Chemicals, Emergency Preparedness and Response

Lessons Learned from a Chemical Release

In yesterday’s Advisor, we discussed a recent Chemical Safety Board (CSB) report concerning a chemical release involving a delivery and inadvertent mixture of incompatible chemicals. Today we will review CSB recommendations for the facility, the delivery company, and the local emergency responders. These recommendations are widely applicable to all chemical facilities, delivery companies, and local emergency responders.

Briefly, to recap the incident, a tanker truck from Harcros Chemicals arrived at an MGPI Processing plant in Atchison, Kansas, to deliver sulfuric acid. He inadvertently connected to a tank containing sodium hypochlorite, which is incompatible with sulfuric acid. The chemical reaction lead to a shelter-in-place order for thousands of nearby residents, and at least 140 employees and members of the public needed medical attention.

Lessons for the Facility

While the CSB has recommendations for all involved, the bulk of the lessons learned are directed at the facility. These include:

  1. Commission an independent engineering evaluation of applicable buildings and ventilation systems, and based on the results of that evaluation, implement design changes and controls to protect occupants from a chemical release.
  2. Conduct an evaluation of chemical transfer equipment (e.g., fill lines, transfer valves, transfer piping, tanks, and other associated equipment) and install appropriate engineering safeguards to prevent and mitigate an unintended reaction, chemical release, or spill during bulk unloading.
  3. Where feasible, install safeguards, such as alarms and interlocks, to prevent personnel from opening the incorrect chemical transfer valves during deliveries. In addition, install mitigation measures to automatically shut down the transfer of chemicals into the facility based on process deviations or abnormal conditions (e.g., pressure, temperature, flow, or level indications; gas detection).
  4. Design processes and chemical transfer equipment to account for human error. Suggestions include:
    • Physically isolate or use distance to separate fill lines.
    • Work with motor carriers to select hose couplings and fill line connections with uniquely shaped and color-coded fittings for each chemical or class of chemicals.
    • Ensure that pipe markings on transfer equipment and piping are accurate and legible.
    • Make sure pipe markers are as close to the fill line as possible.
    • Install interlocks and mitigation measures to maintain safe operations during chemical unloadings.
    • Develop agreed upon procedures with your chemical distributors for chemical unloading.

Lessons for the Delivery Company

It is clear from the CSB report that the driver was not sufficiently trained in safe cargo tank motor vehicle (CTMV) unloading operations. Lessons learned for delivery companies and chemical distributors include:

  1. Establish a refresher training program to ensure drivers know the location of various CTMV emergency shut-off devices, when to use them, and the effectiveness of those devices to stop the flow of chemicals during emergencies. The refresher training program should include:
    • Drills for drivers to simulate the activation of all shutoff devices in defined incident scenarios (e.g., inadvertent mixing, chemical releases) during unloading operations; and
    • A process to evaluate the effectiveness of the refresher training program.
  2. Establish a process to evaluate the respiratory hazards associated with chemical unloading at customer sites. The evaluations should determine whether drivers need emergency escape respirators in the event of an accidental reaction and/or release of chemicals. If needed:
    • Provide the appropriate respiratory equipment and training.
    • Ensure that the equipment is stored in an area that allows for immediate access.

Lessons for Emergency Responders

Although the incident is reviewed in this CSB report and the Atchison County Department of Emergency Management’s response was largely viewed as a success, several issues and areas for improvement for the department were identified. These suggestions, which are applicable to any emergency response organization, include:

  1. Review facility risk management plans as they are submitted or revised, and conduct preplanning at Risk Management Program-covered facilities and all other facilities within the county that, based on annual Tier II reporting forms, store large amounts of hazardous chemicals.
  2. Conduct a full-scale hazardous materials exercise that involves an off-site chemical release scenario. The exercise should include participants from local emergency response organizations, hospitals, schools, and fixed facilities. Resolve coordination or communication issues identified during the exercise.
  3. Increase participation in state and regional emergency response training and programs.
  4. If not already done, submit a Hazardous Materials Emergency Preparedness grant proposal to your state emergency management department to assist in funding additional training and preplanning activities within the county.

Are your drivers adequately trained to prevent or respond to a chemical release? According to the Pipeline and Hazardous Materials Safety Administration (PHMSA), human error is a major contributing factor for incidents occurring during loading and unloading operations. Check tomorrow’s Advisor for some training tips for drivers in the event of a chemical release.

Print

Leave a Reply

Your email address will not be published. Required fields are marked *

This site uses Akismet to reduce spam. Learn how your comment data is processed.