19XX. and
the observations as presented in this report provide a snapshot of conditions existing at the facility
during the audit time frame. They do not represent planned or anticipated changes proposed or
ongoing at the facility. The recommendations and other report observations contained in this report
are not mandatory actions that the facility must implement. In addition, EPA makes no assurances
that if implemented, the recommendations and other report observations contained in this report will
prevent fiiture chemical accidents, equipment failures, unsafe management practices, or provide
protection from a future enforcement action under any applicable law or regulation.
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1.0 INTRODUCTION
1.1 Chemical Safety Audit Program
The Chemical Safety Audit (CSA) program has evolved from efforts of the U.S. Environmental
Protection Agency (EPA) under the Chemical Accident Prevention (CAP) program. The primary
objectives of the CAP program are to identify the causes of accidental releases of hazardous
substances and the means to prevent such releases from occurring, to promote industry initiatives in
these areas, and to share activities with the community.
The CSA program is part of this broad initiative and has been designed to accomplish the following
chemical accident prevention goals:
Heighten awareness of the need for chemical safety among chemical producers,
distributors, and users, as well as in communities where chemicals are located.
Visit facilities handling hazardous substances to learn and understand problematic and
successful practices and technologies for preventing and mitigating releases.
Build cooperation among authorized parties by coordinating joint accidental release
investigations where appropriate.
Establish a national database for the assembly and distribution of chemical safety
information obtained from facility investigations and from other sources.
The audit consists of interviews with facility personnel and onsite review of various aspects of facility
operations related to the prevention of accidental chemical releases. CERCLA Sections 104(b) and
104(e), as amended by SARA, provide authorities for entering a facility and accessing information.
Specific topics addressed in the audit include:
Process characteristics.
Hazard evaluation and release detection techniques.
Training of operators and emergency response personnel.
Management structure (corporate and facility).
Preventive maintenance and inspection programs.
Community notification mechanisms and techniques.
1.2 Facility X Pacific Town, Washington, Audit
This report contains observations, conclusions, and recommendations from an audit conducted at
Facility X. a water treatment plant in Pacific Town. Washington, from February 5 through
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February 8,19XX, The facility was selected for an audit because of a series of releases of chlorine,
the last one of approximately 50 pounds. This report identifies and characterizes the strengths of
specific chemical process safety management program areas to allow the elements that are
particularly effective to be recognized. Copies of this report have been provided to the facility's
corporate management so that weak and strong program areas may be recognized.
3.0 BACKGROUND
3.1 General Facility and Audit Information
Facility X is owned by XYZ Manufacturing, Inc.. the parent company. Facility X operates at the
following address:
Facility X
1 Industry St.
Pacific Town. WA 99999
The facility has two water treatment processes and is located north of Interstate Highway 1 and
west of County Highway. The facility produces treated water for the surrounding community.
The audit was conducted from February 5 through February 8. 19XX. by a team of regional
representatives from the EPA. EPA was assisted by representatives from the Occupational Safety
and Health Administration (OSIIA). the State Emergency Response Commission (SERO. and
the LEPC. The names of the team members, their affiliations, their responsibilities in the audit, and
their expertise are provided in Appendix A.
3.2 Purpose of the Audit and Facility Selection Process
The purpose of the audit was to examine the facility's chemical process safety management practices
associated with chlorine. The facility was selected for an audit based on an analysis of chemical use
in the region, and the facility's release history. Region 11 identified ammonia and chlorine as the
two chemicals used in the highest volume in the region. Based on the facility's release history, the
Regional Office decided that a CSA be conducted. There was a series of accidental releases of
chlorine occurring over the past year, the last one of approximately 50 pounds.
3.3 Audit Methodology
The audit centered around the process areas related to the use of chlorine in the water treatment
process. The audit addressed chlorine hazards, chemical accident prevention, process operation and
maintenance, hazard evaluation and modeling, release prevention systems, accidental release incident
investigation, facility emergency preparedness and planning, and community and facility emergency
response planning activities. However, the audit is limited in that is does not attempt to make
comparisons or otherwise distinguish between the safety systems used only for urea manufacturing
processes and those used for other chemical processes at the facility.
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Exercise 1 - Answer Sheets
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4.0 FACILITY BACKGROUND INFORMATION
Facility X is located approximately 100 miles west of Seattle on the Pacific coast in an area
known as Pacific Town. This facility is located north of Interstate Highway 1 and west of
County Highway. Figures 1 and 2 are maps of the area provided to the audit team by the
facility. The facility is bounded on the north side bv the railroad tracks. There are five
structures on the property: two water clarifiers. two filter buildings, and offices. There is also
a parking lot. The facility can be accessed from either the main gate off the Interstate Highway
or from the railroad spur. Hazardous and extremely hazardous substances can be transported
both by highway and rail. The facility is 20 years old and employs 45 persons.
The facility occupies 100 acres in a relatively sparse area approximately 2.5 miles from the
nearest community shopping mall. An elementary school is within three miles and a lake,
critical to the town's water supply, is within 3.5 miles of the plant. The shopping mall, the
school, and the lake are considered by the facility to be sensitive populations and environments
for a major chlorine release. Both the County Highway and the Interstate Highway are heavily
traveled routes.
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Exercise 1 - Answer Sheets
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CAPE CORAL REVERSE OSMOSIS WATER
TREATMENT FACILITY
BASIC REVERSE OSMOSIS PROCESS
RAW
WATER
PUMP
Sulfuric
Acid
Raw
Water
CARTRIDGE
FILTER
PRESSURE
ฆH PUMP R.O. UNIT
DEGASIFIER
-S*
Scale
- Inhibitor
(Flocon 100)
Reject
Water
CLEARWELL/
STORAGE TANK
Chlorine
Usable
Water
Caustic
Soda
Salt
+ Water
Lake
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