### Inherently Safer Technology (IST) Implementation Summary
January 15, 2010

Background

The Best Practices Standards at TCPA/DPCC Chemical Sector Fac ilities (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 Environm ental 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 faci lities regulated under the TCPA to co nduct 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 manufactur ing and handling facilities, refineries, power generation facilities and other f acilities that handle Extraordinar ily Hazardous Substances (EHS) performed IST reviews, as Chemical Sector f acilities did under the Best Practices Standards.

The Best Practices Standards and the TCPA IS T rules are similar in that they require the subject facilities to conduct th e IST review and to evaluate identified IST alternatives to determine whether they are feasible. The IST alte rnatives are not mandated to be implemented. If the facilities decide to implement any of th e 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 th e IST review requirements under both the Best

Practices Standards and the State IST rules. It sh ould be noted that these are facilities that have been regulated under the TCPA pr ogram 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. D EPARTMENT OF E NVIRONMENTAL P ROTECTION
J ON S. C ORZINE P.O. B OX 402 M ARK N. M AURIELLO

Governor Trenton, NJ 08625-0402 Acting Commissioner

1 The Best Practices Standards define Chemical Sector Fac ilities as all facilities that are subject to the TCPA or the Discharge Prevention, Containment and Countermeasure (DP CC) 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 RecyclableSummary

This summary is based on the Department’s review of 85 IST reports that have been submitted since August 2008. From the 85 faci lity reports, a total of 143 additional IST measures were reported to have been implemente d 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 implem entation for the following sectors: chemical, food (ammonia refrigeration), power generation, petroleum refinery, wa ter/wastewater, and

other.

Table 1. Summary of IST Measures Im plemented 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 byImplementing 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 revi ewed 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 me asures. A total of 77 additional IST measures were reported to be implemented or scheduled to be implemented. Facilities reported some significant IST measures resulti ng from the IST review. One facility has replaced bulk storage of acetylene with onsite generation. Another faci lity is planning to grea tly reduce its chlorine inventory with an onsite genera tion 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 automaticshutdown systems with interlocks, protection of storage vessels fr om weather conditions, changes to truck traffic patterns, improved t ypes and materials of c onstruction of piping, installation of power backup systems for controls and equipment, improved computer control systems, addition of EHS leak detectors, and a cl osed circuit television system. Several of the

chemical sector facilities that had no additi onal 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 manufacturi ng facilities run processes in which there is no

feasible alternative for the EHS and i nventories 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 fac ility plans to replace anhydrous ammonia with aqueous ammonia as one of its treatment chem icals. 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 reconfig uration, and adding remote shutoff through the computer control system. Some of the water/wa stewater facilities utilize ozone for treatment, which is considered an IST since ozone is ge nerated onsite and continuously consumed. The facilities that are registered fo r 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 identif ied alternatives to replace chlorine but have not reported plans to implement replacement.

Petroleum Refineries

Four petroleum refineries su bmitted 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 re ported 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 asse ssment studies and had already been implemented. One New Jersey re finery that uses hydrogen fluoride (HF) in the alkylation unit reported that it w ould investigate the use of a so lid catalyst and identified substituting HF with sulfuric ac id 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 al kylation process, which incorporates a suppressant in the HF that reduces the HF volatility and amount of an airborne releas e. This significantly reduces the number of people that would be impact ed by an accidental release. Using a sulfuric acid process or a solid catalyst would complete ly eliminate the risk of an HF release.Ammonia Refrigeration at Food Ma nufacturing and Handling Facilities

Fourteen food ammonia refrigeration facilitie s 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 sc heduled to be implemented. Examples of significant IST measures reported fo r implementation include adding leak detectors to shut down equipment, updating computer co ntrols, replacing mechanical controls with microprocessors, installing interl ocks, converting single safety va lves to dual valve systems, removing unnecessary piping and equipment, inst alling seal-less pumps, upgrading the material of construction of equipment, adding safety inst rumentation, installing fail-safe instrumentation, indoor containment of storage vessels, and redunda nt critical equipment. Several facilities reported they would not replace ammoni a with another refrigerant such as hydrochlorofluorocarbons and hydr ofluorocarbons due to environmental concerns such as contribution to the greenhouse effect and ozone de pletion 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 em issions in a selectiv e catalytic reduction process, submitted IST reports. Only one of thes e facilities reported one additional IST measure scheduled to be implemented, which is to insta ll an emergency stop and interlocked shutdown of the unloading pump. The facilities stated th at additional IST measures were not necessary because of the measures already in place which re sulted 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, a nd automatic shutdown systems.

Other Sector Facilities

Seven facilities in other miscellaneous sect ors 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 in clude installing a computer control system, enhanced pipe inspections, installing a simula tion training station, adding a thermal imaging camera, reducing the frequency of storage cylin der 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 implemen t additional IST measures. Two water treatment facilities have substituted their EHS, chlorine, with sodium hypoc hlorite as a result of the IST review and have deregistered from the TCPA program. Approximate ly 48% of the 85 facilitie s reported that they had implemented or scheduled to implement IS T measures as a result of conducting the IST review. Several facilities reported that ther e 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 impl ement them, primarily for economic reasons, and

some facilities indicated that these IST measur es 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 alte rnative chemicals or pr ocesses identified through periodic IST reviews if f easible and practicable. It is clear th at IST evaluation has the potential to provide cost effective and technically feasible al ternatives at many of th e facilities of concern.