From CPIHazardWatch.org
February 25, 2008
CPI uses and stores two extremely hazardous materials in amounts above the California Accidental Release Prevention (CalARP) program thresholds – nitric acid and potassium cyanide. As a result, they are required to prepare a Risk Management Plan (RMP). The Plan has several sections, including amounts of these hazardous materials, scenarios they consider would lead to the worst case releases of these materials, the offsite consequences of these releases, and a hazard review that identifies the hazards with the processes and procedures that use these materials and serves to identify the risks of accidents by identifying the training, containment systems and other engineering and / or administrative controls.
CPI had previously submitted Risk Management Plans in 2004 and 2006. In 2007, CPI contracted with a new consultant, Steve Maher of Risk Management Professionals, Inc, to prepare a new Risk Management Plan.
The County has recently completed their audit of this document, using an outside consultant to do a third party review. The County objected to some of the contents of the RMP and some of the safety practices and safety systems at CPI. Nicole Pullman, Hazardous Materials Program Manager, has sent a six page letter (CPI audit letter) to CPI with their objections, requiring a written response in 90 days.
The County did not accept a number of the assumptions used by CPI to determine the “Worst Case Release” accident scenarios for both nitric acid and potassium cyanide and the computed toxic endpoint distances following these hypothetical but conceivable accidents. The scenarios used by CPI in the 2007 RMP were quite different from those in their previous RMP. This RMP used much less conservative assumptions, and the distances that were computed were much smaller. The results, shown at the neighborhood meeting in March 2007, did not extend beyond the CPI property line. The County is asking CPI to reconsider and redo these sections of the RMP.
The County also identified several deficiencies of the hazard review section of the RMP. Several of the deficiencies include violations of the Uniform Fire Code, which is the jurisdiction of the Palo Alto Fire Department. The letter from the County was sent to the Fire Department and they concurred with the County’s conclusions.
The RMP also lists the quantities of the hazardous materials above the CalARP threshold. As they have said publicly, CPI has reduced the amounts of these substances since June 2006. However, the amounts are still many times the thresholds. The following table lists the quantities CPI has disclosed in their last three Risk Management Plans.
|
|
CalARP thresholds |
January 2004 |
June 2006 |
June 2007 |
|
Potassium Cyanide (lbs) |
100 |
402 |
632 |
559 |
|
Nitric Acid (lbs) |
1000 |
3201 |
4161 |
3155 |
|
RMP Deficiency |
What CPI Did |
RMP Audit comment |
|
Worst Case Release Scenario for Nitric Acid.
Worst case release is release of the largest quantity from a vessel or pipe failure that results in a specified concentration of toxic materials (10 ppm for nitric acid) spreading to the greatest distance. |
CPI said worst case scenario was due to a leak from 230 gallon tank of nitric acid in the basement. But they used fact that the double wall of the tank (passive containment of the spill) would reduce the amount of the spilled liquid pool. |
They cannot use double wall of tank as passive mitigation to limit the amount of nitric acid released for the worst case scenario.
They also need to look at these possible scenarios as possible worst case: 1. because of proximity of nitric acid delivery to property boundary, examine effect of break of hose connection from hose connection to tanker; 2. release of nitric acid during transfer of 30 gallon keg of nitric acid |
|
RMP Deficiency |
What CPI Did |
RMP Audit comment |
|
Worst Case Release Scenario for Potassium Cyanide.
|
CPI said the worst case is the release is from the largest container, 276 gallon silver plating tank. To determine the distance where concentration of toxic fumes pose a hazard to the public, they used 0.025 mg/l as concentration at the toxic endpoint. |
They must use a lower concentration of cyanide, 0.0025 mg/l, to determine the end point distance. |
|
Alternate Case Release Scenario |
No scenario was presented |
Must submit alternate case release scenario. |
|
RMP Deficiency |
What CPI Did |
RMP Audit comment |
|
Process Hazard Analysis. Process Hazard reviews hazards associated with the regulated substances, processes and procedures. |
CPI used a what/if checklist to evaluate possible process hazards and consequences. |
The what/if checklist fails to take into account the probability/likelihood of process failures and hence the risk associated with process. This is important factor in prioritizing the action to be taken for mitigation. CPI should use the HAZOP method in the future. |
|
RMP Deficiency |
What CPI Did |
RMP Audit comment |
|
Process Hazard Analysis. Considered possible release of 0.8 gallons of nitric acid into the storage shed and consequences to personnel. |
CPI felt goggles and appropriate clothing would be adequate. |
No protection from splash. Add use of respirator during transportation activity. |
|
RMP Deficiency |
What CPI Did |
RMP Audit comment |
|
Process Hazard Analysis. Considered possible release of three 0.8 gallon containers during transportation. |
CPI said this is worst community hazard near storage, but no potential toxic off-site impact. |
Provide supporting document to show that there is no potential toxic off-site consequence. |
|
RMP Deficiency |
What CPI Did |
RMP Audit comment |
|
Process Hazard Analysis. Leak of release of largest potassium cyanide tank in the plating shop and process over flow when adding water to the tanks. |
CPI said they have positive ventilation with the scrubbers. |
Back up power is required for treatment systems and all detection systems. Scrubber failure has not been taken into account. Uniform Fire Code (UFC) Section 8003.1.8 Stand by Power: “When mechanical ventilation, treatment systems, temperature control, alarm, detection or other electrically operated systems are required, such systems shall be connected to a secondary source of power. |
|
RMP Deficiency |
What CPI Did |
RMP Audit comment |
|
Process Hazard Analysis. Release of largest nitric acid tank in plating shop.
|
CPI would consider a manual over ride of the emergency exhaust fan activation during a spill event if personnel are evacuated from the area. |
Unless the emergency ventilation is connected to the scrubber, activation of the exhaust ventilation in case of a spill is contradictory to the Fire Code requirements. This needs to be verified with the Palo Alto Fire Department since CPI personnel stated the activation of the emergency exhaust ventilation was a Fire Department requirement. |
|
RMP Deficiency |
What CPI Did |
RMP Audit comment |
|
Process Hazard Analysis. Potential for localized personnel hazard during transport of dry cyanide chemicals from the storage yard to the plating shop. |
CPI has trained the personnel. |
Training of personnel is inadequate. The transport employee and the technician responsible for plating bath preparation were both unfamiliar with exposure effects of potassium cyanide. Additional training required. Procedure for cartridge replacement shall be reviewed. |
|
RMP Deficiency |
What CPI Did |
RMP Audit comment |
|
Process Hazard Analysis. Seismic event that impacts the plating shop |
CPI has performed seismic design calculations for bracing of tanks and plating baths |
CPI needs to have a qualified professional do a “seismic walk down,” which is a visual verification of the facility seismic compliance including structure, storage tanks, process piping, etc. |
|
RMP Deficiency |
What CPI Did |
RMP Audit comment |
|
Process Hazard Analysis. Truck events associated with the delivery process. |
CPI has a delivery checklist. Hand brake is used to prevent truck movement. |
The delivery process does not require chocking. The delivery procedure should be modified to require chocking of the truck as hand brakes can fail. |
|
RMP Deficiency |
What CPI Did |
RMP Audit comment |
|
Process Hazard Analysis. Open Items identified in Hazard Analysis |
CPI said they were considering: 1. placing timer on the preventative maintenance program; 2. evaluating with Palo Alto Fire Department the merits of installing a HCN sensor and local alarm.
|
Update status of these items
|
The County's audit letter to CPI can be found here: CPI audit letter.