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“Case Studies on Safer Alternatives for Solvent Degreasing Applications”

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The transition to sustainable manufacturing is best accomplished by using pollution prevention (P2) approaches. This paper summarizes a number of case studies that highlight the P2 approach of switching to aqueous and less toxic metal cleaners to reduce health risks and manufacturing costs. EPA compiled these case studies as a supplement to “Pollution Prevention (P2) Spotlight: Reducing Trichloroethylene (TCE) Waste in the Fabricated Metals Sector.”

What are cleaning solvents and how are they used?

Cleaning solvents are used to remove oil, grease, solder flux, and other contaminants. Facilities that produce metal products often use solvents and other chemicals as degreasers to clean metal parts in preparation for further finishing operations, like painting or welding.

Trends in the reduced use of TCE reported by the fabricated metals sector to EPA’s Toxic Release Inventory (TRI) database:

Trichloroethylene (TCE): used as a solvent for metal degreasing, as well as a refrigerant and in dry cleaning fluid. TCE is a volatile organic compound (VOC) that poses a human health hazard to the central nervous system, kidney, liver, immune system, reproductive system, and to the developing fetus. TCE is also characterized by U.S. Environmental Protection Agency (EPA) as carcinogenic to humans by all routes of exposure (i.e., by inhalation, ingestion, and dermal exposure). Learn more about TCE.

Methyl chloroform (TCA): used as a solvent and in some consumer products. Exposure to TCA can result in mild motor impairment (e.g., increased reaction time), lightheadedness, impaired balance, and lack of muscle control in acutely exposed humans. Cardiac arrhythmia and respiratory arrest may result from the depression of the central nervous system.

Dichloromethane (DCM, methylene chloride): used as a solvent in paint strippers, a process solvent in the manufacture of pharmaceuticals and film coatings, a propellant in aerosols, and a solvent for metal cleaning and finishing in electronics manufacturing. Effects of short-term (acute) exposures to workers and consumers, including bystanders, can result in harm to the central nervous system, or neurotoxicity. Effects of longer periods of exposure (chronic) for workers includes liver toxicity, liver cancer, and lung cancer. Learn more about DCM.

Case Studies:

1. Schick (formerly American Safety Razor) in Verona, Virginia, manufactures a variety of blades and tools from steel stock. TCE was used as a cleaning solvent in both liquid and vapor cleaning/degreasing operations at a newly acquired facility. Schick’s prior experience with TCE as a potential environmental contaminant, combined with increasing costs associated with its distillation and waste disposal and higher regulatory risk, made TCE elimination a priority.

Schick installed aqueous “wash boxes” on production lines to replace TCE-based cleaning processes, and also used an alcohol-based vapor degreaser as an effective substitute. TCE use has been completely eliminated at this plant. In addition to risk reduction, these P2 measures have resulted in an estimated cost reduction of $250,000 a year from reduced energy, material and hazardous waste disposal costs.

Learn more: www.epa.gov/p2/pollution-prevention-accomplishments-schick-manufacturing-verona-virginia

2. Lightolier in Fall River, Massachusetts, fabricates aluminum reflectors for lighting product lines. The facility was using large amounts of TCE and acids annually. Only 10 percent of the used TCE was captured for recycling. In addition, the company became aware of hidden costs such as liability, worker safety, and opportunities for increased productivity.

Furthermore, Lightolier’s degreasing systems were old and required increasing maintenance. The company replaced the TCE degreasers with an aqueous degreaser and a powder coat degreaser. In addition, switching from pure petroleum lubricants to water-soluble coolants would eliminate the generation of oily parts in the first place.

Since removing the degreasers and making other improvements such as installing still-rinse tanks, implementing countercurrent rinsing, and increasing the drip time to reduce acid discharges, the company has eliminated approximately 1.25 million lbs of TCE and saved an estimated $170,000. Volatile organic compound (VOC) emissions have dropped 90 percent from 125,000 to 12,000 lbs per year, also significantly reducing air compliance costs.

Learn more: www.turi.org/TURI_Publications/Case_Studies/Process_Efficiency/

3. V.H. Blackinton & Co., Inc in North Attleboro, MA, is a large manufacturing operation — blanking, stamping, punching and machining raw stock prior to cleaning, enameling, brazing, polishing, plating and refinishing — of metal plated items. The facility had used ozone-depleting Freon, as well as TCE and other VOCs and ammonia but was able to eliminate them.

Blackinton eliminated the use of Freon by replacing the existing finished work dryer with one that uses a deionized water rinse and hot air. The TCE cleaning operations were replaced with an aqueous cleaning system. Approximately 45 gallons of water-based cleaner is used annually, achieved by carefully monitoring the bath chemistry and ultra-filtering the cleaner weekly for reuse. In addition, a small in-tank filter, an oil skimmer, and conversion to compatible water-based pressing and stamping oils, made the new aqueous cleaning system more efficient.

More recently, new brazing furnaces with belts twice as wide as those in the old furnaces were installed, doubling the process capacity. The new furnaces use a 25 percent hydrogen and 75 percent nitrogen mix, eliminating over 20,000 lbs a year of disassociated anhydrous ammonia used in the old furnaces. The cost of the new system and quality of the finished product is the same or better. A close looped cooling water system that reuses water for the furnaces conserves 5000 gallons per day and additional water conservation activities eliminate the use of more than 25,000 gallons per day.

Learn more: www.turi.org/Our_Work/Business/Industry_Sectors/Metal_Finishing/May-20-2004-Metal-Finishing-Forum/Handouts/Case-Studies/Case-Study-V.-H.-Blackington-Company Exit

4. Danfoss Chatleff LLC in Buda, Texas, manufactures refrigeration and air conditioning components, and had been using a TCE-based degreaser to remove machine oil from metal parts. The facility replaced TCE with an aqueous degreaser/parts washer and evaporator eliminating 9,900 lbs of hazardous waste per year and saving the facility $36,000/year. (Danfoss estimates saving approximately $10,000 per year in disposal costs and $1,000 in training and reporting costs.) The new cleaning process requires less operator time, estimated to be worth $25,000/year. By eliminating the use of TCE, Danfoss also significantly reduced future environmental risk/liability associated with the shipping, storage, and use of a hazardous chemical.

Learn more: www.zerowastenetwork.org/success/story.cfm?StoryID=1155&RegionalCenter Exit

5. Perkins Products Inc. in Chicago, Illinois, was using mineral spirits for parts cleaning to remove straight cutting oil from metal work pieces in the milling department. The company replaced these solvents with aqueous detergents. The detergent was found to be safer for employees, better for the environment, less expensive and compatible with current production process. A total of 1,600 gallons of solvent were eliminated, 10,400 lbs of VOCs were avoided, and $500 saved per year, with only a one-year return on investment period.

Learn more: www.istc.illinois.edu/info/library_docs/TN/TN15-116.pdf Exit (2 pp, 668.6 K, About PDF)

6. Marathon in Ashland, Minnesota, had been using a terpene-based cleaner and petroleum distillate for external cleaning of large equipment. The terpene solvent was suspected to be impairing the biological processes of the refinery’s wastewater treatment plant. During testing, two aqueous cleaners were applied as a foam that adhered to vertical surfaces for several minutes — enough time for the cleaner to work — then rinsed off with hot water. The refinery staff using one of the foaming agents described the result as “requiring less chemical, less time and less water, while providing better results” compared to the terpene-based cleaner.

Learn more: www.mntap.umn.edu/mach/resources/marathon.htm Exit

7. Lockheed Martin Defense Systems in Pittsfield, Minnesota, used 125 tons each year of 1,1,1- trichloroethane (trichlor, 1,1,1-TCA, methyl chloroform) and chloroflourocarbon-113 (CFC-113, Freon) in 39 vapor degreasers to clean precision products, emitting 70 tons of these chemicals each year into the air.

The company evaluated alternative cleaners for economic and technical feasibility and potential worker health and safety impact. Ultimately, seven aqueous systems and two semi-aqueous systems replaced 36 of the 39 degreasers and reduced facility solvent use to less than 2 tons per year, and air emissions to less than 1 ton per year. Cost savings included: $497,000 in solvent procurement; $17,500 in waste disposal and $65,000 in permitting and record keeping. The company incorporated a “closed loop” aqueous cleaning system in the transmission assembly and repair process. The system included a variety of substrates (steel, stainless steel, aluminum, cast iron, and bronze) and contaminants (plastic and oil, grease, wax and metal, plastic or rubber shavings) requiring removal. This process reduced consumption of 2,000,000 gallons of water per year and saved $3,450 in water and sewer costs.

Learn more: www3.epa.gov/ttn/atw/hlthef/trichlor.html

8. Dayton Rogers metal stamping facility in Minneapolis, Minnesota, was using TCA as a vapor degreaser to remove forming lubricant oil from parts prior to dry-sander deburring. The solvent was eliminated by upgrading its deburring operation to deburr and clean parts simultaneously. The company modified the vibratory tumbling machines to increase throughput, added a wet sander and switched to a water-based lubricant so that removing the forming lubricants would be easier in the water-based deburring system. This resulted in saving $26,575 per year and a payback period for the equipment of approximately three months. This approach would be suitable in stamping and machining operation where deburring is done, but precision cleaning is not necessary.

Learn more: mntap.umn.edu/mach/resources/87-Deburring.htm Exit

9. Rosemount Aerospace Inc. in Burnsville, Minnesota, used TCA during sensor cleaning at a large manufacturer of aircraft data instrumentation. After sensor assembly, the TCA comes in contact with silicone oil during testing to remove the oil before a soldering process. Aqueous cleaners tested on the sensors removed light oils and fingerprints at least as well as the existing vapor degreasing system and eliminated worker exposure to TCA.

Learn more: www.mntap.umn.edu/mach/resources/Rose-it6.htm Exit

10. APS Materials Inc., a small metal finishing company in Dayton, Ohio, used TCA and methanol in its degreasing operation to clean orthopedic implants such as those used for metal knee and hip replacements. A dilute limonene solution was tested as replacement cleaner. This dilute terpene-based cleaner adequately cleaned metal parts without adversely affecting the performance of the plasma-arc coating application. The replacement cleaner resulted in a cost savings of $4,800 per year and a payback period of 4.5 months. Elimination of the disposal problems associated with methanol and TCA, coupled with the maintenance of plasma-arc coating quality, makes the use of terpene-based cleaners attractive to other plasma spray coating processes as well as other metal cleaning/coating operations.

Learn more: citeseerx.ist.psu.edu/viewdoc/download?doi=10.1.1.405.5454&rep=rep1&type=pdf

11. Roberts Automatic Products, a third generation family-owned precision production machining company in Chanhassen, Minnesota specializes in precise and complex computer numeric control (CNC) machining and screw machine parts. Roberts used DCM as a degreasing solvent to clean its parts and reported to TRI as much as 40,000 pounds a year of DCM wastes that were released or treated by the plant.

Roberts purchased the Serec closed-loop vacuum degreasing unit in 2011 and put it into service in 2012. Roberts reduced its DCM waste to 13,636 pounds from more than 44,000 pounds the previous year. The facility is no longer required to file TRI reports for DCM and has eliminated DCM as a source of toxic waste and a hazardous air pollutant.

Learn more: www.epa.gov/toxics-release-inventory-tri-program/reducing-dichloromethane-waste

 

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“TSCA Reform: A Simple 5-point Summary of What You Need to Know “

After 40 years, the Toxics Substances Control Act (TSCA) has been reformed in an effort to more effectively manage chemicals in this country and give EPA more authority to evaluate and mitigate the associated risks. This infographic summarizes the important points of TSCA reform.

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“Maximum Civil Penalties for Violations of Environmental (USEPA) Statutes Are Now Significantly Higher After Inflation Adjustment”

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In a federal rulemaking published last week, the U.S. Environmental Protection Agency (EPA) issued interim final regulations adjusting the maximum civil penalty dollar amounts for violations of various provisions of law. 81 Fed. Reg. 43091 (July 1, 2016).

The recently enacted Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (2015 Act), not only required an adjustment form current penalty maximum levels to account for inflation, but also included a catch-up provision for inflation. That requires each agency to evaluate and provide for an inflation adjustment dating back to the enactment of the relevant statute’s effective date. (Section 5(b)(2)(C) of the 2015 Act provides that the maximum amount of any initial catch-up increase shall not exceed 150 percent of the level that was in effect on November 2, 2015.) See related Implementation of the Federal Civil Penalties Inflation Adjustment Act, OMB Memorandum M-16-06 (February 24, 2016). In addition, beginning January 15, 2017, each agency must make subsequent annual adjustments for inflation.

EPA’s interim final rule revises Table 2 to 40 CFR 19.4, showing the results of the Agency’s calculations and adjustments, that include: (1) the maximum or minimum penalty level established when each statutory section was originally enacted or last adjusted by Congress; and (2) the statutory maximum or minimum civil penalty level, adjusted for inflation under the 2015 Act, that applies to statutory civil penalties assessed on or after August 1, 2016 for violations that occurred after November 2, 2015.

Readers familiar with EPA’s penalty structure know that statutory penalties of $25,000 per day per violation were previously adjusted for inflation to $37,500. With the catch up provision under the interim final rule, the maximum penalty will vary by statute. For example, the $25,000 per violation penalty under the Clean Air Act is now $44,539; under the Clean Water Act is now $44,539; under RCRA is now in a range of $56,467 to $70,117, and under CERCLA (including most EPCRA violations) is now $53,907. Other maximum penalties are also adjusted.

The new civil penalty amounts are applicable only to civil penalties assessed after Aug. 1, 2016, whose associated violations occurred after Nov. 2, 2015.

For more information on this or any related topic please contact the authors, your Seyfarth attorney, or any member of the Environmental Compliance, Enforcement & Permitting Team.

Source: Seyfarth, Shaw

“New TSCA Law Starts NOW!”

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“For the first time in 20 years, we are updating a national environmental statute,” said President Obama before signing the Frank R. Lautenberg Chemical Safety for the 21st Century Act on Wednesday. The president noted that the updated law, the Toxic Substances Control Act (TSCA), which took effect in 1976 “didn’t quite work the way it should have in practice.” That was a vast understatement, particularly in regard to the regulation of existing chemicals. The president pointed out that of the 62,000 chemicals in the marketplace in 1976, only 5 have been banned.

“Five,” said the president. “And only a tiny percentage have even been reviewed for health and safety. The system was so complex, it was so burdensome that our country hasn’t even been able to uphold a ban on asbestos—a known carcinogen that kills as many as 10,000 Americans every year.”

The president added that the new law will do away with an outdated bureaucratic formula to evaluate safety and, instead, focus solely on the risks to public health.

Industry Pushed Hard

The law passed both chambers of Congress with overwhelming, but not unanimous, support. Pockets of resistance remain, particularly regarding the law’s provision allowing federal preemption of state action on chemicals the EPA is reviewing. Nonetheless, the law made it to the president’s desk despite today’s extremely partisan climate in Washington. The president noted that passage of the legislation revived the bipartisan tradition of the early 1970s when Democrats and Republicans came together to pass “those pillars of legislation to protect our air, and our water, and our wildlife.”

The president specifically thanked the American Chemistry Council and S.C. Johnson, both of which “pushed hard for this law,” noting also that the law “gives them the certainty they need to keep out-innovating and out-competing companies from other parts of the world.”

In its statement of support following congressional approval, S.C. Johnson spoke favorably of EPA’s new authority to systematically prioritize all chemicals currently in commerce for safety evaluations.

What’s Next?

The law took effect with the president’s signature.  The major deadlines in the law apply to the EPA. As the EPA sees it, the most immediate effect is on the new chemicals review process. The Agency is now required to make an affirmative determination on a new chemical or significant new use of an existing chemical before manufacturing can commence. For companies that submitted premanufacture notices (PMNs) before enactment, which are currently undergoing review, the new law effectively resets the 90-day review period.

EPA’s other deadlines include the following:

  • Within 180 days, the Agency must publish an initial list of at least 10 high-priority chemicals and 10 low-priority chemicals. Within 3.5 years, the EPA must have 20 ongoing risk evaluations.
  • The EPA must publish an annual goal for the number of chemicals to be subject to the prioritization screening process. The Agency must also keep current and publish a list of chemicals (1) that are being considered in the prioritization process, (2) for which prioritization decisions have been postponed, and (3) that are designed as high- or low-priority chemicals.
  • When unreasonable risks are identified, the EPA must take final risk management action within 2 years or 4 years if an extension is needed.
  • Within 2 years, the EPA must develop any policies, procedures, and guidance necessary to carry out the bill’s requirements with respect to (1) requesting safety data from manufacturers or processors, (2) prioritizing existing chemicals for evaluation of their risks, (3) reviewing new chemicals or significant new uses of existing chemicals, and (4) conducting safety assessments and safety determinations on whether a chemical meets the safety standard. Those policies, procedures, and guidances must be reviewed every 5 years and revised as necessary to reflect new scientific developments or understandings.
  • Within 9 months, the EPA must publish a list of those chemical substances it has a reasonable basis to conclude are persistent, bioaccumulative, and toxic (PBT). Within 2 years after enactment, the EPA must designate as a chemical of concern each chemical substance on the PBT list. Not later than 2 years after this designation, the Agency must promulgate a rule with respect to the chemical substance to reduce likely exposure to the extent practicable.
  • Any confidential business information (CBI) claims to protect the specific identities of existing, active chemicals on the list from disclosure would need to be reaffirmed and substantiated. The EPA must maintain both a confidential and nonconfidential portion of its chemical inventory. Within 5 years of compiling that list of active chemicals, the EPA must establish a plan to review all CBI claims.
Funding

Also, the law provides a means for the Agency to collect the money it will need to do all of the above and more. Specifically, the statute allows the Agency to collect up to $25 million a year in user fees from chemical manufacturers and processors in addition to supplements approved by Congress.

The new TSCA law is here.

Source: BLR

“RMP Changes Are Almost Here, Stay A Step Ahead”

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By Timothy P Fagan, Senior Legal Editor

It has been 3 years since the ammonium nitrate explosion in West, Texas, killed 15 people, injured hundreds, and caused widespread damage.  Just a few months after that event, President Obama’s Executive Order (EO) 13650 set into motion actions by numerous government agencies designed to enhance the safety and security of chemical facilities and reduce the risks that hazardous chemicals pose to owners and operators, workers, and communities.

In addition to enhancing cooperation and information sharing among federal agencies and state and local authorities, the activities stemming from EO 13650 included modernizing key regulations, such as U.S. Environmental Protection Agency’s (EPA) Risk Management Program (RMP) and OSHA’s Process Safety Management (PSM) Program.  To that end, the EPA recently proposed amendments to RMP regulations under 40 CFR 68, and the Occupational Safety and Health Administration (OSHA) has made policy changes with respect to PSM that will impact how facilities comply with the RMP.

What changes are coming?

The changes to RMP regulations being proposed by the EPA impact the implementation of release prevention programs, the development of emergency response plans, and the sharing of information.

Release prevention programs.  The proposed changes to the accidental release prevention programs include:

  • Requiring all facilities with Program Level 2 or 3 processes to conduct root cause analyses as part of any incident investigation of a catastrophic release or a “near miss.” Identifying the root cause rather than the immediate cause will be more beneficial in preventing similar accidents in the future.
  • Requiring all facilities with Program Level 2 or 3 processes to hire an independent third party to perform a compliance audit after the facility has a reportable release.  Currently, such audits are self-audits, so requiring a third party increases the objectivity of the audit.
  • Requiring facilities in the paper manufacturing, petroleum and coal products manufacturing, and chemical manufacturing sectors with Program 3 processes to conduct a safer technology and alternatives analysis (STAA) as part of the process hazard analysis that must be updated every 5 years.  The facilities must then evaluate the feasibility of any inherently safer technology (IST) identified in the STAA.   The implementation of IST potentially reduces the risk of accidental releases within these industries, which the EPA has identified as having a disproportionate share of reportable releases.

Emergency response plans.  The proposed changes to emergency response plans include:

  • Requiring all facilities with Program Level 2 or 3 processes to coordinate with the local emergency response agencies at least once a year to ensure that resources and capabilities are in place to respond to an accidental release and to ensure that emergency contact information is up to date.  Effective coordination and communication between facilities and emergency responders can reduce the severity of accidental chemical releases.
  • Requiring all facilities with Program Level 2 or 3 processes that have developed their own emergency response plan to conduct a full field exercise at least once every 5 years and one tabletop exercise annually in the other years.   In addition, such facilities that have a reportable accident would be required to conduct a full field exercise within 1 year of the accident.  Such exercises will help ensure that all emergency response personnel understand their roles and responsibilities and be better prepared in the event of a real accident.

Access to information.  The proposed changes to accessing RMP information include:

  • Requiring RMP facilities to provide certain basic information to the public through easily accessible means such as a facility website.  If no website exists, the owner or operator may provide the information at public libraries or government offices or use other means appropriate for particular locations and facilities.
  • Requiring RMP facilities to hold a public meeting after an RMP reportable accident.
  • Requiring certain facilities to provide, on request, local emergency response agencies with summaries of audits, emergency response exercises, investigation reports, and implemented ISTs.
The surprising omission

After the issuance of EO 13650, there was significant speculation that the modernization of RMP regulations would involve additions to the listed chemicals regulated under 40 CFR 68 and a reevaluation of the thresholds at which chemicals became subject to the RMP.  However, the EPA opted not to regulate any additional chemicals under the RMP, nor did the agency change any of the thresholds as part of the recently released proposed regulations.

OSHA’s impact on RMP

Any RMP process that is subject to OSHA’s PSM must comply with Program Level 3 requirements, the most stringent requirements.  Last year OSHA revised its interpretation of the PSM standard’s retail facility exemption, which will result in thousands of facilities no longer being exempt from PSM.  Most of these facilities are already subject to the RMP under Program Level 2, but the change in the exemption interpretation will result in these facilities becoming Program Level 3 facilities.  OSHA will begin enforcing the new exemption interpretation on September 30, 2016, and the EPA will require risk management plan updates within the following 6 months.

What happens next?

For several years there has been speculation about what changes would be made to RMP regulations and how facilities would be impacted.  Now the proposed regulations are here, and facilities must begin the evaluation process.  Facilities must evaluate the proposed regulations and provide comments to the EPA, if necessary, and facilities must evaluate their own programs, procedures, and plans to determine what changes must be implemented to ensure continued compliance with a changing RMP.

“U.S. Chemical Safety Board Releases New Safety Video, “Dangerously Close: Explosion in West, Texas,” Detailing Report Findings and Recommendations on 2013 Fatal West Fertilizer Company Explosion and Fire “

January 29, 2016, Washington, DC – Today the U.S. Chemical Safety Board (CSB) released a safety video into the fatal April 17, 2013, fire and explosion at the West Fertilizer Company in West, Texas, which resulted in 15 fatalities, more than 260 injuries, and widespread community damage. The deadly fire and explosion occurred when about thirty tons of fertilizer grade ammonium nitrate (FGAN) exploded after being heated by a fire at the storage and distribution facility.

The CSB’s newly released 12-minute safety video entitled, “Dangerously Close: Explosion in West, Texas,” includes a 3D animation of the fire and explosion as well as interviews with CSB investigators and Chairperson Vanessa Allen Sutherland. The video can be viewed above or on the CSB’s website and YouTube.

Chairperson Sutherland said, “This tragic accident should not have happened. We hope that this video, by sharing lessons learned from our West Fertilizer Company investigation, will help raise awareness of the hazards of fertilizer grade ammonium nitrate so that a similar accident can be avoided in the future.”

The CSB’s investigation found that several factors contributed to the severity of the explosion, including poor hazard awareness and fact that nearby homes and business were built in close proximity to the West Fertilizer Company over the years prior to the accident. The video explains that there was a stockpile of 40 to 60 tons of ammonium nitrate stored at the facility in plywood bins on the night of the explosion. And although FGAN is stable under normal conditions, it can violently detonate when exposed to contaminants in a fire.

In the video, Team Lead Johnnie Banks says, “We found that as the city of West crept closer and closer to the facility, the surrounding community was not made aware of the serious explosion hazard in their midst. And the West Fertilizer Company underestimated the danger of storing fertilizer grade ammonium nitrate in ordinary combustible structures.”

The CSB investigation concludes that this lack of awareness was due to several factors, including gaps in federal regulatory coverage of ammonium nitrate storage facilities. The video details safety recommendations made to OSHA and the EPA to strengthen their regulations to protect the public from hazards posed by FGAN.

Finally, the video explains how inadequate emergency planning contributed to the tragic accident. The CSB found that the West Volunteer Fire Department was not required to perform pre-incident planning for an ammonium nitrate-related emergency, nor were the volunteer firefighters required to attend training on responding to fires involving hazardous chemicals. As a result, the CSB made several safety recommendations to various stakeholders, including the EPA, to better inform and train emergency responders on the hazards of FGAN and other hazardous chemicals.

Chairperson Vanessa Allen Sutherland said, “The CSB’s goal is to ensure that no one else be killed or injured due to a lack of awareness of hazardous chemicals in their communities. If adopted, the Board’s recommendations can help prevent disasters like the one in West, Texas.”

The CSB is an independent federal agency charged with investigating serious chemical accidents. The agency’s board members are appointed by the President and confirmed by the Senate. CSB investigations look into all aspects of chemical accidents, including physical causes such as equipment failure as well as inadequacies in regulations, industry standards, and safety management systems. The Board does not issue citations or fines but makes safety recommendations to companies, industry organizations, labor groups, and regulatory agencies such as OSHA and EPA. Please visit our website, www.csb.gov

For more information, contact Communications Manager Hillary Cohen at public@csb.gov or by phone at 202.446.8095.

 

“CSB Releases New Safety Video Entitled “Shock to the System” Offering Key Lessons for Preventing Hydraulic Shock in Ammonia Refrigeration Systems”

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Latest Safety Video Includes Detailed Animation of 32,000- Pound Release of Ammonia in Alabama which Led to Offsite Injuries Including Multiple Hospitalizations in 2010

Washington, D.C, March 26, 2015 – Today the US Chemical Safety Board (CSB) released its latest safety video detailing key lessons from the release of 32,000 pounds of anhydrous ammonia that occurred at Millard Refrigerated Services Inc. on August 23, 2010. The accident resulted in over 150 exposures to offsite workers, thirty of which were hospitalized – four in an intensive care unit.

The newly released seven-minute safety video, entitled “Shock to the System,” includes a detailed 3D animation of the events that led up the resulting ammonia release. The video is based on the CSB’s recent View of cracked pipe following the 2010 ammonia release safety bulletin entitled “Key Lessons for Preventing Hydraulic Shock in Industrial Refrigeration Systems.”

Chairperson Rafael Moure-Eraso said, “The CSB’s new safety video is a valuable tool intended for use at the large number of facilities that utilize anhydrous ammonia. The key lessons learned from our investigation – examined in our report and in this video — can help facilities prevent a similar accident from occurring due to hydraulic shock.”

The CSB’s video is available at its YouTube channel and at www.csb.gov

The CSB’s investigation found that the day prior to the accident the Millard facility experienced a loss of power that lasted more than seven hours. During that time the refrigeration system was shut down. The next day, on August 23, 2010, the system regained power and was up and running, though operators reported certain problems.  While doing some troubleshooting an operator cleared alarms in the control system, which reset the refrigeration cycle on a group of freezer evaporators that were in the process of defrosting.

This resulted in both hot, high-pressure gas and extremely low temperature liquid ammonia to be present in the coils and associated piping at the same time. This caused the hot high-pressure ammonia gas to rapidly condense into a liquid.  Because liquid ammonia takes up less volume than ammonia gas – a vacuum was created where the gas had condensed.

The sudden pressure drop sent a wave of liquid ammonia through the piping – causing a sudden pressure surge known as “hydraulic shock.”

This abnormal transient condition results in a sharp pressure rise with the potential to cause catastrophic failure of piping, valves, and other components. Often prior to a hydraulic shock incident there is an audible “hammering” in refrigeration piping,.

CSB Investigator Tyler said, “The CSB’s animation details how the pressure surge ruptured the evaporator piping manifold inside one of the freezers causing a roof-mounted 12-inch suction pipe to catastrophically fail, resulting in the release of more than 32,000 pounds of anhydrous ammonia and its associated 12-inch piping on the roof of the facility.”

The release resulted in injuries to a Millard employee when he fell while attempting to escape from a crane after it became engulfed in the traveling ammonia cloud.  The large cloud traveled a quarter mile from the facility south toward an area where 800 contractors were working outdoors at a clean-up site for the Deepwater Horizon oil spill. A total of 152 offsite workers and ship crew members reported symptomatic illnesses from ammonia exposure. Thirty two of the offsite workers required hospitalization, four of them in an intensive care unit.

The video presents the key lessons learned from the CSB’s investigation including avoiding the manual interruption of evaporators in defrost and requiring control systems to be equipped with password protection to ensure only trained and authorized personnel have the authority to manually override systems. On the day of the incident, the control system did not recognize that the evaporator was already in the process of defrosting, and allowed an operator to manually restart the refrigeration cycle without removing the hot ammonia gas from the evaporator coil.

The CSB also found that the evaporators at the Millard facility were designed so that one set of valves controlled four separate evaporator coils. As a result, the contents of all four coils connected to that valve group were involved in the hydraulic shock event – leading to a larger, more hazardous pressure surge. As a result, the CSB notes that when designing ammonia refrigeration systems each evaporator coil should be controlled by a separate set of valves.

And the CSB found that immediately after discovering the ammonia release, a decision was made to isolate the source of the leak while the refrigeration system was still operating instead of initiating an emergency shutdown. Shutting down the refrigeration system may have resulted in a smaller release, since all other ammonia-containing equipment associated with the failed rooftop piping continued to operate. A final key lesson from the CSB’s investigation is that an emergency shutdown should be activated in the event of an ammonia release if a leak cannot be promptly isolated and controlled. Doing so can greatly reduce the amount of ammonia released during an accident.

The CSB is an independent federal agency charged with investigating serious chemical accidents. The agency’s board members are appointed by the president and confirmed by the Senate. CSB investigations look into all aspects of chemical accidents, including physical causes such as equipment failure as well as inadequacies in regulations, industry standards, and safety management systems.

The Board does not issue citations or fines but does make safety recommendations to plants, industry organizations, labor groups, and regulatory agencies such as OSHA and EPA. Visit our website, http://www.csb.gov.  For more information, contact public@csb.gov.

 

“The US EPA Is Improving Public Access to (YOUR) Environmental Inspection and Compliance Data”

 

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Marion Herz, the Chief of Staff for EPA’s Office of Compliance, just blogged that EPA has launched a new compliance website to “make it easier to stay informed about our work and to share tools that can help companies and others follow the law.”

Herz notes that the Enforcement and Compliance History Online (ECHO) database “lets you analyze compliance and enforcement data through dashboards, maps and charts. It also gives you access to other EPA tools designed to identify pollution sources, including greenhouse gases, wastewater discharges and toxic chemicals.”

Another related recent EPA blog discusses the Agency’s recent updates to the ECHO database, which provides information about environmental inspections, violations, and enforcement actions for EPA-regulated facilities. “As one of our most important and popular resources, ECHO houses information about more than 800,000 facilities nationwide, and last year, it was visited more than 2 million times.” Emphasis added.

Significant updates to ECHO include the ability for anyone with access to the Internet to download data to analyze violations at any of the 800,000 ECHO facilities, which data is now updated within the week.

With this now ever expanding and broadening release and publication of individual facility environmental inspection and compliance data, it is important that responsible company representatives are accessing and monitoring what the Agency is posting on your facilities. The data, hopefully, will not be a surprise (though in some cases it may likely be), but errors in data transmission and uploading are inevitable, and corrections should possibly be submitted and documented in company files. Consider whether it is important that your company data be reflected accurately online by the Agency, and take steps to monitor and correct erroneous data if is the case.

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