Emergency
Preparedness for Chemical Accidents
Toxic Gas
Release from CPI on Feb 2nd 2006
Art Liberman 4/2006
Updated 12//2006
On the 2nd of February 2006, residents of
Barron Park who live next to the Stanford Research Park received an unexpected “wake
up” call. The message: accidents involving the extremely hazardous chemicals at
the industrial facility that is very close to your homes could quickly and
seriously affect your health and safety. In the afternoon of that day in
February, a mishandling of chemicals in Building #2 of Communications and Power
Industries (CPI) on 811 Hansen Way sent a plume of toxic nitric acid vapors from
their facility into the adjacent residential area. Several residents on Chimalus
drive and construction workers on the opposite side of CPI reported smelling an
irritating, acrid, choking odor, and a worker on the roof at 728 Chimalus said
afterwards that the fumes nearly caused him to faint and fall from his perch.[1] Fortunately, this accident did not cause any long term serious
injuries. But because this facility is so close to residences and handles such
large amounts of such extremely hazardous materials, a natural disaster or
another industrial accident in the future could have much more serious
repercussions.
CPI Building
#2 CPI chemical storage and chemical
processing facilities at 811 Hansen Way
.
This figure, from Google Earth, shows an aerial view
of the CPI manufacturing facilities on Hansen Way and the nearby residences in
the Barron Park neighborhood.
Not only are the CPI buildings themselves close to
residences, but the areas in the buildings where the largest amounts of the
most hazardous chemicals are used and
stored are about as close to residences as they could possibly be. The areas in
the CPI building #2 where the tanks of liquid hazardous materials are used in
an electroplating shop and the acid waste tanks from which the toxic gas plume
in February emanated are both on the side of the building directly facing
the residents, and less than 75' from their property line. The storage buildings for
toxic chemicals are actually against the wall that borders the greenbelt
which separates the CPI property from residences on Chimalus Drive. These areas
are outlined in the following figure, using a photo of the CPI Building #2 and
the neighboring residences from a Windows Live Local website.
This accident was a wake up call to residents living
near CPI. Our first response, as a step toward emergency preparedness, should
be to understand the hazards from the industrial site next to our homes. We
need to educate ourselves about the materials used by CPI that have serious
toxic effects and are used in significant quantities. These are the ones that
pose the highest risk to us in the event of an accident. Then we must ask what might be the
consequences of an even more serious industrial accident, or if a seismic event
were to occur and a significant toxic gas release spreads over our area in the
future? How far away from the emission site are residents seriously at risk
from suffering permanent health damage?
Ultimately, we must become more active citizens and take personal and
political responsibility and move to influence the regulating authorities in
the city and county who have the legal oversight of CPI. That is the only way
to reduce the possibility of another and potentially more serious accident,
from happening. And that is the purpose
of this report.
What happened inside CPI on Feb 2nd ?
We do not know the full story. The Palo Alto Fire Department (PAFD) has the
responsibility to oversee hazardous material usage. Their Hazardous Materials
Division is conducting an investigation of the accident and of the response of
CPI. The objective is to uncover the cause of the accident and determine if CPI
followed its stated safety procedures, and whether those procedures were
adequate. We hope it will also require remedial steps by CPI in procedures and
training, in monitoring and possibly in other areas. Hopefully it will also
result in more rigorous oversight of CPI by the PAFD.
The PAFD has not released their report of the
investigation of the accident on Feb 2nd. CPI filed a hazardous
material report of the accident, dated February 7th, that is on file
with the Santa Clara County Department of Environmental Health (DEH) with their
description of the events. This report suggests the accident was due to human
error, starting with the incorrect mixing of an acid bath. The report states: “The bath involved was a newly made up Copper Bright
Dip (approximately 95 gallons), which should consist of 60% sulfuric acid and
40% nitric acid. It is possible the ratio was reversed.” When the mixture did not
clean the metals properly, the CPI workers dumped the bath into the waste tank.
“When the acid entered the
Concentrated Acid Waste (CAW) tank in the basement of the building, the mixture
heated up, resulting from diluting acid into water already present in the CAW
tank. Once heated, acid fumes were liberated.” The vapor containment
measures, scrubbers’ in the tank venting system, did not prevent a substantial
amount of the nitric acid vapors from escaping into the air, into their
building, and then beyond their site and onto our residences.
It appears the accident was due to human error, but it
is not clear from the report if the accident was a consequence of someone making
the incorrect acid mixture, or because there was too little or too much water
in the CAW tank, or some combination of these factors. Was it employee carelessness
or poor training or poor oversight or a poorly documented process procedure? A
contributing factor could also be rapid changes in the workplace. During 2005,
CPI reconstructed the ‘Plating Shop’ in the interior of Building 2. The Fire
Department inspected CPI more than 30 times during the reconstruction,
according to Fire Marshal Dan Firth.[2]
It is possible that the changes to the interior structures and operations there
contributed to the accident on Feb 2nd
CPI did not notify the authorities following the accident
though this is mandated by law. The Palo Alto Municipal Code states: “Any responsible person or an employee, authorized
representative, agent, or designee of such person shall, upon discovery,
immediately report any release or threatened release of a hazardous material to
the fire department.” In addition, the Code says
that the Palo Alto Fire Department Chief must be notified whenever “a release or unauthorized
discharge escapes secondary containment, or is contained but presents a threat
to health or property.”
[3] The chemical spill at CPI on February 2nd breached
secondary containment and, considering the effect of the fumes on residents and
workers on Chimalus Drive, the toxic vapors clearly presented a threat to their
health.
Because of the failure by CPI to notify the PAFD
immediately after the spill, the City Attorney’s office is also conducting an
investigation with the possibility of a pursuing an enforcement action.[4]
At the present time, because of the pending legal action, neither the Fire
Department nor the City Attorney will make any public comment on their investigations
or on the status of any possible enforcement action.
Immediate Resident Response to the Feb 2nd
Accident
It was the newspaper reporter of the Palo Alto
Weekly who alerted the authorities to the presence of toxic gas vapors in our
neighborhood on Feb 2nd. No one in Barron Park called 911 for
assistance. This sounds very surprising at first glance. But the people on Chimalus Drive with whom I
spoke said they didn’t call 911 for one or another of two reasons. First, thankfully,
no one felt that they were in a life or death emergency situation. Some people returned to their houses and
were able to escape the irritating and unpleasant odors until the vapors
outside dissipated. Secondly, it appears that no one was actually aware that
unpleasant gases could come from an accident at CPI, wafting in over their
backyard fences. They were just baffled and puzzled and confused; no one was
prepared, mentally, to connect the smells and the odors and their unpleasant
respiratory sensations with a chemical spill at CPI and the consequent emission
of toxic gases. Most residents were unaware of the use and
storage of the large quantities of extremely hazardous materials so close to
their homes.
What were the
nitric acid levels inside CPI and offsite on Feb 2nd ?
The CPI report of the accident on Feb 2nd
states that their detectors in various parts of their facility recorded
relatively low values of nitric acid vapors, on the order of 0.5 to 1 ppm
(parts per million) at various places
inside their facility. However the measurements were not made at the emission
site at the time of the accident, but afterwards at various places within their
facility when the vapor cloud began to dissipate.
The reactions reported by people on Chimalus Drive
give a very rough estimate of the nitric acid airborne concentration levels
offsite. The EPA has guidelines that anticipate human adverse health effects
caused by exposure to toxic chemicals. These are called the Emergency Response
Planning Guidelines (ERPG)[5].
The ERPG's are three-tiered guidelines with different concentration levels for
one hour exposure duration, from least severe, level 1, to the most severe,
level 3. At the lowest level, 1 ppm for nitric acid vapors, individuals would
report transient health effects, notable discomfort, irritation, and a disagreeable
odor. This seems to agree with what exposed individuals on Chimalus Drive
reported.
In their accident report, CPI did not mention the
amount of nitric acid in vapor form that was released in the accident. The PAFD
should require CPI to make a thorough analysis and come up with an estimate as
part of their investigation. This may be difficult and require professional
expertise[6],
but it would be a very useful piece of information to have. It could connect
the measurements with the reactions of CPI personnel and residents. Another
reason for requiring CPI to make this estimate would be to benchmark the
analysis CPI uses to estimate offsite consequences for the potentially more
serious accidents that will be described below.
What are the principal hazards at CPI ?
Many of the buildings in the Stanford Research Park are
offices, corporate headquarters and R & D laboratories. However, CPI, which
was spun off from Varian in the mid-90’s, is different. Their Building #2 at
811 Hansen Way is a manufacturing facility. They manufacture microwave devices,
(klystrons, gyrotrons, traveling wave tubes, and the like) for radar,
satellites and electron accelerators. One
requirement of the reconstruction in 2005 to Building #2 was to accommodate an
increased amount of manufacturing for products that CPI had previously built in
San Carlos. After transferring the
product line to Palo Alto, CPI closed and sold their San Carlos site.
To manufacture these parts, CPI uses a large number
of hazardous chemicals. After transferring their San Carlos product line to
Palo Alto, the number and quantities of hazardous chemicals have both
increased. Their filing with the Palo Alto Fire Department in March 2006 lists
over 340 hazardous chemicals, solids, liquids and gases - some toxic, some
flammable, some irritating, some associated with acute health hazards, others
posing chronic health hazards. And each
year the list of hazardous materials that CPI has filed with the PAFD grows.
The principal risks to the neighbors of CPI are from
hazardous chemical spills that would result in toxic gas releases – this is
just what happened on Feb 2nd. The two chemicals CPI uses with the highest risk of causing serious
offsite effects from a toxic gas plume are nitric acid and potassium
cyanide. On Feb 2nd it was a
plume of nitric acid and associated acid vapors.
Potassium cyanide is the other principal chemical
hazard at CPI. Potassium cyanide is a highly toxic solid, which is very
poisonous when ingested or when its vapors are inhaled. The risk to residents
offsite is from hydrogen cyanide gas that is produced when potassium cyanide comes
in contact with any mixture of acids. CPI uses both large amounts of acids and potassium
cyanide in its plating operation. CPI personnel must exercise extreme care and
employ stringent internal safety measures, documented procedures and have
highly trained personnel and controls to prevent an accident. In addition, CPI
must handle and store these chemicals with great care. Yet, even knowing the obvious dangers of
associating the acids with cyanides, an inspection report from the Palo Alto
Fire Department in 2002 contained a recommendation to CPI that they should “Look
into the proper separation of cyanides, acids and bases in the plating room.”[7]
CPI uses nitric acid and potassium cyanide along
with other chemicals in several process steps in their product manufacturing
operation[8].
The acids remove surface contaminations and oxides from metals by chemical
cleaning or etching - dipping the metal pieces into acid baths, called ‘bright
dip.’ These baths contain varying concentrations of nitric, sulfuric, and
hydrochloric acids. After cleaning, some of the metal parts are then coated
(plated) with other metals, such as copper, silver, nickel, or gold - this
dipping them in chemical plating baths, usually assisted by applying electric
current, These plating baths at CPI contain potassium cyanide in solution with
a variety of metal plating salts and other noxious chemical compounds.
In February 2004, CPI filed documents stating they
had a total of 3200 lbs of nitric acid onsite and 402 lbs of potassium cyanide.
In two years, following the reconstruction, CPI reported in their June 2006 an
increase in their inventory of nitric acid by about 30% to 4161 lbs, and
potassium cyanide by 57% to 632 lbs, including a 110 lb drum of solid potassium
cyanide. The tanks holding the hazardous material liquids at CPI are large. The
‘Copper Bright Dip” is a 276 gallon tank that contains a 27% concentration of
nitric acid, and the ‘Electroless Nickel Utility’ is a 81 gallon tank of 67%
concentrated nitric acid. The ‘Silver Plate’ is a 276 gallon tank of a 7%
concentration of potassium cyanide (177 lbs of potassium cyanide in solution) and
the ‘Copper Plate’ is a 73 gallon tank with an 11% concentration of potassium
cyanide.
The possibility of an accident involving these large
amounts of extremely hazardous materials poses a significant risk to the
residents in the surrounding residential area, as well as to other personnel in
the Stanford Research Park.
Oversight of Chemical
Hazards at CPI by the Palo Alto Fire Department
The Palo Alto Fire Department has the primary
oversight responsibility for usage of hazardous materials by companies like
CPI. The city’s Municipal Code Titles 15 and 17 contain requirements that users
of hazardous materials must follow. These regulations include hazardous
materials registration and filing of Hazardous Material Business Plans and
Hazardous Material Inventories with the PAFD. The operators must list all the
hazardous materials and their quantities on their site. It is the PAFD’s
responsibility to review these documents and to monitor and insure the user’s
compliance with all the Hazardous Materials requirements in the Municipal Code.
Furthermore, the PAFD conducts regular inspections
of hazardous materials usage at CPI. State Law requires the inspections every
three years. The last inspection in the PAFD files before the 2005 CPI
reconstruction was in 2002. The PAFD policy is to announce an inspection to CPI
ahead of time. The PAFD says this is
done because of efficiency, so the proper paperwork and personnel are available
to the inspectors when they arrive.
Because of the amounts of extremely hazardous
materials at CPI and the proximity of usage and storage areas to residents, the
offsite consequences of an accident would be significant. It would seem to
follow that the risk to residences would lead to a more stringent oversight of
CPI by the PAFD than of comparable companies whose facilities are further from
residences. However, this is not the
case. At the Barron Park Association sponsored Neighborhood Meeting[9]
Fire Marshal Firth, who is in charge of the Hazardous Materials section, stated
that the PAFD had never considered inspecting CPI any differently or any more frequently
than any other sites in the city (except during its reconstruction when
construction changes in building plans needed to be regularly verified). Only
rarely does the PAFD conduct unannounced inspections of any site, and he said
this was unnecessary for CPI. The Fire Department, also under Fire Marshal
Firth, reviews plans for any building project where hazardous materials would
be used or stored. He also stated that this review does not consider the
proximity of a proposed hazardous materials facility to nearby residences.
Oversight of Chemical
Hazards at CPI by Santa Clara County: Title 19
The Santa Clara County Department of Environmental
Health (DEH) has oversight responsibility in Palo Alto for the California
Accidental Release Prevention program, also
referred to as CalARP or Title 19[10]. This is
California’s implementation of the federal Emergency Planning and Community
Right to Know Act and the Clean Air Act that were passed following the Bhopal
disaster in India. The objective is to have owners and operators of sites where
substantial amounts of hazardous materials are used or stored inform the public
of the risks to them from an accidental release. This legislation and the implementing
regulations apply to sites that use or store any one or more of a list of
extremely hazardous materials in quantities above specific threshold amounts.
The State of California had determined that hazardous materials of these types
and in these quantities could, if accidentally released, cause widespread and
serious harm to the surrounding area. CPI is regulated under Program Level 2 because of its
close proximity to residences and the potential for serious effects of an
accidental release to offsite “receptors” (individuals, schools, hospitals).
CPI
uses and stores two chemicals that exceed the Title 19 thresholds: nitric acid and potassium cyanide (the
chemical reaction of these two creates the toxic gas hydrogen cyanide). Their
inventory of these two chemicals exceeds by about a factor of five the Title 19
threshold limits, which are 1000 lbs of nitric acid and 100 lbs of potassium cyanide.
There
are only two facilities in all of Palo Alto that are subject to the Title 19
program: CPI and the Palo Alto Waste
Water Treatment Plan near the Bay. CPI is the only site that is near a
residential area. There are no sites
subject to Title 19 in Mountain View and about twenty two in all of Santa Clara
County.
Hazardous Materials and the CPI
Reconstruction Project
CPI’s reconstruction included changes to
their plating shop inside Building #2 to accommodate the increase in their
manufacturing capacity. As a consequence, CPI has increased the quantity of
hazardous materials they use. This all happened unbeknownst to residents, without any notification to
anyone in the neighborhood. Many
residents were aware of significant construction activity at CPI during 2005
because of the sounds and noises and construction vehicles, but the city did
not hold a public hearing nor did they send any notifications to residents
before or after building permits were issued. This was a missed opportunity to have
dialogue with the residents, to have the hazardous materials storage and usage
sites moved some distance away from the residential zones and to create a safer
environment for residents leaving adjacent to the CPI facility. This was also a
missed opportunity for the neighbors to be educated about the hazardous
materials near their homes and the safety improvements CPI was required to
implement as part of the reconstruction effort.
There was no notification because, under the current
regulations and planning guidelines, the Planning Department considered CPI’s reconstruction
of Building #2 a ‘minor’ project. This was the case even though the building
permit fees alone were over $100k. The Architectural Review Board process did
not apply because there was little exterior visual change or change to the character
of the structure. Under the Architectural Review Board guidelines, neighbors
are notified and a public hearing held only for major projects in an industrial
zone, such as a new structure or where the exterior is modified in a
significant way, not for a ‘minor’ project even when the industrial site abuts
a residential area and the project involves significant amounts of hazardous
materials.
The Fire Department has taken the position, reiterated
by Fire Marshal Firth[11],
that they have a ‘ministerial’ responsibility in allowing building permits for
use and storage of hazardous materials. They have no discretion; permits must
be issued if hazardous materials are allowed in that zone, regardless of the
amount or the toxicity of hazardous materials and their proximity to residences
provided that the building plans satisfy the Building Codes, the Uniform Fire
Code, and that they are otherwise stored and used according to safety standards
mandated and regulated by the Fire Department.
While
the hazardous materials used by CPI are in a zone where they are permitted,
toxic gas releases from an accident do not obey zoning regulations. Following
discussions with the City staff and hearings by the Planning Commission, a Zoning
Update Ordinance,[12]
referred to a Performance Standards, was approved by the Planning Commission on
November 1, 2006. If approved by the City Council, these will impose
regulations on projects and facilities using Hazardous Materials in Research
Park sites adjacent to residential zones. The provisions of the
Performance Standards that could reduce the risk to residents from an
accidental release of hazardous materials by are in section 18.23.10 (B) (vi).
There are three listed cases, all of which apply to projects that would use or
store hazardous materials above Title 19 threshold limits:
· First, these new regulations would require both new and reconstructed buildings that would handle amounts of hazardous materials above Title 19 threshold limits to be setback at least 300' from residential properties.
· Second, existing structures within 300’ of a residential zone would not be allowed to increase the amount of a hazardous material used or stored above Title 19 threshold limits if the quantity of that material was previously below those limits.
· Third, the use or storage of hazardous materials already above Title 19 threshold limits in existing structures within 300’ of residential zones capped at 25% above amounts in Risk Management Plan in force on November 1, 2006.
Since
CPI is the only facility in this category, with its buildings well within the
300’ setback and using and storing hazardous materials already above Title 19
threshold limits, only CPI would benefit from this last provision. Instead of
allowing a 25% increase, which would increase the risks to residents, the city
should, at the minimum, cap the amounts at current levels.
Specific Requirements of Title 19: Risk Management Plan
Companies subject to these regulations must prepare
and file a Risk Management Plan (RMP) with the Santa Clara County DEH. The Risk Management Plan must contain several
elements, including a listing of the regulated substances, description of the
release prevention program and emergency response program, a hazard assessment and
the most important component for the public - an offsite consequence
analysis.
Offsite Consequence Analysis
The Offsite Consequence Analysis required by the
Title 19 program is very unusual. Instead of being done by the program
regulators, it is the responsibility of the operators of the hazardous
materials sites themselves to identify serious, plausibly realistic accident
scenarios, such as ones that might be caused by natural disasters or the misuse
of materials on their site, and then determine the extent of the hazardous
materials release on the surrounding area.
Thus the operators must analyze their own operation and determine its most
serious vulnerabilities, where the risks of a serious accident are the
greatest. Among the possibilities that CPI considered are hazardous material releases
caused by seismic events, mishandling of storage containers, spillage and
leakage of storage of tanks containing acids and cyanide compounds. Once an
accident scenario is identified, the offsite consequences are computed using
rules or computer programs provided by the EPA[13]. CPI, like other regulated sites, is required to define two serious
accident scenarios that would result in emission and spread of toxic gases, a
‘worst case scenario’ and an ‘alternative case scenario’, and then determine
the ‘endpoint distance’ of the toxic gas cloud in each case. These terms are
defined in the following sections.
What is meant by “the Worst
Case Scenario” and the “Alternative Case Scenario?”
The
“worst case scenario” is what the company believes would be the worst possible
accident involving their chemical or flammable hazardous materials. The effects
of such an accident would spread the furthest and impact the largest number of
people. The EPA guidance for determining the worst case scenarios is “the release of the largest quantity of a regulated
substance from a single vessel or process line failure that results in the
greatest distance … a toxic vapor cloud, heat from a fire, or blast waves from
an explosion will travel before dissipating to the point that serious injuries
from short-term exposures will no longer occur.” 13
The “alternative case scenario” is also a very serious
accident, but the regulatory guidance to the operator says it should be one
that is perhaps more likely to occur. There is another difference between these
two cases. For the worst case scenario, the spill is assumed to be contained
only by passive means, such as dikes, berms, sumps and the like. The toxic
vapors would be released from the spilled chemicals until the pool of liquid itself
evaporates or the concentration of the hazardous chemical remaining in the pool
drops to a low level. This would be the case in the event of a very serious
earthquake on a weekend or evening, where power is lost and trained supervisory
personnel are not able to reach the site of the spill. In the alternative case,
the release of toxic vapors could be reduced by using pumps to send liquids
into sumps, scrubbers and other active means.
It is up to the company to identify the worse case and alternative case
scenarios, and they are legally responsible to do this correctly.
CPI developed worst-case and alternative case accident
scenarios for both nitric acid and potassium cyanide. For potassium cyanide,
the most serious offsite consequences would occur if some amount of it were to
react with acid and produce hydrogen cyanide. This is, in fact, what CPI
assumed would happen with potassium cyanide in their worst case and alternative
case scenarios.
What is the Endpoint Distance?
The
ultimate objective of the offsite consequence analysis is to find how far from
the accident site would the concentration of spreading toxic vapors still
seriously impact the health of the general public. This is called the ‘endpoint
distance,’ “the distance from the
emission site to the point where the airborne concentration of a substance has
fallen below the level at which nearly all individuals could be exposed for up
to one hour without experiencing or developing irreversible or other serious
health effects or symptoms which could impair an individual’s ability to take
protective action.” 13 People living or working closer to the
emission point than this distance should evacuate promptly. People beyond the endpoint
distance may still be affected adversely, but most likely not irreversibly. The
airborne concentration of the toxic vapors at this endpoint distance is called
the ‘toxic endpoint.’
What is the Toxic Endpoint ?
Some
chemicals are more toxic than others. Chemical fumes with more serious toxic
effects will affect people at a greater distance from the emission site; such
chemicals are said to have a lower ‘toxic endpoints.’ The toxic endpoints for many
hazardous materials have been established by various scientific groups and
adopted by the EPA[14]. The values for different chemicals are in
the Title 19 regulations. For nitric acid vapors, the value is .026 mg/L, which
is equivalent to 10 ppm. Chief Nick Marinaro of the PAFD was quoted1 as saying that “the safety threshold for nitric acid fumes is 100 ppm and the
reportable level is 50 ppm.” He may have been referring to very short term occupational
levels, or he may have been misquoted because these levels are much higher than
are permissible by the EPA or the State of California for exposure to the
general population. The 100 ppm of nitric acid had been the level at which
exposure was considered immediately dangerous to life and health, the IDLH
level, by NIOSH, the National Institute for Occupational Safety and Health, until
1994, and it was then reduced to 25 ppm[15].
As those who were exposed on Feb 2nd
know, nitric acid fumes have an acrid, irritating, suffocating, chlorine-like
odor.
The toxic endpoint for hydrogen cyanide is 0.011
mg/L, which is also equivalent to 10 ppm. Hydrogen cyanide has a faint, bitter,
almond-like odor that some people are unable to smell.
Worst Case Scenario for
Nitric Acid
This scenario starts with the rupture of the 250
gallon tank that is full of 67% concentrated nitric acid in the basement of
Building 2 of CPI at 10 AM during a week day. The acid is confined by berms and
most of the spill drains through a sump into an underground pool, 14 square
feet. In this scenario, a total of 0.2 lbs of nitric acid in vapor form is
released into the atmosphere during the first 10 minutes. The concentration of
nitric acid drops over this time period so that little is released after 10
minutes, according to the EPA guidance. The endpoint distance for the spread
of the toxic vapors is 0.2 miles (~1000 feet).
Worst Case Scenario for
Potassium Cyanide
In
this scenario, the 250 gallon tank of copper plating solution spills. This has 177
lbs of potassium cyanide in solution. There are containment berms around the
tank, but 30% of the tank may react with acid that also may have spilled. This
reaction would generate 24 lbs of hydrogen cyanide inside the plating shop. CPI
says that if the ventilation system/ scrubbers fail, the plating shop is
evacuated and sealed. The scenario assumes a release of 13 lbs of hydrogen
cyanides outside. The endpoint distance for the spread of the toxic vapors
is 0.2 miles (~1000 feet), the same as the worst case scenario for nitric
acid.
The following figure, from Google Earth, shows two
circles of 0.2 miles (~1000 feet) radius, one centered on the Acid Waste
Tank-Plating Shop area in CPI’s Building #2 and the other centered on the
Chemical Storage buildings. The figure shows the affected regions as circles
centered on one emission point, but this is just an estimate. The wind conditions on the day of the
accident would distort and change the pattern of the affected region. Nitric
Acid vapors are a dense vapor and would normally sink. Following the Feb 2nd
accident, the nitric acid must have exited the roof vents and fans to make a
worker feel sick on the roof of 710 Chimalus, which is to the left in the
figure along Chimalus Drive of the Building #2.
Nonetheless, with these caveats, a circle is the
best estimate of the affected region resulting from this worst case scenario. They
include parts of Chimalus, Matadero, Josina, Whitsell, some houses on Kendall
and all of Julie Court and Tippawingo in Barron Park. The circle from Building #2
includes parts of the Creekside Inn and approaches El Camino, while the circle
from the Chemical Storage buildings crosses El Camino. Several buildings and
parts of others in the Stanford Industrial Park on Hansen Way are also within
the endpoint distance circle. CPI
estimated that 525 persons offsite would be within the endpoint distance
circle.
Alternative Case Scenario
for Nitric Acid
This scenario starts with a seismic event and the
dumping of a 130 gallon tank of copper bright dip (28% solution of nitric acid)
onto the floor of their plating shop. The spilled liquid would form a pool of
527 sq ft. A total of 0.4 lbs of nitric acid in vapor form would be released. Because
of active mitigation measures, CPI estimates that the endpoint distance
would be less than 0.1 mile.
Alternative Case Scenario
for Potassium Cyanide
This scenario starts with a spill of 110 lbs of
potassium cyanide from a storage drum, and then a reaction of 25% of the
spilled material with acid that may also have spilled due to a seismic event.
The reaction produces hydrogen cyanide gas. The estimate is that a total of 10
lbs of hydrogen cyanide will be released inside the storage building over 10
minutes and 5.5 lbs of hydrogen cyanide released outside. The distance to
the endpoint is 0.1 miles,
Summary Conclusions
- The Feb2nd accident
and toxic gas release at CPI was a “wake up” call. Another industrial
accident at CPI or natural disaster could cause a much more serious toxic
gas release.
- CPI uses and stores
large quantities of extremely hazardous materials, and the facilities on
its site using these hazardous materials are very close to the residential
property line.
- Title 19 is a
California law that applies to sites that use or store any one or more extremely
hazardous materials above specific threshold limits. Accidental releases of these hazardous
materials in these quantities can cause harm to the individuals in the
surrounding area. Title 19 is
administered by the County Department of Environmental Health.
- CPI is one of only two
sites in Palo Alto that are subject to Title 19 regulations, and the only
one that is bordered by a residential zone. Thus, CPI presents the
greatest risk to residents from an accidental release of a hazardous
material of any site in Palo Alto.
- CPI is subject to
Title 19 because it uses and stores large amounts of both nitric acid and
potassium cyanide, each about five times their Title 19 threshold limits. Potassium
cyanide is a hazard to residents offsite because it reacts with acids
creating highly toxic hydrogen cyanide vapors.
- Companies subject to Title
19 must submit a Risk Management Plan. The most critical component of the
Risk Management Plan is the “Offsite Consequence Analysis.” The site operator has the responsibility
of generating several hypothetical but realistic scenarios where hazardous
materials are released, and then determine the consequences.
- The offsite
consequences of the “worst case scenario” release of either nitric acid or
potassium cyanide at CPI extend a distance of 0.2 miles from the release
site.
- The Palo Alto Fire
Department does not consider the proximity of a hazardous material site to
residences when conducting its inspections, when regulating the hazardous
materials on the site or when evaluating new building projects and plans.
- The City does not have
any evacuation plan that could assist residents in case of a serious toxic
gas release from CPI. The City’s disaster notification plan is undergoing
some review, but currently is also inadequate. An evacuation exercise was
held in Barron Park twenty years ago, in 1987, but there has not been any
retraining exercise involving residents since that time.
- The Fire Department
and City Counsel have not released their investigation of the Feb2nd accident
and toxic gas release at CPI.
CPI’s version attributes the accident to human error.
- Until the
investigation is released, CPI will not discuss Hazardous Materials issues
with residents. Residents are unaware of any corrective actions undertaken
by CPI since the accident, of any additional monitoring of toxic gases, or
updated training of their personnel or changes in their Emergency Response
Plans.
- The inspections by the
PAFD of CPI were not able to prevent an accidental release. Accidents are,
by their nature, usually due to unexpected circumstances.
- The only ways to
reduce risks to residents from a hazardous material accident at CPI are to
a) reduce the amounts of hazardous materials and b) move the hazardous
materials further from residential properties.
Recommendations
City Council
The
City Council will review the Zoning Update Ordinance recommendation from the
Planning and Transportation. At the
very minimum, the Council should modify the section that allows CPI to increase
by 25% the amounts of Hazardous Materials they use and store that are
already above Title 19 threshold limits in buildings within the 300’ setback
from residences. Instead they should cap these amounts to the current levels or
mandate a reduction.
City
Council should be pressed to establish larger minimum setbacks from residential
properties for the use of hazardous materials above Title 19 threshold limits
in both new or reconstructed and existing facilities.
The
release of the PAFD investigation of the Feb2nd toxic gas release should be
coordinated with a public meeting to present the conclusions, with PAFD, CPI
and other city officials in attendance.
City
Council and the PAFD should be reminded of the need to establish evacuation
procedures because of the possibility of a disaster from a hazardous materials
release. Disaster preparedness is one the City Council’s top priorities.
CPI
CPI should be encouraged to improve their toxic gas
monitoring detectors (for nitric acid and hydrogen cyanide) beyond what is
required by the PAFD and other regulators. These could be connected to CPI’s
emergency response center or, even better, directly to the PAFD. They should
employ instruments that measure and also capture/record toxic vapor
concentrations continuously, for example using a chart recorder or wireless web
server technology. These instruments should be placed both inside their
building and at various locations at their site periphery.
CPI management should show residents that they will
support any feasible effort to reduce the possibility of an accident, and will
set compliance levels above and beyond any regulatory guidelines. This will
give us assurance that CPI considers our safety as important as their employees'
safety. CPI has a record now of having a chemical spill accident and their
first reaction was to avoid notifying the PAFD.
Palo Alto Fire Department
Residents should encourage the PAFD, through letters
and phone calls to city officials and to the City Council, to increase their
surveillance of hazardous materials use at CPI, and to step up their vigilance
because of the exceptional risk an accident at this site poses to nearby
residents.
PAFD should review CPI’s Emergency Response Plan and
Contingency Plans and require remedies of several serious deficiencies. The
PAFD should also review the training of CPI’s emergency response personnel.[16]