Inherently Safer Technology (IST) Implementation Summary

January 15, 2010 

Background 

The Best Practices Standards at TCPA/DPCC Chemical Sector Facilities (Best Practices 

Standards), issued November 21, 2005 by the New Jersey Domestic Security Preparedness Task 

Force, required Chemical Sector facilities subject to the Toxic Catastrophe Prevention Act 

(TCPA) Program rules to prepare inherently safer technology (IST) review reports.1

 

Subsequently, the Department of Environmental Protection adopted new rules under the 

TCPA Program, published in the May 5, 2008 New Jersey Register at N.J.A.C. 7:31-3.6 and 

4.12, that require all facilities regulated under the TCPA to conduct IST reviews and to submit an 

IST review report to the Department by September 2, 2008. As a result of this action, water and 

wastewater treatment facilities, food manufacturing and handling facilities, refineries, power 

generation facilities and other facilities that handle Extraordinarily Hazardous Substances (EHS) 

performed IST reviews, as Chemical Sector facilities did under the Best Practices Standards. 

 The Best Practices Standards and the TCPA IST rules are similar in that they require the 

subject facilities to conduct the IST review and to evaluate identified IST alternatives to 

determine whether they are feasible. The IST alternatives are not mandated to be implemented. 

If the facilities decide to implement any of the ISTs, the implementation schedule is required to 

be included in the IST review report submitted to the Department. The following paragraphs 

outline the results of the implementation of the IST review requirements under both the Best 

Practices Standards and the State IST rules. It should be noted that these are facilities that have 

been regulated under the TCPA program for many years resulting in the past implementation of 

IST and risk reduction measures. That being said, even after twenty years of the TCPA program 

targeting risk reduction, the IST evaluations resulted in the discovery of additional 

implementable alternatives in approximately half of the TCPA facilities. 

 

DEPARTMENT OF ENVIRONMENTAL PROTECTION

JON S. CORZINE P.O. BOX 402 MARK N. MAURIELLO

Governor Trenton, NJ 08625-0402 Acting Commissioner 

 

 

1

 The Best Practices Standards define Chemical Sector Facilities as all facilities that are subject to the TCPA or the 

Discharge Prevention, Containment and Countermeasure (DPCC) programs and that are identified by any of the 

following Standard Industrial Classification (SIC) major groups: 28 (chemical and allied products), 30 (rubber and 

miscellaneous plastic products), 5169 (chemicals and allied products, not elsewhere classified), or the corresponding 

North American Industry Classification System (NAICS) codes (325, 326, and 424690). 

New Jersey is an Equal Opportunity Employer l Printed on Recycled Paper and Recyclable 
Summary 

This summary is based on the Department’s review of 85 IST reports that have been 

submitted since August 2008. From the 85 facility reports, a total of 143 additional IST 

measures were reported to have been implemented or scheduled to be implemented. Forty-one 

facilities implemented or scheduled to implement from one to eleven additional IST measures. 

Table 1 below provides a summary of IST implementation for the following sectors: chemical, 

food (ammonia refrigeration), power generation, petroleum refinery, water/wastewater, and 

other. 

Table 1. Summary of IST Measures Implemented or Scheduled by Sector 

Sector # of 

Facilities 

Submitted 

an IST 

Report 

Total # of 

IST 

Measures 

Implemented 

or Scheduled

# of 

Facilities 

Reporting 

One or More 

Measures to 

be 

Implemented

Percentage of 

Facilities 

Implementing 

IST Measures 

Maximum # 

of ISTs to be 

Implemented 

by a Facility 

# of 

Facilities 

Eliminated 

EHS Use by 

Implementing IST 

Chemical 41 77 18 44 11 0 

Water/ 

wastewater

13 15 7 54 4 2 

Refinery 4 10 2 50 3 0 

Food 14 35 9 64 7 0 

Power 6 1 1 17 1 0 

Other 7 9 4 57 4 0 

Total 85 143 41 48 11 2 

Chemical Sector Facilities

 Forty-one of the 85 reports reviewed by the Department were from chemical facilities 

subject to the Best Practices Standards. Eighteen facilities implemented or scheduled to 

implement from one to eleven additional IST measures. A total of 77 additional IST measures 

were reported to be implemented or scheduled to be implemented. Facilities reported some 

significant IST measures resulting from the IST review. One facility has replaced bulk storage 

of acetylene with onsite generation. Another facility is planning to greatly reduce its chlorine 

inventory with an onsite generation process. Other significant examples of IST measures 

reported to be implemented include redesign of a relief system, changes in equipment and vessel 

configuration, safer EHS storage location, addition of remotely activated valves and automatic 
shutdown systems with interlocks, protection of storage vessels from weather conditions, 

changes to truck traffic patterns, improved types and materials of construction of piping, 

installation of power backup systems for controls and equipment, improved computer control 

systems, addition of EHS leak detectors, and a closed circuit television system. Several of the 

chemical sector facilities that had no additional IST recommendations had already implemented 

IST measures in the past that were identified in process hazard analysis and risk assessment 

studies. Also, many of these chemical manufacturing facilities run processes in which there is no 

feasible alternative for the EHS and inventories have already been minimized. 

Water/Wastewater Treatment Facilities 

 Thirteen water/wastewater facilities submitted IST reports. Seven facilities implemented 

or scheduled from one to four additional IST measures. A total of 15 additional IST measures 

were reported to be implemented or scheduled to be implemented. Two facilities replaced 

chlorine with sodium hypochlorite. One facility plans to replace anhydrous ammonia with 

aqueous ammonia as one of its treatment chemicals. Other IST measures reported include 

elimination of 150 pound cylinder usage, a scrubber for the chlorine storage room, upgrading the 

control system, equipment redesign and reconfiguration, and adding remote shutoff through the 

computer control system. Some of the water/wastewater facilities utilize ozone for treatment, 

which is considered an IST since ozone is generated onsite and continuously consumed. The 

facilities that are registered for chlorine have implemented past IST measures such as indoor 

storage, leak detectors, remote and automatic shutdown, scrubbers, and mitigation systems such 

as water fogs/sprays; these facilities have identified alternatives to replace chlorine but have not 

reported plans to implement replacement. 

Petroleum Refineries

 Four petroleum refineries submitted IST reports. Two of the refinery facilities 

implemented or scheduled to implement additional IST measures as a result of the IST review. A 

total of six additional IST measures were reported to have been implemented or scheduled to be 

implemented. Examples of the IST measures reported to be implemented include labeling of 

valves and equipment and revising procedures. The four refineries reported that many IST 

measures were identified in past process hazard analysis and risk assessment studies and had 

already been implemented. One New Jersey refinery that uses hydrogen fluoride (HF) in the 

alkylation unit reported that it would investigate the use of a solid catalyst and identified 

substituting HF with sulfuric acid or modified HF as possible alternatives, but stated that 

implementing these substitutes was too costly to implement. Refineries in California and other 

states have chosen to utilize a modified HF alkylation process, which incorporates a suppressant 

in the HF that reduces the HF volatility and amount of an airborne release. This significantly 

reduces the number of people that would be impacted by an accidental release. Using a sulfuric 

acid process or a solid catalyst would completely eliminate the risk of an HF release. 
Ammonia Refrigeration at Food Manufacturing and Handling Facilities

 

Fourteen food ammonia refrigeration facilities submitted IST reports. Nine facilities 

implemented or scheduled to implement from two to seven additional IST measures. A total of 

35 additional IST measures were reported to be implemented or scheduled to be implemented. 

Examples of significant IST measures reported for implementation include adding leak detectors 

to shut down equipment, updating computer controls, replacing mechanical controls with 

microprocessors, installing interlocks, converting single safety valves to dual valve systems, 

removing unnecessary piping and equipment, installing seal-less pumps, upgrading the material 

of construction of equipment, adding safety instrumentation, installing fail-safe instrumentation, 

indoor containment of storage vessels, and redundant critical equipment. Several facilities 

reported they would not replace ammonia with another refrigerant such as 

hydrochlorofluorocarbons and hydrofluorocarbons due to environmental concerns such as 

contribution to the greenhouse effect and ozone depletion potential of these chemicals. Several 

facilities identified carbon dioxide systems or carbon dioxide/ammonia cascade systems as 

potential replacements for the existing system but stated that they would not implement due to 

the substantial cost to completely replace the entire refrigeration system. 

Power Generation Facilities 

Six power generation facilities, five of which use aqueous ammonia and one which uses 

anhydrous ammonia to reduce nitrogen oxides emissions in a selective catalytic reduction 

process, submitted IST reports. Only one of these facilities reported one additional IST measure 

scheduled to be implemented, which is to install an emergency stop and interlocked shutdown of 

the unloading pump. The facilities stated that additional IST measures were not necessary 

because of the measures already in place which resulted in no or minimal offsite impact of a 

release. Some IST measures reported already in use include storage tank spill containment, leak 

detection, deluge systems, and automatic shutdown systems. 

Other Sector Facilities

Seven facilities in other miscellaneous sectors submitted IST reports and reported a total 

of nine additional IST measures to be implemented or scheduled to be implemented. Four 

facilities implemented or scheduled from one to four additional IST measures. Examples of the 

IST measures reported to be implemented include installing a computer control system, 

enhanced pipe inspections, installing a simulation training station, adding a thermal imaging 

camera, reducing the frequency of storage cylinder changes, and adding light towers for EHS 

leak alarms, warning labels, upgraded filter media, and reducing EHS flow. 
Conclusion

 The Best Practices Standards and TCPA IST rules were successful in encouraging 

several facilities to implement additional IST measures. Two water treatment facilities have 

substituted their EHS, chlorine, with sodium hypochlorite as a result of the IST review and have 

deregistered from the TCPA program. Approximately 48% of the 85 facilities reported that they 

had implemented or scheduled to implement IST measures as a result of conducting the IST 

review. Several facilities reported that there are no additional IST measures available beyond 

those that have already been implemented in their processes. A few facilities did identify 

additional IST measures but chose not to implement them, primarily for economic reasons, and 

some facilities indicated that these IST measures would be evaluated and considered in the 

future. 

Most of the facilities that use extraordinarily hazardous substances could become less 

attractive terrorist targets by converting to alternative chemicals or processes identified through 

periodic IST reviews if feasible and practicable. It is clear that IST evaluation has the potential to 

provide cost effective and technically feasible alternatives at many of the facilities of concern.