Inherently Sa

Inherently Sa

Technology Work

Technology Wor

New Jersey DEP New Jersey DEP

Bureau of Release Preventio

Bureau of Release Preventio

June 17, 2008 June 17, 2008
What Is IST What Is IST

 Concept first introduced by Dr. Tr

Concept first introduced by Dr. Tr

noted process safety expert, about 

noted process safety expert, about 

 Inherently Safer Chemical Processe

Inherently Safer Chemical Processe

Cycle Approach Cycle Approach, 1996, by the Cent

, 1996, by the Cent

Chemical Process Safety of the Am

Chemical Process Safety of the Am

Institute of Chemical Engineers Institute of Chemical Engineers

 New Jersey is the only State or Fed

New Jersey is the only State or Fed

with IST requirements with IST requirements

 Contra Costa County California req

Contra Costa County California req

reviews reviews
IST is not New to the TC

IST is not New to the TC

 Incorporated into the July 14, 2003 

Incorporated into the July 14, 2003 

 Applied to newly designed and con

Applied to newly designed and con

covered processes covered processes
Best Practices Standards 

Best Practices Standards 

 Signed by the Attorney General and 

Signed by the Attorney General an

Commissioner November 21, 2005 

Commissioner November 21, 2005 

approved by the Governor approved by the Governor

 Authority under the NJ Domestic S

Authority under the NJ Domestic S

Preparedness Act Preparedness Act

 Applied to existing and new faciliti

Applied to existing and new faciliti

Chemical Sector Chemical Sector

 43 TCPA facilities 43 TCPA facilities Due March 21, 2006 Due March 21, 2006
IST Principles IST Principles

 Reduce the amount of Extraordin

Reduce the amount of Extraordin

Hazardous Substances (EHS) Hazardous Substances (EHS)

 Substitute less hazardous material

Substitute less hazardous material

 Using EHS in the least hazardous 

Using EHS in the least hazardous 

conditions or form conditions or form

 Designing equipment and process

Designing equipment and process

minimize the potential for equipm

minimize the potential for equipm

and human error and human error
Application of IST Application of IS

 Cover the entire process Cover the entire process 

– transpor

transpor

material receipt and handling, stora

material receipt and handling, stora

equipment, treatment, product ship

equipment, treatment, product ship

 Applies to the layers of protection 

Applies to the layers of protection 

process (i.e. some layer of protectio

process (i.e. some layer of protectio

may be 

“inherently safer inherently safer” than othe

than oth
IST success storie

IST success storie

 Substitution of a less hazardous subs

 wastewater treatment facilities have switch

chlorine to sodium hypochlorite for disinfetreated wastewater.

 electric generation and cogeneration plants 

anhydrous ammonia with aqueous ammoniair pollution control systems.

 a facility switched from chlorine to bromoc

for use as an algicide in treating cooling wat
IST success storie

IST success storie

 Reduction in the amount of a hazard

stored on-site

 a facility switched from bulk storage of liqu

to on-site generation of gaseous sulfur trioxconsumption into the process.

 a facility switched from bulk storage of chlo

generation of ozone for disinfection of pota

 a facility switched from bulk storage of chlo

generation of chlorine dioxide as a bleachin
TCPA IST Rule TCPA IST Rule

 Proposed in the April 16, 2007 New 

Proposed in the April 16, 2007 New 

Register Register

 Effective upon May 5, 2008 New J

Effective upon May 5, 2008 New J

publishing publishing

 Applies to all TCPA facilities (Prog

Applies to all TCPA facilities (Prog

Program 3, new and existing) Program 3, new and existing)

 Intended to provide improved risk 

Intended to provide improved risk 

 Penalties for noncompliance Penalties for noncompliance
TCPA IST Rule Require

TCPA IST Rule Require

N.J.A.C. 7:31 N.J.A.C. 7:31

-3.6 and 

3.6 and 

 (a) IST review report must be subm

(a) IST review report must be subm

by September 2, 2008 by September 2, 2008 

 IST review report conducted und

IST review report conducted un

Practices Standards may be subm

Practices Standards may be subm

comply

 (b) Update required every five year

(b) Update required every five year

schedule with hazard review or PH

schedule with hazard review or PH

new processes, and for major chang

new processes, and for major chang
TCPA IST Rule Requir

TCPA IST Rule Requir

N.J.A.C. 7:31 N.J.A.C. 7:31

-3.6 and 

3.6 and 

 (c) Conducted by team of qualifie

(c) Conducted by team of qualifie

with expertise in environmental h

with expertise in environmental h

safety, chemistry, design and engi

safety, chemistry, design and eng

process controls and instrumenta

process controls and instrumenta

maintenance, production and ope

maintenance, production and ope

chemical process safety chemical process safety

 Include front line workers and th

Include front line workers and th

representatives representatives
TCPA IST Rule Require

TCPA IST Rule Require

N.J.A.C. 7:31 N.J.A.C. 7:31

-3.6(d) and 4.

3.6(d) and 4.

 Analysis of the 4 IST principles and 

Analysis of the 4 IST principles and 

to identify IST alternatives or comb

to identify IST alternatives or comb

alternatives that minimize or elimin

alternatives that minimize or elimin

potential for an EHS release potential for an EHS release
TCPA IST Rule Require

TCPA IST Rule Require

N.J.A.C. 7:31 N.J.A.C. 7:31

-3.6(e) and 4.

3.6(e) and 4.

 Determine whether IST is feasible, 

Determine whether IST is feasible, 

being accomplished in a successful 

being accomplished in a successful 

taking into account factors: taking into account factors:

 Environmental Public health and safety Legal Technological Economic
Feasibility Factors Feasibility Factor

Environmental and Public Healt

Environmental and Public Healt

 There would be a significant negative en

There would be a significant negative en

impact

 Consideration of water resources, water pol

Consideration of water resources, water po

pollution, solid and hazardous wastes, noise

pollution, solid and hazardous wastes, noise

 The IST could decrease the hazard but w

The IST could decrease the hazard but w

the overall risk the overall risk

 The risk would be shifted to another loc

The risk would be shifted to another loc

risk would be the same or higher risk would be the same or higher

 If infeasibility claimed because of risk, n

If infeasibility claimed because of risk, n

document the difference in frequency an

document the difference in frequency an

consequences with and without the IST consequences with and without the IST

 All qualitative and quantitative All qualitative and quantitative
Legal Feasibility Fac

Legal Feasibility Fa

 The IST would result in a conflict w

The IST would result in a conflict w

federal, state, or local laws federal, state, or local laws

 The IST would violate a license agr

The IST would violate a license agr

the license agreement cannot be mo

the license agreement cannot be m

must remain in effect must remain in effect

 Qualitative Qualitative
Technological Feasibility 

Technological Feasibilit

 Is in conflict with Recognized and Gene

Is in conflict with Recognized and Gene

Good Engineering Practices ( Good Engineering Practices (qualitative

qualitative

documents) documents)

 Product quality specifications cannot be 

Product quality specifications cannot be 

and quantitative) and quantitative)

 Availability of materials (qualitative and 

Availability of materials (qualitative and 

 Space restrictions (qualitative and quanti

Space restrictions (qualitative and quanti

 Impact on production rate (qualitative an

Impact on production rate (qualitative a

 Commercially available, not intended to 

Commercially available, not intended to 

process from research stage process from research stage
Economic Feasibility F

Economic Feasibility F

 Life Cycle Analysis Life Cycle Analysis Capital investment, including design and Capital investment, including design and 

implementation implementation

 Net operating costs Net operating costs

 Change in the cost of materials including tr

Change in the cost of materials including tr

handling related costs handling related costs

 Change in energy consumption Change in energy consumption Change in human costs such as number of 

Change in human costs such as number of 

 Any other direct manufacturing costs Any other direct manufacturing costs

 Net regulatory compliance cost, change 

Net regulatory compliance cost, change 

 Demolition and future clean Demolition and future clean

-up and disp

up and disp
Economic Feasibility F

Economic Feasibility F



“Not

” affordability of an IST altern

affordability of an IST altern

to the o/o

’

s facility facility

 Generally feasible if IST has been s

Generally feasible if IST has been s

applied to similar processes, or sim

applied to similar processes, or sim

– focus on significant cost differen

focus on significant cost differen

 Quantitative Quantitative 

– provide cost/benefi

provide cost/benefi
Documentation of Qualit

Documentation of Qualit

Quantitative Infeasibility Ju

Quantitative Infeasibility Ju

 Vendor data Vendor data Engineering Codes and Standards Engineering Codes and Standards Reference books, published articles

Reference books, published articles

 Citations of Federal, State, or Loca

Citations of Federal, State, or Loca

regulations regulations

 Industry organizations such as CCP

Industry organizations such as CCP

Chlorine Institute Chlorine Institute

 Risk Assessment Risk Assessment
IST Review Repor

IST Review Repor

N.J.A.C. 7:31 N.J.A.C. 7:31

-3.6(f) and 4.

3.6(f) and 4.

 Identification of process, team memb

Identification of process, team memb

date, review method date, review method

 IST questions asked and answered IST questions asked and answered List of IST already present List of IST already present List of additional IST identified List of additional IST identified List of IST selected to be implemente

List of IST selected to be implemente

 List of infeasible IST List of infeasible IST Written justification of infeasible IST

Written justification of infeasible IST

using a qualitative and quantitative ev

using a qualitative and quantitative ev

feasibility factors. feasibility factors.
New Covered Proce

New Covered Proce

 4.2(g) deleted and replaced with sim

4.2(g) deleted and replaced with sim

requirements at 3.4(e) and 4.11(e) requirements at 3.4(e) and 4.11(e)

 IST review report must be submitte

IST review report must be submitt

required documents for the new co

required documents for the new co

submittal submittal
Annual/Triennial Re

Annual/Triennial Re

 Submit each IST review report com

Submit each IST review report com

during: during:

 Previous three years (for Program 2 t

Previous three years (for Program 2 t

- N.J.A.C. 7:31 N.J.A.C. 7:31

-3.3(b)6 3.3(b)6 

 Previous year (for Program 3 annual 

Previous year (for Program 3 annual 

N.J.A.C. 7:31 N.J.A.C. 7:31

-4.9(b)6 4.9(b)6 
Contact Informati

Contact Informati

Paul Komosinsky, Section Chief Paul Komosinsky, Section ChiefBureau of Release Prevention Bureau of Release PreventionNJDEPStation Plaza 4, 22 S. Clinton Ave. Station Plaza 4, 22 S. Clinton Ave.P.O. Box 424 P.O. Box 424Trenton, NJ 08625 Trenton, NJ 08625

-0424

(609) 633 (609) 633

-0610

paul.komosinsky@dep.state.nj.us paul.komosinsky@dep.state.nj.us