This week we got word that the Olin Corp has announced that they will be reconfiguring their Henderson, NV facility to make bleach. This is the facility that in 1991 when owned and operated by Pioneer Chlor Alkali Company, Inc. had the largest Chlorine release on record, 70-100 tons of chlorine. The response to the release was not well managed and FEMA did an investigation to examine the response. The liquefied chlorine was stored in tanks at a pressure of approximately 50 pounds per square inch (psi) and temperature of approximately 30 degrees Fahrenheit. The chlorine was dried in the process of compression and, when dry, is noncorrosive. If it is contaminated by water or water vapor, hydrochloric acid is produced and the resulting product is extremely corrosive. It is believed that a tube failure in a heat exchanger allowed water to mix with the chlorine going into one of the storage tanks. When workers began to transfer the contents of that tank to a railroad tank car, the corrosive liquid began to rapidly deteriorate the steel piping system. CLICK HERE for the FEMA report and CLICK HERE for the NIOSH Health Hazard Evaluation (HHE) Report.
With the recent tragedy in Boston, MA involving an anhydrous ammonia (NH3) fatality the internet is buzzing with discussions about what level of PPE is needed to SAFELY respond to an uncontrolled release of NH3. The accident in Boston involved an ammonia refrigeration process inside an enclosed building without adequate ventilation (based on the levels of NH3 the first entry team encountered). The first arriving engine company from BFD (which has an ISO rating of 2) attempted to enter the building for rescue of a missing employee using their turnout/bunker gear and SCBA. They were turned away due to the high levels of NH3 they encountered and two (2) FF's were treated for skin injuries they received in their attempt. A Level III HAZMAT was declared and the HAZMAT team entered the building donned in LEVEL A ensembles and were able to reach the already deceased employee. One might imagine that this type of tragedy would convince many over to becoming "believers" of LEVEL A and NH3, but some of the discussions I have had with responders just amazes me. Here we have FIRST HAND accounts of an uncontrolled NH3 release (liquid release) and responders receiving injuries (not life threatening) because of the level of their PPE and yet many still want to believe that LEVEL B with just a few more strands of duct tape is all that is needed. I like to remind those non-believers once again of an OSHA LOI from all the way back in 1991 that helps us see what OSHA's expectations are...
This video is the best source of details we have at this time regarding the fatal NH3 accident at a Boston, MA Seafood Warehouse, as well as a major NH3 release during an oil draining incident at an ice rink. The boston incident involved a liquid pipe on the bottom of the receiver.
These guys provide us the FIRST-HAND perspective of responding to uncontrolled releases of NH3. The ice rink incident also involved FF's using Turnout Gear as their initial response PPE and this resulted in two having to be transported for injuries. We also get insight into how professional FF's view NH3 hazards (Toxic and Flammability). WORTH your time to watch!
OSHA fines New Orleans tank cleaner $226K for willful, repeat violations after a worker died, and two others were hospitalized, while they cleaned a rail tank car. The three workers were overcome by a lack of oxygen inside the rail tanker on Oct. 8, 2015. OSHA found the company failed to test the atmosphere inside the tanker before the three employers entered the tank, and to mandate that the workers attach a lifeline to their harnesses to allow a rescue. OSHA has cited the company for the same confined space violations three times before at its locations in Illinois. In April 2012, the agency issued eight serious violations at the company's IL location. In May 2012, inspectors found nine serious and two willful violations at that location. In July 2014, an investigation found four serious and seven repeat violations. Willful violations include failing to test atmospheric conditions within a confined space before allowing workers to enter and evaluate a rescuer's ability to respond in a timely manner and function appropriately while rescuing entrants from confined spaces. Serious violations include failing to have a complete respiratory protection program and to medically evaluate and fit test employees before allowing them to use respirators. Repeat violations include failing to take all necessary steps to guarantee safe entry into a confined space, provide fixed points or mechanical devices for retrieving workers from a permit-required space and verify and check appropriate entry conditions on a permit before letting workers enter a confined space.
Here is a breakdown of the citations:
Shelby County Emergency Management Agency Director Jared Rowcliffe described in an email Wednesday afternoon that the driver connected the truck’s tank to the storage tank to offload, but the truck rolled. Instead of the hose breaking, causing an automatic shut-off, the fitting on the truck failed and the product was released. Fire Chief Troy Agney said the cause of the spill was due to “fractured plumbing” on the transport truck.
Official release is stated to have been 19 tons (38,000 pounds). CLICK HERE for the news story
On April 24, 2007, the town of Seward, IL was slammed with a catastrophic release of 40,000 pounds of NH3 at a fertilizer facility. That release covered most of the small rural town and it too was caused when the UNLOADING HOSE failed. Flash forward to April 5, 2016 and we have yet another TOTAL LOSS of a MC331 carrying NH3 which occurred during the UNLOADING process in Stewardson, IL. The Coast Guard's NRC Reports does not yet include April 5th so I am unsure of the amount lost, but from photographs we can see that it was a substantial release and the Shelby County Emergency Management administrator stated it was a 20 Ton (40,000 pounds) container being unloaded. One news account states the release was 19 Tons (38,000 pounds). According to the safety and regulatory director for the facility, "a contractor was hauling ammonia to the facility and off-loading product before the spill. The vehicle moved, causing the hose to stretch and then the break happened." News accounts state 200 were evacuated, with 20-25 injuries transported to a hospital and one admitted for further treatment/observation.
Imagine my surprise when reading the latest edition of "Chemical Process Safety (Fourth Edition), Learning from Case Histories", August 2015, by Roy E. Sanders when I came across a very nice mention of SAFTENG.net. In 2014 I received some very nice feedback from Mr. Sanders regarding my work with the Incident Alerts and my Process Safety Articles, but I never thought I would get a shout-out in one of my favorite series of process safety books...
Respondent owns and operates a carbonated beverage bottling plant. At the facility, respondent produces, processes, handles, or stores substances listed in, or pursuant to, CAA 112(r)(3) or other extremely hazardous substances identified as such due to toxicity, reactivity, flammability, volatility. or corrosivity, including anhydrous ammonia. On March 29, 2015, there was a 3,750 pound release of anhydrous ammonia from the facility due to a closed compressor discharge valve and a failed high pressure compressor shutdown interlock.
EPA found that Respondent had violated regulations implementing Section 112(r) of the Act at 40 C.F.R. Part 68 by failing to comply with the regulations as noted on the enclosed Risk Management Plan Inspection Findings and Alleged Violations Summary, which is hereby incorporated by reference. In consideration of Respondent's size of business, its full compliance history, its good-faith effort to comply, and other factors as justice may require, and upon consideration of the entire record, the parties enter into the ESA in order to settle the violations described in the enclosed Summary for the total penalty amount of $12,000.
Hundreds of workers evacuated a candy manufacturing plant when an evaporator unit pipe failed and released approximately 22 pounds of anhydrous ammonia throughout the facility. No workers were injured in the incident which closed the plant for more than two hours. OSHA investigated the Sept. 23, 2015, incident and cited the company with three repeat, 14 serious and two other-than-serious safety violations. On March 31, OSHA proposed penalties of $193,600. The agency has also placed the company in its Severe Violator Enforcement Program. Here is a breakdown of the citations:
OSHA found that the nation's largest chicken producer failed to use proper safety procedures that allowed a release of 79 pounds of anhydrous ammonia and endangered workers at its Waco facility on Sept. 28, 2015. OSHA cited the facility for two repeat and two serious violations under its Process Safety Management Standard. The company faces penalties of $122,500. OSHA issued the two repeat citations for failing to implement proper standard operating procedures with accurate information on safety systems and how they worked. The company's process hazard analysis failed to address issues in the plant. Inspectors also found the company's inspections and equipment testing were not completed as scheduled or documented as required. The agency cited the company for the same or similar violations at its plants in in TX in February 2015 and in Arkansas in July 2013. The agency also issued serious citations for failing to use proper methods to prevent over-pressurization and explosions in the system, and for placing the control and maintenance room facilities in the engine room for ammonia refrigeration. Here is a breakdown of the citations: