FEASIBILITY STUDY, RISK ASSESSMENT, AND SAFETY PROCEDURES FOR CAUSTIC SODA OPERATIONS PORT OF BAYONNE, NEW JERSEY, UNITED STATES PORT OF SOUTHAMPTON, UNITED KINGDOM SEAQUEST PROJECT NUMBER: 6976 PREPARED FOR: MS. JODY MILLER LEAD, CREW SAFETY PROGRAM MARITIME SAFETY AND COMPLIANCE ROYAL CARIBBEAN CRUISES LTD. 1050 CARIBBEAN WAY MIAMI, FLORIDA 33132 PREPARED BY: SEAQUEST TESTING & CONSULTING 5150 SOUTHWEST 48TH WAY, SUITE 610 FORT LAUDERDALE, FLORIDA 33314 AUGUST 15, 2013 ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● 5150 Southwest 48th Way, Suite 610, Fort Lauderdale, Florida 33314 Phone: 954/792‐4549, Fax: 954/792‐2221, Toll Free Phone: 877/247‐8146, On the Web: www.SeaquestTesting.com Asbestos Consulting Business ZA‐304, Radon Business RB2184 & Lead Based Paint Business FL‐16418‐1 CERTIFICATION PAGE FEASIBILITY STUDY, RISK ASSESSMENT, AND SAFETY PROCEDURES FOR CAUSTIC SODA OPERATIONS PORT OF BAYONNE, NEW JERSEY, UNITED STATES PORT OF SOUTHAMPTON, UNITED KINGDOM SEAQUEST PROJECT NUMBER: 6976 PREPARED FOR: MS. JODY MILLER LEAD, CREW SAFETY PROGRAM MARITIME SAFETY AND COMPLIANCE ROYAL CARIBBEAN CRUISES LTD. 1050 CARIBBEAN WAY MIAMI, FLORIDA 33132 PREPARED BY: SEAQUEST TESTING & CONSULTING 5150 SOUTHWEST 48TH WAY, SUITE 610 FORT LAUDERDALE, FLORIDA 33314 AUGUST 15, 2013 _________________________ TRACI-ANNE BOYLE, CIH, CSP SENIOR PROJECT MANAGER ii TABLE OF CONTENTS PAGE 1 1 INTRODUCTION 1.1 SCOPE – FEASIBILITY STUDY 1.2 SCOPE - ENVIRONMENTAL HEALTH AND SAFETY PROTOCOLS 1.3 PORT AND VENDOR VISITS 1 2 2 2 3 ABOUT SODIUM HYDROXIDE (CAUSTIC SODA) 2.1 PHYSICAL PROPERTIES 2.2 OCCUPATIONAL EXPOSURE SUMMARY 2.3 ENVIRONMENTAL SPILL CONSIDERATIONS 3 3 3 3 5 FEASIBILITY OF SUPPLY AND DELIVERY METHODS 3.1 CAPE LIBERTY 3.1.1 RAIL CAR 3.1.2 TANKER TRUCK TO VESSEL 3.1.3 BARGE DELIVERY TO VESSEL 3.1.4 TANKER TRUCK TO ONSITE STORAGE TANK 3.2 SOUTHAMPTON 3.2.1 RAIL CAR 3.2.2 TANKER TRUCK TO VESSEL 3.2.3 BARGE DELIVERY TO VESSEL 3.2.4 TANKER TRUCK TO ONSITE STORAGE TANK 5 5 5 14 14 15 15 15 15 20 4 21 DESIGN CONSIDERATIONS 4.1 GENERAL 4.2 VESSEL 4.3 PORT 21 21 21 5 23 REGULATORY REQUIREMENTS & RESOURCES 5.1 REGULATORY REQUIREMENTS 5.2 INDUSTRY GUIDELINES 23 23 6 30 CONCLUSIONS AND RECOMMENDATIONS iii ...............................28 APPENDICES Appendix I .............Summary of Vendor Inquiries.TABLES Table 1 .24 Table 6 .......................................... Southampton ..Summary of Contacts. Cape Liberty ..............................6 Table 2 ............................. United States ....................Provided Documentation Appendix II – Hazardous Substance Fact Sheet – Sodium Hydroxide Appendix III – Preliminary Risk Assessment Appendix IV – Resource CD iv ...............................................18 Table 5 .........................................................Summary of Contacts............................................. Bayonne ..........16 Table 4 .................................. United Kingdom .......Summary of Regulations.Summary of Regulations...................................... Southampton ............................Summary of Vendor Inquiries.10 Table 3 ........... United Kingdom Review of relevant United Kingdom regulations (Maritime Coastguard Authority. The project consists of identifying and evaluating the feasibility of vendors to deliver approximately 37.Port of Bayonne Identify three (3) potential vendors to service the port of Bayonne Confirm vendors are able to supply amount (37. Ltd (RCCL) and documentation provided to SeaQuest Senior Project Manager. United States and the Port of Southampton. United Kingdom. contacted authorities and contacted vendors to evaluate whether it is feasible to have 37. Based upon the feasibility of the project. New Jersey. risk assessment and developed preliminary health and safety protocols for introducing caustic soda into the emission scrubbing process for vessels scheduled to call on the Ports of Bayonne. Ms. The feasibility study also examined applicable laws and evaluated the logistics of the material handling. Traci-Anne Boyle (see Appendix I).United States Review of CFR 29.000 gallons of 50% sodium hydroxide delivered to the ports of Bayonne and Southampton every two (2) weeks. including all necessary security authorizations needed to access the port Evaluate the vendor/supplier understanding of the port operations and close proximity of other operations being performed concurrently. 46 and 49.1 SCOPE – FEASIBILITY STUDY SeaQuest reviewed regulations.1 INTRODUCTION SeaQuest Testing & Consulting (“SeaQuest”) conducted a feasibility study. a risk assessment was performed and preliminary health and safety protocols were established for the safe handling of the material. as well as related United States Coast Guard (USCG).000 gallons) and concentration (50%) needed. 1. Determine if the vendors are able and willing to comply with port operations. The scope of work was developed based upon conversations with Ms. NJ and other local community ordinances. Joe Mujwit of Royal Caribbean Cruises. 33. as well as the guests and crew embarking and debarking Determine what method will the vendor use for transferring onboard Determine how long the bunkering operations will take Determine who will be involved in bunkering operations and if they have the necessary certifications Regulatory Review . The feasibility study consisted of: Regulatory Review . Jody Miller and Mr. Review of Cape Liberty and the Port Authority of New York/New Jersey guidance Discussion with the Captain of the Port (COTP) and the Officer in Charge of Marine Inspection (OCMI) Discussion with Cape Liberty Cruise Port and Ports of NY and NJ authorities Discussion with the New Jersey Department of Environmental Protection Vendor Evaluation . Health and Safety Executive) Review of relevant European Parliament and of the Council (EC) regulations Discussion with the Maritime Coastguard Authority and the Health & Safety Executive 1 .000 gallons of 50% sodium hydroxide to the ports every two (2) weeks. Department of Transportation (DOT) and Occupational Safety & Health Administration (OSHA) policy documents Review New Jersey Statutes Review of City of Bayonne. 1. Ports of NY and NJ. Health and Safety Executive) and EC regulations Review of NJ statutes Review of City of Bayonne. Environmental Health and Safety Protocols Review of US federal requirements. Cape Liberty Cruise Port. NJ and other local community ordinances Review of Cape Liberty and the Port Authority of New York/New Jersey guidance. SeaQuest conducted visits of both ports and met with potential vendors in Bayonne to discuss the project. Discussion with the Port of Southampton authorities (Harbor Master) Vendor Evaluation .2 SCOPE . the ship and in the water.Port of Southampton Identify three (3) potential vendors to service the Port of Southampton Confirm vendors are able to supply amount (37. NY) Discussion with New Jersey Department of Environmental Protection Discussion with port authorities (e. including USCG. including all necessary security authorizations needed to access the port Evaluate the vendor/supplier understanding of the port operations and close proximity of other operations being performed concurrently. and Port of Southampton) Discussion with Maritime Coastguard Authority and Health & Safety Executive representatives SeaQuest also developed preliminary health and safety protocols for the safe handling of the material.000 gallons) and concentration (50%) needed. as well as the guests and crew embarking and debarking Determine what method will the vendor use for transferring onboard Determine how long the bunkering operations will take Determine who will be involved in bunkering operations and if they have the necessary certifications 1. 2 . Review of regulations from relevant United Kingdom authorities (Maritime Coastguard Authority. Environmental Protection Agency (EPA) and OSHA regulations pertaining to procedures for spills on land. in the water or on the ship.3 PORT AND VENDOR VISITS Although not in the scope of work. Discussion with COTP and OCMI (USCG Sector.ENVIRONMENTAL HEALTH AND SAFETY PROTOCOLS SeaQuest reviewed relevant environmental health and safety regulations and guidance to evaluate applicable safety procedures and contingencies for spills on land.g. Determine if the vendors are able and willing to comply with port operations.. It has a health hazard rating of 3. and in waste water treatment plants for use in the scrubbing process. including gloves. the use of a dilute acid can be used to neutralize the solution. 2. in tissue digestion. The material is used in manufacturing. the material is typically transported as a liquid and it is readily available in 50% solutions required in the specifications provided to SeaQuest. the material temperature will have to be regulated throughout the transportation. 2. In a 50% solution as required by the RCCL specifications. However. Given this relatively high freezing temperature. sodium hydroxide has a freezing temperature of approximately 58F or 14C. As an example. chemical pulping.3 ENVIRONMENTAL SPILL CONSIDERATIONS In the event of a spill of sodium hydroxide in solution. In the event of a spill into a contained water body (i. a spill in the ocean would not likely result in a response.e.1 PHYSICAL PROPERTIES A copy of New Jersey Department of Health and Senior Services Hazardous Substance Fact Sheet for sodium hydroxide is provided in Appendix II. as a cleaning agent. Particulate respirators must be worn if airborne concentrations of sodium hydroxide are expected to be near the PEL/TLV/REL.2 ABOUT SODIUM HYDROXIDE (CAUSTIC SODA) Sodium hydroxide (commonly known as caustic soda) is used throughout the world for a wide variety of purposes. Sodium hydroxide is an odorless white solid that readily absorbs moisture from the air. sulfuric acid and nitric acid) as well water to rapidly release heat. the caustic soda will be added to the scrubbing water circulation in order to maintain the process pH and consequently the sulfur removal efficiency of the air emissions scrubbers. in food preparation. In accordance with information provided by RCCL. pool). a fire hazard rating of 0 and a reactivity hazard rating of 1. storage and use of the chemical. Sodium hydroxide is not combustible and its vapor density is heavier than air. In the event of contact with the skin or eyes. The American Conference of Governmental Industrial Hygienist (ACGIH) Threshold Limit Value (TLV) and National Institute of Occupational Safety & Health (NIOSH) Recommended Exposure Limit (REL) is also 2 mg/m3. The material reacts with strong acids (such as hydrochloric acid. the material should be absorbed with sand or earth and placed into sealed containers for proper disposal. The material is a strong base and can cause severe burns if exposed to the skin or eyes or if it is inhaled in the air. immediate flushing with copious amounts of water is necessary to reduce injury.2 OCCUPATIONAL EXPOSURE SUMMARY The Occupational Safety & Health Administration (OSHA) 8-hour Time Weighted Average (TWA) Permissible Exposure Limit (PEL) for sodium hydroxide is 2 mg/m3. 2. in 2004 a 3 . coveralls and a full facepiece splash shield. Contact with the skin and eyes should be prevented through diligent use of personal protective equipment. Partly due to the strong reaction process. 000 gallons of 50% sodium hydroxide (an unknown amount of which spilled into the Arthur Kill waterway). 2013. resulted in no on-water cleanup. 4 .1 1 http://www.tank failure resulted in a spill of over 460.gov/northeast/kinder/index.darrp.html. Accessed August 3.noaa. 1.1. based upon current logistics during port calls. The installation of a crane would have to be approved through the Port Authority approval process.1 CAPE LIBERTY The results of inquiries into vendors for Cape Liberty are provided in Table 1. Jim Papernik of IMTT. it is unlikely that sufficient separation between tanker and pedestrians can be accomplished. it would not be possible to install railroad tracks between the two (2) terminals due to the land purchase and installation requirements. However. 3. it appears that an onsite storage tank or barge deliveries are feasible options at this port. Therefore. 3.000 gallons) would take an average of 10 tankers each requiring approximately 2 hours to bunker their load. this option may be feasible. and Mr. the Director of the Cape Liberty Cruise Port. A boom crane would be required to support the hose connection from the tanker to the ship. Based upon the research and interviews conducted (see Table 2). Caputo.3 FEASIBILITY OF SUPPLY AND DELIVERY METHODS Caustic soda is commercially used throughout the world and is readily available. Due to the limited space portside. If temporary. delivery at this port by tanker truck is not feasible. If a permanent containment is constructed. The tanker trucks will have to back into a containment structure (permanent or temporary). potentially within sight of boarding passengers. There appear to be vendors at both Cape Liberty and Southampton that can supply the quantity (37. which could take months to over a year to complete. 3. This would have bunkering operations continuing for approximately 20 hours. it was determined that rail car delivery is not an option at this port. Therefore.000 gallons). at the required quantity. If it is determined that only 6. at the required interval (every 2 weeks) and at the correct mix (50%). according to information obtained from Mr. which could take months to over a year to complete. According to Mr. the maximum number of tanker trucks that could be accommodated would be 2 or 3. However. 5 .1 Rail Car The IMTT Terminal that supplies caustic soda to many of the vendors is located less than three (3) miles from Cape Liberty and has rail car access. However. it will have to go through the Port Authority approval process. the following should be considered: Personnel bunkering the caustic soda would be wearing full personal protective equipment.000 to 10. Anthony Caputo. ground support will be needed to deploy for each delivery.2 Tanker Truck to Vessel Having tanker trucks delivered to the ship when it calls to Cape Liberty is problematic for the required quantity: The vessel is in port for 10-12 hours.000 gallons were required during the port call. delivering the required quantity (37. 11 Full tank truck loads (~3. NJ 07105 p) 973/465‐1122. Met with Mr.Table 1 ‐ Summary of Vendor Inquiries. NJ 07016 JLMyers@harborchem. Ext 111 fran@seidlerchem. The method of delivery with this vendor would be from tanker truck to Aboveground Storage Tank (AST) at the port. Barge delivery is also a possibility. Would source the material from IMTT at the Port of Bayonne. although not practical. Have the means and resources to supply the material if a tank were onsite. Seidler Chemical Company appears to be a suitable supplier for the caustic soda.com p) 908/272‐7070 Seidler Chemical Company Francis Penkethman 537 Raymond Boulevard Newark. Able and willing to comply with NJ and Port regulations. Bayonne Reference Harborchem Jonathan Myers PO Box 630 Cranford. Stephen Maybaum on July 23. At this screening level. Very interested in the project.com Information Approximately 9 tank trucks. each needing roughly 2 hours to bunker. Transport into the port can be easily arranged with proper planning. At this screening level. Harborchem appears to be a suitable supplier for the caustic soda. Myers and President of Harborchem. 6 .500 gallons. The method of delivery with this vendor would be from tanker truck to AST at the port. each truck holds about 4. Able and willing to comply with port requirements.363 gallons per tanker) over a 3 day maximum. ) and equates to $0. Estimated cost for product per delivery. Rents a LCS tank at IMTT Port in Bayonne. Discussed feasibilty of railcar delivery and direct pipeline to the port.000/37. Took a tour of their tank operations at the IMTT port.com Met with Mr.500 total/delivery]. NJ 07002 www. hoses. Mr. 7 .imtt.000. Papernik does not believe barge is an option either. Believe that a barge delivery is not possible.com p) 201/339‐4992 c) 908/447‐8484 jimpapernik@imtt. etc.0073/LB or $29/DST.000 LBS or 12 Dry Short Tons) will be close to $350 per truckload [~$3. Willing to assist with the plans for building the tanks at the port. Papernik on July 24th with representatives from Brenntag Global." This does not include the cost of the product (current pricing is approximately $60. and provided documentation (see reference disk). IMTT Jim Papernik Vice President Chemical Sales & Marketing 250 East 22nd Street PO Box 67 Bayonne. Neither option believed feasible due to the properties between the IMTT and Cape Liberty Terminals. fuel. compressor. Have the means and resources to supply the material if a tank were onsite. "The cost associated with delivering 1 truckload of the Caustic (approximately 48. It is believed that all of the vendors contacted would be sourcing their NaOH from IMTT. Brenntag Global appears to be a suitable supplier for the caustic soda. Able and willing to comply with port requirements. Estimate cost of tank installation around $150. This includes all elements of the delivery (labor. Had a tour of their tank farm.com Information World's largest distributor of liquid caustic soda and one of the biggest in the US. including various security and safety precautions. since he thinks that the NaOH barges hold hundreds of thousands of gallons of NaOH and would not be willing to make deliveries of the small quantity needed at the frequency needed.com Steven Watts Process Improvement Manager p) 484‐575‐6497 swatts@brenntag. Concurs with Steve Watts from Brenntag that 4 smaller tanks would be better than 1 big tank because of the design requirements for such a heavy and dense liquid.000 gallons) At this screening level.Table 1 ‐ Summary of Vendor Inquiries. Papernik identified that frac tanks may be a temporary solution until a permanent solution could be implemented at the port. LLC John Samoylo Account Manager p) 732/674‐5186 Jsamoylo@brenntag. Mr. Bayonne Reference Brenntag Global Marketing. less than 3 miles from the Cape Liberty terminal. Met with several representatives of Brenntag on July 23 and 24th. They estimate that the cost per 37. RCCL Director of Northeast operations. in and out of the port a lot.000/37.com p) 202‐314‐6456 Information Can get the required quantity.Table 1 ‐ Summary of Vendor Inquiries. Whelpley by Anthony Caputo.000/load. Bayonne Reference Veckridge (Chemical Distributor) Tom or Bob p) 973/344‐1818 Whelpley Construction Dave Whelpley dwhelpley@wescocm. Mr.com p) 732‐995‐1144 www. This does not include the cost of the product (current pricing is approximately $60. so familiar with port regulations. Mr. perhaps they could be combined with the terminal improvement permitting that he has underway to shorten the timeline. Carola from RCCLs current barge suppliers (Ray Baldwin with Harbor Petroluem and Ralph Duca with Clean Waters NY) as well as Fran Penkethman with Seidler Chemical Company for possible barge delivery. Referred to Mr. Spoke with Mr. At this screening level. He indicated that if the storage tanks were an option. Carola who indicates that this is possible by barge because Kuehne both manufactures caustic and owns its own caustic barge. Mr.com Referred to Mr. Carola indicates that Kuehne would need an advanced schedule for proper planning. Kuehne Chemical appears to a suitable supplier for the caustic soda. Did not return repeated calls for followup information.000 gallons). No additional consideration of this vendor is recommended. Whelpley's firm is the vendor that is currently in the permitting process for the upgrades to the Bayonne terminal.kuehnecompany. They would deliver the material by barge to the ship.000 gallon delivery to be approximately $15. Kuehne Chemical Ken Corolla kdcarola@kuehnecompany. Whelpley indicated that permitting with the Port Authority is particularly onerous and can be very time consuming (months ‐ years). 8 . Met with Mr. Mr. Garrison on July 24th.net Information Referred to Ken's Marine Service by Anthony Caputo. Garrison provided a lot of information on the safe design of bunkering the material from a barge. use a universal connection (camlock). Pat Garrison Spill Supervisor 116‐20 East 22nd Street Bayonne. RCCL Director of Northeast operations. do not have the connections over water. Bayonne Reference Ken's Marine Service. Garrison also discussed the hazards of using dry powder. source flexible hosing that moves with the ship. He is willing to assist with the preparation of the needed spill prevention plan. Mr. Inc. Specifically. Ensure containment at the barge and on the ship. 9 . he'd recommend that it be contained within a heated building. support the hose in 3 places using a boom crane. Garrison discussed that if a tank was installed at the port. NJ 07002 p) 201/339‐0673 c) 201/800‐1409 pat@kensmarine. it would keep the pumps protected and the fittings protected (which are the weaknesses and most likely places for a failure to occur).Table 1 ‐ Summary of Vendor Inquiries. The building would provide protection in the event of a tank failure. There will be blending issues even with circulators and agitators. Ken's Marine is a suitable vendor to provide emergency response services in the event of a spill. Mr. and have 3 shut offs in place. The most significant hazard is a dust explosion and rapid reaction producing heat. 10 . Once it is determined to be a TAA. 3. Clyne. Nguyen.gov Very helpful contact for general questions. cover letter and drawings to the PA’s Engineering department for their decision of whether this is a TAA or a MWA. Kim Nguyen Port Authority NYNJ p) 973/578‐2155 knguyen@panynj. will need to hire an Architect or Engineer of Records (A/EOR) who is licensed to practice in the state of NJ and NJMT TAA Program office will schedule a kick‐off meeting between the tenant. I will forward the tenant’s email. cover letter and drawings could be scanned and emailed to me at the above email address. its Engineer of Records and its Contractor. 2.gov RCCL needs to fill out and submit the proper paper work (TAA‐MWA) and to send the engineer that will be designing the tanks to meet with her as well as other NYNJ Port officials. the tenant. Contact her to schedule. Submit the form TAA‐MWA Ph 1 01 (attached) . " In a phone conversation with Ms. from the tenant (Royal Caribbean) to the NJMT General Manager. together with some drawings and location plan. Thomas F. The form Ph 1 01 needs to be signed by the Tenant (Royal Caribbean) and dated. Bayonne Reference Information George Wojnar Port Authority NYNJ p)973/578‐2157 gwojnar@panynj. she could not estimate on how long the permit process would take. together with a cover letter. Mr. See reference disk for additional forms and instructions. For any tenants to propose any work on the Port Authority’s leased property. She said it depended upon the thoroughness of the application. will point you in the right direction when needed.Table 2 ‐ Summary of Contacts. the PA’s Tenant Construction and Alteration Process (TCAP) requires the followings: 1. Royal Caribbean. All the form. describing the proposed work. Table 2 ‐ Summary of Contacts. there are no of Expertise regulations that specifically pertain to having it on board.reddy@dep. p) 954/767‐2140 ext. Bayonne Reference Information Jeffrey Sterling Supervisor DEP Hazardous Waste Enforcement Northern Region Field Office p)973/656‐4498 Bob Gomez New Jersey DEP p)609/292‐3837 Provided Bob Gomez's Contact information Gary Sobin DEP Discharge Prevention p)609/292‐2482 Any hazardous chemical in amounts greater than 20. 1005 Lt. designed and built pursuant to N. Plans for the holding tanks need to be submitted 180 days prior to operation. Mike Metz Any further questions that may come up should be handled with Lt.6" See Reference CD for more information.A. Keith Hanley p)617‐223‐8541 11 . contact Discharge Prevention Program within the DEP Any smaller containments at the site of the holding tanks will also be included in the 20. Priit Pals NJAC 7:1E‐2.J.state.000 gallons requires a DPCCDCR (Discharge Prevention Containment and Countermeasure and Discharge Cleanup and Removal) No DEP regulations pertaining to the transport of sodium hydroxide. 7:1E‐2. p)954/767‐2140 Lt. Permit Coordination beth.3 "All tank car or tank truck loading or unloading areas employed in the loading or DEP Discharge Prevention unloading of hazardous substances shall be equipped with secondary containment or a diversion p)609/633‐1152 system.nj. Reddy to be Beth Reddy DEP Engineer with Discharge Prevention & assigned a NJ DEP project manager as soon as wanted. Mike Metz. Email Ms.us US Coast Guard Cruise Ship National Center Because the sodium hydroxide on board the ship is not cargo and is a consumable.C.000 gallons. There are unloading area requirements. Com. gov/police/ p) 800/828‐7273 Sargaent D'Amato Charles "Chuck" King
[email protected] Chief Weaver is also the city's Emergency Management contact. Referred to the Fire Official. Christopher Czuba.gov/html/nypd/html/precin ct_maps/precinct_finder. but referred us to Mr.shtml Port Authority Police Department http://www. King. Referred to the Port Authority Police Department. Bayonne Police Department http://www.bayonnenj.nyc.org/government/de partment‐of‐public‐safety/bayonne‐police‐ department/ Sargeant Jim Ashe 201/858‐5642 Bayonne Fire Department Deputy Chief Keith Weaver 201/858‐6009 Fire Official Christopher Czuba 201/858‐6024 foczuba@gmail. Mr. New York City Police Department Precinct 1 p) 212/334‐0611 http://www.panynj. Bayonne Reference Information Referred to Deputy Chief Keith Weaver of the Bayonne Fire Department.gov p) 973/578‐2158 Sargaent D'Amato does not believe this is a police department matter. King indicated that the Port Authority Police Department will review the application that is submitted to the Port Authority as part of the TAA process (see Reference Disk). Czuba is working to identify if any additional requirements will apply from the fire department. Mr.Table 2 ‐ Summary of Contacts. 12 . The results of the inquiry will be forwarded upon receipt. National Transportation Safety Board Office of Marine Safety Bill Curtis p) 202‐314‐6456 The NTSB has no authority over these matters as they are an investigation agency. If there was an incident. they may be called upon to investigate it. Bayonne Reference Information Officer Murphy returned a voicemail left for Chief Heacock.gov/xp/cgov/toolbox/conta importing the caustic soda.cbp.Table 2 ‐ Summary of Contacts. cts/ports/nj/4601. 13 . He indicated that since we are not Customs and Border Protection http://www. Customs and Border Protection would not be involved.xml p) 201/443‐0408 Officer Murphy Waterfront Commission Police Headquarters Carol Laurens p) 212/742‐9280 Repeated phone messages in July were not returned. No construction permits or regulatory requirements to implement. o A boom crane would be required to support the hose connection from the storage tank to the ship. Based upon the information gathered during this investigation. 14 . A redundant power supply may be needed. ground support will be needed to deploy for each delivery. Potential challenges with barge delivery include: Coordination between fuel barge and caustic barge.1. The temperature requirement will limit the distance that pipes can travel from the tanks to the ship.3. Contact information is provided in Table 1. emptying and storage of the caustic soda provides more opportunities for spills or accidents. has been identified that can supply the material by barge. Personnel bunkering the caustic soda would be wearing full personal protective equipment. o The storage tank(s) placement and design would have to be approved.3 Barge Delivery to Vessel Barge delivery is an attractive option at Cape Liberty: It will not interfere with the portside logistics. The material will have to be maintained at a temperature sufficient to prevent freezing. Only regulatory requirements include safe handling procedures and spill response responsibilities. It can be done without investment of port infrastructure. 3. it will have to go through the Port Authority approval process. The approval process could take several months or more (over a year): o The tanker trucks will have to back into a containment structure (permanent or temporary). Kuehne Chemical Company. Potential challenges with this scenario include: The Port Authority would have to grant approval for the infrastructure needed.1. The storage tank would be filled over several days prior to the ship’s arrival. If a permanent containment is constructed. It will be out of view of the passengers and most crew. barge delivery appears to be the most attractive option. The infrastructure would have to be maintained. If temporary. Only one supplier was identified that is capable of providing the material by barge. Continuous filling. A vendor. potentially within sight of boarding passengers.4 Tanker Truck to Onsite Storage Tank Several vendors were identified that could provide the caustic soda to an onsite above ground storage tank that could be installed at the port (see Table 1). Then the material would be transferred to the ship when it is in port. this option may be feasible. Therefore. it may be prudent for RCCL to conduct additional research into identifying a supplier. ground support will be needed to deploy for each delivery.3 Barge Delivery to Vessel A supplier has not been identified that can deliver the material by barge in Southampton. It will be out of view of the passengers and most crew. 15 . The tanker trucks will have to back into a containment structure (permanent or temporary). Based upon the research and interviews conducted (see Table 4). 3. delivering the required quantity (37. unless a supplier can be identified that can deliver the material by barge. it appears that an onsite storage tank will be required at this port.2 SOUTHAMPTON The results of inquiries into vendors for Southampton are provided in Table 3. therefore. Therefore. at the required quantity. for the same reasons that this delivery method is an attractive option in Bayonne. additional rail would be required. this is not a feasible option. Benefits include: It will not interfere with the portside logistics. If it is determined that only 6. potentially within sight of boarding passengers.2. However.000 to 10. This would have bunkering operations continuing for approximately 20 hours. A boom crane would be required to support the hose connection from the tanker to the ship.2.000 gallons) would take an average of 10 tankers each requiring approximately 2 hours to bunker their load. delivery at this port by tanker truck is not feasible. it will have to go through the Associated British Ports approval process. it is unlikely that sufficient separation between tanker and pedestrians can be accomplished.000 gallons were required during the port call. However. If temporary.2.3. If a permanent containment is constructed. it is equally as attractive in Southampton. However. It can be done without investment of port infrastructure. The installation of a crane would have to be approved through the Associated British Ports approval process. Due to the limited space portside. Based upon conversations with port authorities.2 Tanker Truck to Vessel Having tanker trucks delivered to the ship when it calls to Southampton is problematic for the required quantity: The vessel is in port for 10-12 hours. no rail car lines meet up to the port side. 3.1 Rail Car There is rail car availability at Southampton. the following should be considered: Personnel bunkering the caustic soda would be wearing full personal protective equipment. 3. However. co. frequency and mix required. However.uk Contact: John Holt Chemtek OrbisEnergy Wilde Street Lowestoft Suffolk NR33 1XH Tel: 0845 154 3330 Fax: 01502 539064 Email:
[email protected]. No additional consideration of this vendor is recommended. they withdrew from consideration.uk Web: www. no further contact upon asking for credentials. subsequently.co.altransliquids. FL11 5 AD England Ph: 01453 544 940 Email: info@altransliquids. frequency and mix required.uk Information Believed that delivery and transfer directly to the ship tanks by road tankers would be the best method. Stated they can supply the quantity. Altrans Liquids appears to be a suitable supplier for the caustic soda. However. frequency and mix required.Table 3 ‐ Summary of Vendor Inquiries. Believes feasible with onsite storage tank.71 per tonne).co. Very helpful and interested in the project. No additional consideration of this vendor is recommended.uk Altrans Liquids Ltd Sheephouse Farm. Although initially they appeared interested. Contact: Anthony Millard 16 . Originally stated they can supply the quantity. State they can supply the quantity. they cannot supply the quantities needed. At this screening level. Uley Road Gloucestershire. Southampton Reference Aquachem Office K/Redwither Business Centre Wrexham LL13 9XR 01978 664077 watertreatmentwaste.34 per litre (£222.uk ReAgent Chemicals 0800 990 3258 enquiries@reagent. Believed that delivery and transfer directly to the ship tanks by road tankers would be the best method.co. Estimated costs at this time: £0. No additional consideration of this vendor is recommended. Security and port permissions need to be verified for tanker access. co. Tuffa has prebuilt. Also able to supply NaOH in powder for mixing onsite. frequency and mix required. 17 . State they can supply the quantity. Whittaker Tankers Barge Company Southampton Docks Ph: 02380 339 989 Mrs.com Simon Hughes Ph: 07540 625 135 Nick Hughes Ph: 07734 440 268 Information Believes feasible with onsite storage tank.uk Tel: +44 (0) 1889 567700 Fax: +44 (0) 1889 567600 Only able to deliver oil. At this screening level. Security and port permissions need to be verified for tanker access. PBH Chemicals appears to be a suitable supplier for the caustic soda. Amy Bowd Sales Coordinator amy@tuffa. preheated and bundled tanks suitable and available.co. Southampton Reference PBH Chemicals Facility Services 323 Woodside Way Springvale Industrial Estate Cwmbran NP44 5BR Paul Hughes Ph: 07988 071 248 Email:
[email protected] http://www.Table 3 ‐ Summary of Vendor Inquiries. Table 4 ‐ Summary of Contacts.uk/mca/ Ph: 02380 329 100 Emailed June 9th and several follow up telephone calls were not returned. Woods on June 28th in relation to potential for storage tank to be erected at the port. No concerns providing that port arrangements are adhered to. safety and security matters. No 24 of 2011 (Builk Liquids Transfer Request Form). No 19 of 2011 (Dangerous Substances in Harbour Area) and No 10 of 2011 (Marine Safety Management Systems) are applicable and are included in the Resource CE. Port Security. Heagren on June 8th. Met with Mr.uk/yachting_and_leisure/notices_to_mariners/ In particular. but it is possible.gov.co.southamptonvts. He referred us to speak with Paul Wood. Very helpful with health.abports. 18 . No concerns as long as the NaOH is not dumped at sea and any spillage contained and properly managed.co. Escorted during the port visit and provided paperwork.uk Information Forms and requirements for the use and transportation of sodium hydroxide can be found on the website at http://www.uk ABP Health and Safety Manager David Fox ABP Port Security Officer Paul Woods ABP Port Agent Steve Heagren Not particularly helpful in telephone or email discussions. Southampton Reference Associated British Ports (ABP) Ocean Gate Atlantic Way Southampton SO14 3QN Tel: 023 80488692 www. RCCL will have to approach ABP directly to discuss.uk/conta ctus/default. ABP. procedures and security requirements for vendors. ABP Perry Dack Cruise Passenger Services Manager Dockside Handling Environment Agency Romsey Depot Bill Scott Environmental Enforcement Officer Ph: 03708 506 506 www. Met with Mr.aspx Maritime and Coastguard Agency John Simpson http://www.gov.co.dft. ABP Port Health and Safety Advisor Christopher Turner cturner@abports. Met with Mr. Dack on June 28th.environmentagency. Table 4 ‐ Summary of Contacts, Southampton Reference Beth Evans | Sales & Marketing Manager | Associated British Ports Ocean Gate | Atlantic Way | Southampton | SO14 3QN Tel: 023 8048 8844 | Mob: 07730047048 | www.abports.co.uk | www.abparking.co.uk Information Ms. Evans indicated that permission from ABP would be required to establish an aboveground tank at the site for Royal Caribbean's use. She indicated that the first step would be to contact the City Terminal Manager, Tom Dynes (
[email protected]). After Mr. Dynes understands the requirements, and determines suitable space is available, they can provide additional informaton on the permitting requirements and costs. 19 Only regulatory requirements include safe handling procedures and spill response responsibilities. Challenges with barge delivery include: Coordination between fuel barge and caustic barge. A supplier has not been identified in Southampton that is capable of providing the material by barge. 3.2.4 Tanker Truck to Onsite Storage Tank Several vendors were identified that could provide the caustic soda to an onsite above ground storage tank that could be installed at the port (see Table 3). The storage tank would be filled over several days prior to the ship’s arrival. Then the material would be transferred to the ship when it is in port. Potential challenges with this scenario include: Associated British Ports would have to grant approval for the infrastructure needed. The approval process could take several months or more: o The tanker trucks will have to back into a containment structure (permanent or temporary). If temporary, ground support will be needed to deploy for each delivery. If a permanent containment is constructed, it will have to go through the Associated British Ports approval process. o A boom crane would be required to support the hose connection from the storage tank to the ship. o The storage tank(s) placement and design would have to be approved. The material will have to be maintained at a temperature sufficient to prevent freezing. A redundant power supply may be needed. The infrastructure would have to be maintained. The temperature requirement will limit the distance that pipes can travel from the tanks to the ship. Personnel bunkering the caustic soda would be wearing full personal protective equipment, potentially within sight of boarding passengers. Continuous filling, emptying and storage of the caustic soda provides more opportunities for spills or accidents. Benefits include: It is the only feasible option at this time since a supplier by barge was not identified. Additional research into delivery by barge is recommended. 20 4 DESIGN CONSIDERATIONS While there are numerous design considerations that are outside the scope of this investigation, several were identified that are presented below. 4.1 GENERAL Based upon information gathered during this investigation, all design considerations must take into account the temperature at which the material will freeze, approximately 58°F (14°C). All storage (storage tanks on board the ship or at the port), transfer equipment, and transportation equipment must be heated to prevent freezing throughout most of the year at both ports. In accordance with the specifications prepared by Meyer Werft and supplied by RCCL: Any part of tank or tank fittings which may come in to contact with caustic soda should not contain the following metals or alloys: aluminum, magnesium, zinc, brass, and tantalum. Caustic soda corrodes these metals and the reaction may generate flammable hydrogen gas. Particularly reaction with aluminum is vigorous. Long term exposure to caustic soda can deteriorate materials containing silica, e.g. glass. It is recommended to check supplier’s compatibility information regarding gaskets for manholes and flanged tank fittings. Typically PTFE or EPDM should be used. Viton is not suitable as gasket or sealing material. Finally, any areas where the material is transferred must have immediate access to a safety shower and eye wash station. 4.2 VESSEL Given the various types of activities that occur while the ships are in port, the ideal location of connections for bunkering the caustic soda will vary depending upon the type of transfer (either by barge or aboveground storage tank). Connections that are at the extreme ends of the vessel may require heated pipe runs over long distances if the above ground storage tanks are at opposite ends of the vessel. Furthermore, regardless of the transfer method, connections will have to be accessible on both the port and starboard side to enable connections to the ship regardless of how it is docked. It is recommended that one (1) or more Chief Engineers review the plan layout for additional considerations. For instance, the Chief Engineer aboard the Independence of the Seas noted that in the event of a leak, the sodium hydroxide could destroy the integrity of equipment within the hull, such as electricity cabling. Also, the Chief expressed concerns that wind direction may potentially direct fumes in the direction of passengers. The design should include a plan for routine maintenance to inspect all tanks, piping, fittings and connections associated with the handling, storage and use of the caustic soda. 4.3 PORT In the event that aboveground storage tanks are used, the design and location of the tanks will have to account for access for tanker trucks within a contained system. The footprint of the tanks would be minimized if one (1) storage tank were used. However, given the density of the 21 material. piping and fittings exposed to the elements). the design should account for passenger visibility. piping. The location of the tanks will have to be made with approval from the port owners and managers. it was recommended that four (4) smaller tanks would be preferable. fittings and connections associated with the handling. Consideration to housing the tanks within a building should be evaluated to determine if it would be preferable over an extended period of time (reduction on wear and tear of the tank. The design should include a plan for routine maintenance to inspect all tanks. passenger proximity. 22 . as well as a permanent boom crane system to support the hose during bunkering operations. storage and use of the caustic soda. Additionally. com) and includes: a) Pamphlet 80 Recommended Practices for Handling Sodium Hydroxide Solution and Potassium Hydroxide Solution (Caustic) Barges b) Pamphlet 94 Sodium Hydroxide Solution and Potassium Hydroxide Solution (Caustic) Storage Equipment and Piping Systems c) Pamphlet 87 Recommended Practices for Handling Sodium Hydroxide Solution and Potassium Hydroxide Solution (Caustic) Tank Cars d) Pamphlet 65 Personal Protective Equipment for Chlor . and proximity of emergency showers and eye wash stations. A summary of regulatory requirements is provided in Table 5 (United States) and Table 6 (United Kingdom).5 REGULATORY REQUIREMENTS & RESOURCES Appendix IV contains a compact disk of various regulations. nearly all of the identified regulations will apply. It is recommended that vendors be sourced and contracted to respond to a release on land or on the ocean.2 INDUSTRY GUIDELINES Because caustic soda is a chemical used throughout the world for a variety of commercial and industrial applications. However. Occupational exposure precautions include appropriate training. 5. One of the most comprehensive compilations of best practices is published by the Chlorine Institute (www. airborne exposure limits. If storage tanks are constructed at the ports to house the caustic soda. A preliminary risk assessment was developed for the safe handling of the caustic soda based upon United States regulations and is presented in Appendix III. 23 . The selected vendors should be under contract to respond within 1 – 2 hours (if not sooner) of the report of a release.Alkali Chemicals A copy of these publications is included on the resource disk provided in Appendix IV. 5. use of protective clothing (full face and body splash protection). transportation and storage of caustic soda is regulated in both the United States and the United Kingdom.1 REGULATORY REQUIREMENTS The handling.cl2. there are many good resources for the safe and proper use of this material. only occupational exposure regulations and spill response will apply to the process. if the material is bunkered using a barge. forms and resources that were identified as part of the research for this project. An example of a suitable vendor is Ken’s Marine (see Table 1). or process.132 & Protective Equipment. Section VIII. 29 CFR 1910. therefore. Body and Feet Material Sampling: Face. used. Neck.5 (c)(1) states that if a standard is specifically applicable to a condition. including personal protective equipment for eyes. etc. unfired pressure vessels. It can rapidly cause damage to the eyes and skin as well as when inhaled or ingested. head. Eyes and Hands Loading (employee is away from loading connection): Head. practice. United States Reference Information OSHA 29 CFR 1910.262 (ll) Shut‐off Valves for Open Tanks & Vats Emergency shut off valves for holding tanks must be located at a distance which eliminates risk of coming in contact with the caustic soda in the event of a splash. shall be provided.262 (oo) prevails over more general regulations that may counteract it. Initial Line Break: Head. General PPE Requirements for Caustic Soda and maintained for those working with and around the Sodium Hydroxide. The Chlorine Institute's Pamphlet 65 protective clothing. respiratory devices. Proper PPE and other appropriate equipment is required to be provided to employees working with the Sodium Hydroxide. Valves shall conform to the ASME Pressure Vessel Code. Extreme caution must be exercised when working with this chemical. operation.262 (oo) Handling Caustic Soda Means shall be provided for handling and emptying caustic soda and caustic potash containers to prevent workers from coming in contact with the caustic. and extremities. Face. and protective shields and barriers. Hands.Table 5 ‐ Summary of Regulations. 1910. face. it shall prevail over any different general standard which might otherwise be applicable. All PPE equipment should be chemical resistant in the following conditions: 10‐50% NaOH Solution with an ambient temperature no greater than 120 degrees Fahrenheit. Eyes. OSHA 29 CFR 1910. Face. OSHA 29 CFR 1910. Eyes and Hands Open Dome‐ No Product Flow: Eyes Sodium Hydroxide is colorless and odorless and causes severe irritation when it comes in contact with human tissue. method. means. 24 . pollutants and contaminants.000 pounds where a 50% solution of NaOH contains approximately 6. a comprehensive work plan. safety and health training program. ~The written health and safety program must include but is not limited to: organizational structure. OSHA 29 1910. RCCL is to follow these guidelines for proper response.Table 5 ‐ Summary of Regulations. medical surveillance program and standard operating procedures for safety and health involving hazardous materials. in the case that there is an emergency. United States Reference OSHA 29 1910. Spills in excess of approximately 156 gallons are will require reporting to the National Response Center and the US Coast Guard. emergency response operations and a guidelines for a written health and safety program. When spills in excess of 156 gallons occur. site specific safety and health plan.4 pounds per US Gallon. EPA 40 CFR 300 National Oil and Hazardous Substances Pollution Contingency Plan: Subpart E‐ Hazardous Substance Response The organizational structure and procedures for preparing for and responding to discharges of oil and releases of hazardous substances. EPA 40 CFR 302.1200 Hazard Communication Ensures that the hazards of caustic soda is evaluated.20 Hazardous Waste Operations and Emergency Response Information It is required to either hire a company with properly trained personnel to be on call or train appropriate employees in 40 hour HAZWOPER. Relevant hazard communication should be added to RCCL's existing hazard communication documents. This section covers the clean up operations at uncontrolled hazmat waste sites. and that information concerning the hazards is transmitted to employers and the employees of RCCL that will be working with the hazardous material. 25 .4 Hazardous Substances & Reportable Quantities The reportable quantity for Sodium Hydroxide is 1. The holding tanks at the port and onboard the ship must be appropriately and thoroughly labeled in accordance with this regulation.16 Detailed hazardous materials incident reports Each person involved in the transport of the Sodium Hydroxide must submit a Hazardous Materials Incident Report to the US DOT Pipeline and Hazardous Materials Safety Administration. In the event of a spill.000 lbs. RCCL should refer to this section for management and clean up. The table identifies the hazard class and identification number. 49 CFR 172. and the costs that may be imposed or reimbursed for the removal of a discharge of oil or hazardous substances under the FWPCA.101 Purpose and use of hazardous materials table The table designates the materials listed therein as hazardous for the purpose of transportation. step‐by‐step procedures for proper use. first aid instructions and the stowage and segregation guidelines. United States Reference 46 CFR Part 147 Subpart A Hazardous Ships' Stores 33 CFR Part 153 Control of Pollution by Oil and Hazardous Substances. Sodium Hydroxide: Hazard Class 8 Identification Number UN1824 26 . (Reportable quantity for NaOH: 1.25 gallons) 49 CFR 171. or 156. The purpose of this part is to prescribe regulations concerning notification to the Coast Guard of the discharge of oil or hazardous substances as required by the Federal Water Pollutions Control Act.15 Immediate notice of certain hazardous materials incidents Information The Sodium Hydroxide must be labeled with the technical/proper shipping name. as amended (FWPCA).Table 5 ‐ Summary of Regulations. Discharge Removal 49 CFR 171. in the event of an incident. manufacturer's or supplier's name and address. the procedures for the removal of a discharge of oil. hazard classification (8 corrosive material). In the event of a spill of the reportable quantity or more. the National Response Center must be notified within 12 hours. Any person conducting remediation shall comply with this chapter and all guidance found on the New Jersey Department of Environmental Protection website. design. This New Jersey Statute should be reviewed by all personnel involved in working with the holding tanks at the port as well as onboard the ship. This chapter constitutes the minimum technical requirements to investigate and remediate contamination at any site. if implemented. and maintenance requirements for owners and operators of major facilities which handle hazardous substances.Table 5 ‐ Summary of Regulations. United States Reference Information NJAC 7:1E This chapter covers the discharge of hazardous substances. operations. reporting. The rules that are applicable to the owners or operators of major facilities storing. NJAC 7:1E‐1. 27 .8 Environmentally Sensitive Areas NJAC 7:1‐2 Prevention and Control of Discharges at Major Facilities NJAC 7:26E Technical Requirements for Site Remediation For the purposes of designing and implementing a DPCC and a DCR plan. for the state NJ Department of Environmental Protection of New Jersey. including Sodium Hydroxide. These rules set forth guidelines and procedures to be followed by all persons in the General Provisions event of a hazardous substance release. This New Jersey statute should be thoroughly reviewed as part of the holding tank design process. They also set forth certain registrations. It is important to review this section in designing site plans. the port of Bayonne area is an environmentally sensitive area. processing or using hazardous materials. transferring. Your obligations depend upon your role in the supply chain. Must provide information. Classification. if an ingredient is purchased from outside EU then they will need to register. 28 . Importer of substances or mixtures. and health surveillance. New European legislation derived from EU GHS ‐ (EC) No 1272/2008 (2009 ‐2015 7yr trans period) CLP effect on companies.hse. Requires substances to have MSDS sheets and Risk Assessments for storage and use. Register date for quantities >100 tonne should be registered before June 2013.europa. is physically introduced in the customs territory of the EU. http://www. However. If you place a hazardous substance on the market.uk/reach/resources/basics.gov.uk/ghs/backgrnd.eu/documents/10162/13562/clp_introductory_en. Suppliers may have one or more of these roles: Manufacturers of substances or mixtures. Distributor (including retailer). Authorisation and Restriction of Chemicals 2007 (Reach) Control of Substances Hazardous to Health (COSHH) 2002 Reach – if a supplier is importing caustic from outside EU they will need to register with Reach. Downstream user (including formulator and re‐importer). If they are manufacturing within EU and all “ingredients” are purchased from within EU they do not have to register with REACH. you must classify.pdf Works alongside REACH regulations. Producer of specific articles.eu/regulations/clp/clps‐effect‐on‐ companies) Guidance link‐ http://echa.gov.pdf Registration. Evaluation. Labelling and Packaging of Substances and Mixtures 2009 (CLP Regulations) If you are a supplier of chemicals. you must notify ECHA of its classification and labelling within one month of placing the substance on the market for the first time. The CHIP Regulations will be fully repealed in 2015 (http://www.europa. For importers.htm). instruction and training. label and package your substances and mixtures in accordance with the CLP Regulation. the one month is counted from the day when a substance. United Kingdom Reference Information Dangerous Substances Directive (67/548/EEC) These Directives have been implemented in the UK as the Chemicals (Hazard Information and Packaging) for Dangerous Preparations Directive (1999/45/EEC) Supply Regulations 2009 (CHIP[2][3]). (http://echa.Table 6 ‐ Summary of Regulations. on its own or contained in a mixture.hse. htm) 29 .uk/cdg/regs.unece. United Kingdom Reference European Agreement concerning the International Carriage of Dangerous Goods by Road.htm International des Marchandises Dangereuses par Route 1967 (ADR Agreement) United Nations Economic Commission for Europe (UN/ECE) Carriage of Dangerous Goods and Use of Came into force on 1 July 2009. Labelling and Packaging of Substances and Mixtures 2009 (CLP) The CHIP Regulations will be fully repealed in 2015 and replaced with CLP 2009.gov.Table 6 ‐ Summary of Regulations.legislation.gov.org) ADR link ‐http://www. (unece. They replace the 2007 regulations. Implemented through ADR.org/fileadmin/DAM/trans/danger/publi/adr/adr2011/ Accord European Relatif au Transport http://www. Information ADR is an agreement between states in EU. ADR applicable as from 1 January 2011. Transportable Pressure Equipment Regulations http://www.gov.uk/ghs/backgrnd.hse.hse.uk/uksi/2009/1348/contents/made 2009 CDG 2009 Health and Safety Executive SI 2009 No 1348 Classification. (http://www. use of personal protective equipment and routine monitoring of the entire system for evidence of wear) risk to people and the environment is considered minimal in the proposed closed loop caustic soda scrubbing process. It is recommended that RCCL use its purchasing power to negotiate with global manufacturers (such as Dow Chemical and Brenntag Global) to possibly identify more barge delivery options.6 CONCLUSIONS AND RECOMMENDATIONS It is feasible to source 37. Alternatively (and perhaps required). However. if RCCL decides to proceed with installation of storage tanks. it is recommended that RCCL formerly retain engineers to initiate the design process and engage the port authorities (PANYNJ and ABP) and regulatory agencies as soon as possible to meet a target date of November 2014. If RCCL decides that installation of storage tanks is the desired solution. 30 . sale of the caustic soda to other vessels may be considered to possibly off-set the implementation cost. tanker truck delivery directly to the ship will only be feasible if limited quantities (less than 10. With the appropriate risk management tools (training. SeaQuest recommends that professionals engaged in the process be given access to this report and the accompanying resource disk. There are excellent industry resources available to guide engineers in the design and implementation of use of caustic soda that are provided with this report. Rail car delivery does not appear to be an option at either port. Depending upon the projected industry use. although only one supplier in Bayonne and no suppliers in Southampton were identified. aboveground storage tanks appear to be options at both ports.000 gallons) are required. To be implemented. piping and boom crane) would be required. significant investment in time (approval process) and infrastructure (installation of the storage tanks. The preferred delivery method to the vessel appears to be by barge.000 gallons of caustic soda every two (2) weeks in the both the Port of Bayonne and the Port of Southampton. Given the time constraints while in port. housing structure. Mr. containment and boom infrastructure (to support the hose) would have to be installed. Dave Whelpley of Whelpley Construction (see Table 1) will be a good resource at the Port of Bayonne as he is currently working on the terminal improvements there. APPENDIX I PROVIDED DOCUMENTATION . 017 List of Alterations Kind of Alteration No. transfer and feed System NaOH 50 % Bunkering. 1) 2) 3) 4) 5) 752 V 1000 753 V 1000 721 V 1000 724 M 2000 711 M 2004 A List of Reference Drawings Description Service air Control air Technical water Boiler Wash and Exhaust Gas Cleaning LT Circle MWS 0.2013 Alt.2 Labels Plotdate: 23.2013 Kostilew 4772 100 % Material test 3.2013 Kostilew 4772 100 % See marked in grey.04.2013 Kostilew 4772 100 % Updates signed with arrows A 18.1. Date Name Tel.1.1.1.1.7--.04. transfer and feed System NaOH 50 % Bunkering.1. Operating fluids for exhaust gas cleaning System: Armatures Date .1.071 MWS 0.2013 List of Included Drawings Description 2 1100 1200 1300 1001 1002 General Description Material and Piping Standards Monitoring and Alarms via the “IAMCS” NaOH 50 % Bunkering. FG See marked in
[email protected] BGN 774 M 1100 General Description 774 M 1200 Pipe System specification 774 M 1300 Monitoring and Alarms via the “IAMCS” 774 M 1001 774 M 1002 NaOH 50 % Bunkering.04.7--.1. No.1 BGN 774 774 774 774 774 Sheet M M M M M Person in charge: Kostilew Owner: Vessel: BGN: DEPT.04. NO: Phone: +49(0)4961 81-4772 RCL S.de Date: 18.04.2013 Kostilew 4772 100 % Name 2. symboltable and details Sheet Description 2. Drawing No.1.2013 Kostilew 4772 100 % Updates signed with arrows A 18. A 18.2 A 18.697 774 M 1000 E-mail anatol. A 18. symboltable and details No.04.04. NO: Phone: +49(0)4961 81-4772 RCL S.1 Classification Class: Det Norske Veritas + 1 A1 Passenger Ship ECO. dated 31 March 2011 x General Electrical Requirements S.2.g.6 Ch.0 m³/h Type: Texel MES-050 16 meters (Caustic Soda) JLM Number: 527.04. IMO resolution MEPC.3 AOS’s AOS_059 (NOS 05899) 2.697 774 M 1100 E-mail daniel. Plotdate: 23.7 l Oper.15 Sec.de Date: 18. Tables: C9. in case of tank service or inspection. EQUIPMENT & CHARACTERISTICS 3. CLEAN DESIGN .4410 Maker: GEA Ecoflex GmbH Type: NT50M CDS-10 1.4 Alkali Transfer Pump (15P08) Capacity: Pressure: 10.4250 Maker: Seikow Chemical Engineering Machinery.2013 Capacity: Pressure: 20 m³/h 3.5 bar JLM Number: 527. F-M. K 3.04.4430 Maker: Reflex Type: reflex 25D 3.0°C). Classification & Regulations 2. x EU: Sulphur directive 2005/33/EC If any interpretation of class or Marpol rules is needed.184(59). C10 and C14. x IMO: Marpol Annex VI.0 bar JLM Number: 527. especially Exhaust Gas Cleaning System Guidelines. BIS EO.4240 Maker: 3M Pumps The alkali topping-up pump is used to transfer alkali from storage tanks to small built-in tanks of bleed-off treatment units. LCS-DC.2012 x Ship flag: Bahamas (Germany before ship delivery) x Ship classification: DNV x DNV: Vibration class Pt. SPECIFICATION & AOM’s 1.3 Rules and
[email protected] Rev. LT Expansion TK Expansion tank Capacity: 18.3 CST HEAT.4420 Maker: Behrens Pumpen Type: SFN 51A G 3.5 ALKALI TOPPING UP PUMP (15P18) Capacity: Pressure: 3.2013 System: Operating fluids for exhaust gas cleaning Alt. NAUT-AW.Person in charge: Kostilew Owner: Vessel: BGN: DEPT. Scheme B.A.5 meters (Caustic Soda) JLM Number: 527.1 HEAT EXCHANGER CAUSTIC SODA TANKS Plate Heat Exchanger Capacity: Imput: 19. Pressure: 6. dated 09.02.6 ALKALI DOSING PUMP(15P17) .0 m³/h Type: TSP MAG-P52 PP/PVDF 11. COMF-V (1) FUEL (380 cSt.3 m³/h 180kW JLM Number: 527. they should be clarified as early as possible. 3.2 NAOH STORAGE TK HEAT TRANSFER PUMP AOM_011 1. 1010 Kg/m³.2 AOM’s 3.2 Regulations The following rules and regulations apply: x Newbuilding Specification – RCL – P09140-C1. 2. Chapter: G3. 3. The first of each type of scrubber component will be measured at factory acceptance test.1 Specification Technical Specification SOx Scrubber System Rev. A Solution (Caustic) Storage Equipment and Piping System (Edition 3) GENERAL DESCRIPTION 1. LTD The alkali transfer pump is used to empty the alkali storage tank or one compartment to the other or to the bunker station e. Typically 50% NaOH (Sodium Hy. solution is used as alkali. After bunkering the transport truck’s delivery hose and the filling line are to be cleaned with compressed air and flushed with water.4230 Maker: IWAKI PUMPS The alkali dosing pump is used for pumping the alkali from the alkali storage tank to bleed-off buffer tank to keep the pH in the bleed-off buffer tank above 4pH.droxide).9 m³ NaOH Store TK 12S-2 57. Filling pipe material recommendation is AISI 316L or black steel DIN 2448. sensors and filters. 1310-73-2 EINECS No. The customer/operator should acquire the chemical according to the following specification.g.1 General Alkali is automatically added to the scrubbing water circulation when operating in closed loop mode to maintain the process pH and consequently the SOx removal efficiency. In normal operating conditions one pump is in operation and the other pump in stand-by. 215-185-5 ADDITIONAL TRADE NAME(S): CAUSTIC SODA 50%. Caustic soda storage tank should be provided with the following alarms: • Temperature high (set point 50ºC) • Temperature low (set point 20ºC) • Level low (e. Transport trucks are provided with several different connection types depending on supplier and country. alkali transfer pump. Tank Name Capacity NaOH Overflow TK 12S 6. also known as Caustic Soda or Lye. alkali dosing pump. Na-OH: 45… 52%-weight CHLORIDE (Cl) < 0. The alkali feed module consists of two chemical dosing pumps. The complete module includes also valves.4 meters (Caustic Soda) JLM Number:
[email protected] MPa JLM Number: 527.2013 System: Operating fluids for exhaust gas cleaning Alt.1%-weight as NaCl . The pH control uses information of the pH of the scrubbing water as input. Alkali storage tank air and overflow pipe are led in similar way as normal air and overflow pipes (e. Recommended cleaning interval for storage tank is 5 years. Pressure: 28.1 Alkali specification Wärtsilä scrubber system typically uses 50% NaOH solution as neutralizing agent in the process. 4.55kW Motor Steel Frame: AISI316L or equivalent Piping: Dry weight: 200 kg Weight in operation: 300 kg 3. To prevent any splashes in case of leakages the module is equipped with doors and drip tray. It is recommendation to use seal paste for pipe fillers.10 Storage tank NaOH The tank is divided into 3 compartments plus one overflow compartment to be able to handle even Plotdate: 23. including hydrostatic static pressure to air vent head above the bulkhead deck. Piping should be sloped downwards without pockets.10.0 m³ NaOH Store TK 12S-3 47. One pump is normally in operation and the other is stand-by. Adapters may be required.5 m³ NaOH Store TK 12S-1 50.g. alkali topping-up pump and alkali storage tank.9 Tank instruments Alkali tank filling line should be led below the minimum service level and should be provided with vacuum breaker hole at the upper end where anti siphon effect may occur.1 3. Therefore compressed air and water connections should be located near to bunkering stations. The main control is automatically adjusted based on the measured pH of scrubbing water.04. Detail 724 M ----1002 3. LYE 50% CHEMICAL COMPOSITION SODIUM HYDROXIDE.1. abovebulkhead deck and overboard). Also the tanks in the truck are to be cleaned with water.1 Tank coating Maker: International Marine Coatings Type: Interline 994 (Epoxy Phenolic Tank Coating) 4 System Description 4. 3. NO: Phone: +49(0)4961 81-4772 RCL S. The scrubbing water pH is regulated by the amount of alkali added to the circulation.52 t/m3.8 Tank outlet valves See automation chapter 2. 50% NaOH solution specification (typical for marine scrubber): SODIUM HYDROXIDE (NaOH) 50% SOLUTION .de Date: 18.697 774 M 1100 E-mail daniel.g.7 ALKALI FEED MODULE 2 (15N04/1 and 15N04/2) Alkali feed module consists of two pumps. Main components in alkali system are alkali feed modules. It is also possible to pump between the compartments.04.2013 0. 30%) • Level high (e. 85%) Instead of sounding pipe an approved type local hydrostatic level indicator can be used.4220 527. note that devices need to be calibrated for caustic soda density.4210 Maker: Metso Type: 0. A small amounts of alkali.0 m³ Tank for 50% NaOH should be dimensioned for specific density of 1. 3.Capacity: Pressure: 100 l/h Type: LK-F47VS Person in charge: Kostilew Owner: Vessel: BGN: DEPT.TECHNICAL QUALITY TECHNICAL NAME: SODIUM HYDROXIDE SOLUTION 50% (WATER SOLUTION) CHEMICAL FORMULA: NaOH (aq) CAS No. 4 FUEL Part 6.6 BIS Part 3. Chapter 9 LOADING COMPUTER SYSTEMS FOR STABILITY AND LONGITUDINAL STRENGTH Does not apply for this system. 5. The recommended storage temperature is between 25 and 35°C. tanks and sounding pipes. and tantalum.697 774 M 1100 E-mail daniel. The warning sign to be used is standard “corrosive 8” sign.Person in charge: Kostilew Owner: Vessel: BGN: DEPT.5 LCS-DC Part 6.3 The requirements for the safety Caustic soda bunkering areas.g. alkali feed module area and bleed-off treatment units. If the safety shower is located out-doors.2 Alkali feed module shutdown is connected to the emergency stop. The module is equipped with drip tray. System: 5. NO: Phone: +49(0)4961 81-4772 RCL S. See Appendix 1 for more information of NaOH Plotdate: 23. Viton is not suitable as gasket or sealing material. A .2013 NOTE! Any part of tank or tank fittings which may come in to contact with caustic soda should not contain the following metals or alloys: aluminium. 5. The drip tray triggers an alarm in case of leakage (LS501at 527.3 4. CLASS NOTATION 5. Long term exposure to caustic soda can deteriorate materials containing silica e. The safety showers should be clearly marked with dedicated signs.de Date: 18. zinc.4220) 4. glass. Caustic soda corrodes these metals and the reaction may generate flammable hydrogen gas. with text “Sodium Hydroxide Solution” and “UN 1824” nearby. Chapter 3 EQUIPMENT AND SYSTEM NOTATION UNATTENDED MACHINERY SPACE Does not apply for this system. Particularly reaction with aluminium is vigorous. brass.7 E0 Part 6. Typically PTFE or EPDM should be used.2 Operating fluids for exhaust gas cleaning COMF-V(1) Part 5 Chapter 12 COMFORT CLASS Does not apply for this system 5. Corrosive properties of caustic soda are aggravated at temperatures above 49°C (when carbon steel is used) and thus caustic soda storage should not have common structures with e. Chapter 1 SHIPS BUILT FOR IN WATER SURVEY Does not apply for this system.04. Safety showers (with shower and eye wash) be arranged for relevant alkali handling areas. heated fuel oil service and settling tanks. It is recommended to check supplier’s compatibility information regarding gaskets for manholes and flanged tank fittings. Additionally texts “NaOH Solution” and “Caustic Soda Solution” can be included as well. 5. Chapter 8 NAUTICAL SAFETY Does not apply for this system.3 Storage tank heating 50% caustic soda is solidifying at temperatures below 12°C and therefore the tank should preferably be located so that it shares common boundaries with engine room as far as possible. 5.2013 5. Chapter 14 FUEL TREATMENT AND CONDITIONING SYSTEMS Does not apply for this system 5.04. feed module and pipes be provided with warning signs to ensure that all crew members are aware of the hazards involved in general and in particular when any maintenance or repairs are made. Following personal protective equipment must be worn when handling alkali: • Impervious overalls • Protective clothing • Chemical boots • Safety helmet • Safety goggles or face shield All locations where alkali is handled are to be provided with good ventilation. Chapter 3 PERIODICALLY UNATTENDED MACHINERY SPACE Does not apply for this system 5. If the tank temperature is expected to drop below 16°C additional heating should be provided. magnesium.g. Chapter 12 ENVIRONMENTAL CLASS Does not apply for this system.8 NAUT-AW Part 6. Chapter 4 ADDITIONAL FIRE PROTECTION Does not apply for this system.4210 and LS502 at 527. Alt. such as bunker stations. F-M Part 6. it must be insulated and heat traced in order to prevent freezing (Bunker station).1 ECO Part 6.jamaer@meyerwerft. See automation 3.9 CLEAN DESIGN Part 6. Store TK’s Heat requirement 5.0 SAFE RETURN TO PORT Plotdate: 23.5 kW 57.0 Cool fresh w.0 39.16 * /t «¬ h »¼ Medium 7.0 20. Person in charge: Kostilew Owner: Vessel: BGN: DEPT.3 4.4 kW 161 kW * * Q ª m³ º * 1. A .697 774 M 1100 E-mail
[email protected]. . Heat [kW] V [m³/h] P [bar] T in [°C] T out [°C] LT fresh w. the following systems can to be treated: There are no special regulations because the cleaning system isn’t essential for propulsions. The following operating data are based on: Value Ambient temperatures: + 45 °C Ambient air temperature: min.0 4. NO: Phone: +49(0)4961 81-4772 RCL S.2013 CALCULATIONS The pumps and heat exchangers for propulsion are designed according to information of supplier for tropical conditions.7°C Sea water temperature: + 0°C Engine room temperature: +20°C Performance: heating up within 24 h Tank Name NaOH Overflow TK 12S NaOH Store TK 12S-1 NaOH Store TK 12S-2 NaOH Store TK 12S-3 Sum.2013 Operating fluids for exhaust gas cleaning With regard to ‘Safe Return to Port’ regulations. General data V System: Alt. ± 0 °C max.6. (hot) 180 22.0 32.04.de Date: 18. + 32 °C Seawater temperature inlet Design temperature + 32 °C Seawater temperature outlet + 48 °C Tank heating System The layout of heating surfaces is based on the following conditions: Outside air temperature: . + 35 °C Seawater Sea water: min.0 28.7 °C. 36 h in harbour max.1 kW 51.0 kW 47. (cold) 180 19. 04. NO: Phone: +49(0)4961 81-4772 RCL S.2013 System: Operating fluids for exhaust gas cleaning Alt.Plotdate: 23. A
[email protected] 774 M 1200 E-mail daniel.de Date: 18.2013 Person in charge: Kostilew Owner: Vessel: BGN: DEPT. 2013 Person in charge: Kostilew Owner: Vessel: BGN: DEPT.04. NO: Phone: +49(0)4961 81-4772 RCL S. A .04.697 774 M 1200 E-mail daniel.Plotdate: 23.2013 System: Operating fluids for exhaust gas cleaning Alt.de Date: 18.jamaer@meyerwerft. 697 774 M 1200 E-mail daniel.2013 Person in charge: Kostilew Owner: Vessel: BGN: DEPT.de Date: 18. A . NO: Phone: +49(0)4961 81-4772 RCL S.04.2013 System: Operating fluids for exhaust gas cleaning Alt.Plotdate: 23.04.jamaer@meyerwerft. de Date:
[email protected] 774 M 1300 E-mail daniel. A .2013 System: Operating fluids for exhaust gas cleaning Alt. NO: Phone: +49(0)4961 81-4772 RCL S.2013 Person in charge: Kostlew Owner: Vessel: BGN: DEPT.Plotdate: 23. NO: Phone: +49(0)4961 81-4772 RCL S. A .de Date: 18.04.2013 Person in charge: Kostlew Owner: Vessel: BGN:
[email protected] System: Operating fluids for exhaust gas cleaning Alt.697 774 M 1300 E-mail daniel.Plotdate: 23. 697 774 M 1300 E-mail daniel.Plotdate: 23.2013 System: Operating fluids for exhaust gas cleaning Alt.2013 Person in charge: Kostlew Owner: Vessel: BGN:
[email protected] Date: 18. NO: Phone: +49(0)4961 81-4772 RCL S. A . . . Typically 50% NaOH (Sodium Hydroxide). alkali feed module area and bleed-off treatment units. Additionally texts "NaOH Solution " and "Caustic Soda Solution" can be included as well. alkali dosing pump. Figure 7. tanks and sounding pipes.a4 14 March 2013 7-1 .hWJtilfil Environmental Technologies 7.1 "Corrosive 8" sign Safety showers (with shower and eye wash) should be arranged for relevant alkali handling areas. The scrubbing water pH is regulated by the amount of alkali added to the circulation . Main components in alkali system are alkali feed modules. alkali transfer pump.g. it must be insulated and heat traced in order to prevent freezing . also known as Caustic Soda or Lye. with text "Sodium Hydroxide Solution " and "UN 1824" nearby. such as bunker stations.Scrubber. solution is used as alkali.2 Safety shower and eye wash signs Following personal protective equipment must be worn when handling alkali: Meyer Werft 697 . The pH control uses information of the pH of the scrubbing water as input. The requirements for the safety shower are defined e. Alkali Feed System Alkali is automatically added to the scrubbing water circulation when operating in closed loop mode to maintain the process pH and consequently the SOx removal efficiency. in standard SFS 5411. One pump is normally in operation and the other is stand-by. Caustic soda bunkering areas. alkali topping-up pump and alkali storage tank. If the safety shower is located outdoors. The safety showers should be clearly marked with dedicated signs. Figure 7. anq feed module should be provided with warning signs to ensure that all crew members are aware of the hazards involved in general and in particular when any maintenance or repairs are made. The main control is automatically adjusted based on the measured pH of scrubbing water. The warning sign to be used is standard "corrosive 8" sign.1 General Installation Planning Instructions 7. Alkali Feed System 7. The alkali feed module consists of two chemical dosing pumps. . engine specific fuel oil consumption and fuel sulphur content..5%5fu e l I • 3.3 Storage Onboard storage capacity is dictated by the following parameters: vessel autonomy. .2 Consumption Alkali consumption depends on the concentration of the solution.-· 2tl0 <( -- 10 0 0 '5000 10000 15000 20000 2 5000 Operating power(kW) 30000 35000 40000 As a rule of thumb the alkali consumption can be estimated to be 5 liters/MWh per fuelS%. s:: - .__ 300 .ifl@"iiii Installation Planning Instructions 7. ..5%5 fue l 2P 5 ftJe l • 1.5%5 fue l • •• •• • '500 - no • ..a4 14 March 2013 .. It also indicates the relations of the affecting parameters.-+·----+-----' .. 7..05fuel - 2.. The alkali supply is automatically controlled based on these parameters. E ll I ]! - -L 3. alkali consumption and vessels operation profile and area. when using 50% caustic soda A'lka'li demand per eng'ine power 80 - 700 - ~ '6 00 ~ GJ E.. 7..-_ __.. Figure 7. Indication of the alkali consumption can be seen in the figure below.. See Appendix 1 for more information of NaOH...or:.3 Alkali consumption per operating power. .__.5! Q. engine operating power. 7-2 Meyer Werft 697 .. Alkali Feed System Environmental Technologies I Impervious overalls Protective clothing Chemical boots Safety helmet Safety goggles or face shield All locations where alkal i is handled are to be provided with good ventilation.Scrubber . To minimize the transportation costs and ease the bunkering arrangement. The temperature limits should be respected as above 49°C temperatures carbon steel is susceptible to stress corrosion cracking.0% 5 fue l . brass.5% .. special measures including weld stress relieving and use of alternative materials should be considered case by case. 400 +-----~----~~~-h~~~~~---+=r~-~-·----4. Particularly reaction with aluminum is vigorous. . magnesium.. Air vents need to be arranged from the highest points designed according to rules of applicable classification society. . by comparing it to the fuel consumption.------~----~ . The ideal storage capacity should be at least 1. when using 50% caustic soda Alka li demand per fuel consumption 2000 . glass. Tank should be externally or internally stiffened.0%5 fue l 1. If higher tank temperatures are expected. also known as "caustic embrittlement". Caustic soda corrodes these metals and the reaction may generate flammable hydrogen gas. --~ 600 200 1 .4 Alkali consumption per consumed fuel...-·- 800 ········ ..5%5 fue l § .. For vessels that are operating in regular routes or in specific areas.. the corresponding alkali consumption is 630 m3 per year.· ik/t9Jt11M Environmental Technologies I Installation Planning Instructions 7.. "" 1000 t: ·0 . .. General shipbuilding steels can be used for tank construction. NOTE! Any part of tank or tank fittings which may come in to contact with caustic soda should not contain the following metals or alloys: aluminum.a4 14 March 2013 7-3 . When using a hybrid scrubber the capacity of the storage tank is dependent on the time when closed loop or hybrid mode is used. When alkali tank location and volume are outlined.. tank capacity should be adequate to receive the total volume from one delivery truck. 5%Sfu~ l lSOO - _1600 'E - 1400 a 1200 ~ 3. including hydrostatic static pressure to air vent head above the bulkhead deck. . ... .g.. Tank bottom should preferably be sloped towards drain pipe. Alkali Feed System Figure 7.. Recommended cleaning interval for storage tank is 5 years. high density of 50% caustic soda solution and the margin against overfilling {15-20%) are to be considered .2. zinc.. A single tank configuration can be used. and tantalum... Long term exposure to caustic soda can deteriorate materials containing silica e..5 times the volume of the truck.3. If alkali is bunkered every two weeks the required amount is 24 m3. In each case when tank construction involves structural members special consideration by classification society is required. On top of this some margin should be added to take into account the increasing effect of possible higher sulphur content or different operating profile.- 0 0 2000 4 00 6000 00 10000 12000 14000 16000 1 000 20000 Fuel consumption (ton) Required storage tank capacity can be calculated e.. It is recommended to check supplier's compatibility information Meyer Werft 697 . There is generally no limitation to tank geometry. .. Due to the relatively high density of caustic soda a low center of gravity for storages may be favorable regarding vessel stability. If ship's annual fuel consumption is 10 000 ton and average fuel sulphur content 2... .. if operation and regulation compliance with low sulphur fuel is a possible and feasible alternative during the above mentioned periods.g. the storage capacity could be equal to the fuel bunkering interval.52 tfm3 .5 % 5 fue l • • • • • • 2.Scrubber. Integrity of storage tank and related air vents should be hydrostatically tested prior the tank coating.. .. Tank for 50% NaOH should be dimensioned for specific density of 1. The temperature of the substrate should be minimum 10°C and at least 3°C above the dew point of the air.2 Example products for tank coating from Teknos Coating for buffer and alkali tanks 7-4 Product Teknos lnerta 280 Description Used as coat in epoxy systems inside kerosene and oil tanks. Temperature Max 70°C Specific gravity Film thicknesses 400 J.Jm Colours Red . The coating should not be exposed to oil.1 Example products for tank coating from Jotun Coating for buffer and alkali tanks Product Marathon 2:1 Description High solids.1? Primer Marathon 2:1. Withstands aliphatic hydrocarbons. 7.Jm Colours Limited selection Pre-treatment Sa2V2 (ISO 8501-1) Surfaces All surfaces should be clean and free from contamination.5 kg/1 Film thicknesses 500 J. two-pack epoxy coating reinforced with glass flakes. The temperature of the ambient air. Viton is not suitable as gasket or sealing material. Fully cured after 7 days.4 Tank coating Internal tank coating is recommended to avoid corrosion that may occur particularly on tank upper parts. Alkali Feed System Environmental Technologies regarding gaskets for manholes and flanged tank fittings. Suppliers ' recommendation is to be followed concerning intended use. Major suppliers have epoxy resins that are suitable for this purpose. Pink Finish Marathon 2:1. Table 7. Other products with similar properties can also be used. For aggressive chemical exposure. green or white Pre-treatment Sa2Y2 (ISO 8501-1) Surfaces The surface must be dry and least 4 weeks old.k@ij!§i Installation Planning Instructions 7. The surface should be assessed and treated in accordance with ISO 8504. The relative humidity of the concrete should not exceed 80%.Scrubber. temperature and relative humidity measured in the vicinity of the substrate. In the following some example coatings are presented. Touch dry after 12 hours. Typically PTFE or EPDM should be used. surface or paint should not fall below + 10°C. alkaline solutions and acids.a4 14 March 2013 . Grey Table 7. Steel structures subject to aggressive exposure. surface preparation and application. chemicals or mechanical stress until cured. Thinner Teknosolv 6560 Primer Teknos lnerta 280 Finish Teknos lnerta 280 Meyer Werft 697 . The surface temperature should remain at least 3°C above the dew point. both atmospheric and mechanical. Thinner Jotun Thinner No. Touch dry after 4 hours. Temperature Withstands +70°C in immersion Specific grafity 1. Drying times Dust dry after 3 hours.5 hours. Fully cured after 7 days. Drying times Dust dry after 5. 3 Example products for tank coating from Tikkurila Coating for buffer and alkali tanks Product Tikkurila TEMALINE BL TES Description Two component. Finish TEMALINE BL Product SIGMASHIELD 460 (LT) Description Two component high solids glass flake reinforced polyamine adduct tar free epoxy coating . Temperature Withstands + 150°C dry heat and +60°C in immersion Specific gravity 1.Scrubber .gloss (light colours on request) Pre-treatment Sa2Y2 (ISO 8501-1) Surfaces All surfaces should be clean and free from contamination. alkali and salts in immersion . The temperature of the ambient air. The same heat transfer coefficients through the external tank walls that are typically used for heavy fuel oil are applicable.a4 14 March 2013 7-5 . Storage tank heating requirement can be determined by calculating heat transfer through each tank boundary. Alkali Feed System Table 7.1) Surfaces All surfaces must be dry. exhaust gas or steam pipes) should be isolated from tank structures. Maximum relative humidity during application and curing is 85%. Relative humidity should not exceed 80 %. Touch dry after S hours. Thinner Thinner 10S1 or acetone Primer TEMALINE BL Drying times Dust dry after 8 hours. Good resistance to acids. Thinner Sigma Thinner 91-92 Drying times Overcoating interval min 16 hours. The surface temperature of the steel should remain at least soc above the dew point. solvent free epoxy coating.5 kg/1 Film thicknesses Min 400 iJm Colours Black . Fully cured after 7 days. Coating for buffer tank Temperature Specific gravity 1. Also other heat sources that may locally increase temperature inside the tank to exceed the before mentioned value (e.lf/N'Irilfti Environmental Technologies Installation Planning Instructions 7.4 kg/1(mixed) Film thicknesses 500 iJm Colours Red and green Pre-treatment Sa2Y2 (ISO 8501. Primer SigmaCover 280 (min 50 iJm) Finish 7. Suitable to be used as a heavy duty coating on steel and co ncrete surfaces exposed to chemical and mechanical stress in immersion. Touch dry after 12 hours. surface or paint should not fall below+ 1ooc during application and drying. Meyer Werft 697 . Suitable for coating of lead-free tanks. Fully cured after 7 days. If the tank temperature is expected to drop below 16°C additional heating should be provided. The temperature of the substrate should be between -1ooc up to 15°C during application and curing and at least soc above the dew point and free from ice and any contaminations.5 Storage tank heating 50% caustic soda is solidifying at temperatures below 12°C and therefore the tank should preferably be located so that it shares common boundaries with engine room as far as possible. The recommended storage temperature is between 25 and 35°C . heated fuel o il service and settling tanks.g.g. In some cases external tank insulation could be considered to reduce heat losses . The surface should be assessed and treated in accordance with ISO 8504. Corrosive properties of caustic soda are aggravated at temperatures above 49°C {when carbon steel is used) and thus caustic soda storage should not have common structures with e. Curing to hardness takes longer in lower temperatures and complete resistance will be reached when temperature increases. for example nickel. To avoid corrosion of heating coils external surface. the storage tank should be equipped with a quick closing valve. Heating coils should be positioned to provide heating particularly in suction pipe area. note that devices need to be calibrated for caustic soda density. if turbulent flow conditions can be achieved. inlet water temperature should remain below 49°C. Piping should be sloped downwards without pockets.Scrubber . feed} the lines are located below the alkali storage tank level. Filling pipe material recommendation is AISI 316L or black steel DIN 2448. Also in these cases the specified heating elements should not exceed maximum surface temperature. Therefore compressed air and water connections should be located near to bunkering stations. transfer. if relevant) Level low (e. Also the tanks in the truck are to be cleaned with water. Adapters may be required. Relevant classification society's rules concerning sounding requirements should be verified. Local temperature gauge (gauge with stainless steel pocket) Each caustic soda storage tank should be provided with a standard 600 mm x 400 mm manhole. In these cases the appropriate heat exchanger material should be selected. It is recommendation to use seal paste for pipe fillers.g. Alkali Feed System RMiJijld Environmental Technologies I If heat losses from the tank are remarkable. Sight glasses are not recommended . if provided with heating) Temperature low (set point 20°C. Mean heat transfer coefficient from water coils to caustic soda can be estimated to 60 W/(m2 x 0 C}. returning LT cooling water can be utilized for heating and heating coils can be connected in parallel to the central cooler.t) between the lower storage temperature (25°C} and the arithmetic mean temperature of incoming I outgoing circulating water. 30 %) Level high (e. An alternative heating method is to provide a separate caustic soda circulation through an external heat exchanger. For example. Thus the heating media can be low pressure steam or high temp heat recovery water. If heat losses are moderate. 85%) Caustic soda storage tank should be provided with the following indications: Local level gauge (hydrostatic type with sensor isolating valve). also external electric heating can be used. 7. Transport trucks are provided with several different connection types depending on supplier and country.Installation Planning Instructions 7.6 Storage tank fitting and instruments When anywhere in the alkali system (bunkering . Diameter is according to installation specific system diagram.a4 14 March 2013 . Alkali tank filling line should be led below the minimum service level and should be provided with vacuum breaker hole at the upper end where anti siphon effect may occur. 7-6 Meyer Werft 697 . Instead of sounding pipe an approved type local hydrostatic level indicator can be used. Heating coil dimen sioning is based on the differential temperature (t-. Each connection below the maximum surface level should be provided with safety quick closing valves. The alkali feed module shut-off valve should be installed before alkali feed modules 15N04 and possible other alkali pumps. heating with water circulation in carbon steel coils can be used.g. The central cooler pressure drop or a dedicated circulation pump can be used for induced circulation depending on the pressure drop in the tank heating system. The primary suction should be located approximately 100 mm from storage tank bottom. Tanks should also be provided with low suction for complete draining prior to maintenance. Heating elements are adhesive and attached directly to the tank wall under the insulation. After bunkering the transport truck's delivery hose and the filling line are to be cleaned with compressed air and flushed with water. Caustic soda storage tank should be provided with the following alarms: Temperature high (set point 45°C. Coils should be installed to an approximate height of 300 mm from tank bottom and located so that thermal agitation pattern will occur. sensors and filters. Module connection "A" vertical location to be max 1000 mm above bottom of alkali storage tank. Figure 7.g. Alkali Feed System Figure 7. To prevent any splashes in case of leakages the module is equipped with doors and drip tray. above bulkhead deck and overboard).a4 14 March 2013 7-7 .5 Caustic soda storage tank fittings TI I HD HOLE Alkali storage tank air and overflow pipe are led in similar way as normal air and overflow pipes (e.7 Alkali feed module Alkali feed module consists of two pumps. the air pipe end should be protected by a plate or similar means. Number: One module per scrubber Meyer Werft 697 . To minimize the suction line length the preferred location of the alkali feed module is near the storage tank.i?fUiifii Environmental Technologies I Installation Planning Instructions 7. In normal operating conditions one pump is in operation and the other pump in stand-by.6 Example of "spray protector" plate for alkali storage tank air and overflow pipe. The complete module includes also valves. To prevent spraying of alkali. FROM NaOH STORAGE TANK 7.Scrubber. Installation Planning Instructions 7.1 kW Weight: 37 kg Meyer Werft 697.8 pH control of the bleed-off buffer tank To keep the pH in the bleed-off buffer tank above 4pH there will be alkali feed to bleed-off recirculation line. Drip trays are to be provided at the lowest point with such a leak detector that automatically activates the NaOH storage tank quick closing valve.10 Alkali topping-up pump The alkali topping-up pump is used to transfer alkali from storage tanks to small intermediate tank near aeration tank and to small built-in tanks of bleed-off treatment units. 7. The module is equipped with drip tray. Selected pump type is self-priming. automatic drainage to safe tank. The drip tray drainage should be arranged with one of the following alternatives: Alternative 1. and provided with heating where necessary to avoid stiffening of the caustic soda. Alternative 3. Selected pump type is self-priming.25 kW Weight: 14 kg 7. Capacity: 100 1/h Motor: 0. drain pipes from the drip trays are conducted freely flowing back to the NaOH storage tank or any other suitable tank. A sensor in the drip tray triggers an alarm in case of leakage. In the flow rate has been taken into account that the delivery head of topping-up pump is max 11.5 meters and suction height max 1.55 kW Frame: Steel Piping : AISI316L or equivalent Dry weight: 200 kg Weight in operation: 300 kg Width : 900mm Depth: 700 mm Height: 1950 mm f¥iiQibJ Environmental Technologies I Alkali feed module shutdown is connected to the emergency stop. Such drip trays are without drainage. Vertical conditions permitting . A sensor in the drip tray triggers an alarm in case of leakage. Such drain pipes should be of adequate size. Alkali Feed System Type: Chemical dosing Motor: Approx 0. automatic quick closing valve.9 Alkali dosing pump The alkali dosing pump is used for pumping the alkali from the alkali storage tank to bleed-off buffer tank when pH drop below the set value. Alternative 2. The pH will be measured from the recirculation line and the alkali is only dosed if the pH is below the set value. alarm. 7. Capacity: 3 m3Jh 7-8 Motor: 1.5 meters. Drip trays are to be of adequate capacity to receive such leak quantity which may escape from the system prior to closing of the quick closing valve. Leak detection and quick closing system are to be of fail to safe type.Scrubber. The main components in the bleed-off buffer tank pH control are alkali dosing pump and pH sensor. The bleed-off treatment unit uses the alkali for adjusting the pH to correct level as required by the other treatment chemicals in the treatment process.a4 14 March 2013 . including quantity in the supply pipe. . ..185-5 ADDITIONAL TRADE NAME(S): CAUSTIC SODA 50%... .. .. ...... . ..12 Alkali specification Wartsila scrubber system typically uses 50% NaOH solution as neutralizing agent in the process............. ... ..............Scrubber .... .......... . ...... DBAC4587 43 DBAC458676 DBAC458676 DBAC458669 DBAC458669 Alkali transfer pump manual ..... ..... 7-19 Alkali topping-up pump . ......... ............. In the flow rate has been taken into account that the delivery head of alkali transfer pump is max 16 meters and suction height max 1... .... ........................ .................. ...... . ....... ..... ............. ............................ 7-11 DBAC458743 - Alkali transfer pump ........ . .. . LYE 50% CHEMICAL COMPOSITION SODIUM HYDROXIDE. ... . ....... ..... The customer/operator should acqu ire the chemical according to the following specification .. ... . ... .... . ...... ................... ....13 Drawings DBAC471142DBAC471141- Alkali feed module ... . .......... Capacity: 10 m3/h Motor: 3....5 meters..a4 14 March 2013 7-12 7-9 ...... 7-18 Alkali dosing pump manual .7 kW Weight: 84 kg 7..... ... .. ..... 50% NaOH solution specification (typical for marine scrubber): SODIUM HYDROXIDE (NaOH) 50% SOLUTION -TECHNICAL QUALITY TECHNICAL NAME: SODIUM HYDROXIDE SOLUTION 50 % (WATER SOLUTION) CHEMICAL FORMULA: NaOH (aq) CAS N:o 1310-73-2 EINECS N:o 215.... .. 52 %-weight OH CHLORIDE (CI) < 0.. ..........45 .IMJti!fii Environmental Technologies I Installation Planning Instructions 7. ... in case of tank service or inspection....... .. ....... .. Na................. ..... ..... ...... ..... ... ................ .... ... ... 7-1 0 Alkali feed module .11 Alkali transfer pump The alkali transfer pump is used to empty the alkali storage tank or one compartment to the other or to the bunker station e............. 7-13 Alkali dosing pump .......... Alkali Feed System 7. ..... .. .................. .......................... .... ............... ... ................... ...... ....... Selected pump type is self-priming.. ..... . . 7-61 - Meyer Werft 697 ....... ...... ... .......... ..g.... ..................1 %-weight as NaCI 7........... .......... ........... .. ...... 7-60 Alkali topping-up pump manual . .......... ........... ... .......... .............. ........ ...... ..... APPENDIX II HAZARDOUS SUBSTANCE FACT SHEET – SODIUM HYDROXIDE . ~ Medical observation is recommended for 24 to 48 hours after overexposure . cellophane. nose and throat. SEE G LOSSARY ON PAGE 5. as pulmonary edema may be delayed . 3=senous. Seek medical attention immediately. which should not be exceeded at any time.I.. while flushing . and pulp and paper. It is used to make textiles. Contact can irritate the mouth. ~ Begin rescue breathing (using universal precautions) if breathing has stopped and CPR if heart action has stopped . even though air levels are less than the limits listed above. EMERGENCY NUMBERS Poison Control: 1-800-222-1222 CHEMTREC: 1-800-424-9300 NJDEP Hotline: 1-877-927-6337 National Response Center: 1-800-424-8802 CAS Number: 1310-73-2 RTK Substance Number: 1706 DOT Number: UN 1823 (solid) UN 1824 (solution) EMERGENCY RESPONDERS >»> SEE LAST PAGE Hazard Summary Hazard Ratin~:~ HEALTH FLAMMABILITY REACTIVITY CORROSIVE DO NOT USE WATER NFPA 3 0 1 NJDOH - Hazard Rat(ng Key: 0-mrmma/. in soaps and detergents. Sodium Hydroxide is a HIGHLY CORROSIVE CHEMICAL and contact can severely irritate and burn the skin and eyes with possible eye damage. . if worn . Inhaling Sodium Hydroxide can irritate the lungs. a medical emergency. ACGIH . Seek medical attention immediately. Workplace Exposure Limits OSHA: The legal airborne permissible exposure limit (PEL) is 2 mg/m 3 averaged over an 8-hour workshift. NIOSH. you may be overexposed. Sodium Hydroxide in contact with water or moisture may generate enough heat to ignite combustibles. 1=s/rght.. 4=severe ~ ~ ~ ~ ~ ~ Sodium Hydroxide can affect you when inhaled and by passing through the skin . Reasons for Citation ~ ~ Sodium Hydroxide is on the Right to Know Hazardous Substance List because it is cited by OSHA. Repeated exposure can lead to permanent lung damage. Sodium Hydrate Chemical Name: Sodium Hydroxide Date: May 2001 Revision : April2010 Description and Use Sodium Hydroxide is an odorless. ACGIH : The threshold limit value (TLV) is 2 mg/m should not be exceeded at any time . . Inhalation ~ Remove the person from exposure. lifting upper and lower lids. . Higher exposures may cause a build-up of fluid in the lungs (pulmonary edema).!!!!!IHazardous Substance Fact Sheet Right to Know common Name: SODIUM HYDROXIDE Synonyms: Caustic Soda. Skin Contact ~ Quickly remove contaminated clothing . When skin contact also occurs. and for etching and electroplating. Immediately flush with large amounts of water for at least 30 minutes. . 2=moderate. Lye. which The above exposure limits are for air levels only. NIOSH: The recommended airborne exposure limit (REL) is 2 mg/m 3 . FIRST AID Eye Contact ~ Quickly brush off excess chemical from the face.. Remove contact lenses. ~ 3 . . NFPA and EPA. DOT. ~Transfer promptly to a medical facility. This chemical is on the Special Health Hazard Substance List.. white solid that absorbs moisture from the air. Immediately blot or brush off excess chemical and wash gently with large amounts water for at least 30 minutes. ~ The New Jersey Right to Know Act requires most employers to label chemicals in the workplace and requires public employers to provide their employees with information concerning chemical hazards and controls. read the New Jersey Department of Health Hazardous Substance Fact Sheet. Health Hazard Information Acute Health Effects The following acute (short-term) health effects may occur immediately or shortly after exposure to Sodium Hydroxide: ~ ~ ~ Contact can severely irritate and burn the skin and eyes with possible permanent eye damage (corneal opacities) .C. Duration of exposure.nj.J. the following are recommended before beginning work and at regular times after that: ~ Lung function tests If symptoms develop or overexposure is suspected . Mixed Exposures ~ Smoking can cause heart disease. phlegm . causing blindness. This Fact Sheet is a summary of available information regarding the health hazards that may result from exposure. This is based on test results presently available to the NJDOH from published studies.gov/health/eoh/rtkweb) or in your facility's RTK Central File or Hazard Communication Standard file. Medical Testing For frequent or potentially high exposure (half the PEL or greater). Reproductive Hazard ~ There is no evidence that Sodium Hydroxide affects reproduction. Higher exposures may cause a build-up of fluid in the lungs (pulmonary edema). a medical emergency. stopping now will reduce your risk of developing health problems.A. ~ Repeated exposure can lead to permanent lung damage. The federal OSHA Hazard Communication Standard (29 CFR 1910. and under the federal Occupational Safety and Health Act (OSHA) if you are a private worker. Inhaling Sodium Hydroxide can irritate the lungs causing coughing and/or shortness of breath . Other Effects ~ Sodium Hydroxide can irritate the lungs. Medical tests that look for damage already done are not a substitute for controlling exposure. the following are recommended : ~ ~ Consider chest x-ray after acute overexposure Exam of the eyes and vision Any evaluation should include a careful history of past and present symptoms with an exam. available on the RTK website (www. Request copies of your medical testing . Chronic Health Effects The following chronic (long-term) health effects can occur at some time after exposure to Sodium Hydroxide and can last for months or years: Cancer Hazard ~ According to the information presently available to the New Jersey Department of Health. Repeated exposure may cause bronchitis to develop with coughing . You have a legal right to this information under the OSHA Access to Employee Exposure and Medical Records Standard (29 CFR 1910. with severe shortness of breath.1200) and the PEOSH Hazard Communication Standard (N. 12:100-7) require employers to provide similar information and training to their employees . and other respiratory problems .1 020).Page 2 of6 SODIUM HYDROXIDE Determining Your Exposure ~ Read the product manufacturer's Material Safety Data Sheet (MSDS) and the label to determine product ingredients and important safety and health information about the product mixture. nose and throat. ~ For each individual hazardous ingredient. concentration of the substance and other factors will affect your susceptibility to any of the potential effects described below. lung cancer. It may worsen respiratory conditions caused by chemical exposure. and/or shortness of breath. Even if you have smoked for a long time . Medical ~You have a right to this information under the New Jersey Worker and Community Right to Know Act and the Public Employees Occupational Safety and Health (PEOSH) Act if you are a public worker in New Jersey. Contact can irritate the mouth . Sodium Hydroxide has not been tested for its ability to cause cancer in animals. . emphysema. "' Wash hands carefully before eating. "' Extinguish fire using an agent suitable for type of surrounding fire. The following recommendations are only guidelines and may not apply to every situation . "'Leave the area immediately if (1) while wearing a filter or cartridge respirator you can smell . particulate filter respirator with an N. or the equivalent. "' Always wash at the end of the workshift. Fire Hazards If employees are expected to fight fires. as described in the OSHA Respiratory ProtectionStandard (29 CFR 1910. "' Change into clean clothing if clothing becomes contaminated. "' Sodium Hydroxide in contact with water or moisture may generate enough heat to ignite combustibles. "' Safety equipment manufacturers recommend Butyl . applying cosmetics or using the toilet. Respiratory Protection Improper use of respirators is dangerous. "' Consider all potential sources of exposure in your workplace. Safety equipment suppliers and manufacturers can provide recommendations on the most protective glove and clothing material for your operation. prefilters or cartridges to protect against different forms of a chemical (such as vapor and mist) or against a mixture of chemicals. Neoprene. or those that are reproductive hazards or sensitizers. In addition.134). "' Wear a face shield along with goggles when working with corrosive. and medical exams . Sodium Hydroxide itself does not burn. smoke. Respirators should only be used if the employer has implemented a written program that takes into account workplace conditions. processed or stored . DO NOT DRY SWEEP. R or P1 00 filter.cdc. Personal Protective Equipment The OSHA Personal Protective Equipment Standard (29 CFR 191 0. consult the NIOSH document on Control Banding at www. headgear) should be clean. Wear personal protective equipment made from material which can not be permeated or degraded by this substance. or otherwise detect Sodium Hydroxide. Check to make sure the respirator-to-face seal is still good. "' Use water spray to keep fire-exposed containers cool. You may need a combination of filters. the following may be useful or required: "' Use a vacuum to reduce dust during clean-up. "'POISONOUS GASES ARE PRODUCED IN FIRE. or drink in areas where chemicals are being handled. air-purifying. More protection is provided by a full facepiece respirator than by a half-mask respirator.gov/niosh/topics/ctrlbanding/. footwear. require expert advice on control measures if a less toxic chemical cannot be substituted. and (3) using general ventilation to control exposures to skin and eye irritants. Page 3 of6 Eye Protection "' Wear eye protection with side shields or goggles. If the possibility of exposure above 10 mg/m exists.156). (2) using local exhaust ventilation for chemicals that may be harmful with a single exposure . you may need a new respirator. DO NOT get water inside containers. and Trellchem® HPS and VPS . gloves. use a NIOSH approved self-contained breathing apparatus with a full facepiece operated in a pressure-demand or other positive-pressure mode equipped with an emergency escape air cylinder. and Tychem® SL. drinking. Provide employees with hazard information and training. If the seal is no longer good . (2) while wearing particulate filters abnormal resistance to breathing is experienced . available each day. "' Get special training to wash contaminated clothing . and even greater protection is provided by a powered-air purifying respirator. "' Wash or shower if skin comes in contact with a hazardous material. "'Do not eat. highly irritating or toxic substances. use a NIOSH approved supplied-air respirator with a full facepiece operated in a pressure-demand or other positive-pressure mode. If it is. as protective clothing materials for Sodium Hydroxide solid or solution. replace the filter or cartridge. and put on before work. Gloves and Clothing "'Avoid skin contact with Sodium Hydroxide.SODIUM HYDROXIDE Workplace Controls and Practices Very toxic chemicals. . Use engineering controls if concentrations exceed recommended exposure levels. Viton and Barrier® as glove materials for Sodium Hydroxide in solution . Control measures include: (1) enclosing chemical processes for severely irritating and corrosive chemicals. Nitrile. or (3) eye irritation occurs while wearing a full facepiece respirator. requirements for worker training .132) requires employers to determine the appropriate personal protective equipment for each hazard and to train employees on how and when to use protective equipment. For increased protection use in combination with an auxiliary self-contained breathing apparatus or an emergency escape air cylinder. "' Where the potential for high exposure exists. smoking . "' Provide eye wash fountains and emergency showers. respirator fit testing. The following work practices are also recommended : "' "' "' "' Label process containers. taste. For further information on workplace controls. Monitor airborne chemical concentrations. 3 "' Where the potential exists for exposure over 2 mg/m . use a NIOSH approved negative pressure. 3 "'Exposure to 10 mglm is immediately dangerous to life and 3 health . Silver Shield®/4H®. they must be trained and equipped as stated in the OSHA Fire Brigades Standard (29 CFR 191 0. "' Do not take contaminated clothing home. and Responder®. Polyvinyl Chloride. "' All protective clothing (suits . ... For Sodium Hydroxide in solution .. .. earth . . ..SODIUM HYDROXIDE Spills and Emergencies If employees are required to clean-up spills . . and MOISTURE to rapidly release heat... If Sodium Hydroxide is spilled or leaked. . CHLORINE. Sodium Hydroxide reacts with STRONG ACIDS (such as HYDROCHLORIC. WATER . It may be necessary to contain and dispose of Sodium Hydroxide as a HAZARDOUS WASTE . Store in tightly closed containers in a cool .gov/health/eoh/rtkweb The Right to Know Hazardous Substance Fact Sheets are not intended to be copied and sold for commercial purposes. NITRATES. . and ORGANIC MATERIALS ...120) may apply. PLASTICS. CHLORINATED SOLVENTS... BROMINE and FLUORINE)....us Web address: http://www.. AMMONIA.. they must be properly trained and equipped. nj.state. SULFURIC and NITRIC). Handling and Storage Prior to working with Sodium Hydroxide you should be trained on its proper handling and storage . Contact your state Department of Environmental Protection (DEP) or your regional office of the federal Environmental Protection Agency (EPA) for specific recommendations . PEROXIDES.... and industrial hygiene and medical investigations and evaluations. NJ 08625-0368 Phone: 609-984-2202 Fax: 609-984-7407 E-mail: rtk@doh .. well-ventilated area away from WATER and MOISTURE . . Eliminate all ignition sources . Sodium Hydroxide can form shock sensitive salts on contact with NITROGEN CONTAINING COMPOUNDS (such as NITROMETHANE) . Evacuate personnel and secure and control entrance to the area. Sodium Hydroxide reacts with METALS (such as ALUMINUM . or a similar material and place into sealed containers for disposal. DO NOT wash into sewer. These services include providing informational resources.. CHLORATES. absorb liquids in dry sand . Sodium Hydroxide can attack IRON. Sodium Hydroxide is not compatible with OXIDIZING AGENTS (such as PERCHLORATES. LEAD . educational materials. . PERMANGANATES. .. . public presentations... .nj. please contact: New Jersey Department of Health Right to Know PO Box 368 Trenton . . TIN and ZINC) to form flammable and explosive Hydrogen gas . Page 4 of6 Occupational Health Information Resources The New Jersey Department of Health offers multiple services in occupational health. For more information. RUBBER and COATINGS.. Collect solid material in the most convenient and safe manner and place into sealed containers for disposal... DO NOT USE WATER OR WET METHOD. . COPPER. take the following steps: . Ventilate and wash area after clean-up is complete.. The OSHA Hazardous Waste Operations and Emergency Response Standard (29 CFR 1910. liquid or solid that causes destruction of human skin or severe corrosion of containers. evaluates and approves respirators. liquid. The critical temperature is the temperature above which a gas cannot be liquefied. Acute Exposure Guideline Levels (AEGLs) are established by the EPA. miscarriages. A flammable substance is a solid . and proposes standards to OSHA. which are the regulations of the United States government. vapor or gas that will 1gmte eas1ly and burn rapidly. DOT is the Department of Transportation . mg/m3 means milligrams of a chemical in a cubic meter of air. CFR is the Code of Federal Regulations. A teratogen is a substance that causes birth defects by damaging the fetus. IARC is the International Agency for Research on Cancer a scientific group. A mutagen is a substance that causes mutations. ' Ionization Potential is the amount of energy needed to remove an electron from an atom or molecule. at the same temperature and pressure. DEP is the New Jersey Department of Environmental Protection . regardless of the pressure applied . liquid or gas that releases energy under certain conditions. . ppm means parts of a substance per million parts of air. assigned by the Chemical Abstracts Service . The higher the vapor pressure the higher concentration of the substance in air. Boiling point is the temperature at which a substance can change its physical state from a liquid to a gas. They describe the risk to humans resulting from once-in-a lifetime. It is a measure of concentration (weighUvolume) . NIOSH is the National Institute for Occupational Safety and Health. identifying number. It classifies substances according to their fire and explosion hazard.SODIUM HYDROXIDE Page 5 of6 GLOSSARY ACGIH is the American Conference of Governmental Industrial Hygienists. LEL or Lower Explosive Limit. EPA is the Environmental Protection Agency. exposure to airborne chem icals. maintained by federal EPA. STEL is a Short Term Exposure Limit which is usually a 15mlnute exposure that should not be exceeded at any time during a work day. A fetus is an unborn human or animal. NTP is the National Toxicology Program which tests chemicals and reviews evidence for cancer. It is a guide for emergency responders for transportation emergencies involving hazardous substances. ERG is the Emergency Response Guidebook. PEOSHA i~ the New Jersey Public Employees Occupational Safety and Health Act. Vapor Density is the ratio of the weight of a given volume of one gas to the weight of another (usually Air) . A mutation is a change in the genetic material in a body cell. which adopts and enforces health and safety standards. the federal agency that regulates the transportation of chemicals. A corrosive substance is a gas. NFPA is the National Fire Protection Association. It is measured in electron volts. conducts studies of workplace hazards. UEL or Upper Explosive Limit is the highest concentration in air above which there is too much fuel (gas or vapor) to begin a reaction o~ explosion . Protective Action Criteria (PAC) are values established by the Department of Energy and are based on AEGLs and ERPGs. Mutations can lead to birth defects. The CAS number is unique. liquid or gas that will burn . It tests equipment. is the lowest concentration of a combustible substance (gas or vapor) in the air capable of continuing an explosion . It is a measure of concentration by volume in air. The flash point is the temperature at which a liquid or solid g1ves off vapor that can form a flammable mixture with air. the federal agency responsible for regulating environmental hazards. OSHA is the federal Occupational Safety and Health Administration . They are used for emergency planning of chemical release events. A carcinogen is a substance that causes cancer. or rare. IRIS is the Integrated Risk Information System database on human health effects that may result from exposure to various chemicals. A combustible substance is a solid . to a specific chemical. Permeated is the movement of chemicals through protective materials. Emergency Response Planning Guideline (ERPG ) values prov1de estimates of concentration ranges where one reasonably might anticipate observing adverse effects . which adopts and enforces health and safety standards in public workplaces. The vapor pressure is a force exerted by the vapor in equilibrium with the solid or liquid phase of the same substance. A reactive substance is a solid. They publish guidelines called Threshold Limit Values (TLVs) for exposure to workplace chemicals. or cancer. 8-hr TWA 3 NIOSH: 2 mg/m . if worn . Nitrile. WATER. earth . Use water spray to keep fire-exposed containers cool. 0. and ORGANIC MATERIALS. Sodium Hydroxide is hazardous to the environment. POISONOUS GASES ARE PRODUCED IN FIRE. Remove contact lenses.. PEROXIDES.I Health! Right to Know Hazardous Substance Fact Sheet -. and MOISTURE to rapidly release heat. Sodium Hydroxide reacts with METALS (such as ALUMINUM . AMMONIA.SCBA 3 FIRST AID AND DECONTAMINATION Remove the person from exposure. BROMINE and FLUORINE).1(air=1) Vapor Pressure: 0 mm Hg at 68°F (20°C) Specific Gravity: 2. CHLORINE. especially water organisms.Health Extinguish fire using an agent suitable for type of surrounding fire . PVC. Viton and Barrier® (>8-hr breakthrough for Sodium Hydroxide in solution) Coveralls: Tychem® SL and Responder®. SULFURIC and NITRIC). or a similar material and place into sealed containers for disposal. Sodium Hydroxide in contact with water or moisture may generate enough heat to ignite combustibles . NITRATES. Sodium Hydrate CAS No: 1310-73-2 Molecular Formula: NaOH RTK Substance No: 1706 Description: Odorless.Full facepiece APR with High efficiency filters 3 >10 mglm . SilverShield®I4H®. Sodium Hydroxide is not compatible with OXIDIZING AGENTS (such as PERCHLORATES. Sodium Hydroxide can form shock sensitive salts on contact with NITROGEN CONTAINING COMPOUNDS (such as NITROMETHANE) . throat and lung irritation with coughing and severe shortness of breath (pulmonary edema) PROTECTIVE EQUIPMENT Gloves: Butyl . CHLORINATED SOLVENTS. Ceiling 3 ACGIH : 2 mglm .~«- Emergency Responders Otick Refnnce Common Name: SODIUM HYDROXIDE Synonyms: Caustic Soda. burns and possible eye damage Skin: Irritation and severe burns Inhalation: Nose. Seek medical attention immediately. Neoprene.534°F (1 . PERMANGANATES. DO NOT wash into sewer. 1 (water = 1) Water Solubility: Soluble Boiling Point: 2. RUBBER and COATINGS. Sodium Hydroxide can attack IRON. Immediately blot or brush off excess chemical and wash with large amounts of water for at least 30 minutes. Ceiling 3 10 mg/m IDLH: The Protective Action Criteria values are: 3 3 PAC-2 = 5 mglm PAC-1 = 0.-. DO NOT USE WATER OR WET METHOD. Sodium Hydroxide reacts with STRONG ACIDS (such as HYDROCHLORIC. Quickly remove contaminated clothing. DO NOT get water inside containers.. PLASTICS. April2010 . Quickly brush off excess chemical from the face . Transfer promptly to a medical facility. Medical observation is recommended as symptoms may be delayed. Vapor Density: 2. Lye. TIN and ZINC) to form flammable and explosive Hydrogen gas.Fire 1 . Sodium Hydroxide itself does not burn. LEAD. Neutralize water spills with a dilute acid . CHLORATES. Flush with large amounts of water for at least 30 minutes. white solid that absorbs moisture from the air HAZARD DATA Hazard Rating Firefighting Reactivity 3.390°C) Melting Point: 604°F (318°C) Molecular Weight: 40 EXPOSURE LI MITS 3 OSHA: 2 mg/m . Collect solid material in the most convenient and safe manner and place into sealed containers for disposal. Seek medical attention immediately. COPPER.5 mg/m PAC-3 = 50 mg/m 3 H EALTH EFFECTS Eyes: Severe irritation. and Trellchem® HPS and VPS (>8-hr breakthrough for Sodium Hydroxide solid or solution) Respirator: <1 0 mg/m .Reactivity DOT#: UN 1823 (solid) UN 1824 (solution) ERG Guide #: 154 Hazard Class: 8 (Corrosive) PHYSICAL PROPERTIES SPILL/LEAKS Isolation Distance: Odor Threshold: Odorless Spill (solid): 25 meters (75 feet) Fire: 800 meters (1/2 mile) Flash Point: Noncombustible Spill (liquid) : 50 meters (150 feet) For Sodium Hydroxide in solution absorb liquids in dry sand . Begin artificial respiration if breathing has stopped and CPR if necessary. APPENDIX III PRELIMINARY RISK ASSESSMENT . This preliminary risk assessment will address the following issues: a. these regulations are based on sound. this risk assessment would require review and possible modification to comport with any details.PRELIMINARY RISK ASSESSMENT FOR THE USE OF CAUSTIC SODA IN AN ENGINE EXHAUST STACK SCRUBBING SYSTEM 1. or Sodium Hydroxide. is a highly corrosive chemical and contact with this substance can severely irritate and burn the skin and eyes leading to possible blindness. Protective Measures c. Sodium Hydroxide. 2. Residual Risk Summary 3. INTRODUCTION The process in consideration involves adding 50% Caustic Soda solution to the scrubbing water of an Alkali Feed System operating in closed loop mode for the purpose of removing acid sulfur gases from engine stack emissions. CAS Number: 1310‐73‐2 iv. Although the regulations may not be required for workers employed in international waters. Risk Management f. Caustic Soda. Chemical Formula: NaOH iii. Synonyms: Caustic Soda. PROLOGUE This risk assessment is referred to as a “Preliminary Risk Assessment” because it pertains to a process that is contemplated for use but does not presently exist. The following risk assessment cites several United States Federal Occupational Safety and Health Regulations (OSHA) applicable to workers involved in the process being considered. Hazard Identification b. information derived from specific job safety analyses and other characteristics of the process that are presently unknown. Regulations Applicable to Caustic Soda d. RTK Substance Number: 1706 Appendix III – Page 1 SeaQuest Testing & Consulting – Preliminary Risk Assessment . Risk Assessment e. Product Identification i. HAZARD IDENTIFICATION a. The potential hazards of working with Caustic Soda make it important that all persons handling Caustic Soda know and follow strict procedures for safety. Lye. Should the process be implemented. Sodium Hydrate ii. state of the art industrial hygiene principles that provide a safe and healthy environment for workers. Eye contact: May cause irritation (possibly severe). clear Workplace Exposure Limits i. e. absorbs moisture from air ii. Product Description i. iii. Remove contaminated clothing. d. This material is a strong irritant and is corrosive to all human tissue. the length of tissue contact time. jewelry. Ingestion: May cause irritation (possibly severe). forcibly holding eyelids apart to ensure complete irrigation of all eye and lid tissues. First Aid i.b. chemical burns. chemical burns. GET MEDICAL ATTENTION IMMEDIATELY. Eye Contact: Immediately flush eyes with a directed stream of water for at least 15 minutes. After exposure there may be a time delay before irritation and other effects occur. and vomiting. c. DOT Number: UN 1823 (solid). and shoes immediately. Washing eyes within several seconds is essential to achieve maximum effectiveness. OSHA: The legal airborne permissible exposure limit (PEL) is 2 mg/m3 averaged over an 8‐hour work shift. iv. ii. which should not be exceeded at any time. Caustic Soda is on the Right to Know Hazardous Substances List which requires employers using this material to comply with the Federal OSHA Hazard Communication Standard (29 CFR 1910. white solid. eye damage. Inhalation: May cause irritation (possibly severe). nausea. ii. v. and blindness. Skin contact: May cause irritation (possibly severe) and chemical burns. Skin Contact: Immediately flush contaminated areas with water from a safety shower. NIOSH: The recommended airborne exposure limit (REL) is 2 mg/m3. Note: The severity of tissue damage is a function of its concentration. v. Potential Health Effects i. ii. NIOSH: The airborne concentration likely to cause death or immediate or delayed permanent adverse health effects or prevent escape from such an environment (IDLH) is 10 mg/m3. chemical burns. 50% Solution: odorless. and local tissue conditions. Wash the affected skin for 15 minutes. iii. Hazardous Waste Number: D002 vii. If the eyes have not been exposed do not remove your goggles until your head and hair has Appendix III – Page 2 SeaQuest Testing & Consulting – Preliminary Risk Assessment .1200). and pulmonary edema. Solid state: odorless. ACGIH: The threshold limit value (TLV) is 2 mg/m3. which should not be exceeded at any time. iv. UN 1824 (solution) vi. Thoroughly clean and dry contaminated clothing before reuse. Completely contain spilled material with dikes. If vomiting occurs spontaneously. to rapidly release heat. vi. ii. Sodium Hydroxide reacts with STRONG ACIDS (such as HYDROCHLORIC. and ORGANIC MATERIALS. NITRATES. iii. Sodium Hydroxide is not compatible with OXIDIZING AGENTS (such as PERCHLORATES. iii. GET MEDICAL ATTENTION IMMEDIATELY. Neutralize with weak acid (acetic acid) if necessary. If respiration or pulse has stopped. LEAD. keep airway clear. iii. f. iv. etc. Sodium Hydroxide can form shock sensitive salts on contact with NITROGEN CONTAINING COMPOUNDS (such as NITROMETHANE). sandbags. acid or incompatible materials may cause splattering and release of large amounts of heat. BROMINE and FLUORINE). Stability and Reactivity i. CHLORINE. Vacuum up for reuse or disposal. v. PERMANGANATES. Give large amounts of water. If breathing is difficult. remove to uncontaminated area. Give more water when vomiting stops. SULFURIC and NITRIC). Inhalation: If adverse effects occur. Give artificial respiration if not breathing. do not induce vomiting. AMMONIA. Wash contaminated areas with soap and water. Sodium Hydroxide reacts with METALS (such as ALUMINUM. Carefully dilute remaining material vi. Ingestion: Never give anything by mouth to an unconscious or convulsive person. v. Reactivity/ Stability: Stable at normal temperatures and pressures. oxygen should be administered by qualified personnel. Will react with some metals forming flammable hydrogen gas. Conditions to Avoid: Mixing with water. ii. TIN and ZINC) to form flammable and explosive Hydrogen gas. Accidental Releases i. CHLORATES. PEROXIDES. Notes to Physician: The absence of visible signs or symptoms of burns does NOT reliably exclude the presence of actual tissue damage. CHLORINATED SOLVENTS. Probable mucosal damage may contraindicate the use of gastric lavage. v. Wear appropriate personal protective equipment recommended in section 4 below. If swallowed. g. Discard contaminated leather goods. iv. Appendix III – Page 3 SeaQuest Testing & Consulting – Preliminary Risk Assessment . GET MEDICAL ATTENTION IMMEDIATELY. iv. Evacuate personnel and secure and control entrance to the area. WATER.been thoroughly rinsed. have a trained person administer basic life support (Cardio‐ Pulmonary Resuscitation/Automatic External Defibrillator) and CALL FOR EMERGENCY SERVICES IMMEDIATELY. Fire Fighting: Move container from fire area if it can be done without risk. The threshold limit for Caustic Soda is 1. state and local authorities if threshold limits are exceeded.. iv. they must be trained and equipped as stated in the OSHA Fire Brigades Standard (29 CFR 1910. Skin and Body Protection: Wear chemical resistant clothing and rubber boots when potential for contact with the material exists. viii.134 must be followed whenever workplace conditions warrant use of a respirator. iii. If employees are required to clean up spills. Cool containers with water. Contaminated clothing should be removed.vii. ii. Polyvinyl Chloride. Hand Protection: Wear appropriate chemical resistant gloves iv.S. h. The OSHA Hazardous Waste Operations and Emergency Response Standard (29 CFR 1910.120) may apply. Provide an emergency eye wash fountain and quick drench shower in the immediate work area. a full face style mask should be used. iii. spill reports to the National Response Center (1‐800‐424‐ 8802) will comply with federal reporting requirements under CERCLA and SARA regulations. mist) cartridges may be permissible under certain circumstances where airborne concentrations are expected to exceed exposure limits. Nitrile. Viton v. Appendix III – Page 4 SeaQuest Testing & Consulting – Preliminary Risk Assessment . Extinguishing Media: Use media appropriate for surrounding fire. Respiratory Protection: A NIOSH approved respirator with N95 (dust. 4. Accidental releases to the environment may trigger reporting requirements to federal. PROTECTIVE MEASURES a. The Coast Guard may also need to be notified under the Clean Water Act. ix. fume. Neoprene. then discarded or laundered.156). they must be properly trained and equipped. If eye irritation occurs. A respiratory protection program that meets 29 CFR 1910. Personal Protective Equipment i. or when symptoms have been observed that are indicative of overexposure.000 lbs. In the U. Fire Hazard: Caustic Soda is not flammable ii. Protective Material Types: Natural rubber. Fire Emergency i. If employees are expected to fight fires. Eye Protection: Wear chemical safety goggles with a face shield to protect against eye and skin contact when appropriate. ii. such as cleaning storage tanks. physical and chemical characteristics (such as vapor pressure and flash point). its manufacturer and appropriate hazard warnings. b. 5. Employers must have a material safety data sheet (MSDS) for each hazardous chemical in its workplace. common name and names of chemical ingredients in the hazardous chemical. REGULATIONS APPLICABLE TO CAUSTIC SODA a. use a NIOSH approved supplied‐air respirator with a full face piece operated in a pressure‐demand or other positive‐pressure mode. Safety showers should be located directly above the eyewash fountains. iv. For increased protection use in combination with an auxiliary self‐contained breathing apparatus or an emergency escape air cylinder. whether the chemical will cause cancer.Where the potential for high exposure exists. Eyewash and safety showers should be designed to comply with 29 CFR 1910. The program must list all hazardous chemicals known to be in the workplace and tell employees about non routine tasks (such as cleaning out tanks) that might expose them to the hazardous chemicals. health hazards (such as signs and symptoms of exposure). The label must identify the chemical. 29 CFR 1910. precautions for safe handling and use (including protective measures). Private sector workers in New Jersey are covered by Federal OSHA. Other Protective Measures i. iii. the name and telephone number of the manufacturer or other Appendix III – Page 5 SeaQuest Testing & Consulting – Preliminary Risk Assessment . permissible exposure limits. The MSDS must include (among other things) the identity used on the container label. iv.151(c)—Medical Services and First Aid. explosion and reactivity to other substances that are incompatible). how the chemical can enter your body. emergency and first aid procedures. Employees must be trained to read such labels. Diking able to contain the entire volume of Caustic Soda in the system should be installed. physical hazards (such as potential for fire.1200—Hazard Communication Standard—requires that employees be informed of chemical hazards in their workplace. b. Containers of hazardous chemicals must be labeled. ii. Some highlights of the standard follow: i. Eyewash fountains should be located near all caustic soda handling areas. iii. Employers must develop and implement a written hazard communication program and make that program available to employees. when the MSDS was prepared or last changed. Compensation.000 lb. vi. of hazardous substances without regard to location of the hazard. lines of authority and lines of communication.10. The Coast Guard may also need to be notified under the Clean Water Act. personal protective equipment and emergency procedures).000 lbs. and protective measures (including work practices.source that can provide additional information (including emergency procedures). e. Employees must be taught to use them. Employees must be trained in how to detect the presence of a hazardous chemical. EMS. v. c. and the local fire department with jurisdiction over the facility. its health hazards. iii. These requirements include a written emergency response plan. If a release is reportable under CERCLA section 103. training. and Liability Act of 1980—Accidental releases i. d. The MSDSs must be readily accessible to employees during each work shift. The threshold for Caustic Soda is 10. Emergency Response Plan must address the following: a. CERCLA Reportable Quantity for Caustic Soda: 1. personnel roles. Appendix III – Page 6 SeaQuest Testing & Consulting – Preliminary Risk Assessment .. police. is present in an amount exceeding a specified threshold. the Local Emergency Planning Committee. Such a facility must submit a material safety data sheet (MSDS) for each hazardous chemical which meets or exceeds a specified threshold quantity at the facility. to the state emergency response commission. d. i.e. (note: this is well below the projected weekly use). Employees must be informed of the location of hazardous chemicals. 29 CFR 1910. notify the National Response Center at (800) 424‐8802 or (202) 426‐2675. control and cleanup. etc. Certain requirements must be complied with under the HazWOPER standard. ii. Reporting thresholds are codified in 40 CFR 370. b. EPCRA Section 311‐312‐‐ Emergency Planning and Community Right‐to‐Know Act of 1986‐‐ applies to any facility at which a hazardous chemical. fire. safe distances and places of refuge. CERCLA SECTIONS 102a/103‐‐ Comprehensive Environmental Response..120‐‐ OSHA Hazardous Waste Operations and Emergency Response Standard (HazWOPER) i. pre‐emergency planning and coordination with outside responding agencies. emergency recognition and prevention (what constitutes an emergency and how to prevent the occurrence). as defined by the Occupational Safety and Health Act. e. site security and control. ii. or substantial release threat. This standard applies to emergency response operations for release. vii. c. Level 1: First Responder Awareness b. but not limited to. 29 CFR 1910. h. Level 2: First Responder Operations c. evacuation routes and procedures. Additionally. engineering controls. Section Q of the standard specifies the training requirements.120 (HazWOPER).132—Personal Protective Equipment—General requirements— requires protection for employees’ eyes.156‐‐ OSHA Fire Brigades Standard If employees are expected to fight fires. Level 3: Hazardous Materials Technician d. air monitoring m. emergency alerts and response. Once the spill is contained. 29 CFR 1910. The employer shall be responsible for the establishment and maintenance of a respiratory protection program with required worksite‐specific procedures and elements for required respirator use. Level 4: Hazardous Materials Specialist e. it must be stopped at the source. h. k. f. Level 5: On‐Site Incident Commander v. Training‐‐required for any employee who responds to an emergency. including. critique of response procedures and follow‐up. 29 CFR 1910. which mandates a buddy system in these circumstances. head and extremities in the presence of hazards that require such protection. chemical hazards and hazards encountered through absorption. personal protective equipment and emergency equipment.134—Personal Protective Equipment—Respiratory protection— includes (among other pertinent subjects) the selection. cleaned up and disposed of properly. Appendix III – Page 7 SeaQuest Testing & Consulting – Preliminary Risk Assessment . iv. a. g. j. emergency medical treatment and first aid.f. The program must be administered by a suitably trained program administrator. i. face. fitting and care for respirators and instructions to employees about the use of respirators. decontamination procedures. they must be trained and equipped in accordance with the Fire Brigades Standard. l. g. inhalation or physical contact. a trained Level 5 Incident Commander must be present. 29 CFR 1910. Control and Cleanup At least two Level 2 technicians are required to slow and control a hazardous spill as specified in 29 CFR 1910. i. They are broken down into 5 levels that are tied to specific duties.133—Personal Protective Equipment—Eye and face protection— requires protection against liquids and other hazards to the eyes and face. j. These risk management options include: a. 29 CFR 1910. of solution weight or 223. 29 CFR 1910. 7. Training on the safe handling of the material must be given to every employee involved in the handling. i. Close fitting safety goggles and chemical resistant gloves ii. storage and use of the material.850 lbs. It is conceivable that such an activity could produce significant caustic soda aerosol inhalation exposure. An offset to the hazards involved in the use of this substance in this particular application is the fact that the scrubbing system consists of a closed loop mode. potentially greater exposure to caustic soda is probable for employees charged with the task of cleaning storage tanks. sounding pipes.700 lbs. bunkering areas. Additional clothing and equipment may be required. feed module and bleed‐off treatment units. Safety showers and eye washes should be clearly marked with dedicated signs. d. The following personal protective equipment must be worn when handling Caustic Soda. b. Hard hat b. where the eyes or body of any person may be exposed to injurious corrosive materials. tanks.151(c)—Medical Services and First Aid—requires suitable facilities for quick drenching or flushing of the eyes and body in the work area for immediate emergency use. Additionally. Full face shield (in addition to close fitting safety goggles) Appendix III – Page 8 SeaQuest Testing & Consulting – Preliminary Risk Assessment . c. Chemical resistant apron c. Safety showers and eye washes should be conveniently located and readily accessible near all areas where Caustic Soda will be handled. Caustic Soda dry weight. Periodic surveillance of the storage tanks. RISK MANAGEMENT Based on the risk assessment of the various conditions defined in section 6. the following risk management measures are recommended: a.1200. which eliminates potential employee exposure to splashing of the liquid and aerosol formation under normal conditions of operation. This quantity is equivalent to 447. 6.000 gallons of 50% Caustic Soda solution per week would be utilized. piping and connections for evidence of wear is required. Caustic Soda will be directly handled by employees involved with unloading tank trucks. It was projected that approximately 37. fittings. A job safety analysis for each task involving direct handling of Caustic Soda needs to be conducted to determine the proper personal protective equipment for the task being performed. e. However. RISK ASSESSMENT Caustic Soda falls under the category of “Hazardous Substance” according to OSHA’s Hazard Communication Standard. it can be concluded that the risk to workers and the environment can be classified as minimal. Chemical resistant boots e. Full chemical protective suit with hood and air supplied respirator 8. Appendix III – Page 9 SeaQuest Testing & Consulting – Preliminary Risk Assessment . Chemical protective suit (jacket and pants) f. RESIDUAL RISK SUMMARY Based on the nature of Caustic Soda solution hazards. its use in the closed loop scrubbing system and selection of appropriate risk management tools.d. APPENDIX IV RESOURCE DISK Available as a Separate Submittal .