Mancuso Chemicals Limited
Environmental Emergency Plan
5725 Progress Street
Niagara Falls, Ontario
Canada, L2G 0C1
February 2019
THIS IS A CONTROLLED DOCUMENT
REVISION 4 – February 2019
MANCUSO CHEMICALS LIMITED - ENVIRONMENTAL EMERGENCY PLAN
SIGNED_______________________
Shari Rankin, Project Manager
Section 1.0 Purpose, Scope, Facility Description, Environmental Policy and AODA
1.1
Purpose _______________________________________________________________________________ 4
1.2
Scope_________________________________________________________________________________ 4
1.3
Facility Description _____________________________________________________________________ 5
1.4
Environmental Policy ____________________________________________________________________ 7
1.5
Accessibility for Ontarians with Disabilities _________________________________________________ 10
Section 2.0 When to call 911, Command Structure, Communications, and
Community Notification
2.1
Calling 911 for a Medical Emergency ______________________________________________________ 12
2.2
Incident Management Team, Organization _________________________________________________ 12
2.3
Incident Management Team, Role Holders _________________________________________________ 13
2.4
Incident Command Centre ______________________________________________________________ 14
2.5
Chain of Command ____________________________________________________________________ 14
2.6
Notification of Government Agencies and Vital Services ______________________________________ 15
2.7
Surrounding Community Evacuation Order _________________________________________________ 16
Section 3.0 Roles and Response Organization
3.1
Command Section _____________________________________________________________________ 18
3.2
Operations Section ____________________________________________________________________ 20
3.3
General Instructions for All Mancuso Chemicals Personnel ____________________________________ 22
Section 4.0 Emergency Classification and Specific Emergency Scenarios
4.1
Fires and Smoke _______________________________________________________________________ 24
4.2
Hazardous Materials Incident ____________________________________________________________ 25
4.3
Multiple Serious Injury/Fatality Accidents __________________________________________________ 26
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MANCUSO CHEMICALS LIMITED - ENVIRONMENTAL EMERGENCY PLAN
4.4
Bomb Threat __________________________________________________________________________ 27
4.5
Crimes of Violence and Terrorism ________________________________________________________ 29
4.6
Severe Weather and Power Outages ______________________________________________________ 29
Section 5.0 Emergency Response Equipment
5.1
First Aid Equipment ____________________________________________________________________ 31
5.2
Decontamination Equipment ____________________________________________________________ 31
5.3
Mancuso Emergency Response Team Equipment ____________________________________________ 32
APPENDIX
Environmental Emergency Assessments (E2 Chemicals)
ENVIRONMENTAL EMERGENCY ASSESSMENT FOR HYDROFLUORIC ACID (49%) __________________________ 34
ENVIRONMENTAL EMERGENCY ASSESSMENT FOR HYDROCHLORIC ACID (31%) __________________________ 38
ENVIRONMENTAL EMERGENCY ASSESSMENT FOR PHENOL ___________________________________________ 43
ENVIRONMENTAL EMERGENCY ASSESSMENT FOR OLEUM (30% SO3) ___________________________________ 47
Evacuation Map ______________________________________________________________________________ 55
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MANCUSO CHEMICALS LIMITED - ENVIRONMENTAL EMERGENCY PLAN
Section 1.0
Purpose, Scope, Facility Description,
Environmental Policy and AODA
1.1
Purpose
1.2
Scope
1.3
Facility Description
1.4
Environmental Policy
1.5
Accessibility for Ontarians with Disabilities
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MANCUSO CHEMICALS LIMITED - ENVIRONMENTAL EMERGENCY PLAN
1.1
Purpose
The purpose of the Mancuso Chemicals Environmental Emergency Plan is to provide for a safe,
timely, effective and coordinated response by employees in concert with other responders and
the community.
1.2
Scope
The plan focuses on response organization and critical functions to manage a range of
hazardous material incidents. These incidents can include a spill, discharge or emission that
adversely affects air, land or water. Contamination of private or public property might result in
harm to public health, as well as natural and economic resources. The plan will also cover
procedures to be followed in the event of a medical emergency, fire, bomb threat, crime of
violence or terrorism, or inclement weather.
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MANCUSO CHEMICALS LIMITED - ENVIRONMENTAL EMERGENCY PLAN
1.3
Facility Description
Mancuso Chemicals Limited, based in Niagara Falls Ontario, Canada, is a worldwide supplier of
Foundry Resins, Chemicals and Consumables, Tin and Steel Mill Chemicals, Polyester, Alkyd
Resins for the Coatings Industries, and Automotive Fluids. The company operates 5 days per
week 24 hours per day. The facility consists of:
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Administrative office which also provides the main Emergency response center.
R&D building housing six laboratories with six fume hoods, a lunch room, and a
Production warehouse where drumming and packaging operations are carried out. The
warehouse portion of the building is explosion rated with appropriate Class I, Div. II,
rated equipment
Hot Oil heater (9 MMbtu/hour) and oil pump rooms providing hot thermal oil heating to
production equipment. Hot oil volume pumped through the facility is 3200 kg of Calflo
AF oil
Two diked tank farms. The southern tank farm primarily holds finished goods (resins),
heated phenol storage, MDI storage, several mixing tanks and a bulk tank truck loading
station. The northern tank farm holds storage for raw materials such as solvents
(mineral spirits, toluene, methanol, xylene, propylene glycol, linseed oil and furfuryl
alcohol)
Reactor room (explosion-proof rated) housing eight production kettles and a mixing
tank: three foundry kettles used to produce phenolic and furan resins, three kettles
that produce industrial acids (toluene/phenol/xylene sulfonic acids) and a mixing tank
for the acids and two kettles used to produce alkyd resins. Associated equipment
includes mixing tanks, gas scrubbers, vacuum pumps, material transfer pumps. Attached
outside to the reactor room is a heated storage/pumping facility for Oleum and several
peripheral tanks used to collect by-product materials generated during the resin cooking
processes.
Maintenance shop containing power/welding equipment.
Loading “tent” facility which houses packaged materials being staged for shipping as
well as two loading docks.
5635 Progress Street; three buildings for indoor storage of raw materials, finished good
and packaging. An area for mixing automotive fluids with three tanks for storage and
mixing. A reverse osmosis purification system with a water storage tank. A changeroom
and offices.
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MANCUSO CHEMICALS LIMITED - ENVIRONMENTAL EMERGENCY PLAN
The Facility is located on land that is zoned Industrial. The land use immediately surrounding
the Facility is zoned Prestige Industrial, General Industrial, Light Industrial and Open Space.
There is considerable distance between the facility and residential areas.
Four Schedule 1, Part 2, E2 substances are stored on site and used in our production processes:
1.
2.
3.
4.
Oleum, UN 1831, Fuming Sulfuric Acid, Class 8(6.1), PG I (Bulk Storage)
Phenol, UN 2312, Molten, Class 6.1, PG II (Bulk Storage)
Hydrochloric Acid (31%), UN 1789, Class 8(9.2), (Man-Hib Bulk Storage and IBC)
Hydrofluoric Acid (49%), UN 1790, Class 8(6.1)(9.2), (Plastic Drums)
Separate Emergency Plans and Risk Assessments are appended to this document.
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1.4
Environmental Policy
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1.5
Accessibility for Ontarians with Disabilities
Mancuso Chemicals is dedicated to ensuring the Health and Safety of all of our employees,
volunteers, visitors, customers and guests. As such, we will provide our Environmental
Emergency Plan in a format that takes into consideration individual needs.
It is critical that all of our employees, volunteers, visitors, customers and guests know and
understand our Emergency Response Plan. If the information provided to you is unclear or is in
a format that prevents you from fully knowing and understanding our process, please contact
the following person as soon as possible:
Office Administrator:
Telephone:
Email:
In person:
Ashley Perri
905-357-3626
aperri@mancusochemicals.com
At Main Office
Mancuso Chemicals will work with the individual, as soon as practicable, to identify solutions
and options that take into consideration their needs. Alternative options include, but are not
limited to:
•
•
•
•
Enlarged text
Braille format
Communication support either in person or over the phone
Documents provided via email.
If requested, and upon approval by the individual, the Environmental Emergency and Fire
Evacuation Plan shall be shared with the person designated to provide assistance to the
individual.
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Section 2.0
When to call 911, Command Structure, Communications, and
Community Notification
2.1
Calling 911 for a Medical Emergency
2.2
Incident Management Team, Organization
2.3
Incident Management Team, Role Holders
2.4
Incident Command Centre
2.5
Chain of Command
2.6
Notification of Government Agencies and Vital Services
2.7
Surrounding Community Evacuation Order
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2.1
Calling 911 for a Medical Emergency
When you dial 911, the Operator will ask you what emergency service you require. In
this case the response would be Ambulance. You will be connected to the Ambulance
Dispatcher who will ask you a series of questions. The person making the call should be
prepared to:
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2.2
Identify themselves
Identify their location address and phone number
Describe the type of emergency
Provide information regarding the condition of the patient
If no chemical exposure: STATE CLEARLY NO CHEMICAL EXPOSURE
Do not hang up until the Dispatcher says to
Report back to co-worker or first aider who told you to call
If additional information of assistance develops, make another call to 911
Ensure a knowledgeable person meets the ambulance at the gates
Incident Management Team, Organization
The flowchart below depicts the Incident Management Team organization once the
Environmental Emergency Plan is activated:
Incident Commander
Information
Officer
Documentation
Officer
Assembly
Area Officer
Off-Site Traffic
& Safety
Officer
Operations
Chief
Emergency
Response
Team
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2.3
Incident Management Team, Role Holders
The following chart below lists selected Mancuso Chemicals Ltd. personnel and their assigned
roles within the Incident Management Team:
Role
Mancuso Chemicals Ltd. personnel
Incident Commander
Plant Manager
Information Officer
Development Manager
Documentation Officer
Project Manager
Assembly Area Officer
Administrative Assistant; Finance Manager
Off-Site Traffic & Safety Officer
Quality Control Manager; Technician
Operations Chief
Production Manager
Emergency Response Team
Production Operator (up to 5 personnel)
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2.4
Incident Command Centre
When the Environmental Emergency Plan is activated:
1. All personnel except Mancuso Emergency Response Team Members will report
to the front gate. Emergency Team Members report to the emergency response
room in the trailer on the far west of the property.
2. The Assembly Area Officer will account for all personnel.
3. The Incident Commander will confirm a safe location to set up the Incident
Command Centre. Unless otherwise specified this safe location will be in the
Main Office.
4. Personnel will then assume their assigned role.
The Main Office Incident Command Centre includes the following information:
1. Environmental Emergency Plan Documentation
2. Large facility maps, interactive for use by responders and the Incident
Commander for coordination with the Operations Chief
3. Checklists for efficient execution of emergency response roles
4. Computerized access to facility Safety Data Sheets
5. First-Aid Kit
2.5
Chain of Command
In the event of Incident Commander’s absence another Incident Management Team
member will assume the role. The “new” Deputy Incident Commander will delegate their
duties. The Incident Commander will wear a “Lime” coloured vest. The following chain of
command will be followed in the event of Incident Commander absence:
Incident Commander
Information Officer
Documentation Officer
Operations Chief
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2.6
Notification of Government Agencies and Vital Services
The following agencies are notified depending on the nature of emergency:
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Fire / Police/ Ambulance 911
Ministry of Labour – critical injury or fatality
Ministry of the Environment – chemical spill or release
Regional Municipality of Niagara – release to storm or sanitary sewers
Workplace Safety and Insurance Board – lost time injury or illness
Emergency Contact List:
Contact
Ambulance
Fire Department
Emergency
Non-emergency
911
911
1-866-895-6227
905-356-1321
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Police Department
Poison Information Centre
Ministry of Environment – Spills Action Centre
Ministry of Environment
Niagara Health System (Niagara Hospitals)
Ministry of Labour
Niagara Peninsula Energy (Hydro)
Ontario Hydro
Enbridge (Natural Gas)
Transport Canada
Terrapure Emergency Response – Primary
Responder
First Response Environmental – Backup Responder
City of Niagara Falls
Regional Municipality of Niagara
Workplace Safety and Insurance Board (WSIB)
Ensign Electronic Alarm Systems
911
1-800-268-9017
1-800-268-6060
Ext 22118 Deputy Fire Chief
Ext 2200 for setting up
practice drills- switchboard
905-688-4111
905-704-3916
905-378-4647
1-877-202-0008
905-356-2681
1-800-567-7455
1-800-434-1235
1-866-763-5427
1-800-268-4686
1-888-737-2911
1-866-774-5501
905-688-1571
905-356-7521
1-800-263-7215
1-800-663-6639
905-358-5739
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2.7 Surrounding Community Evacuation Order
The Incident Commander will give an Evacuation Order to evacuate surrounding areas
and businesses after careful consideration of all the factors involved, and with life safety being
paramount.
When possible, the Incident Commander will consult with emergency responders before
the Evacuation Order is given. In an extreme situation where emergency responders are not
available the Evacuation Team will do the notifying using office phones, wireless phones and in
person. Below is a list of surrounding community contacts:
Community Contact List:
Community Contact
Address
Phone
5805 Progress Street
5835 Progress Street
5869 Progress Street
905-374-5227
905-356-2574
905-374-0033
West Side
Niagara Analytical
Progressive Mechanics Ltd
Can Mar Mfg. Inc.
East Side
Gilson’s Auto Repair
8407 Stanley Ave 9 & 10
South Side
Food Roll Sales
Factor Forms
8464 Earl Thomas
8481 Earl Thomas
905-358-5747
905-358-0699
North Side
Residential Homes approximately 0.8 kilometers to the north-west on Ramsey Street.
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Section 3.0
Roles and Response Organization
3.1
Command Section (Green)
3.2
Operations Section (Yellow)
3.3
General Instructions for All Mancuso Chemicals Personnel
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3.1
Command Section
Incident Commander
Information Officer
Documentation
Officer
Assembly Area Officer
Off-Site Traffic
Control & Safety
Officer
Incident Commander
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Role Holder – Plant Manager
Represents Mancuso Chemicals Limited site response
Coordinates with Company Officers and Directors
Gives instructions to the Operations Section Chief
Activates elements of the Incident Command System and this plan
Works according to risk management principles to protect people, property and the
environment
Ensures and undertakes briefings and planning meetings with the Incident Management
Team
Reviews, augments and/or approves the response strategy and incident action plans
Authorizes release of information to news media
Participates in media and public forums
Integrates decisions and actions with other agencies
Approves the ordering and use of response equipment, contractors and hired personnel
Monitors and evaluates the overall performance of responsible parties
Invokes an information centre with regular status reports, if required
Initiates measures for personnel and equipment security
Communicates directly to Government officials
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Information Officer
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Role Holder – Development Manager
Acts as a consultant to the Incident Commander by virtue of knowledge
Provides technical data regarding Mancuso Chemical’s raw materials and products to the
Incident Commander upon request
Delegates duties and assumes the role of Deputy Incident Commander in event of
Incident Commander’s absence
Documentation Officer
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Role Holder – Project Manager
Records all command / management decisions and directions in log book
Logs communications, incident reports, injury claims and situation status reports
Maintains a documentation system which will include photographic and video records
Follows the “chain of command” and supports the Deputy Incident Commander in event
of Incident Commander absence
The Documentation Officer may delegate certain required duties to an assistant who
aids in the maintenance of minute to minute logs, photographic and video records
Assembly Area Officer
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Role Holder – Administrative Assistant; Finance Manager
Obtains or requests “visitor sign-in” and “punch card” information from the main office
lobby and Warehouse time clock area
Accounts for presence of all visitors and contractors on Mancuso Chemical’s property
Accounts for all Mancuso personnel by conducting head count
Reports head count information to the Incident Commander
Documents and coordinates the release of trucks on Mancuso Chemical’s property
Off – Site Traffic Control and Safety Officer
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Role Holder – Quality Control Manager; Quality Control Technician
Controls the East Gate and roadway in front of Mancuso Chemicals
Identifies hazards and unsafe situations that need to be addressed
Controls off-site traffic protecting the safety of the public and Mancuso personnel
Ensures emergency responders, fire and ambulance services and all supporting
equipment have clear access to the West Gate of the facility
Ensures all off-site unsafe practices and injuries are reported to the Incident
Commander
May delegate certain required duties to an assistant
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3.2
Operations Section
Operations Chief
Emergency Response Team
Operations Chief
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Reports a head count of Emergency Response Team Members to the Incident
Commander
Undertakes initial hazardous material assessment to determine hazardous material
control zones and personal protective equipment required
Establishes communications with the Incident Commander and Mancuso Emergency
Response Team
Recommends, based on initial site assessment, courses-of-action regarding
public/commercial business evacuation or stay in place activities, to the Incident
Commander
Directs immediate rescue operations in contaminated areas using a matching site plot
plan to the Incident Commander and Mancuso Emergency Response Team
Records and controls the movement of contaminated personnel and equipment to the
Decontamination Team
Authorizes the deployment of the Mancuso Emergency Response Team
Tracks the movement of the Mancuso Emergency Response Team within designated
entry, control areas and routes
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Mancuso Emergency Response Team
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Consults SDS for initial hazardous material assessment to determine control zones and
personal protective equipment requirements
Conducts rescue operations in contaminated areas
Recommends, based on initial site assessment courses-of-action regarding local
public/commercial business evacuation or stay in place
Oversees the placement of barriers and warning signage for zone delineation
Controls the movement of contaminated people to the Warm Zone
Maintains adequate communications among all hazmat responders
Alerts responders and supporting agencies of unsafe situations or practices
Assists with the removal and disposal of collected hazardous material wastes (spill
material, soil, water, equipment, etc.) obtained from the Hot and Warm Zones.
Conducts final assessments to ensure area is safe
Decontamination:
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Maintains West Gate security and the transfer of people through the gate
Sets up the Decontamination Station and Warm Zone for the Mancuso Emergency
Response Team and any casualties at the West Gate
Undertakes decontamination of all casualties, response personnel and equipment in the
Warm Zone
First Aid support:
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Undertakes First Aid tactical operations within the Warm Zone and the Cold Zone as
directed by the Operations Chief
Sets up a First Aid Station and Emergency Responder prep area to treat casualties
Coordinates movement of contaminated personnel to emergency responders
Maintains records of employees and responders exposed to hazardous materials
Evacuation Team:
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Follows direction from the Operations Chief to address evacuation matters
Undertakes public and local business evacuation when authorized by the Incident
Commander
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3.3
General Instructions for All Mancuso Chemicals Personnel
General Instructions
Safety is the responsibility of all Mancuso Chemical’s
Personnel to apply and to monitor.
When the Environmental Emergency Plan is activated:
STOP. FOCUS. Be Aware of surroundings.
 Safely cease all activities – this includes emergency reactor shutdown
procedures
 All drivers, visitors and contractors report to the Front Gate Assembly Area
 Assist co-workers only if it safe to do so
 Report to the Assembly Area Officer
 Report all accidents and injuries
 Remain in the Assembly Area
 Wait for instructions from the Incident Commander
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Section 4.0
Emergency Classification and Specific Emergency Scenarios
4.1
Fires and Smoke
4.2
Hazardous Materials Incident
4.3
Multiple Injury / Fatality Accidents
4.4
Bomb Threat
4.5
Crimes of Violence and Terrorism
4.6
Severe Weather and Power Outages
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4.1
Fires and Smoke
ASSUMPTION: Fire with visible flames or strong odours of burning and/or smoke
INITIAL RESPONSE:
1. For the person discovering the fire:
A. Call out for help and sound air horn if possible
B. Extinguish only if you can do so safely
a. Notify Incident Commander
C. If the fire cannot be extinguished:
a. Pull the nearest fire alarm and alert others
b. Activate the storm and sanitary sewer shut off valve
c. Proceed to the Front Gate Assembly Area
d. Notify Incident Commander
e. Safely shut down batches, cut heat, start cooling (Operations)
2. For occupants of a building:
A. Close the doors to your immediate area
B. Evacuate the building via the nearest exit
C. Assist others as necessary
D. Avoid smoke filled areas
E. Proceed to the Front Gate Assembly Area
SECONDARY RESPONSE:
1. Notify company Officers and Directors
2. Prepare media response
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4.2
Hazardous Materials Incident
ASSUMPTION: A hazardous materials incident may be a spill or release of chemicals, inside a
building or to the environment. Employees may manage small spills using the four emergency
spill kits located in key areas around the plant. Major spills and/or emergencies require
assistance from 24-hour emergency response and the Fire Department.
INITIAL RESPONSE:
1.
2.
3.
4.
5.
Evacuate the location and alert others/evacuate if necessary
Cover and/or dike storm drains
Activate the storm and sanitary sewer shut off valve
Proceed to the Front Gate Assembly Area
Notify Incident Commander
A. Determine if emergency responders are needed
B. Determine if immediate hazards are under control and the situation is stable
C. Activate required roles of the Environmental Emergency Plan
D. Notify required Government Agencies i.e. MOE for reportable releases
E. Determine if the site can be reoccupied or if further remediation is needed
SECONDARY RESPONSE:
1. Notify company Officers and Directors
2. Prepare media response
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4.3
Multiple Serious Injury/Fatality Accidents
ASSUMPTION: An accident has resulted in multiple employee injuries and/or fatalities.
EMERGENCY CLASSIFICATION: 1
INITIAL RESPONSE:
1. Dial Emergency Response 911
2. Notify Incident Commander
A. Determine if immediate hazards are under control and the situation is stable
B. Activate required roles of the Environmental Emergency Plan
C. Notify required Government Agencies i.e. MOL (life threatening injuries), WSIB
SECONDARY RESPONSE
1. The Incident Commander or designate conducts family notifications including:
A. Nature of the injury/death
B. Location of the injury/death
C. Additional information, as appropriate
2. The Incident Commander or designate conducts employee notifications including the
securement of any counselling or psychological assistance.
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4.4
Bomb Threat
ASSUMPTION: A bomb threat is phoned or mailed into Mancuso Chemicals.
INITIAL RESPONSE:
1. At the time a threat is received, there are two possible options:
A. Ignore the threat
B. Evacuate immediately
2. Telephone Threat:
A. All personnel are advised to follow the procedures listed below if they receive a
bomb threat over the telephone.
a. Remain calm. This type of response may assist in obtaining more
information from the caller.
b. The bomb threat caller is the best and maybe the only source of
information. When the bomb threat is called in:
i.
Keep the caller on the line as long as possible. Ask him/her to
repeat the message.
ii.
If the caller does not indicate the location of the bomb or the
possible time of detonation, ask for that information.
iii.
Inform the caller the plant is occupied, and detonation could
result in injury or death.
iv. Pay particular attention to background noises such as motors
running, music playing and any other noises that may give a clue
as to the location of the caller.
v.
Listen closely to the voice of the caller, male or female, calm or
agitated, accent, etc.
c. Remain available; law enforcement personnel will want to interview the
employee receiving the threat.
3.
4.
5.
6.
Notify Incident Commander
Proceed to the Front Gate Assembly Area
Activate the Environmental Emergency Plan
Evacuate the area if necessary
SECONDARY RESPONSE:
1. Notify company Officers and Directors
2. Notify employees not currently on the property
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TELEPHONE BOMB THREAT CHECKLIST
Mission:
Keep calm. Do not get excited or get others excited.
Delay and ask caller to repeat message.
Time Call is Received: ________ Time Call is Terminated: ________
Exact words of the caller:
QUESTIONS YOU SHOULD ASK:
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What time is the bomb set to explode?
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Where is the bomb located?
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What kind of bomb is it?
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Description of bomb.
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Why has the bomb been planted?
VOICE DESCRIPTION:
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Male / Female
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Young, old, middle-aged
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Calm / Nervous
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Rough / Refined
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Accent: yes/no Description:
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Speech impediment: yes/no Description:
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Unusual phrases:
ADDITIONAL INFORMATION:
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Do you recognize the voice?
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Who do you think it was?
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Background noises:
 Music: yes/no Type:
 Running Motor: yes/no Type:
 Traffic Whistles
 Bells
 Horns
 Voices
 Machinery
 Other:
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4.5
Crimes of Violence and Terrorism
ASSUMPTION: Violent incidents and acts of terrorism including but not limited to assaults and
workplace violence can occur on Mancuso Chemical’s property.
EMERGENCY CLASSIFICATION: Variable
INITIAL RESPONSE:
1. Notify supervisor, Incident Commander and alert others
2. In case of emergency dial 911:
A. What is happening?
B. Your name and address
C. Who is involved?
D. Type of weapon(s) involved, if any
E. Contact RCMP SIR Program contact for terrorism
F. Conduct Investigation
4.6
Severe Weather and Power Outages
EMERGENCY CLASSIFICATION: Variable
INITIAL RESPONSE:
1. Notify Incident Commander of weather or power concern
A. Secure the plant- this could include reactor emergency shutdown procedures
and/or stalling batches
B. Evaluate the situation and if necessary, call emergency response 911
SECONDARY RESPONSE:
1. Notify company Officers and Executives
2. Notify employees not currently on the property
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Section 5.0
Emergency Response Equipment
5.1
First Aid Equipment
5.2
Decontamination Equipment
5.3
Mancuso Emergency Response Team Equipment
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5.1
First Aid Equipment
The following are First Aid Equipment on-site locations at Mancuso Chemicals:
MAIN FIRST AID STATION
Location:
West Gate Office Trailer
DIPHOTERINE STATION NUMBER 1
Location: Reactor Room upper level
DIPHOTERINE STATION NUMBER 2
Location: Employee Lunchroom/Washroom
MAIN OFFICE COMMAND POST
Location: Main Office Employee Lunchroom
**This First Aid Kit is Mobile during an event where a new Command Post required**
5.2
Decontamination Equipment
The following is the Decontamination Equipment on-site location at Mancuso Chemicals:
Mancuso Emergency Response Equipment Room
Location:
West Gate Office Trailer
Equipment:
Tool Drop Bucket
20 Universal Absorbent Pads (Grey)
6 Rubber Mats
1 Decontamination Wash Bucket
500mL PEG for mixing wash solution
1 Flashlight
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5.3
Mancuso Emergency Response Team Equipment
Mancuso Chemicals Limited has a trained team of employees to safely respond to
emergency situations on-site. Their mission is to preserve life, protect the environment and
minimize damage to equipment. The team will respond to medical emergencies, chemical spills
and small fires once the Environmental Emergency Plan is activated.
Location: West Gate Office Trailer
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APPENDIX
Environmental Emergency Assessments
(E2 Chemicals)
A
Hydrofluoric Acid (49%)
B
Hydrochloric Acid (31%)
C
Phenol
D
Oleum
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APPENDIX A
ENVIRONMENTAL EMERGENCY ASSESSMENT FOR HYDROFLUORIC ACID (49%)
This Document is intended for internal purposes only.
Hydrofluoric Acid (49%), UN 1790, Class 8(6.1)(9.2)
CAS Number: 7664-39-3*0
DANGER
For additional details about hazards of Hydrofluoric acid, its properties and characteristics *2
refer to the attached product SDS.
PRODUCT FLOW and COMMERCIAL PROCESSING*3





Quantity of HF requiring an Environmental Emergency Plan: 450kg @ 50%*1
Receiving in closed top plastic drums, average quantity 2 drums
Storage in drums in the paved yard. Drum in use will be stored in a diked area and in a
tamper-resistant structure which is moved by fork truck.
Pumping from drum into plastic pails, average quantity 11 Kgs.
Pouring from pail into funnel located on suction side of circulation pump.
QUANTITIES
Receiving
 Drums (210 Kgs each)
Storage
 Covered concrete pad, 630 Kgs Max*3
Utilization
 Average 100 Kgs/month
*0
Environmental Emergency Regulations SOR/2003-307 Section 9(2)c
Environmental Emergency Regulations SOR/2003-307 Section 4(1)c(i)
*2
Environmental Emergency Regulations SOR/2003-307 Section 4(2)a
*3
Environmental Emergency Regulations SOR/2003-307 Section 4(2)a,b
*1
DESCRIPTION OF HYDROFLUORIC ACID STORAGE AND USE*4
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Hydrofluoric acid is received in plastic drums, usually ordered two at a time. Drums are
stored outside on covered concrete area. Only one drum at a time is in use, the other remains
sealed in storage. A special device holds the drum and it is moved around using a forklift truck.
The drum is positioned inside a diked area Hydrofluoric acid is manually added to the system
by addition through a funnel to the suction side of the circulation pump In addition, only the
Supervisor will add the hydrofluoric acid and will employ PPE to include a chemical resistant
suit, gloves and face mask.
*4
Environmental Emergency Regulations SOR/2003-307 Section 4(2)c
POTENTIAL CONSEQUENCES FROM AN ENVIRONMENTAL EMERGENCY ON ENVIRONMENT,
LIFE AND HEALTH*5
Mancuso Chemicals Ltd. maintains a minimal quantity of HF on site that never exceeds
three drums of material. Drums are ordered two at a time once stocks are approaching 50 Kg.
HF is stored under a covered area on concrete. Any spill would be easily absorbed with
absorbent and neutralized. There would not be enough quantity to enter a sewer from this
area, thus there is minimal environmental concern if a drum were to leak. The drum of HF in
use is on a protected gantry that is positioned within a diked area. No concern to the
environment exists if this drum were to leak or spill.
The health concern related to HF regards contact. HF is a very corrosive material and is a
contact poison. It should therefore be handled with extreme care, using protective equipment
and safety precautions beyond those used with other mineral acids. Exposure to HF requires
immediate flushing with water and calcium gluconate or specially designated Hexafluorine
washing stations that are located in the Emergency Response Trailer. HF is a neutral lipidsoluble molecule that penetrates tissue more rapidly than typical mineral acids allowing it to
penetrate tissue. Thus, poisoning can occur readily through exposure of skin or eyes, or when
inhaled or swallowed. Symptoms of exposure to hydrofluoric acid may not be immediately
evident, and this can provide false reassurance to victims, causing them to delay medical
treatment. HF interferes with nerve function, meaning that burns may not initially be painful.
Accidental exposures can go unnoticed, delaying treatment and increasing the extent and
seriousness of the injury.
Once absorbed into blood through the skin, it reacts with blood calcium and may cause
cardiac arrest. Burns with areas larger than 160 cm2 (25 square inches) have the potential to
cause serious systemic toxicity from interference with blood and tissue calcium levels. In the
body, hydrofluoric acid reacts with the ubiquitous biologically important ions Ca and Mg.
Formation of insoluble calcium fluoride is proposed as the etiology for both precipitous fall in
serum calcium and the severe pain associated with tissue toxicity. In some cases, exposures can
lead to hypocalcemia. Thus, hydrofluoric acid exposure is often treated with calcium gluconate,
a source of Ca2+ that sequesters the fluoride ions. HF chemical burns can be treated with a
water wash and 2.5% calcium gluconate gel or special rinsing solution. However, because it is
absorbed, medical treatment is necessary; rinsing off is not enough. Intra-arterial infusions of
calcium chloride have also shown great effectiveness in treating HF burns.
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*5
Environmental Emergency Regulations SOR/2003-307 Section 4(2)d,3b
MEASURES TO PREVENT, PREPARE, RESPOND AND RECOVER FROM A HYDROFLUORIC ACID
EMERGENCY*6
*6
Environmental Emergency Regulations SOR/2003-307 Section 4(3)a,c
RISK ASSESSMENT RECEIVING
PREVENTION
LEAKS
Check for leaks before unloading. Handle
carefully when bringing final destination by
fork lift truck
PRESSURE BUILD-UP IN DRUMS
Relieve pressure by loosening bung very
slowly. Wear full protective equipment as
specified for Hydrofluoric Acid
RISK ASSESSMENT STORAGE
PREVENTION
PUNCTURE OF DRUMS
Store out of the way of traffic at
predetermined permanent place
PRESSURE BUILD-UP IN DRUMS
Observe drums when utilizing product.
Release pressure slowly through valve or
bung
STORAGE IN HF PUMPING SYSTEM
A new HF pumping system will begin service
at Mancuso Chemicals spring 2015. This is a
fully-contained pumping system that
employs a drum located on a secured
gantry that is positioned within a diked
area. The gantry also has a tamper-proof
top thus preventing access to the drum
bung
RISK ASSESSMENT HANDLING
PREVENTION
SPILL DURING TRANSFER INTO PAILS
Don the required PPE. Open valve slowly. If
using a pail, make sure that pail is centered
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under valve. In case of pumping, make sure
nozzle is placed inside pail.
SPILL DURING HANDLING OF PAILS
Normally spill would occur on asphalt or
concrete with no access of spilled product
to public sewers. Small quantities to be
neutralized with lime or soda ash and
disposed of after testing. A closed lid
container has been provided for handling
EMERGENCY SPILL RESPONSE
Responders and reactor operators receive special training concerning the unique
hazards of hydrofluoric acid and wear personal protective equipment as per product SDS and
manufacturer’s instructions. A video about handling is utilized. HF specific first aid is available.
Due to the small quantities received, stored and used, even a larger spill of one
complete drum should not create an environmental hazard as the spill can be confined to
impervious areas, neutralized, tested and disposed of.
A containment kit and neutralizing agents (lime, soda ash) are on site permanently. An
emergency spill kit has been positioned in the storage area of hydrofluoric acid. Used
absorbent, booms, mats etc. will be treated as hazardous waste. All spills will be investigated
using the environmental incident investigation report to improve handling of the product and
spill response.
In the case of a leak to the automated HF pumping system, the pump has an automatic
leak shut off system. This will shut the pump off in the event of a leak in the pumping line. The
line itself is shielded within a steel conduit. Should a leak occur the leaked material would be
captured in a pail located in the box. Care should be taken when opening the box in case any HF
may have been dripped into the system. Proper PPE including a chemical resistant suit, gloves
and face mask will ensure the worker is not exposed. Any visible liquid should be neutralized
and absorbed with Haz-Mat pads before disposal. Only trained personnel are permitted to
operate this system.
HEALTH*7
• TOXIC; inhalation, ingestion or contact (skin, eyes) with vapors, dusts or substance may cause
severe injury, burns or death
• Reaction with water or moist air may release toxic, corrosive or flammable gases
• Reaction with water may generate much heat that will increase the concentration of fumes in
the air
• Fire will produce irritating, corrosive and/or toxic gases
• Runoff from fire control or dilution water may be corrosive and/or toxic and cause pollution
FIRE OR EXPLOSION*7
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• Non-combustible, substance itself does not burn but may decompose upon heating to
produce corrosive and/or toxic fumes
• Vapors may accumulate in confined areas (basement, tanks, hopper/tank cars etc.)
• Substance may react with water (some violently), releasing corrosive and/or toxic gases and
runoff
• Contact with metals may evolve flammable hydrogen gas
• Containers may explode when heated or if contaminated with water
PUBLIC SAFETY*7
• As an immediate precautionary measure, isolate spill or leak area in all directions for at least
50 meters (150 feet)
• Keep unauthorized personnel away
• Stay upwind
• Keep out of low areas
• Ventilate enclosed areas
PROTECTIVE CLOTHING*7
• Wear positive pressure self-contained breathing apparatus (SCBA)
• Wear chemical protective clothing that is specifically recommended by the manufacturer. It
may provide little or no thermal protection
• Structural firefighters' protective clothing provides limited protection in fire situations ONLY;
it is not effective in spill situations where direct contact with the substance is possible
*7
Emergency Response Guidebook 2012, Transport Canada, Page 254, Guide 157
APPENDIX B
ENVIRONMENTAL EMERGENCY ASSESSMENT FOR HYDROCHLORIC ACID (31%)
This Document is intended for internal purposes only.
Hydrochloric Acid (31%), UN 1789, Class 8(9.2)
CAS Number: 7647-01-0*0
DANGER
For additional details about the hazards of Hydrochloric Acid, its properties and characteristics*2
refer to the attached product SDS.
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PRODUCT FLOW AND COMMERCIAL PROCESSING*3





Quantity of HCl requiring an Environmental Emergency Plan: 6,800 Kgs @ 30%*1
Receiving in closed plastic IBC’s, average quantity 2 IBC’s
Storage in IBC’s under a covered concrete area
Storage in Man-Hib HDPE Tank#046 @ 10% of batch formulation
Pumping into batches from IBC to Reactor
QUANTITIES
Receiving
 Max 4 IBC’s (Total 4,600 Kgs)
Storage (IBC) *3
 Covered concrete pad, 8,000 Kgs Max
Storage (Man-Hib HDPE Tank #046) *3
 4,400 Kgs Max in the Mixture
Utilization
 Average 5,000 Kgs/Month
*0
Environmental Emergency Regulations SOR/2003-307 Section 9(2)c
Environmental Emergency Regulations SOR/2003-307 Section 4(1)c.(i)
*2
Environmental Emergency Regulations SOR/2003-307 Section 4(2)a
*3
Environmental Emergency Regulations SOR/2003-307 Section 4(2)a,b
*1
DESCRIPTION OF HYDROCHLORIC ACID STORAGE AND USE*4
Hydrochloric acid is received in plastic IBC’s which are stored outside in a covered
concrete area. Two to four IBC’s are received per shipment. Hydrochloric acid is used in our
Man-Hib foundry binder resin, having an approximate concentration of 10%. Man-Hib is stored
temporarily in HDPE Tank#046 with a capacity of 44,000 Kgs before product is transferred to
totes. A quantity of up to 44,000 kg (Man-Hib) is usually held in this tank for short periods.
*4
Environmental Emergency Regulations SOR/2003-307 Section 4(2)c
POTENTIAL CONSEQUENCES FROM ENVIRONMENTAL EMERGENCY ON ENVIRONMENT, LIFE
AND HEALTH*5
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Mancuso Chemicals Ltd. maintains a minimal quantity of HCl on site. IBC’s are ordered
two to four at a time once stocks are approaching 3,000 Kg. HCl is stored on a covered concrete
pad. Any spill would be easily absorbed with absorbent and neutralized. Drain covers and
emergency spill kits are on hand to dike a spill. An emergency drain shut-off is installed to
prevent leaks entering a sewer.
The health concern related to HCl regards contact. HCl is a very corrosive material. It
should therefore be handled with extreme care, using protective equipment and safety
precautions. Exposure to HCl requires immediate flushing with water and/or Diphoterine which
is located at stations around the plant. Chemical burns can occur readily through exposure of
skin or eyes, or when inhaled or swallowed. Symptoms of exposure to hydrochloric acid may
not be immediately evident, and this can provide false reassurance to victims, causing them to
delay medical treatment. Accidental exposures can go unnoticed, delaying treatment and
increasing the extent and seriousness of the injury.
*5
Environmental Emergency Regulations SOR/2003-307 Section 4(2)d,3b
MEASURES TO PREVENT, PREPARE, RESPOND AND RECOVER FROM A HYDROCHLORIC ACID
EMERGENCY*6
*6
Environmental Emergency Regulations SOR/2003-307 Section 4(3)a,c
RISK ASSESSMENT RECEIVING
PREVENTION
LEAKS IN HOSES AND FITTINGS
Preventive maintenance of transfer
equipment. Operator training and
loading batch sheet. Select only HCl
resistant transfer equipment. Stop
transfer immediately in case of leaks
RECEIVING TOTE DAMAGED OR VALVE LEAKING
Inspect totes for visible damage before
unloading.
DAMAGE OF TOTES DURING TRANSPORT TO
STORAGE AREA
Transport of totes only by certified fork
lift drivers
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RISK ASSESSMENT STORAGE
PREVENTION
PUNCTURE OF TOTES
Store totes outside of traffic areas. Keep
safe distance to other containers.
Frequent inspection. Limit usage of totes
to reasonable lifespan.
LEAKING VALVES ON TANK/TOTES
Frequent inspections of storage area.
Limit usage of totes to reasonable
lifespans
OTHER DAMAGE TO TOTES
Limit tier stacking to two layers. Keep
solvents away from totes.
RISK ASSESSMENT TRANSFER
PREVENTION
LEAKING HOSES, CAMLOCKS OR PUMP
Possibility of minor leaks or spills. Check
transfer equipment before use. Keep in
good working order. Make sure that only
material compatible with hydrochloric
acid is used
EMERGENCY SPILL RESPONSE
Responders and reactor operators receive special training concerning the unique
hazards of hydrochloric acid and wear personal protective equipment as per product SDS and
manufacturer’s instructions. Hydrochloric acid specific first aid is available.
Due to the small quantities received, stored and used, even a larger spill of one
complete IBC should not create an environmental hazard as the spill can be confined to
impervious areas, neutralized, tested and disposed of.
A containment kit and neutralizing agents (lime, soda ash) are on site permanently. An
emergency spill kit has been positioned in the storage area of hydrochloric acid. Rubber mats
are available to cover storm sewer catch basins in the vicinity of the spill. There is a shut-off
valve in the storm sewer to prevent any spill leaving the property. Used absorbent, booms,
mats etc. will be treated as hazardous waste.
All spills will be investigated using the environmental incident investigation report to
improve handling of the product and spill response.
HEALTH*7
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• TOXIC; inhalation, ingestion or contact (skin, eyes) with vapors, dusts or substance may cause
severe injury, burns or death
• Reaction with water or moist air may release toxic, corrosive or flammable gases
• Reaction with water may generate much heat that will increase the concentration of fumes in
the air
• Fire will produce irritating, corrosive and/or toxic gases
• Runoff from fire control or dilution water may be corrosive and/or toxic and cause pollution
FIRE OR EXPLOSION*7
• Non-combustible, substance itself does not burn but may decompose upon heating to
produce corrosive and/or toxic fumes
• Vapors may accumulate in confined areas (basement, tanks, hopper/tank cars etc.)
• Substance may react with water (some violently), releasing corrosive and/or toxic gases and
runoff
• Contact with metals may evolve flammable hydrogen gas
• Containers may explode when heated or if contaminated with water
PUBLIC SAFETY*7
• As an immediate precautionary measure, isolate spill or leak area in all directions for at least
50 meters (150 feet)
• Keep unauthorized personnel away
• Stay upwind
• Keep out of low areas
• Ventilate enclosed areas
PROTECTIVE CLOTHING*7
• Wear positive pressure self-contained breathing apparatus (SCBA)
• Wear chemical protective clothing that is specifically recommended by the manufacturer. It
may provide little or no thermal protection
• Structural firefighters' protective clothing provides limited protection in fire situations ONLY;
it is not effective in spill situations where direct contact with the substance is possible
*7
Emergency Response Guidebook 2012, Transport Canada, Page 254, Guide 157
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APPENDIX C
ENVIRONMENTAL EMERGENCY ASSESSMENT FOR PHENOL
This Document is intended for internal purposes only.
Phenol, UN 2312, Molten, Class 6.1, PG II
CAS Number: 108-95-2*0
DANGER
For details about hazards of Phenol, its properties and characteristics *2 refer to the attached
product SDS.
PRODUCT FLOW and COMMERCIAL PROCESSING*3





Quantity of Phenol requiring an Environmental Emergency Plan: 9,100 Kgs @ 10%*1
Receiving in bulk tankers
Storage in two bulk storage tanks located in the south tank farm
Pumping from bulk storage tanks into scale tank located in the reactor building
Release from scale tank by gravity flow into reactors
QUANTITIES
Receiving
 Bulk tankers (20,000 Kgs)
Storage
 Two bulk storage tanks T105/105 (53,000 Kgs each) *3
 Level indicator on T105, both tanks heated with insulation, 304 SS with metal cladding
Utilization
 Average 215,000 Kgs/month
*0
Environmental Emergency Regulations SOR/2003-307 Section 9(2)c
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*1
Environmental Emergency Regulations SOR/2003-307 Section 4(1)c.(i)
Environmental Emergency Regulations SOR/2003-307 Section 4(2)a
*3
Environmental Emergency Regulations SOR/2003-307 Section 4(2)a,b
*2
DESCRIPTION OF PHENOL STORAGE AND USE*4
Phenol is toxic, corrosive and combustible. The product is received and stored in a
molten stage at temperatures between 50 and 70 degrees Celsius. The solidification point is 43
degree Celsius. All lines and pumps are heat traced. If the system is allowed to cool, phenol can
freeze in the lines and can cause pump seals to fail. Phenol, like water, will expand on freezing.
If there is a freeze up of the system, maintenance crews need to allow the system to freeze to
prevent a liquid exposure, clean and repair the system and then seal the system back up before
re-applying heat to melt the phenol in the lines. Hot liquid phenol is pumped to a scale tank
located in the reactor room and is fed by gravity into the reactors. Storage tanks are located in
the south tank farm which is a diked area.
*4
Environmental Emergency Regulations SOR/2003-307 Section 4(2)c
POTENTIAL CONSEQUENCES FROM ENVIRONMENTAL EMERGENCY ON ENVIRONMENT, LIFE
AND HEALTH*5
The potential threat to the environment from a phenol spill at Mancuso Chemicals is
minimal. The storage tank is contained in a dike and all transfers are done in asphalt and
concrete covered areas. Phenol freezes at 43oC which means any spill, even in hot summer, will
quickly freeze to a solid on the ground that can be readily contained and collected. The greatest
probability of a spill would occur during transfer of phenol from a tanker truck and this is
conducted on the concrete-covered area.
The primary concerns with phenol regard its toxicity and temperature. Phenol when
transported can arrive at up to 70oC which, being a hot liquid, can cause scalding burns. The
more concerning problem with phenol is its toxicity. It is readily absorbed into skin causing both
corrosive and toxic effects which can result in a chemical burn for a minor exposure to a fatality
in event of a severe exposure. Therefore, all handlers must have correct PPE (Personal
Protective Equipment) including gloves, face shield and rubber suit. Should a worker be
exposed to phenol, a decontaminating shower is located by the phenol unloading station and
pump. Other decontaminating solutions (Diphoterine and PEG solution) are located in the
reactor room, lunch room and first aid station.
*5
Environmental Emergency Regulations SOR/2003-307 Section 4(2)d
MEASURES TO PREVENT, PREPARE, RESPOND AND RECOVER FROM A PHENOL EMERGENCY*6
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*6
Environmental Emergency Regulations SOR/2003-307 Section 4(3)a,c
RISK ASSESSMENT RECEIVING
PREVENTION
LEAKS
Preventive maintenance of transfer
equipment (pump to storage tank,
piping and valves to storage tank).
All hard transfer equipment within
the diked area. Bulk handling operator
watches unloading at all times
PRESSURE BUILD-UP IN TANKER
Possible when unloading by air pressure.
Only done in emergencies when pump
unloading is not possible. Pressure relief
valve installed in tanker
PRESSURE BUILD-UP IN STORAGE TANK
Vent from storage tank open to
atmosphere. Unloader to check air
escape at the beginning of pumping
PRESSURE BUILD-UP IN HOSE (VALVES INNCORRECT) Operator training, unloading check list
PRESSURE BUILD-UP IN HOSE OR PIPE
(FROZEN PRODUCT)
Store unloading hose in warm
environment. Make sure that hose is
drained after use. Heat and insulate
pump and piping
STORAGE TANK OVERFILL
Strict inventory control based on batch
sheets allowing for daily control.
Overflow (vent) pipe outlet in diked area.
Level indicator installed
DISCONNECTING TRANSFER HOSE
Air connection between hose and
external valve to clean hose before
disconnecting
VALVES IN TANK TRUCK FROZEN
Steam Genie Available. Connect hose to
tanker before thawing the valves with
steam. Sudden release will be contained
in hose
RISK ASSESSMENT STORAGE
PREVENTION
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LEAKS IN STORAGE TANK
South tank farm daily inspections in
place. Employees are trained in spill
detection. The south tank farm is a diked
area with more than 53000 Kgs +10%
capacity of both storage tanks
RISK ASSESSMENT TRANSFER
PREVENTION
LEAKS IN PUMPS, PIPING AND VALVES
Leaks are hard to see as all pipes are
traced and insulated. Preventive
maintenance and regular inspections.
Keep all transfer equipment at right
temperature. Make sure valves are in the
right position before starting transfer
pump. Pump could develop high
pressure when pumping against a closed
valve.
EMERGENCY SPILL RESPONSE
Responders and reactor operators receive special training concerning the unique hazards
of Phenol and wear personal protective equipment as per product SDS and manufacturer’s
instructions. Phenol specific first aid is available.
Due to the quantities received, stored and used, even a larger spill of one complete
storage tank should not create an environmental hazard as the spill can be confined to diked
areas, frozen and disposed of.
A containment kit is on site permanently. An emergency spill kit has been positioned in
the warehouse adjacent to the area of phenol unloading. Rubber mats are available to cover
storm sewer catch basins in the vicinity of the spill. There is a shut-off valve in the storm sewer
to prevent any spill leaving the property. Used absorbent, booms, mats etc. will be treated as
hazardous waste.
All spills will be investigated using the environmental incident investigation report to
improve handling of the product and spill response.
HEALTH*7
• TOXIC; inhalation, ingestion or skin contact with material may cause severe injury or death
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• Contact with molten substance may cause severe burns to skin and eyes
• Avoid any skin contact
• Effects of contact or inhalation may be delayed
• Fire may produce irritating, corrosive and/or toxic gases
• Runoff from fire control or dilution water may be corrosive and/or toxic and cause pollution
FIRE OR EXPLOSION*7
• Combustible material: may burn but does not ignite readily
• When heated, vapors may form explosive mixtures with air: indoors, outdoors and sewers
explosion hazards
• Those substances designated with a (P) may polymerize explosively when heated or involved
in a fire
• Contact with metals may evolve flammable hydrogen gas
• Containers may explode when heated
• Runoff may pollute waterways
• Substance may be transported in a molten form
PUBLIC SAFETY*7
• As an immediate precautionary measure, isolate spill or leak area in all directions for at least
50 meters (150 feet) for liquids and at least 25 meters (75 feet) for solids
• Keep unauthorized personnel away
• Stay upwind
• Keep out of low areas
• Fire: If tank, rail car or tank truck is involved in a fire, ISOLATE for 800 meters (1/2 mile) in all
directions; also, consider initial evacuation for 800 meters (1/2 mile) in all directions
PROTECTIVE CLOTHING*7
• Wear positive pressure self-contained breathing apparatus (SCBA)
• Wear chemical protective clothing that is specifically recommended by the manufacturer. It
may provide little or no thermal protection
• Structural firefighters' protective clothing provides limited protection in fire situations ONLY;
it is not effective in spill situations where direct contact with the substance is possible
*7
Emergency Response Guidebook 2012, Transport Canada, Page 246, Guide 153
APPENDIX D
ENVIRONMENTAL EMERGENCY ASSESSMENT FOR OLEUM (30% SO3)
This Document is intended for internal purposes only.
Oleum, UN 1831, Fuming Sulfuric Acid, Class 8(6.1), PG I
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CAS Number: 8014-95-7*0
DANGER
For additional details about the hazards of Oleum, its properties and characteristics*2 refer to the
attached product SDS.
PRODUCT FLOW and COMMERCIAL PROCESSING*3
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Quantity of Oleum requiring an Environmental Emergency Plan: 4,500 kg*1
Receiving in bulk tankers
Unloading from tankers into bulk storage tank (capacity 57,000 kg)
Pumping from bulk storage tank into tank located in the reactor building (capacity 600 Kg)
Release from scale tank by gravity flow into reactors
Release from reactor room day tank into reactors by gravity.
QUANTITIES
Receiving
 Bulk tankers 25,000 to 30,000 Kgs
Storage
 Max quantity 57,000 Kgs
 Horizontal, insulated, heated, carbon steel tank supported with steel saddles over a
concrete dike
Utilization
 Average 72,000 Kgs/month
*1
Environmental Emergency Regulations SOR/2003-307 Section 4(1)c.(i)
Environmental Emergency Regulations SOR/2003-307 Section 4(2)a
*3
Environmental Emergency Regulations SOR/2003-307 Section 4(2)a,b
*2
DESCRIPTION OF OLEUM STORAGE AND USE*4
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Oleum is stored in a heated tank suspended over a concrete containment dike. The tank
has ample capacity to always receive full truck load volumes without concern of over-spillage
and vapors displaced from the tank while it is being filled from the supply tanker. The unloading
process is vented back into the truck tanker. The tank is situated next to the reactor room
where the Oleum is pumped and consumed. The tank is situated away from the offices, labs
and warehouse where most of the employees are located.
*4
Environmental Emergency Regulations SOR/2003-307 Section 4(2)c
POTENTIAL CONSEQUENCES FROM ENVIRONMENTAL EMERGENCY ON ENVIRONMENT, LIFE
AND HEALTH*5
The main concern with Oleum is that it forms a corrosive acid mist composed of sulfur
dioxide and sulfur trioxide on exposure to air. This is exacerbated if Oleum comes in contact
with water as oleum reacts violently with water. Depending on the amounts released and the
level of exposure, the effects can range from respiratory irritation to serious health issues
including death.
The area around the Oleum storage tank is diked with capacity to hold the entire
contents of a full tank. However, the tank is never filled to capacity; single loads are ordered to
replace tank contents when the tank is nearly empty. If a spill were to occur, the contents will
be trapped in the dike and not leak into the environment. An IBC of Drakeol 7 (mineral oil) is
positioned close to the dike for quick addition to contain the acid mist produced during a
containment breach. The area surrounding the tank is paved asphalt.
In the event that a leak in the tank were to develop there could be a potential release of
Oleum gas into the atmosphere. To determine the extent of the release, Conestoga Rovers
(Engineering Contractors) were contracted to prepare an Off-Site Impact Assessment For the
Storage of Oleum at Mancuso Chemicals. The report is a worst case scenario, and is attached to
this Emergency Response document.
Key information must be pointed out that this “worst case” assessment was made using
full tank capacity. The tank is never filled to capacity. The assumption is made; the entire
contents of the tank is immediately released into the dike without capturing it back into either
of two reactors (total capacity 6000 gals plus 600 kg in Oleum day tank) capable of holding the
contents of the leaking tank. In other words this is a worst case scenario release based on
equipment capacities and not the practiced policies. With respect to the inventories held by
Mancuso Chemicals of Oleum (max 44,000 kg= 6,023 gal), these two reactors would hold the
contents of the Oleum tank if a leak were to develop. Thus, the storage tank could be pumped
empty and Oleum safely held in the reactors.
Results of the Assessment: As per the Conestoga Rovers report, a complete release of an
entirely full tank of Oleum into an uncontained dike would cause a dispersed cloud of Oleum as
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described in the report. The concentric yellow rings shown in the report indicate three levels of
effect due to the release:
AEGL-1 indicates the outer perimeter of an area whereby those exposed could detect some
noticeable discomfort, irritation and non-sensory effects, not disabling and reversible upon
cessation.
AEGL-2 indicates the outer perimeter of an area whereby those exposed could experience
irreversible and other serious long term health effects.
AEGL-3 indicates the outer perimeter of an area whereby those exposed could experience lifethreatening health effects or death.
As per figure 5 of the report, in the event of an uncontained spill, AEGL-2, perimeter of
serious health effects, essentially covers the Industrial park in which Mancuso Chemicals is
situated distanced to as far east as Progress street. The AEGL-3 perimeter essentially covers
the Mancuso site. The level of discomfort, irritation (AEGL-1) is shown in Figure 7 to encompass
several residential areas and potentially to the Niagara Falls residents themselves. However, a
contained spill has a much smaller perimeter of detection which effectively covers the industrial
park and the edge of Marineland Theme Park. A fully contained release has an AEGL-3
perimeter that is tightly limited around the storage tank and reactor room areas. The AEGL-2
limit in a fully contained release only encompasses the Mancuso property and part of the
empty lot to the west.
Important as part of this impact assessment, is that the formulae used to calculate the
release perimeters always takes into account that there will be 10% uncaptured release.
Mancuso Chemicals is currently installing a sealed cover over the mineral oil covered
containment dike which would act to enhance the possible release of Oleum. Thus, the realistic
worst case scenario for a diked and contained total release of Oleum would be expected to be
significantly less than the AEGL-1 perimeter ring described in Figure 7. That is, a full release
would likely not be detected within the industrial park. This double containment system is
expected to be completed by the end of March 2015.
*5
Environmental Emergency Regulations SOR/2003-307 Section 4(2)d, 4(3b)
MEASURES TO PREVENT, PREPARE, RESPOND AND RECOVER FROM AN OLEUM EMERGENCY*6
*6
Environmental Emergency Regulations SOR/2003-307 Section 4(3)a,c
RISK ASSESSMENT RECEIVING
PREVENTION
LEAKS OR SPILLS
Preventive maintenance of transfer
equipment, especially the pump. Only
use hose approved for Oleum. Unloading
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only by designated and trained
employees. Follow unloading procedure.
Close off sewer system
PRESSURE BUILD-UP IN TANKER
Pressure relief valve installed in tanker
during unloading. In case of malfunction
the storage tank vent will ensure that no
pressure builds up
PRESSURE BUILD-UP IN STORAGE TANK
Vent from storage tank connected to
tanker. Storage tank additionally vented
to scrubber
BLOCKED VENT LINES IN WINTER
Preventive maintenance. Heated and
insulated vacuum breaker on storage
tank and connections
MATERIAL TOO COLD
Specify product shipping temperature
with supplier and check before
unloading
OVERFILLING OF STORAGE TANK
Level and temperature gauge installed.
Verify level and temperature before
unloading
LEAKS AND SPILLS DURING DISCONNECTING
Install air fitting at beginning of hose and
blow air. Place container under hose
connection to catch drips
FUMES FROM AIR VENTS
Storage tank has as installed scrubber at
end of vent line
RISK ASSESSMENT STORAGE
PREVENTION
SUITABLE MATERIAL OF CONSTRUCTION
Select only material resistant to oleum
for tank, piping, pump, seals and
gaskets. Include generous safety
margins. Oleum is less corrosive than
water
LIFESPAN OF MATERIAL
Dates recorded of installation for all
equipment and replacement parts.
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Periodic testing of storage tank will be
conducted
LEAKS IN STORAGE TANK OR CONNECTIONS
Dike area around tank with concrete
floor and concrete walls. Keep dyke
clean and dry. Rainwater has to be
pumped out regularly
PRESSURE BUILD-UP IN STORAGE TANK
Make sure that vent line into scrubber is
free. Do not overheat product. Make
sure that no water or humidity can enter
into storage tank or pipe connection
RISK ASSESSMENT TRANSFER
PREVENTION
LEAKING PIPES AND PIPE CONNECTION
Preventive maintenance plans. Selection
of suitable materials for pumps, pipes
and gaskets. Replace before the end of
lifespan.
OVERFLOW OF MEASURING TANK
Return line installed from measuring
tank to storage tank with no valves in the
line.
PRESSURE BUILD UP DURING TRANSFER
Verify valve settings in lines.
Recirculating vent line to scrubber is
installed
EMERGENCY SPILL RESPONSE
OLEUM REACTS VIOLENTLY WITH WATER DEVELOPING A VISIBLE AND DRIFTING ACID MIST,
MAINLY CONTAINING SULFUR DIOXIDE AND SULFUR TRIOXIDE
Oleum is sensitive to humidity and water. The sulfur trioxide and sulfur dioxide in the
product is released violently on contact with water. Sulfur trioxide and sulfur dioxide vapours
are very toxic when inhaled. Also, the vapours form corrosive sulfuric acid in combination with
humidity and moisture in the pulmonary tract and on skin.
Due to the toxic and corrosive fumes, full protective equipment including an SCBA, has
to be worn by responders who must approach a danger zone. Approach only from an up-wind
direction to reduce the exposure.
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Responders and reactor operators receive special training concerning the unique
hazards of Oleum and wear personal protective equipment as per product SDS and
manufacturer’s instructions. Oleum specific first aid is available.
Due to the quantities received, stored and used, even a larger spill of one complete
storage tank should not create an environmental hazard as the spill can be confined to the
diked area, covered with mineral oil and disposed of.
A containment kit and neutralizing agents (lime, soda ash) are on site permanently. An
emergency mineral oil IBC has been positioned adjacent to the area of Oleum unloading.
Rubber mats are available to cover storm sewer catch basins in the vicinity of a spill. There is a
shut-off valve in the storm sewer to prevent any spill leaving the property. Used absorbent,
booms, mats etc. will be treated as hazardous waste.
All spills will be investigated using the environmental incident investigation report to
improve handling of the product and spill response.
HEALTH*7
• CORROSIVE and/or TOXIC; inhalation, ingestion or contact (skin, eyes) with vapors, dusts or
Substance may cause severe injury, burns or death
• Fire will produce irritating, corrosive and/or toxic gases
• Reaction with water may generate much heat that will increase the concentration of fumes in
the air
• Contact with molten substance may cause severe burns to skin and eyes
• Runoff from fire control or dilution water may cause pollution
FIRE OR EXPLOSION*7
• May ignite combustibles (wood, paper, oil, clothing, etc.)
• Substance will react with water (some violently), releasing corrosive and/or toxic gases and
runoff.
• Flammable/toxic gases may accumulate in confined areas (basement, tanks, hopper/tank
cars, etc.)
• Contact with metals may evolve flammable hydrogen gas
• Containers may explode when heated or if contaminated with water
• Substance may be transported in a molten form
PUBLIC SAFETY*7
• As an immediate precautionary measure, isolate spill or leak area in all directions for at least
50 meters (150 feet) for liquids and at least 25 meters (75 feet) for solids. Further evacuation
may be required as per attached CRA – Off Site Impact Oleum Risk Assessment (APPENDIX E)
• Keep unauthorized personnel away
• Stay upwind
• Keep out of low areas
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• Ventilate enclosed areas
PROTECTIVE CLOTHING*7
• Wear positive pressure self-contained breathing apparatus (SCBA)
• Wear chemical protective clothing that is specifically recommended by the manufacturer. It
may provide little or no thermal protection
• Structural firefighters' protective clothing provides limited protection in fire situations ONLY;
it is not effective in spill situations where direct contact with the substance is possible
PUBLIC SAFETY
*7
Emergency Response Guidebook 2012, Transport Canada, Page 214, Guide 137
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Evacuation Map
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