Document QMVMqvKOnk6eXXEkE9BMQpZY8
r
TAMPA, FLORIDA SEPTEMBER 13, 1985
VCM QUESTIONNAIRE
SENT COPIES TO 37 COMPANIES
US - 17
13 REPLIED
NON US - 19
16 REPLIED
RECEIVED 67 COMPLETED QUESTIONNAIRES
B. F. GOODRICH ICI ENICHEM POLIMERI LIMBURQSE VINYL
12 10
7 5
SLIDE 1
CTL020682
QUESTIONNAIRE TOPICS
STORAGE VESSELS
- SIZE DISTANCE FROM POPULATED AREAS SAFETY FEATURES
PROCEDURES
- EMERGENCY PLAN INVOLVEMENT OF COMMUNITY
PUMPS, LINES
- SAFETY FEATURES
LOCATION SLIDE 2
- U. S. COMPANY NON U.S. COMPANY
CTL020683
3. WHAT IS THE DISTANCE FROM TANK TO NEAREST RESIDENCE? WHAT IS THE DISTANCE TO NEAREST COMMUNITY?
METERS
<100
RESIDENCE COMMUNITY
2 0
101 201 501
1001 2001
200 500 1000 2000 5000 >5000
15 14 10 17 6
0
3 14 12 21 12 3
SLIDE 3
CTL020684
4. DOES THE PREVAILING WIND BLOW TOWARD A RESIDENTIAL AREA?
YES -26
NO 39
OF THE 26 YESES - CLOSEST RESIDENCE = 150 H
CLOSEST COMMUNITY = 150 M
OF THE 26 YESES - AVER. DIST.TO RESIDENCE = 900 M
AVER. DIST.TO COMMUNITY = 1300 M
5. HAVE YOU DONE ANY VAPOR CLOUD DISPERSION MODELING?
YES - 23 _ 35 % have done modeling
NO -42--1
OF THE 26 YESES IN "4" - 46 % HAVE DONE MODELING
SLIDE 4
CTL020685
6. DOES YOUR PLANT HAVE AN EMERGENCY PLAN WHICH INCLUDES NOTIFICATION OR WARNING OF THE LOCAL COMMUNITY?
YES 54 ----83% INCLUDE COMMUNITY IN THEIR PLAN
NO 11 ___
OF THE 26 PLANTS WITH PREVAILING WIND TOWARD COMMUNITY
88% INCLUDE COMMUNITY IN PLANS
7. HAVE YOU MADE ANY CHANGES IN YOUR OPERATION OR PROCEDURES SINCE THE BHOPAL INCIDENT?
YES NO -
14 ___
ONLY 22% HAVE MADE CHANGES 63 ___
SLIDE 5
cTL020686
8. TANK SAFETY FEATURES: A. IS TANK DIKED?
B. IF SPILL OCCURS DOES VCH COLLECT UNDER TANK OR DOES IT DRAIN AWAY TO BASIN?
YES - 54 83% DIKED
NO 1 1
UNDER - 40 AWAY - 23
C. WHAT SPECIAL FEATURES DOES DIKED AREA OR BASIN HAVE?
HARD SURFACE
- 32%
COVERED PIT
- 8%
FOAM SYSTEM
- 15%
WATER SPRINKLER PUMP OUT PUMP
- 44% - 6%
STEAM CURTAINS 4 SIDES
- 1 PLANT
D. ARE YOUR TANKS SPRINKLED?
YES 60
92%
SPRINKLED NO 5
SLIDE 6
CTL020687
E. ARE FLAMMABLE VAPOR DETECTORS DETECTORS LOCATED WHERE SPILL COULD OCCUR?
YES-39
60% HAVE
DETECTORS NO-26 _
F. ARE VCM AREA MONITORS LOCATED
YES-42 _ 65% HAVE
AT TANKS (FOR MEASURING PPM)?
PPM NO-23 _ DETECTORS
86% HAVE EITHER FLAMMABLE VAPOR DETECTORS OR
PPM DETECTORS OR BOTH
14% HAVE NEITHER
G. DO LEVEL INSTRUMENTS HAVE REDUNDANCY (BACKUP)?
YES-40 -- 62% ARE
REDUNDANT NO-25 _
H. DO LEVELS ALARM AT A CONTROL BUILDING WHICH IS MANNED AROUND THE CLOCK?
YES-52 79% ARE AROUND
NO-13 _ THE CLOCK
I. DOES TANK(S) HAVE DUAL RELIEF VALVE?
YES-51 _ 78% HAVE
NO-14
DUALS
3. IS THERE A RUPTURE DISC UNDER THE RELIEF VALVE?
YES-41 _ 63% HAVE RUPTURE DISCS
OUTSIDE US PLANTS SLIDE 7
YES-22--, 50%
NO-22--
CTL020688
K. HOW IS SPACE MONITORED BETWEEN THE RELIEF VALVE AND THE RUPTURE DISC?
PRESSURE GAUGES - 61%
PRESSURE SWITCH - 29%
OPEN VALVES
- 10%
OTHERS
12%
L. HAVE YOU ESTABLISHED A MAXIMUM FILL LEVEL FOR YOUR
TANK?
YES - 100%
RANGE
- 65% TO 98%
AVERAGE - 84.5%
M. HAS TANK(S) BEEN INTERNALLY INSPECTED SINCE ORIGINAL
INSTALLATION DATE?
YES - 57 NO - 3 (1 NEW,2 DUE SOON)
88%
TANK AGE <10 YRS 11
10-20 27
20-30 >30 11 2
34 1
ONE PLANT REPORTED EXTERNAL CORROSION
TWO REPORTED INTERNAL PITTING (RECOVERED MONOMER)
TWO REPORTED NEGLIGIBLE TO LIGHT CORROSION
REMAINDER FAIR TO GOOD TO EXCELLENT CONDITION
SLIDE 8
CTL020689
N. ANY OTHER TANK SAFETY FEATURES?
MANY REPORTED REMOTE OPERATED VALVES. TOTALIZING METER BACKS UP LEVEL. EXCESS FLOW CHECKS IN LIQUID LINES. 2 HLA'S SET AT 72% -85% - 95% (2 INST). HLS TRIPS PUMP, CLOSES VALVE. SAME FOR VAPOR ALARM. HLS OR HPS CLOSES FEED. LPS CLOSES PUMP SUCTION. INTERNAL BILLET VALVE. ALL VALVES CLOSE ON ABNORMAL CONDITION. AUTO CLOSE INLET WITH HLS. OVERPRESSURE OF TANK VENTED TO INCINERATOR. AUTO VALVE CLOSE WITH XS FLOW OR DELUGE TRIP OR HL. BOTTOM HALF OF SPHERE IN CONCRETE CUP. STEAM CURTAIN ON k SIDES. WATER IN3ECTI0N CAPABILITY FOR LEAK. VAPOR DETECTOR TRIPS SPRINKLER. REPEATERS ON LEVEL TRANSMITTER MAKE Dp CELL MORE RELIABLE BY ELIMINATING VCM FILLED LEG.
SLIDE 9
CTL020690
9. PUMPS AND AND LINES:
A. ARE BOTTOM TANK VALVES EQUIPPED WITH REMOTE OPERATED VALVES?
YES -54_ NO -11_
83% HAVE REMOTE VALVES
B. DO PUMPS HAVE DOUBLE SEALS?
NON-U.S.
C. ARE PUMPS SEALLESS? YES - 11
D. ARE PUMPS STEEL OR WROUGHT IRON CONSTRUCTION?
YES -44. NO -10.
81% HAVE DOUBLE SEALS
YES -23 NO -11
68% HAVE DOUBLE SEALS
NON U.S. -10 U.S. - 1
YES -60_^ NO - 5--
92% HAVE STEEL OR WROUGHT IRON.
SLIDE 10
CTL020691
E. ARE PUMPS PROTECTED FROM DEAD HEADED CONDITION (RUNNING WITH DISCHARGE BLOCKED)?
YES 38-l 5 8%
PROTECTED NO 27_
PSV - 14 TS, FS, PS- 11
RECYCLE- 7
ELECT OVERLOAD- 1
OTHER - COMPUTER CONTROL PUMP START W/FLOW AND RECYCLE
F. ARE PUMPS PROTECTED FROM BLOCKED IN CONDITION?
YES - 27 --. 41%
PROTECTED NO - 38 _
PSV -17 S- 3
G. ARE PIPELINES PROTECTED FROM LIQUID BLOCKED IN CONDITION?
YES - 49 _ 75% ARE
PROTECTED NO - 16 --
PSV -48 BY-PASS - 1
SLIDE 11
CTL020692
H. ARE PIPELINES PROTECTED FROM HYDRAULIC SHOCK OF SUDDEN VALVE CLOSURE?
YES - 21
32% ARE
PROTECTED NO - 44 _
I. WHAT TYPE GASKETS ARE USED IN PIPING?
FLAT RING ASBESTOS
- 56
RETAINED TYPE (FLEXITALLIC) - 9
ONE PLANT USES- FLAT ASBESTOS ON 150 LB RETAINED ON 300 LB
10. TANK CAR LOADING/UNLOADING : 50 PLANTS
A. IS THE T/C AREA PROTECTED BY SPRINKLER?
YES -22 _ 44%
PROTECTED NO - 28 _
B. ARE MONITOR NOZZLES INSTALLED?
YES - 34 NO 16
70% HAD MONITORS
90% HAD EITHER SPRINKLERS OR MONITORS OR BOTH.
SLIDE 12
CTL020693
C. ARE FLEXIBLE HOSES USED IN THE OPERATION?
TEST PROGRAM USED?
YES - 39
78% USE
HOSES NO - 11 _
YES - 24
FREQUENCY
VARIES FROM EACH USE INITIALLY QUARTERLY YEARLY
OTHER COMMENTS - ONE REQUIRED BY LAW TO TEST YEARLY AND WHENEVER DISCONNECTED TO 1.5 X MWP FOR 15 MIN. HOSE HAS TEST DATE TAG AND NUMBER.
ONE HAS DOUBLE WALL HOSE WITH GAUGE ON OUTSIDE HOSE.
ONE DOES ELONGATION TEST DURING PRESSURE TEST AND ELECTRICAL CONDUCTIVITY TEST. EVERY 6 MONTHS OR 1600 HOURS USE.
MOST USE WATER PRESSURE TEST.
D. HAVE YOU HAD A HOSE FAIL UNDER VCM PRESSURE?
SLIDE 13
18% HAD FAILURES NO- 41--
CTL020694
E. HOW IS OVERFILLING OF T/C PREVENTED?
THERE WERE 41 WHO LOAD T/C'S
MAGNETIC FLOAT GAUGES
- 15
TOTALIZING METER AUTO STOP (3 REPORTED TWIN METERS)
- 10
COMBINATION OF LEVEL SWITCH
AND DP CELL
-9
LOAD SCALE
-7
OUTAGE GAUGES
-4
NON - U.S. PLANTS MAGNETICGAUGE -
6 OF26
F. IS T/C AREA DIKED FOR SPILL CONTAINMENT?
YES
11. DO YOU RECEIVE OR SHIP VCM BY T/T?
NO
YES - 18
NON U.S. - 16
U.S. - 2
7 -1 14%
HAVE 41--
12. TOTAL RETURNS 65
NON U.S. - 44 U.S. - 21
SLIDE 14
CTL020695
DOW CHEMICAL U.S.A.
September 19, 1985
TEXAS OPERATIONS pREEPORT TEXAS 77541
TO ALL VINYL CHLORIDE SAFETY ASSOCIATION MEMBERS
VCM DISPERSION MODELING CHEMICAL EXPOSURE RISK FORMULA
Attached is the additional information I presented at the Vinyl Chloride Safety Association Meeting in Tampa.
1. The VCM dispersion modeling was an attempt to show the effect of various releases of VCM with respect to the com munity. The line represents the centerline of the vapor cloud with the circular dot as the source. Concentration, distance and time are shown along the line. The circled number represents the downwind location of communities as reported in Question 3 of the VCM Questionnaire. The wind stability factor used was "B" and the model is one devel oped by Dow using the newest technology.
2. The Chemical Risk Potential Index Formula slides shown dur ing the presentation are attached along with a letter from our company to EPA which gives additional information.
Robert R. Oubre Technical Manager Dow Chemical Company (409) 238-9455
web
attachment
cTL020696
AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY
=Qualitv= Performanc
Means More At Dow
CONTINUOUS LIQUID SPILL - PUMP SEAL LEAKING-
AMOUNT SPILLED: WIND VELOCITY:
AREA OF SPILL:
38 KGS/MIN 4.5 MPS
45 M2
CONCENTRATION, PPM
1030
DISTANCE, TIME, METERS MIN
CENTERLINE GROUND LEVEL
CONCENTRATION DURING
RELEASE EQUILIBRIUM PERIOD
(1-10 MINS)
^
100
50
200
0.75
15 300
400
1.5
(14 500
600
700
CTL020697
800
3.0
CONTINUOUS PSV RELEASE
< CONCENTRATION, DISTANCE, TIME,
PPM
METERS MM
AMOUNT RELEASED: 454 KGS/MIN
HEIGHT:
24M
WIND VELOCITY: 4.5 MPS
100
GROUND LEVEL CENTERLINE ^ CONCENTRATIONS DURING (3) RELEASE EQUILIBRIUM PERIOD
CLOUD t TOUCHES * GROUND
;i
1230
200
300
400
1.5
4
180
- 95 60
4
500
600 700
800
3.0
CTL020698
CONTINUOUS PSV RELEASE
30 25
20 15 10
800
3.0
900
1000
1100 4.0
1200
1300
1400
5.0
1500
1600 6.0
CTL020699
INSTANTANEOUS PSV RELEASE
< , CONCENTRATION, DISTANCE, THE,
PPM
METERS MNS
AMOUNT RELEASED: 454 KGS/MIN
HEIGHT:
24 M
WIND VELOCITY:
4.5 MPS
100
GROUND LEVEL CENTERLINE MAXIMUM CONCENTRATIONS OF MOVING CLOUD. x-v
CLOUD TOUCHES* GROUND V:
1100
200
300
400
1.5
215
500 600
700
40
800
3.0
CTL020''00
INSTANTANEOUS PSV RELEASE
800
3.0
900
1000
15 1100
1200
4.5
10 1300
1400
1500
5.5
1600
CTL020701
CONTINUOUS LIQUID SPILL -MASSIVE LEAK-
CONCENTRATION, DISTANCE, TIME,
PPM
METERS MINS
AMOUNT SPILLED: 11,338 KGS RELEASE TIME: 8 MIMS WIND VELOCITY: 2.5 Mf$
. AREA OF SPiLL: ' 232 M2
::
::
CENTERLINE GROUND LEVEL CONCENTRATION DURING RELEASE EQUILIBRIUM PERIOD (1-6 MINS)
48,200 2600 1050
410
100 200 300 400 1.5
250
500
180
600
700
120
800
3.0
CTL020702
CONTINUOUS LIQUID SPILL - MASSIVE LEAK-
amount SPILLED: TIME OF RELEASE:
WIND VELOCITY: AREA OF SPILL:
1 1,338 KGS # 8 MINS
4.5 MPS 232 M^
CONCENTRATION, PPM
2700
DISTANCE, METERS
TIME, MINS
0
CENTERLINE GROUND LEVEL CONCENTRATIONS DURING RELEASE EQUILIBRIUM PERIOD (1-6 MINS)
1450 470
100 200 300
230
400
1.5
140
500 600
75 700
CTL020703
800
3.0
CONTINUOUS LIQUID SPILL - MASSIVE LEAK
@
800
3.0
55
900
1000 35
1100 4.0
1200 25
1300
1400 10
1500
1600 6.0
cTL020704
CHEMICAL EXPOSURE RISK FORMULA
RISK POTENTIAL INDEX = R.V. X Q.F. X V.D.F. X P.P.F.
D.F. X T.O.X. R.V. = RELATIVE VOLATILITY/ > 760 MM/ USE 1.0
Q.F. = QUANTITY FACTOR/ Pounds "TOO
V.D.f.= VAPOR DISPERSION FACTOR/ ratio of vapor density
OF CHEMICAL TO AIR.
P.P.F = PROCESS PENALTY FACTOR/ multiply by 2 for each (1) Stored above 10 psig (2) Thermally active with
ITSELF/ WATER.OR AIR.
D.F. = DISTANCE FACTOR/ FEET TOO
T.0.X.= ACUTE TOXICITY FACTOR/ DEFINED BY O.S.H.A. AS I.D.H.L./ IMMEDIATELY DANGEROUS TO HEALTH OR
LIFE.
HCL = 100 PPM CHLORINE = 25 ppm
CTL020705
EXAMPLE
A LIQUID CHLORINE SPHERE OF 5.0 MM LB CAPACITY OPERATING AT 20 PSIG AND A250 FEET FROM POINT OF PUBLIC CONCERN.
R.V. = RELATIVE VOLATILITY
1
Q.F. = QUANTITY FACTOR
5000
V.D.F .= VAPOR DISPERSION FACTOR= 2.5
P.P.F.= PROCESS PENALTY FACTOR = 1X2 = 2
D.F. = DISTANCE FACTOR
A
TOX. = TOXICITY FACTOR
25
RISK POTENTIAL INDEX = R.V. X Q.dFt. kX;"Vx .Dio.Fx..- -X- -P- -.P- -.F- .
R.P.I. = 1 X 5000 X 2.5 X 2 = 250 A X 25
DEVELOP RELATIVE R.P.I'S FOR PREPAREDNESS LEVEL NEEDED:
FOR EXAMPLE: - DISPERSION MODELING AND MAPPING
- PLAN FOR COMMUNITY NOTIFICATION - DETERMINATION OF WORST CASE AND PURPOSED
RESPONSES - REVIEW OPERATING PROCEDURES - CONDUCT PRACTICE DRILLS
CTL020706
DOW CHEMICAL U.S.A.
August 1, 1985
TEXAS OPERATIONS FREEPORT. TEXAS 77541
Mr. George Wirth Environmental Protection Agency 401 M St. S.W. Washington, D.C. 20460
RE: AIR TOXIC-SITE GUIDANCE MEETING, JULY 23, 1985
Dear Mr. Wirth:
Attached is the proposed formula for determining the Relative Exposure Risk Potential Index for chemical containment systems I promised last week.
As I understand, EPA is committed to providing community guidance in case of a large, acutely toxic chemical release by listing chemicals of concern. The dedication by you and the other EPA people to establish a very sound scienti fic basis for this guidance while insisting on simplicity is admirable. Toxicity alone is obviously not definitive enough. This proposed formula incorporates every factor you and the other EPA people brought up and dis cussed as being important considerations, and yet, is the simplest type formula mathematically possible.
I would propose the EPA work with several chemical companies to determine an index on many of the chemicals proposed to be placed on the Site Review Guidance List. These indexes could be bracketed into Emergency Response Guidance catagories (i.e. 1 through 5) with a different level of response for each. A "1" might call for nothing more than general information on the chemical such' as making available Material Safety Data Sheets, while a "5" might recommend good communications, evacuation procedures, annual drills, vapor detectors with warning horns, etc. Certainly these different levels would be a positive basis for good rapport between industry and the community. After you formalize any proposal, it would be important to provide a response period for both public and industry to give you their comments.
Hopefully, this type of index can identify those chemicals which can be of great concern to a community and also eliminate those which offer no threat. Probably 95% of chemicals handled in the industry would thus be eliminated from the list.
Once again, I would like to thank you for this opportunity to input during your strategy forming stage. The safety record of the Chemical Industry in the United States is one of the best of all industries and we certainly want to see this record continue.
Sincerely,
Gordon R. Miller Loss Prevention Engineering APB
bj attachment
AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY
CTL020707 Means More At Dow.
CHEMICAL EXPOSURE RISK POTENTIAL INDEX
Scope
Provide a comparable index to measure the relative degree of risk to the public from loss of containment of any chemical.
Introduction
The impact on the public from loss of containment of any chemical is based on: (1) The acute toxicity of the compound, (2) The concentration that reaches the people, and (3) The length of time of exposure.
Even though it is impossible to predict, all of the factors that will control concentration and time of exposure (i.e. temperature, humidity, wind speed and direction), these two factors are equally as important as toxicity. The best one can do in determining the degree of risk from any chemical containment is to develop a simple, relative formula of those important parameters that can be measured and hold all other parameters constant. This will allow a Relative Risk Potential number to be generated which can be catagorized to determine a level of Emergency Response Preparedness needed. These catagories and proper responses will be developed later. Non-linear and logarithimic functions of gas dispersions have been ignored to maintain simplicity.
Formula
R.V. X Q.F. X V.D.F. X P.P.F.
TOX.
I Or
= RISK POTENTIAL INDEX
Factor Identification
1. Tox = Toxicity - Select acute toxicity in ppm by preferred method. Suggest: IDLH = Immediately Dangerous to Life or Health in ppm; See NIOSH/OSHA Pocket Guide, r LC50 at 4 hour value.
2. R.V. = Relative Volatility - Vapor pressure of substance in mm of Hg at 25C divided by 760 mm. If above 760 mm, use 1.0.
3. Q.F. = Quantity Factor - Amount of release in thousand lbs., i.e. 500 lbs. = 0.5, 1000 lbs. = 1.0, 10,000 lbs. = 10, etc. Do not use more than one decimal place. Use only amount that will become airborne in 15 minutes of a "worst"-case release.
4. D. F. = Distance Factors - Determine distance from point of containment to point of public exposure concern in thousand foot increments; i.e. 500 ft. = 0.5, 1000 ft. * 1.0, 10,000 ft. * 10.0, etc. Do not use more than one decimal and round off to one significant number.
5. V.D.F. = Vapor Dispersion Factor - The vapor density relative to air is proportional to dispersion, i.e. light density = rapid dispersion, heavy = slow. Divide the molecular weight of the substance by 28.8 (molecular weight of air) and round to one decimal place, i.e. Ammonia = 17/28.8 = 0.6. Chlorine = 71/28.8 = 2.5, etc.
6. P.P.F. = Process Penalty Factors - Multiply by 2 for each factor: (1) contained above 10 psig; (2) thermally reactive with itself, water, air, or other common on site materials below 100C. (Includes loss of inhibitors).
GRM/8-01-85
CTL020708
SKETCH PAD INFORMATION - FOR PLANNING ONLY
Examples:
* For a 2,000 lb. chlorine cylinder rupture at 1000 ft. distance:
1 x 2 x 2.5 x 2 = 10 = 0.4
25 x 1
25
* For 50,000 lb. methyl isocyanate at 500 ft.:
0.5 x 50 x 2.3 x 2 = 115 = 11.5
20 x 0.5
10
* For 5,000 lb. ammonia spill at 5000 ft.:
1x5x 0.6 x2 = 6
500 x 5
2500
= 0.0024
GRM 8/01/85
CTL020709