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This document summarizes the accidental release prevention and emergency response policies at Criterion Catalyst Company L.P. (Criterion) that minimize the public's exposure to regulated substances used at the facility. Also presented, is a description of hypothetical worst-case accidental releases of aqueous ammonia (29% maximum concentration) and vanadium pentoxide. Criterion has recently installed additional passive mitigation equipment to verify that no offsite impacts would occur at any public receptor associated with the complete loss of containment of 20,500 gallons from an aqueous ammonia storage tank, or a 400-pound drum of vanadium pentoxide. Passive mitigation equipment was installed around our aqueous ammonia storage tank to minimize the surface area for evaporation during a spill. Criterion qualifies for Program level 1 under the EPA RMP and CalARP regulations. 
Criterion actively participated in Contra Costa County's Community Awareness & Emergency Response (CAER) Group's 
May 12, 1999 RMP public meeting. In this public meeting, Criterion presented our worst-case release scenarios for both aqueous ammonia and vanadium pentoxide associated with the RMP program in advance of the June 21, 1999 RMP submittal date. Criterion has disclosed to the public, news media and the Bay Point Community Advisory Panel our RMP Program level 1 status due to the installation of passive mitigation controls. 
Criterion's aqueous ammonia usage is subject to both EPA's Risk Management Prevention and California's Accidental Release Prevention (CalARP) Program requirements for the development of a Risk Management Plan. Criterion's vanadium pentoxide usage is subject only to CalARP's program requirements for the development of a Risk Management Plan. The Contra Costa County Health Services Department (CCCHSD) CalARP Program requires facilities subject to both Federal and State programs to submit a Risk Management Plan for all covered processes by June 21, 1999. 
Since Criterion is ISO 9002 certified, we have many programs in place that are designed to maintain the safe operation, installation and modification of process equipment at the facility and to minimize errors and accidents. Criterion is committed to being a responsible member of the community by operating in a safe and environmentally sound manner. This commitment is documented in our company's policy on health safety and environmental performance, which are available to all employees. Included in this policy are the following statements: 
"Criterion believes that all occupational illnesses, injuries and environmental incidents are preventable, and their occurrence is unacceptable. Criterion's objective is to continuously improve its health safety and environmental performance and in doing so become recognized as a leader in its industry. Criterion will comply with the intent as well as the letter of all applicable healt 
h safety and environmental laws where it operates, and where it believes those laws and regulations are inadequate, it will establish appropriate and more stringent internal standards." 
Although not subject to OSHA Process Safety Management requirements, Criterion has developed many similar procedures to protect the health and safety of our workers, the public and the environment. The following summarizes the prevention programs that are used within Criterion: 
Management of Change 
Criterion has established procedures for a comprehensive review of all proposed process changes, other than replacement-in-kind. Each proposed project must be evaluated by the appropriate department managers (e.g., technical, operations, maintenance, safety and environmental). Written documentation of department approvals, hazard evaluation, changes in P&IDs and operating procedures are maintained.  
Pre-Startup Safety Review 
Criterion requires that new or modified equipment meet all design requirements 
prior to operation. This review includes updating P&IDs, employee/contractor training, documenting operating/maintenance/safety/emergency procedures, environmental permits, information on chemicals (MSDS), and information on technology/equipment. 
All contractors are required to complete training on the hazards and emergency response activities at the facility prior to starting work. Contractor activities are monitored to verify safe work practices and appropriate training.  
Hot Work Permits 
Criterion requires the issuance of hot work permits. Each permit identifies the work to be performed, equipment involved, dates and fire prevention measures. Copies of all permits are maintained. 
Initial training is given to employees at the time of hire. Subsequent training is given when there has been a change to the aqueous ammonia or any other system. On-the-job-training qualification is required for each operator, including an annual review of the aqueous ammonia MSD 
S. Since vanadium pentoxide is used on an infrequent basis, refresher training is conducted prior to each production run involving the material. 
Incident Investigation 
Every accident or near miss incident is investigated to determine the underlying cause(s). Root cause analysis (RCA) is the method used in Criterion for analyzing and evaluating incidents. Each incident is documented in writing along with recommendations to prevent reoccurrence. Recommendations are acted on as soon as practical. All records are maintained. 
Process Safety Information 
Criterion maintains copies of all Material Safety Data Sheets (MSDS) for all raw materials and substances used at the facility. The maximum inventory and largest container sizes for all regulated substances are maintained. MSDS and inventory data is updated as necessary. MSDS and inventory information (i.e., Business Plan) are maintained in binders in several locations around the facility.  
Process Hazard Review 
As part of the Managemen 
t of Change procedures at the facility, every project is evaluated for the appropriateness of a hazard review. Safety and operating hazards are evaluated at Criterion for new or modified equipment using the "What If" technique. Appropriate personnel involved with the equipment operation, maintenance and safety participate in the hazard review. The review is designed to identify the hazards of the process, possible equipment failures and safeguards to prevent failures or errors. Results of the hazard review along with any design changes are incorporated into the project. 
Operating Procedures 
Written procedures for aqueous ammonia and other bulk liquids are located in the H2 Plant Operating Procedure Manual. Procedures include off-loading and tank line-up for service. The Criterion Catalyst Company, including Pittsburg, is ISO 9002 certified through the year 2002. 
Criterion has a preventive maintenance/inspection program established for process equipment and tanks. Ult 
rasonic thickness (UT) testing is conducted on our aqueous ammonia tank. Criterion's maintenance department conducts preventive maintenance to assure mechanical integrity of the aqueous ammonia tank & associated pumps.  
Compliance Audits 
Third-party compliance audits are conducted jointly by Criterion's parents every three years to assure HS&E compliance. HS&E compliance issues are documented and require prompt follow up with action plans to prevent reoccurrence. 
Emergency Procedures 
Criterion Catalyst has established emergency procedures in the event of an accidental release and/or injury that may pose an impact to the community. These procedures are included in the Hazardous Material Business Plan (HMMP). Emergency response activities are coordinated with Contra Costa Fire located two blocks from the facility. 
Criterion's Pittsburg facility manufactures a variety of catalysts for the oil and styrene manufacturing industries. Products manufactured ar 
e dry solids, containing alumina oxide, iron oxide, and other metals. The primary products are hydrotreating catalyst, an aluminum oxide based catalyst for petroleum refineries, and dehydrogenation catalyst, an iron oxide based catalyst for the manufacturing of styrene. Two regulated compounds are used above threshold quantities associated with EPA's Risk Management Prevention and California's Accidental Release Prevention (RMP/CalARP) Programs, aqueous ammonia and vanadium pentoxide.  
1.3.1 Aqueous Ammonia Process 
Criterion has one 21,300-gallon aqueous ammonia storage tank. Due to administrative controls, the tank is limited to 20,500-gallons maximum capacity. The aqueous ammonia has a maximum concentration of 29% ammonia and the solution is stored at ambient conditions. The solution is used in two types of operations: 1) pumped as a liquid into mixing equipment or blending tanks; and 2) for use in air pollution control equipment. 
Criterion uses 
aqueous ammonia as a raw material during the manufacture of hydrotreating catalyst. Generally, the manufacture of hydrotreating catalysts is a two-step process: 1) the raw materials are mixed in a tank, the intermediate product is extruded, dried initially in an oven then in a kiln. This intermediate is used in step 2): the intermediate is impregnated with a metal salt solution and kiln dried again, pelletized, then finally packaged. Liquid aqueous ammonia is pumped into mixing tanks during both step 1 and step 2 portions of the hydrotreating catalyst manufacturing process. 
Criterion also uses aqueous ammonia to reduce air emissions in selective catalytic reduction (SCR) air pollution abatement equipment. Criterion operates two SCR systems to reduce emission of nitrogen oxides (NOx). In these operations, aqueous ammonia is introduced into a process gas stream to convert NOx into nitrogen and water before being exhausted into the atmosphere. Liquid aqueous ammonia is pumped to an ammo 
nia skid at each SCR, filtered, and then vaporized prior to being injected into the process gas stream. The ammonia is consumed in the process.  
1.3.2 Vanadium Pentoxide Process 
Criterion uses vanadium pentoxide on an infrequent basis, which depending on customer orders, could be years between manufacturing runs. Criterion does not maintain an inventory of vanadium pentoxide onsite. The material is only ordered and maintained onsite in preparation for production of appropriate specialty catalyst. 
Criterion receives 55-gallon drums filled with 400 pounds of pure vanadium pentoxide. The drums are off-loaded by forklift from delivery trucks and warehoused until needed. Drums are transported by forklift to the O5 Plant where they are repackaged into 1,500-pound stainless steel totes. The totes remain inside the building until used. The vanadium pentoxide is pneumatically transported from the totes in a closed system to mixing equipment where it is blended with water and other solids. Sm 
all amounts of vanadium pentoxide are used in the manufacture of specialty dehydrogenation catalyst.  
Criterion conducted an offsite consequence analysis, using the EPA's RMP Offsite Consequence Analysis Guidance, and computer dispersion modeling to estimate impacts of potential worst-case scenarios (WCS) from our aqueous ammonia and vanadium pentoxide processes. Both compounds are listed as toxic materials under CalARP regulations. The scenario that resulted in the largest quantity released and which resulted in airborne concentrations traveling the furthest from point of origin was the failure of the aqueous ammonia storage tank. 
The WCS associated with toxic substances at Criterion is the catastrophic failure of the aqueous ammonia storage tank resulting in the release of 20,500 gallons of 29% concentrated aqueous ammonia solution over a 10-minute period. In reality, this event is extremely unlikely since Criterion has many control measures in 
place that would prevent this type of event. Because the aqueous ammonia storage tank is located inside a concrete containment area, any release would be contained within the 800 ft2 diked area. In addition, the containment area is filled with small polypropylene balls that would float on top of the liquid surface, reducing the exposed surface area for evaporation by 90%, and resulting in an effective surface area for evaporation of 80 ft2.   
According to EPA's RMP Offsite Consequence Analysis Guidance, using urban conditions and default values for 30% aqueous ammonia solution, the maximum distance to the toxic endpoint of 0.14 mg/L (200 ppm, ERPG-2 for ammonia) for the WCS is 0.06 miles (320 feet). This distance from the aqueous ammonia storage tank is within the property boundary. There are no public receptors within 320 feet of the tank and the facility has not had an aqueous ammonia release meeting the accident history criteria for five years. Therefore, Criterion's Pittsburg fac 
ility qualifies for Program level 1 under the EPA RMP and CalARP regulations. 
Criterion management realizes the importance of establishing administrative and technological safeguards to ensure the safety of workers and the continued safety of public receptors. Those recommendations that are planned for implementation are described in Section 1.8, Planned Changes to Improve Safety. The safeguards shown in Tables 1 and 2 include both administrative and technological safeguards that prevent, detect, or mitigate releases of aqueous ammonia and vanadium pentoxide, respectively. 
Table 1  
Chemical-Specific Prevention Steps for Aqueous Ammonia Criterion Catalyst Company L.P., Pittsburg Plant 
1. In August 1994, the original aqueous ammonia storage tank was replaced with one built to the appropriate design codes, including: API Standard 650 and Uniform Fire Code Section 80.301(1)4. Ensures structural 
integrity of the vessel and provides adequate secondary containment surrounding the storage tank. 
2. In August 1994, the location of the aqueous ammonia storage was changed to minimize exposure to public receptors. Storage relocated from near facility fenceline and administration buildings to near the center of the facility closer to industrial operations. 
3. In August 1994, a new aqueous ammonia delivery truck unloading station was installed with adequate secondary containment. Ensures that aqueous ammonia spills associated with delivery truck unloading operations are contained. 
4. In September 1994, the aqueous ammonia storage tank was fitted with pressure safety and vacuum-breaker valves. These valves are designed to protect the storage tank against over or under pressurization during tank filling, emptying or temperature changes. 
5. In September 1994, an automatic shutoff pressure switch was installed on the pump used for delivery truck unloading to the tank. The pressure switch w 
ill stop the filling of the storage tank to prevent over pressurization. 
6. In September 1994, a high level switch was installed on the storage tank. The switch will illuminate an alarm light and stop the filling of the storage tank to prevent tank from being overfilled. 
7. In September 1994, an alarm and pump shutoff system was installed to detect a diaphragm failure on the aqueous ammonia pump used to transfer solution to process equipment. The pump would stop and an audible alarm would sound to alert plant personnel of the pump failure. 
8. In September 1994, written operating procedures were developed for proper aqueous ammonia loading and startup. Written procedures document safe operating practices. 
9. In September 1994, training procedures developed for proper aqueous ammonia loading and startup. Training procedures ensure safe operating practices. 
10. In August 1995, the maximum fill level alarm setting was adjusted to limit volume in tank to 20,500 gallons and install pressure  
relief valve on transfer pipeline, relieving back to the storage tank. High level alarm ensures adequate time to stop tank loading so not overfilled. Pressure relief valve eliminates excessive pipeline pressure due to thermal expansion of liquid when pipeline not in use. 
11. In June 1997, outdoor pipeline transferring aqueous ammonia to process equipment is insulated. Insulation minimizes solution over heating in the pipeline to prevent flashing in reaction equipment and minimize the buildup of pressure in the line. 
12. In January 1997, established Ultrasonic Thickness testing program on storage tank to track changes over time. Testing program designed to detect for evidence of corrosion or physical damage. 
13. In June 1999, concrete containment area surrounding storage tank reduced in size and partially filled with small plastic balls designed to float on top of any spilled aqueous ammonia solution. Passive mitigation measures will reduce the surface area for evaporation in the event  
of an aqueous ammonia spill, minimizing impacts to public receptors. 
14. In June 1999, installed a berm between the aqueous ammonia pipeline and the northern fenceline. Will prevent any release of aqueous ammonia due to a pipeline failure from flowing towards the property fenceline. 
Table 2  
Chemical-Specific Prevention Steps for Vanadium Pentoxide Criterion Catalyst Company L.P., Pittsburg Plant 
1. In November 1994, a closed-loop powder batching operation was built to appropriate manufacturing design codes to eliminate operator lifting of raw material bags. Reduces operator fatigue, ensures structural integrity of the system and minimizes air emissions from powder handling operations. 
2. In November 1994, written operating procedures developed for proper loading and startup of powder batching equipment that uses vanadium pentoxide. Written procedures document safe operating practices. 
3. In November 1994, training procedures developed for proper operation of powder batching equipmen 
t that uses vanadium pentoxide. Training procedures ensure safe operating practices. 
4. In November 1994, alarm systems installed to detect equipment malfunctions. Audible and visual alarms would alert operator to location of malfunction. 
Criterion has not had any accidental releases from the aqueous ammonia or vanadium pentoxide systems that resulted in deaths, injuries, or significant property damage onsite, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. Criterion reviewed incident investigations from January 1994. This five-year accident history review satisfies the requirements of Section 2750.9 of the CalARP regulation. The purpose of conducting an accidental release review is to promote an informed community while also documenting that accidental releases are investigated and concrete changes are made to protect against reoccurrence. 
Criterion has established procedures to inves 
tigate accidents and recommend changes to operations to minimize the likelihood that a similar accident would occur again. Although not required under Program level 1 of the CalARP regulations, Criterion has voluntarily adopted many of the procedural requirements required for a level 3 facility. These procedural requirements are highlighted under Section 1.1, Accidental Release Prevention and Emergency Response Policies at Criterion.  
Criterion's emergency response program was developed to comply with Title 19 of California Code of Regulations (T19 CCR'2731, AB2185 Business Plan) and emergency action plan requirements under Title 8 of California Code of Regulations (T8 CCR'3220, HAZWOPER standard). Criterion has coordinated our emergency response plans with local officials and satisfies the requirements of Section 2765.1(b) of the CalARP regulation.  
We developed the emergency response program to minimize the effects of accidental releases of haza 
rdous compounds to employees. Computer dispersion modeling, along with using the EPA's RMP Offsite Consequence Analysis Guidance document, have demonstrated that worst-case releases of aqueous ammonia or vanadium pentoxide would not impact any public receptor. Except for very small spills, Criterion will not to respond to releases of aqueous ammonia and vanadium pentoxide. Emergency response involving aqueous ammonia and/or vanadium pentoxide are coordinated with local fire department and Contra Costa County personnel. For very small spills, Criterion personnel use proper personal safety equipment as required by the material's MSDS. 
Our emergency action plan contains detailed procedures that outline how we respond to spills, injuries, fires, other emergencies, and how training, evacuation, notification and reporting is performed. Criterion's emergency action plan includes a notification matrix that lists the telephone numbers of agencies and individuals that are to be contacted in the 
event of an emergency situation (e.g., fire, hazardous material spill, injury). The agencies and individuals to be contacted include emergency responders (e.g., Fire Department), internal plant contacts (e.g., Plant Manager), and to satisfy public notification and regulatory reporting requirements (e.g., CCCHSD). "Emergency Response Notification Forms" are completed when notifying an agency and document when the telephone calls were placed and the name and position of the person contacted. All completed notification forms are maintained. 
The Fire Department conducts annual walk-throughs of Criterion's processes and periodic fire extinguisher training. Criterion has discussed the details of hazardous materials maintained onsite and mitigating measures available with the Fire Department and CCCHSD. The emergency response program is reviewed annually to ensure that it remains accurate and current. Employees are trained on the emergency response program when initially hired, after change 
s to the emergency response plan, and when employees' responsibilities are changed. Facility personnel are trained on safety issues and appropriate material handling procedures.  
Criterion is continually evaluating potential improvements to worker safety which could minimize a potential release of a hazardous material. Recommendations for improvement routinely come from safety meetings, equipment inspections, technology improvements and employee suggestions. Table 3 describes action items that Criterion is evaluating for additional improvements in worker safety. 
Table 3  
Planned Changes to Improve Safety Criterion Catalyst Company L.P., Pittsburg Plant 
1. Consider installing a low-pressure shutoff switch on the aqueous ammonia pump. The shutoff switch would automatically shut down the pump if an aqueous ammonia pipeline ruptures. Completion date undetermined. 
2. Consider removing the non-utilized aqueous ammonia pipe stub where the original am 
monia tank used to be. Removal of the stub and associated line would prevent a release if stub was accidentally damaged or opened. Completion date undetermined. 
3. Consider removing a flexible tubing pipe connection on vanadium pentoxide handling equipment and replacing tubing with a rigid pipe. A rigid pipe would decrease the likelihood that a piping failure would occur, decreasing the chances of an accidental release inside the building. Completion date undetermined.
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