caustic soda feasibility study

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5150 Southwest 48 th

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

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FEASIBILITY STUDY, R ISK ASSESSMENT,

AND SAFETY PROCEDURES

FOR

CAUSTIC SODA OPERATIONS

PORT OF BAYONNE, NEW JERSEY, U NITED STATES PORT OF SOUTHAMPTON, U NITED K INGDOM

SEAQUEST PROJECT NUMBER : 6976

PREPARED FOR :

MS. JODY MILLER

LEAD, CREW SAFETY PROGRAMMARITIME SAFETY AND COMPLIANCE

R OYAL CARIBBEAN CRUISES LTD.

1050 CARIBBEAN WAY

MIAMI, FLORIDA 33132

PREPARED BY:

SEAQUEST TESTING & CONSULTING

5150 SOUTHWEST 48TH WAY, SUITE 610FORT LAUDERDALE, FLORIDA 33314

AUGUST 15, 2013



ii

CERTIFICATION PAGE

FEASIBILITY STUDY, R ISK ASSESSMENT,

AND SAFETY PROCEDURES

FOR

CAUSTIC SODA OPERATIONS

PORT OF BAYONNE, NEW JERSEY, U NITED STATES

PORT OF SOUTHAMPTON, U NITED K INGDOM

SEAQUEST PROJECT NUMBER : 6976

PREPARED FOR :

MS. JODY MILLER

LEAD, CREW SAFETY PROGRAM

MARITIME SAFETY AND COMPLIANCE

R OYAL 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-A NNE BOYLE, CIH, CSP

SENIOR PROJECT MANAGER



iii

TABLE OF CONTENTS

PAGE

1 INTRODUCTION 1

1.1 SCOPE – FEASIBILITY STUDY 1

1.2 SCOPE - ENVIRONMENTAL HEALTH AND SAFETY PROTOCOLS 2

1.3 PORT AND VENDOR VISITS 2

2 ABOUT SODIUM HYDROXIDE (CAUSTIC SODA) 3

2.1 PHYSICAL PROPERTIES 3

2.2 OCCUPATIONAL EXPOSURE SUMMARY 3

2.3 ENVIRONMENTAL SPILL CONSIDERATIONS 3

3 FEASIBILITY OF SUPPLY AND DELIVERY METHODS 5

3.1 CAPE LIBERTY 5

3.1.1 R AIL CAR 5

3.1.2 TANKER TRUCK TO VESSEL 5

3.1.3 BARGE DELIVERY TO VESSEL 14

3.1.4 TANKER TRUCK TO O NSITE STORAGE TANK 14

3.2 SOUTHAMPTON 15

3.2.1 R AIL CAR 15

3.2.2 TANKER TRUCK TO VESSEL 15

3.2.3 BARGE DELIVERY TO VESSEL 15

3.2.4

TANKER TRUCK TO O NSITE STORAGE TANK 20

4 DESIGN CONSIDERATIONS 21

4.1 GENERAL 21

4.2 VESSEL 21

4.3 PORT 21

5 REGULATORY REQUIREMENTS & RESOURCES 23

5.1

REGULATORY REQUIREMENTS 23

5.2 INDUSTRY GUIDELINES 23

6 CONCLUSIONS AND RECOMMENDATIONS 30



iv

TABLES

Table 1 - Summary of Vendor Inquiries, Cape Liberty ...................................................................6

Table 2 - Summary of Contacts, Bayonne .....................................................................................10

Table 3 - Summary of Vendor Inquiries, Southampton .................................................................16

Table 4 - Summary of Contacts, Southampton ..............................................................................18 Table 5 - Summary of Regulations, United States .........................................................................24

Table 6 - Summary of Regulations, United Kingdom ...................................................................28

APPENDICES

Appendix I - Provided Documentation

Appendix II – Hazardous Substance Fact Sheet – Sodium Hydroxide

Appendix III – Preliminary Risk Assessment

Appendix IV – Resource CD



1

1

INTRODUCTIONSeaQuest Testing & Consulting (“SeaQuest”) conducted a feasibility study, risk assessment and

developed preliminary health and safety protocols for introducing caustic soda into the emissionscrubbing process for vessels scheduled to call on the Ports of Bayonne, New Jersey, United

States and the Port of Southampton, United Kingdom.

The scope of work was developed based upon conversations with Ms. Jody Miller and Mr. Joe

Mujwit of Royal Caribbean Cruises, Ltd (RCCL) and documentation provided to SeaQuest

Senior Project Manager, Ms. Traci-Anne Boyle (see Appendix I). The project consists ofidentifying and evaluating the feasibility of vendors to deliver approximately 37,000 gallons of

50% sodium hydroxide to the ports every two (2) weeks. The feasibility study also examinedapplicable laws and evaluated the logistics of the material handling. Based upon the feasibility

of the project, a risk assessment was performed and preliminary health and safety protocols were

established for the safe handling of the material.

1.1 SCOPE – FEASIBILITY STUDY

SeaQuest reviewed regulations, contacted authorities and contacted vendors to evaluate whether

it is feasible to have 37,000 gallons of 50% sodium hydroxide delivered to the ports of Bayonneand Southampton every two (2) weeks. The feasibility study consisted of:

Regulatory Review - United States

Review of CFR 29, 33, 46 and 49, as well as related United States Coast Guard (USCG),

Department of Transportation (DOT) and Occupational Safety & Health Administration (OSHA)

policy documents

Review New Jersey Statutes

Review of City of Bayonne, NJ and other local community ordinances.

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 - Port of Bayonne

Identify three (3) potential vendors to service the port of Bayonne

Confirm vendors are able to supply amount (37,000 gallons) and concentration (50%) needed.

Determine if the vendors are able and willing to comply with port operations, 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, 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 - United Kingdom

Review of relevant United Kingdom regulations (Maritime Coastguard Authority, 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



2

Discussion with the Port of Southampton authorities (Harbor Master)

Vendor Evaluation - Port of Southampton

Identify three (3) potential vendors to service the Port of Southampton

Confirm vendors are able to supply amount (37,000 gallons) and concentration (50%) needed.

Determine if the vendors are able and willing to comply with port operations, including all

necessary security authorizations needed to access the port

Evaluate the vendor/supplier understanding of the port operations and close proximity of otheroperations being performed concurrently, 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

SCOPE - 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, the ship and in thewater.

Environmental Health and Safety Protocols

Review of US federal requirements, including USCG, Environmental Protection Agency (EPA)

and OSHA regulations pertaining to procedures for spills on land, in the water or on the ship.

Review of regulations from relevant United Kingdom authorities (Maritime Coastguard

Authority, Health and Safety Executive) and EC regulations

Review of NJ statutes

Review of City of Bayonne, NJ and other local community ordinances

Review of Cape Liberty and the Port Authority of New York/New Jersey guidance.

Discussion with COTP and OCMI (USCG Sector, NY)

Discussion with New Jersey Department of Environmental Protection Discussion with port authorities (e.g., Cape Liberty Cruise Port, Ports of NY and NJ, 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.

1.3 PORT AND VENDOR VISITS

Although not in the scope of work, SeaQuest conducted visits of both ports and met with potential vendors in Bayonne to discuss the project.



3

2

ABOUT SODIUM HYDROXIDE (CAUSTIC SODA)Sodium hydroxide (commonly known as caustic soda) is used throughout the world for a wide

variety of purposes. The material is used in manufacturing, as a cleaning agent, in food

preparation, chemical pulping, in tissue digestion, and in waste water treatment plants for use in

the scrubbing process. In accordance with information provided by RCCL, 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.

2.1 PHYSICAL PROPERTIES

A copy of New Jersey Department of Health and Senior Services Hazardous Substance FactSheet for sodium hydroxide is provided in Appendix II. Sodium hydroxide is an odorless white

solid that readily absorbs moisture from the air. The material reacts with strong acids (such as

hydrochloric acid, sulfuric acid and nitric acid) as well water to rapidly release heat. Partly dueto the strong reaction process, the material is typically transported as a liquid and it is readily

available in 50% solutions required in the specifications provided to SeaQuest. Sodium

hydroxide is not combustible and its vapor density is heavier than air. It has a health hazardrating of 3, a fire hazard rating of 0 and a reactivity hazard rating of 1.

In a 50% solution as required by the RCCL specifications, sodium hydroxide has a freezing

temperature of approximately 58F or 14C. Given this relatively high freezing temperature, the

material temperature will have to be regulated throughout the transportation, storage and use ofthe chemical.

2.2

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. 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 is a strong base and can cause severe burns if exposed to the skin or eyes or if it is

inhaled in the air. Contact with the skin and eyes should be prevented through diligent use of

personal protective equipment, including gloves, coveralls and a full facepiece splash shield. Inthe event of contact with the skin or eyes, immediate flushing with copious amounts of water is

necessary to reduce injury. Particulate respirators must be worn if airborne concentrations of

sodium hydroxide are expected to be near the PEL/TLV/REL.

2.3

ENVIRONMENTAL SPILL CONSIDERATIONS In the event of a spill of sodium hydroxide in solution, the material should be absorbed with sand

or earth and placed into sealed containers for proper disposal. In the event of a spill into a

contained water body (i.e. pool), the use of a dilute acid can be used to neutralize the solution.

However, a spill in the ocean would not likely result in a response. As an example, in 2004 a



4

tank failure resulted in a spill of over 460,000 gallons of 50% sodium hydroxide (an unknown

amount of which spilled into the Arthur Kill waterway), resulted in no on-water cleanup.1

1 http://www.darrp.noaa.gov/northeast/kinder/index.html. Accessed August 3, 2013.



5

3

FEASIBILITY OF SUPPLY AND DELIVERY METHODSCaustic soda is commercially used throughout the world and is readily available. There appear

to be vendors at both Cape Liberty and Southampton that can supply the quantity (37,000

gallons), at the required interval (every 2 weeks) and at the correct mix (50%).

3.1 CAPE LIBERTY

The results of inquiries into vendors for Cape Liberty are provided in Table 1. Based upon the

research and interviews conducted (see Table 2), it appears that an onsite storage tank or barge

deliveries are feasible options at this port.

3.1.1 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, according to information obtained

from Mr. Anthony Caputo, the Director of the Cape Liberty Cruise Port, and Mr. Jim Papernik ofIMTT, it would not be possible to install railroad tracks between the two (2) terminals due to the

land purchase and installation requirements. Therefore, it was determined that rail car delivery

is not an option at this port.

3.1.2 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. However, delivering the required quantity (37,000

gallons) would take an average of 10 tankers each requiring approximately 2 hours to bunker their load. This would have bunkering operations continuing for approximately

20 hours.

According to Mr. Caputo, based upon current logistics during port calls, the maximumnumber of tanker trucks that could be accommodated would be 2 or 3.

Therefore, at the required quantity, delivery at this port by tanker truck is not feasible. If it is

determined that only 6,000 to 10,000 gallons were required during the port call, this option may

be feasible. However, the following should be considered:

Personnel bunkering the caustic soda would be wearing full personal protective

equipment, potentially within sight of boarding passengers. Due to the limited space portside, it is unlikely that sufficient separation between tanker

and pedestrians can be accomplished.

The tanker trucks will have to back into a containment structure (permanent ortemporary). 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 Port Authority

approval process, which could take months to over a year to complete. A boom crane would be required to support the hose connection from the tanker to the

ship. The installation of a crane would have to be approved through the Port Authority

approval process, which could take months to over a year to complete.



Table 1 ‐ Summary of Vendor Inquiries, Bayonne

Reference Information

Harborchem

Jonathan Myers

PO Box 630

Cranford, NJ 07016

[email protected]

p) 908/272

‐7070

Approximately 9 tank trucks, each needing roughly 2 hours to bunker, e

4,500 gallons. Barge delivery is also a possibility, although not practical

can be easily arranged with proper planning.

Met with Mr. Myers and President of Harborchem, Stephen Maybaum

in the

project.

Have

the

means

and

resources

to

supply

the

material

if

and willing to comply with port requirements.

At this screening level, Harborchem appears to be a suitable supplier fo

method of delivery with this vendor would be from tanker truck to Abo

(AST) at the port.

Seidler Chemical Company

Francis Penkethman

537 Raymond Boulevard

Newark, NJ 07105

p) 973/465‐1122, Ext 111

[email protected]

11 Full tank truck loads (~3,363 gallons per tanker) over a 3 day maximu

material from IMTT at the Port of Bayonne. Able and willing to comply

regulations.

At this screening level, Seidler Chemical Company appears to be a suita

soda. The

method

of

delivery

with

this

vendor

would

be

from

tanker

t

6





Veckridge (Chemical Distributor)

Tom or Bob

p) 973/344‐1818

Can get the required quantity; in and out of the port a lot, so familiar w

not return repeated calls for followup information. No additional consi

recommended.

Whelpley Construction

Dave Whelpley

[email protected] p) 202‐314‐6456

Referred to Mr. Whelpley by Anthony Caputo, RCCL Director of Northea

Whelpley's firm is the vendor that is currently in the permitting process

Bayonne terminal.

Mr.

Whelpley

indicated

that

permitting

with

the

Po

onerous and can be very time consuming (months ‐ years). He indicate

were an option, perhaps they could be combined with the terminal imp

he has underway to shorten the timeline.

Kuehne Chemical

Ken Corolla

[email protected]

p) 732‐995‐1144

www.kuehnecompany.com

Referred to Mr. Carola from RCCLs current barge suppliers (Ray Baldwin

and Ralph Duca with Clean Waters NY) as well as Fran Penkethman with

Company for possible barge delivery. Spoke with Mr. Carola who indica

barge because Kuehne both manufactures caustic and owns its own cau

Mr. Carola indicates that Kuehne would need an advanced schedule for

estimate that

the

cost

per

37,000

gallon

delivery

to

be

approximately

$

include the cost of the product (current pricing is approximately $60,00

At this screening level, Kuehne Chemical appears to a suitable supplier

would deliver the material by barge to the ship.

8





Ken's Marine Service, Inc.

Pat Garrison

Spill Supervisor

116‐20 East 22nd Street

Bayonne, NJ 07002

p) 201/339

‐0673

c) 201/800‐1409

[email protected]

Referred to Ken's Marine Service by Anthony Caputo, RCCL Director of

with Mr. Garrison on July 24th. Mr. Garrison provided a lot of informat

bunkering the material from a barge. Specifically, source flexible hosing

use a universal connection (camlock), do not have the connections ove

in 3 places using a boom crane, and have 3 shut offs in place. Ensure co

and on

the

ship.

Mr. Garrison also discussed the hazards of using dry powder. The most

explosion and rapid reaction producing heat. There will be blending iss

and agitators.

Mr. Garrison discussed that if a tank was installed at the port, he'd reco

contained within a heated building. The building would provide protec

failure, it would keep the pumps protected and the fittings protected (w

and most likely places for a failure to occur).

He is

willing

to

assist

with

the

preparation

of

the

needed

spill

preventio

suitable vendor to provide emergency response services in the event of

9



Table 2 ‐ Summary of Contacts, Bayonne

George Wojnar Very helpful contact for general questions; will point you in the right d

Port Authority NYNJ

p)973/578‐2157

[email protected]

Kim

Nguyen

Port

Authority

NYNJ

p) 973/578‐2155

[email protected]

1.

Submit the form TAA‐MWA Ph 1 01 (attached) , together with a

(Royal Caribbean) to the NJMT General Manager, Mr. Thomas F. Cly

work, together with some drawings and location plan. The form Ph 1

Tenant (Royal

Caribbean)

and

dated.

All

the

form,

cover

letter

and

dr

emailed to me at the above email address.

2.

I will forward the tenant’s email, cover letter and drawings to th

for their decision of whether this is a TAA or a MWA.

3.

Once it is determined to be a TAA, Royal Caribbean, the tenant,

Engineer of Records (A/EOR) who is licensed to practice in the state o

office will schedule a kick‐off meeting between the tenant, its Engin

Contractor. "

In a phone

conversation

with

Ms.

Nguyen,

she

could

not

estimate

on

would take. She said it depended upon the thoroughness of the app

additional forms and instructions.


RCCL needs to fill out and submit the proper paper work (TAA‐MWA)

will be designing the tanks to meet with her as well as other NYNJ Port

schedule.

For any tenants to propose any work on the Port Authority’s leased pr

Construction and Alteration Process (TCAP) requires the followings:

10





Jeffrey Sterling Provided Bob Gomez's Contact information

Supervisor

DEP Hazardous Waste Enforcement

Northern Region Field Office

p)973/656‐4498

Bob Gomez

New Jersey DEP

p)609/292‐3837

Gary Sobin

DEP Discharge Prevention

p)609/292‐2482

Any smaller containments at the site of the holding tanks will also be i

There are unloading area requirements.

Priit Pals NJAC 7:1E‐2.3 "All tank car or tank truck loading or unloading areas

DEP

Discharge

Prevention

unloading of hazardous substances shall be equipped with seconda

p)609/633‐1152 system, designed and built pursuant to N.J.A.C. 7:1E‐2.6"

See Reference CD for more information.

Beth Reddy

[email protected]

p)954/767‐2140

Lt. Mike Metz Any further questions that may come up should be handled with Lt. M

p) 954/767‐2140 ext. 1005

Lt. Com. Keith Hanley

p)617‐223‐8541

No DEP regulations pertaining to the transport of sodium hydroxide; c

Program within the DEP

Any hazardous chemical in amounts greater than 20,000 gallons requi

Prevention Containment and Countermeasure and Discharge Cleanup

DEP Engineer with Discharge Prevention &

Permit Coordination

Plans for the holding tanks need to be submitted 180 days prior to ope

assigned a NJ DEP project manager as soon as wanted.

US Coast Guard Cruise Ship National Center

of Expertise

Because the sodium hydroxide on board the ship is not cargo and is a c

regulations that specifically pertain to having it on board.

11





Bayonne Police Department

http://www.bayonnenj.org/government/de

partment‐of ‐public‐safety/bayonne‐police‐

department/

Sargeant Jim

Ashe

201/858‐5642

Referred to Deputy Chief Keith Weaver of the Bayonne Fire Departme

New

York

City

Police

DepartmentPrecinct 1

p) 212/334‐0611

http://www.nyc.gov/html/nypd/html/precin

ct_maps/precinct_finder.shtml

Referred to

the

Port

Authority

Police

Department.

Port

Authority

Police

Department

http://www.panynj.gov/police/

p) 800/828‐7273

Sargaent D'Amato

Charles "Chuck" King

[email protected]

p) 973/578‐2158

Sargaent D'Amato does not believe this is a police department matter,

Mr. King indicated that the Port Authority Police Department will revie

submitted to the Port Authority as part of the TAA process (see Refere

Bayonne

Fire

Department

Deputy Chief Keith Weaver

201/858‐6009

Fire Official Christopher Czuba

201/858‐6024

[email protected]

Chief Weaver is also the city's Emergency Management contact. Refer

Christopher Czuba.

Mr. Czuba is working to identify if any additional requirements will app

The results of the inquiry will be forwarded upon receipt.

12





Customs and Border Protection

http://www.cbp.gov/xp/cgov/toolbox/conta

cts/ports/nj/4601.xml

p) 201/443‐0408

Officer Murphy

Officer Murphy returned a voicemail left for Chief Heacock. He indicat

importing the caustic soda, Customs and Border Protection would not

Waterfront Commission

Police Headquarters

Carol Laurens

p) 212/742‐9280

Repeated phone messages in July were not returned.

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 investiga

incident, they may be called upon to investigate it.

13



14

3.1.3 Barge Delivery to Vessel

Barge delivery is an attractive option at Cape Liberty:

It will not interfere with the portside logistics.

It will be out of view of the passengers and most crew.

It can be done without investment of port infrastructure. No construction permits or regulatory requirements to implement.

Only regulatory requirements include safe handling procedures and spill response

responsibilities.

Potential challenges with barge delivery include:

Coordination between fuel barge and caustic barge.

Only one supplier was identified that is capable of providing the material by barge.

A vendor, Kuehne Chemical Company, has been identified that can supply the material by barge.

Contact information is provided in Table 1. Based upon the information gathered during thisinvestigation, barge delivery appears to be the most attractive option.

3.1.4 Tanker Truck to Onsite Storage Tank

Several vendors were identified that could provide the caustic soda to an onsite above groundstorage tank that could be installed at the port (see Table 1). 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:

The Port Authority would have to grant approval for the infrastructure needed. 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). 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

Port Authority 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 tothe ship.


equipment, potentially within sight of boarding passengers.

Continuous filling, emptying and storage of the caustic soda provides more opportunities

for spills or accidents.



15

3.2 SOUTHAMPTON

The results of inquiries into vendors for Southampton are provided in Table 3. Based upon theresearch and interviews conducted (see Table 4), it appears that an onsite storage tank will be

required at this port, unless a supplier can be identified that can deliver the material by barge.

3.2.1

Rail CarThere is rail car availability at Southampton. However, no rail car lines meet up to the port side,

therefore, additional rail would be required. Based upon conversations with port authorities, this

is not a feasible option.

3.2.2 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. However, delivering the required quantity (37,000

gallons) would take an average of 10 tankers each requiring approximately 2 hours to

bunker their load. This would have bunkering operations continuing for approximately20 hours.

Therefore, at the required quantity, delivery at this port by tanker truck is not feasible. If it is

determined that only 6,000 to 10,000 gallons were required during the port call, this option may

be feasible. However, the following should be considered:


equipment, potentially within sight of boarding passengers.

Due to the limited space portside, it is unlikely that sufficient separation between tanker

and pedestrians can be accomplished.

The tanker trucks will have to back into a containment structure (permanent ortemporary). 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. A boom crane would be required to support the hose connection from the tanker to the

ship. The installation of a crane would have to be approved through the Associated

British Ports approval process.

3.2.3 Barge Delivery to Vessel

A supplier has not been identified that can deliver the material by barge in Southampton.

However, for the same reasons that this delivery method is an attractive option in Bayonne, it is

equally as attractive in Southampton. Therefore, it may be prudent for RCCL to conductadditional research into identifying a supplier.

Benefits include:

It will not interfere with the portside logistics.

It will be out of view of the passengers and most crew.

It can be done without investment of port infrastructure.



Table 3 ‐ Summary of Vendor Inquiries, Southampton


Aquachem

Office K/Redwither Business Centre

Wrexham LL13 9XR

01978 664077

watertreatmentwaste.co.uk

Contact:

John Holt

Believed that delivery and transfer directly to the ship tanks by road tank

method. Originally stated they can supply the quantity, frequency and m

subsequently, they withdrew from consideration. No additional conside

recommended.

Chemtek

OrbisEnergy

Wilde Street

Lowestoft

Suffolk NR33 1XH

Tel: 0845 154 3330

Fax: 01502 539064

Email:

[email protected]

Believed that delivery and transfer directly to the ship tanks by road tank

method. Stated they can supply the quantity, frequency and mix require

contact upon asking for credentials. No additional consideration of this v

ReAgent Chemicals

0800 990 3258

[email protected]

Although initially they appeared interested, they cannot supply the quan

consideration of this vendor is recommended.

Altrans Liquids Ltd

Sheephouse Farm, Uley Road

Gloucestershire, FL11 5 AD

England

Ph: 01453 544 940

Email: [email protected]

Web: www.altransliquids.co.uk

Contact:

Anthony Millard

Believes feasible with onsite storage tank. Very helpful and interested in

supply the quantity, frequency and mix required. Security and port perm

for tanker access. Estimated costs at this time: £0.34 per litre (£222.71

At this screening level, Altrans Liquids appears to be a suitable supplier f

16



Table 3 ‐ Summary of Vendor Inquiries, Southampton


PBH Chemicals

Facility Services

323 Woodside Way

Springvale Industrial Estate

Cwmbran NP44 5BR

Paul

HughesPh: 07988 071 248

Email: [email protected]

Simon Hughes

Ph: 07540 625 135

Nick Hughes

Ph: 07734 440 268

Believes feasible with onsite storage tank. State they can supply the qua

required. Also able to supply NaOH in powder for mixing onsite. Securit

to be verified for tanker access.

At

this

screening

level,

PBH

Chemicals

appears

to

be

a

suitable

supplier

f

Whittaker Tankers Barge Company

Southampton Docks

Ph: 02380 339 989

Only able to deliver oil.

Mrs. Amy

Bowd

Sales Coordinator

[email protected]

http://www.tuffa.co.uk

Tel: +44 (0) 1889 567700

Fax: +44 (0) 1889 567600

Tuffa has

prebuilt,

preheated

and

bundled

tanks

suitable

and

available.

17



Table 4 ‐ Summary of Contacts, Southampton


Associated British Ports (ABP)

Ocean Gate Atlantic Way

Southampton SO14 3QN

Tel: 023 80488692

www.abports.co.uk

Forms and requirements for the use and transportation of sodium hydroxid

website at http://www.southamptonvts.co.uk/yachting_and_leisure/notice

In particular, No 24 of 2011 (Builk Liquids Transfer Request Form), No 19 of

in Harbour Area) and No 10 of 2011 (Marine Safety Management Systems)

included in the Resource CE.

ABP Port Health and Safety Advisor

Christopher Turner

[email protected]

Not particularly helpful in telephone or email discussions.

ABP Health and Safety Manager

David Fox

Emailed June 9th and several follow up telephone calls were not returned.

ABP Port Security Officer

Paul Woods

Met with Mr. Woods on June 28th in relation to potential for storage tank t

RCCL will have to approach ABP directly to discuss, but it is possible.

ABP Port Agent

Steve Heagren

Met with Mr. Heagren on June 8th. Very helpful with health, safety and sec

during the port visit and provided paperwork, procedures and security requ

ABP Perry

Dack

Cruise Passenger Services Manager

Dockside Handling

Met with

Mr.

Dack

on

June

28th.

He

referred

us

to

speak

with

Paul

Wood,

Environment Agency

Romsey Depot

Bill Scott

Environmental Enforcement Officer

Ph: 03708 506 506

www.environmentagency.gov.uk/conta

ctus/default.aspx

No concerns as long as the NaOH is not dumped at sea and any spillage con

managed.

Maritime and Coastguard Agency John

Simpson

http://www.dft.gov.uk/mca/

Ph: 02380 329 100 No concerns providing that port arrangements are adhered to.

18



Table 4 ‐ Summary of Contacts, Southampton


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

Ms. Evans indicated that permission from ABP would be required to establis

the site for Royal Caribbean's use. She indicated that the first step would b

Manager,

Tom

Dynes

([email protected]).

After

Mr.

Dynes

understanddetermines suitable space is available, they can provide additional informat

requirements and costs.

19



20

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 groundstorage 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. Theapproval 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.


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.



21

4

DESIGN CONSIDERATIONSWhile 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 transportationequipment 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 shouldnot 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 tocheck 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 safetyshower 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 vesselmay 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 shipregardless 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 willhave 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



22

material, it was recommended that four (4) smaller tanks would be preferable. Consideration to

housing the tanks within a building should be evaluated to determine if it would be preferableover an extended period of time (reduction on wear and tear of the tank, piping and fittings

exposed to the elements). The location of the tanks will have to be made with approval from the

port owners and managers.

Additionally, the design should account for passenger visibility, passenger proximity, as well as

a permanent boom crane system to support the hose during bunkering operations.

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.



23

5

REGULATORY REQUIREMENTS & RESOURCESAppendix IV contains a compact disk of various regulations, forms and resources that were

identified as part of the research for this project.

5.1 REGULATORY REQUIREMENTS

The handling, transportation and storage of caustic soda is regulated in both the United States

and the United Kingdom. A summary of regulatory requirements is provided in Table 5 (United

States) and Table 6 (United Kingdom).

If storage tanks are constructed at the ports to house the caustic soda, nearly all of the identified

regulations will apply. However, if the material is bunkered using a barge, only occupationalexposure regulations and spill response will apply to the process.

Occupational exposure precautions include appropriate training, use of protective clothing (full

face and body splash protection), airborne exposure limits, and proximity of emergency showers

and eye wash stations. 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.

It is recommended that vendors be sourced and contracted to respond to a release on land or onthe ocean. An example of a suitable vendor is Ken’s Marine (see Table 1). The selected vendors

should be under contract to respond within 1 – 2 hours (if not sooner) of the report of a release.

5.2

INDUSTRY GUIDELINES

Because caustic soda is a chemical used throughout the world for a variety of commercial andindustrial applications, there are many good resources for the safe and proper use of this

material. One of the most comprehensive compilations of best practices is published by the

Chlorine Institute (www.cl2.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 - Alkali Chemicals

A copy of these publications is included on the resource disk provided in Appendix IV.



Table 5 ‐ Summary of Regulations, United States

General PPE Requirements for Caustic Soda

Initial Line Break: Head, Neck, Face, Eyes, Hands, Body and Feet

Material Sampling: Face, Eyes and Hands

Loading (employee is away from loading connection): Head, Face, Eyes

Open Dome‐ No Product Flow: Eyes

OSHA 29 CFR 1910.262 (oo)

Handling Caustic Soda

OSHA 29 CFR 1910.262 (ll)

Shut ‐off Valves for Open Tanks & Vats

Valves shall conform to the ASME Pressure Vessel Code, Section VIII, u


Means shall be provided for handling and emptying caustic soda and

prevent workers from coming in contact with the caustic.

1910.5 (c)(1) states that if a standard is specifically applicable to a con

operation, or process, it shall prevail over any different general standa

applicable; therefore, 29 CFR 1910.262 (oo) prevails over more genera

counteract it.

Emergency shut off valves for holding tanks must be located at a dista

coming in contact with the caustic soda in the event of a splash, etc.

Proper PPE and other appropriate equipment is required to be provide

the Sodium Hydroxide.

OSHA 29 CFR 1910.132 &

The Chlorine Institute's Pamphlet 65

Protective Equipment, including personal protective equipment for ey

protective clothing, respiratory devices, and protective shields and bar

and maintained for those working with and around the Sodium Hydrox

All PPE

equipment

should

be

chemical

resistant

in

the

following

condit

with an ambient temperature no greater than 120 degrees Fahrenheit

Sodium Hydroxide is colorless and odorless and causes severe irritatio

human tissue. It can rapidly cause damage to the eyes and skin as well

Extreme caution must be exercised when working with this chemical.

24





OSHA 29 1910.20

OSHA 29 1910.1200

Hazard Communication

EPA 40 CFR 302.4

EPA 40 CFR 300

When spills in excess of 156 gallons occur, RCCL is to follow these guid

This section

covers

the

clean

up

operations

at

uncontrolled

hazmat

wa

operations and a guidelines for a written health and safety program.

~The written health and safety program must include but i

structure, a comprehensive work plan, site specific safety a

health training program, medical surveillance program and

for safety and health involving hazardous materials.

Ensures that the hazards of caustic soda is evaluated, and that informa

transmitted to employers and the employees of RCCL that will be wor

material.

Relevant hazard

communication

should

be

added

to

RCCL's

existing

ha

documents.

Hazardous Waste Operations and

Emergency Response

It is required to either hire a company with properly trained personne

appropriate employees in 40 hour HAZWOPER, in the case that there i

Hazardous Substances & Reportable

Quantities

The reportable quantity for Sodium Hydroxide is 1,000 pounds where

contains approximately 6.4 pounds per US Gallon.

Spills in excess of approximately 156 gallons are will require reporting

Center and the US Coast Guard.

National Oil and Hazardous Substances

Pollution Contingency Plan:

Subpart E ‐ Hazardous Substance Response

The organizational structure and procedures for preparing for and resp

releases of hazardous substances, pollutants and contaminants.

25





46 CFR Part 147 Subpart A

Hazardous Ships' Stores

33 CFR Part 153

In the event of a spill, RCCL should refer to this section for manageme

49 CFR 171.15

(Reportable quantity for NaOH: 1,000 lbs. or 156.25 gallons)

49 CFR 171.16

49 CFR 172.101

Sodium Hydroxide:

Hazard Class

8

Identification Number UN1824

Immediate notice of certain hazardous

materials incidents

In the event of a spill of the reportable quantity or more, the National

notified within 12 hours.

Control of Pollution by Oil and Hazardous

Substances, Discharge Removal

The purpose of this part is to prescribe regulations concerning notifica

discharge of oil or hazardous substances as required by the Federal W

amended (FWPCA); the procedures for the removal of a discharge of o

imposed or reimbursed for the removal of a discharge of oil or hazard

FWPCA.

The Sodium Hydroxide must be labeled with the technical/proper ship

supplier's name and address, hazard classification (8 corrosive materia

proper use, first aid instructions and the stowage and segregation guid

The holding

tanks

at

the

port

and

onboard

the

ship

must

be

appropria

accordance with this regulation.

Detailed hazardous materials incident

reports

Each person involved in the transport of the Sodium Hydroxide must s

Incident Report to the US DOT Pipeline and Hazardous Materials Safet

an incident.

Purpose and use of hazardous materials

table

The table designates the materials listed therein as hazardous for the

table identifies the hazard class and identification number.

26





NJAC 7:1E‐1.8

Environmentally Sensitive Areas

It is important to review this section in designing site plans.

NJAC 7:1‐2

NJAC 7:26E This chapter constitutes the minimum technical requirements to inves

contamination at any site.

Technical Requirements for Site Remediation

Any person conducting remediation shall comply with this chapter a

New Jersey Department of Environmental Protection website.

For the purposes of designing and implementing a DPCC and a DCR pla

an environmentally sensitive area.

This New Jersey Statute should be reviewed by all personnel involved

tanks at the port as well as onboard the ship.

Prevention and Control of Discharges at

Major Facilities

This chapter covers the discharge of hazardous substances; including S

of New Jersey. These rules set forth guidelines and procedures to be f

event of a hazardous substance release. They also set forth certain reg

operations, and maintenance requirements for owners and operators

hazardous substances.

NJAC 7:1E

NJ Department of Environmental Protection

General Provisions

The rules that are applicable to the owners or operators of major facil

processing or using hazardous materials. This New Jersey statute sho

part of

the

holding

tank

design

process,

if

implemented.

27



Table 6 ‐ Summary of Regulations, United Kingdom

eference Information

angerous Substances Directive (67/548/EEC)

angerous Preparations Directive (1999/45/EEC)

These Directives have been implemented in the UK as the Chemicals (Hazar

Supply Regulations 2009 (CHIP[2][3]). The CHIP Regulations will be fully rep

(http://www.hse.gov.uk/ghs/backgrnd.htm).

ew European legislation derived from EU GHS ‐

lassification,

Labelling

and

Packaging

of

ubstances and Mixtures 2009 (CLP Regulations)

(EC) No 1272/2008 (2009 ‐2015 7yr trans period) CLP effect on companies

If you are a supplier of chemicals, you must classify, label and package your

accordance with the CLP Regulation. Your obligations depend upon your ro

may have one or more of these roles: Manufacturers of substances or mixt

mixtures, Producer of specific articles, Downstream user (including formu

(including retailer).

If you place a hazardous substance on the market, you must notify ECHA of

one month of placing the substance on the market for the first time.

For importers, the one month is counted from the day when a substance, o

physically introduced

in

the

customs

territory

of

the

EU.

(http://echa.europ

companies)

Guidance link‐ http://echa.europa.eu/documents/10162/13562/clp_introd

egistration, Evaluation, Authorisation and

estriction of Chemicals 2007 (Reach)

Reach – if a supplier is importing caustic from outside EU they will need to

manufacturing within EU and all “ingredients” are purchased from within E

REACH. However, if an ingredient is purchased from outside EU then they w

quantities >100 tonne should be registered before June 2013.

http://www.hse.gov.uk/reach/resources/basics.pdf

ontrol of Substances Hazardous to Health

COSHH) 2002

Works alongside REACH regulations. Requires substances to have MSDS she

and use. Must provide information, instruction and training, and health su

28



Table 6 ‐ Summary of Regulations, United Kingdom

eference Information

uropean Agreement concerning the

nternational Carriage of Dangerous Goods by

oad.

ccord European Relatif au Transport

nternational

des

Marchandises

Dangereuses

par

oute 1967

ADR Agreement)

nited Nations Economic Commission for

urope (UN/ECE)

ADR is an agreement between states in EU. ADR applicable as from 1 Janu

ADR link ‐http://www.unece.org/fileadmin/DAM/trans/danger/publi/adr/a

http://www.hse.gov.uk/cdg/regs.htm

arriage of Dangerous Goods and Use of

ransportable Pressure Equipment Regulations

009 CDG 2009

ealth and Safety Executive SI 2009 No 1348

Came into force on 1 July 2009. They replace the 2007 regulations. Implem

http://www.legislation.gov.uk/uksi/2009/1348/contents/made

lassification, Labelling and Packaging of

ubstances and Mixtures 2009 (CLP)

The CHIP Regulations will be fully repealed in 2015 and replaced with CLP 2

(http://www.hse.gov.uk/ghs/backgrnd.htm)

29



30

6

CONCLUSIONS AND RECOMMENDATIONSIt is feasible to source 37,000 gallons of caustic soda every two (2) weeks in the both the Port of

Bayonne and the Port of Southampton. The preferred delivery method to the vessel appears to

be by barge, although only one supplier in Bayonne and no suppliers in Southampton were

identified. It is recommended that RCCL use its purchasing power to negotiate with globalmanufacturers (such as Dow Chemical and Brenntag Global) to possibly identify more barge

delivery options.

Alternatively (and perhaps required), aboveground storage tanks appear to be options at both

ports. However, significant investment in time (approval process) and infrastructure (installationof the storage tanks, housing structure, piping and boom crane) would be required. If RCCL

decides that installation of storage tanks is the desired solution, it is recommended that RCCLformerly 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.

Depending upon the projected industry use, if RCCL decides to proceed with installation of

storage tanks, sale of the caustic soda to other vessels may be considered to possibly off-set theimplementation cost. Mr. 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.

Given the time constraints while in port, tanker truck delivery directly to the ship will only be

feasible if limited quantities (less than 10,000 gallons) are required. To be implemented,containment and boom infrastructure (to support the hose) would have to be installed. Rail car

delivery does not appear to be an option at either port.

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. SeaQuest recommends

that professionals engaged in the process be given access to this report and the accompanyingresource disk.

With the appropriate risk management tools (training, 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.



APPENDIX I

PROVIDED DOCUMENTATION



Person in charge: Kostilew Owner:

Phone: +49(0)4961 81-4772 RCL

E-mail [email protected] System: Operating fluids

Date: 18.04.2013

Plotdate: 23.04.2013

1.1.1.1.1 List of Included Drawings 2 List of

BGN Sheet Description No. Drawing No.

774 M 1100 General Description 1) 752 V 1000 Service air774 M 1200 Material and Piping Standards 2) 753 V 1000 Control air

774 M 1300 Monitoring and Alarms via the “IAMCS” 3) 721 V 1000 Technical wat

774 M 1001 NaOH 50 % Bunkering, transfer and feed System 4) 724 M 2000 Boiler Wash a

774 M 1002 NaOH 50 % Bunkering, symboltable and details 5) 711 M 2004 LT Circle

MWS 0.7--.07

MWS 0.7--.01

2.1.1.1.1 List of Alterations

BGN Sheet Description Kind of Alteration

774 M 1100 General Description See marked in grey.

774 M 1200 Pipe System specification Material test 3.2

774 M 1300 Monitoring and Alarms via the “IAMCS” See marked in grey.

774 M 1001NaOH 50 % Bunkering, transfer and feed

SystemUpdates signed with arrows

774 M 1002NaOH 50 % Bunkering, symboltable and

detailsUpdates signed with arrows

Name Date

2.1.1.1.2 Armatures

Labels




Phone: +49(0)4961 81-4772 RCL


Date: 18.04.2013


6. CALCULATIONS

General data

The pumps and heat exchangers for propulsion are designed according to information of supplier for

tropical conditions. The following operating data are based on:

Value

Ambient temperatures: + 45 °C

Ambient air temperature: min. - 7 °C, 36 h in harbour

max. + 35 °C

Seawater

Sea water: min. ± 0 °C

max. + 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: - 7°C

Sea water temperature: + 0°C

Engine room temperature: +20°C

Performance: heating up within 24 h

Tank Name Heat requirement

NaOH Overflow TK 12S 5,1 kW

NaOH Store TK 12S-1 51,5 kW



Sum. Store TK’s 161 kW

h

m

t

QV

³*

*16,1

*

Medium Heat [kW] V [m³/h] P [bar] T in [°C] T out [°C]

LT fresh w. (hot) 180 22,0 4,0 39,0 32,0

Cool fresh w. (cold) 180 19,3 4,0 20,0 28,0

7. SAFE RETURN TO PORT

With regard to ‘Safe Return to Port’ regul

There are no special regulations because




Phone: +49(0)4961 81-4772 RCL


Date: 18.04.2013




Person in charge: Kostlew Owner:

Phone: +49(0)4961 81-4772 RCL


Date: 18.04.2013





Phone: +49(0)4961 81-4772 RCL


Date: 18.04.2013




hW tilfil

Environmental Technologies

7 lkali Feed System

7 1 General

Installation Planning Instructions

7

lkali 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. Typically 50% NaOH (Sodium Hy

droxide), also known as Caustic Soda or Lye solution

is

used as alkali.

Main components

in

alkali system are alkali feed modules, alkali transfer pump, alkali dosing pump, alkali

topping-up pump and alkali storage tank. The alkali feed module consists

o

two chemical dosing pumps.

One pump is normally

in

operati

on

and the other is stand-by.

The scrubbing water pH is regulated by the amount of alkali added to the circulation . The pH contro l uses

information of the

pH

of the scrubbing water

as

input. The main control

is

automatically adjusted based on

the measured

pH o

scrubbing water.

Caustic soda bunkering areas, tanks and sounding pipes, 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 warning sign to be used is standard corrosive 8 sign,

with text Sodium Hydroxide Solution and UN 1824 nearby. Additionally texts NaOH Solution and

Caustic Soda Solution can be included as well.

Figure 7 1 Corros ive 8 sign

Safety showers (with shower and eye wash) should be arranged for relevant alkali handling areas, such as

bunker stations, alkali feed module area and bleed-off treatment units. If the safety shower is located out

doors, it must be insulated and heat traced in order to prevent freezing . The requirements for the safety

shower are defined e.g.

in

standard

SFS

5411.

The safety showers should be clearly marked with dedicated signs.

Figure 7.2 Safety shower and eye wash signs

Following personal protective equipment must be worn when handling alkali :

Meyer Werft 697 - Scrubber- a4

14 March 2013

7-1




7. Alkali Feed System

ifl@ iiii

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. See Appendix 1 for more

in

formation of NaOH.

7.2 Consumption

Alkali consumption depends on the concentration of the solution, engine operating power, engine specific

fuel oil consumption and fuel sulphur content. The alkali supply is automatically controlled based on these

parameters.

Indication of the alkali consumption can be seen in the figure below. It also indicates the relations of the

affecting parameters.

Figure 7.3 Alkali consumption per operating power, when using

50

caustic soda

A l

ka

li

demand

per eng i

ne

power

80

- 3.5 5fu e l

- • 3,

05fue

l I

600 - -

2,5 5

fue

l

700

E

500 - • 1,5 5 fue l

s::

5

-

GJ • • • • • • 2P 5

ftJe l -L

Q. no • +·----+----- _ . or __

E

ll

]

<(

30 0

2tl0

10

0

0

. - ·

5000 10000

15000 20000

2

5000

30000

Operating power kW)

35000

As a rule of thumb the alkali consumption can be estimated

to

be 5 liters/MWh per

fuelS .

.

.

40000

7.3 Storage

7-2

Onboard storage capacity is dictated by the following parameters: vessel autonomy, alkali consumption

and vessels operation profile and area.

Meyer Werft 697 - Scrubber - a4

14 March 2013



·

ik/t9Jt11M


I



Figure 7 4 Alkali consumption per consumed fuel, when using 50 caustic soda

2000

lSOO

_ 1 6

E

- 1400

a

1200

§

1000

t:

·0

...

800

600

Alkali demand per fuel consumption

5 S f u ~

- 3,0% 5 fue l

- - 2,5%5 fue l

• • • • • •

2,0 5

fue l

1,5 5 fue l

········

.

.

-

-·-

.

-

.

400 ~ ~ ~ ~ r ~ ~ ~ - - ~

2

1

0

0 2000 4 00 6000

00

10000

12000

14000 16000

1

000

20

000

Fuel consumption ton)

Required storage tank capacity can be calculated e.g. by comparing it

to

the fuel consumption. If ship 's

annual fuel consumption is 10 000 ton and average fuel sulphur content 2.5% , the corresponding alkali

consumption is 630 m3 per year. If alkali is bunkered every two weeks the required amount is 24 m3 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. When using a hybrid scrubber the capacity

of

the storage tank is de

pendent on the time when closed loop or hybrid mode is used.

For vessels that are operating in regular routes or in specific areas, the storage capacity could be equal to

the fuel bunkering interval. To minimize the transportation costs and ease the bunkering arrangement, tank

capacity should be adequate to receive the total volume from one delivery truck. The ideal storage capacity

should be at least 1.5 times the volume

of

the truck.

When alkali tank location and volume are outlined, high density of 50% caustic soda solution and the

margin against overfilling {15-20%) are to be considered. Recommended cleaning interval for storage tank

is 5 years. A single tank configuration can

be

used, if operation and regulation compliance with low sulphur

fuel is a possible and feasible alternative during the above mentioned periods. Due to the relatively high

density of caustic soda a low center of gravity for storages may be favorable regarding vessel stability.

There is generally no limitation to tank geometry. Tank bottom should preferably be sloped towards drain

pipe. Tank for 50% NaOH should be dimensioned for specific density

of

1.52 tfm3, including hydrostatic

static pressure to air vent head above the bulkhead deck. Tank should be externally or internally stiffened.

Integrity

of

storage tank and related air vents should be hydrostatically tested prior the tank coating. Air

vents need to be arranged from the highest points designed according to rules of applicable classification

society.

General shipbuilding steels can be used for tank construction. In each case when tank construction involves

structural members special consideration by classification society is required. The temperature limits should

be respected as above 49°C temperatures carbon steel is susceptible to stress corrosion cracking, also

known as caustic embrittlement . If higher tank temperatures are expected, special measures including

weld stress relieving and use

of

alternative materials should be considered case by case.

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, 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 mater

ials containing sil ica e.g. glass. It is recommended to check supplier's compatibil ity information

Meyer Werft 697 - Scrubber-

a4

14 March 2013

7-3




7. Alkali

Feed

System

k@ij §i Environmental Technologies

regarding gaskets for manholes and flanged tank fittings. Typically PTFE or EPDM should be

used. Viton is not suitable as gasket or sealing material.

7 4

ank

coating

7 4

Internal tank coating is recommended to avoid corrosion that may occur particularly on tank upper parts.

Major suppliers have epoxy resins that are suitable for this purpose. Suppliers recommendation

is

to be

followed concerning intended use, surface preparation and application.

In

the following some example coatings

are

presented. Other products with similar properties can also be

used.

Table 7.1

Example

products

for

tank coating from

Jotun

Coating

for

buffer

and alkali

tanks

Product Marathon 2:1

Description

High solids ,

two-pack

epoxy coating reinforced with glass flakes. Steel structures subject to

aggressive exposure, both atmospheric and mechanical. For aggressive chemical exposure.

Temperature Max 70 °C

Specific gravity

Film thicknesses

400 J Jm

Colours Limited selection

Pre-treatment Sa2

V2

ISO 8501-1)

Surfaces

All surfaces should be clean and free from contamination. The surface should be assessed

and treated in accordance with ISO 8504. The temperature

of

the substrate should be minimum

10°C and at least 3°C above the dew point

of

the air, temperature and relative humidity

measured in the vicinity

of

the substrate. The coating should not be exposed

to

oil, chemicals

or

mechanical stress until cured.

Drying times Dust dry after 5.5 hours. Touch dry after 12 hours. Fully cured after 7 days.

Thinner

Jotun Thinner No.1?

Primer Marathon 2:1, Pink

Finish Marathon 2:

1,

Grey

Table

7.2

Example products for tank coating from Teknos

Product

Description

Temperature

Specific grafity

Film thicknesses

Colours

Pre-treatment

Surfaces

Drying times

Thinner

Primer

Finish

Coating

for

buffer and

alkali

tanks

Teknos

lnerta

280

Used as coat

in

epoxy systems inside kerosene and oil tanks. Withstands aliphatic hydrocar-

bons, alkaline solutions and acids.

Withstands +70°C in immersion

1.5 kg/1

500

J Jm

Red , green

or

white

Sa2

Y2

ISO 8501-1)

The surface must be dry and least 4 weeks old. The relative humidity

of

the concrete should

not exceed 80

.

The surface temperature should remain at least 3°C above the dew point.

The temperature of the ambient air, surface

or

paint should not fall below +10°C.

Dust dry after 3 hours. Touch dry after 4 hours. Fully cured after 7 days.

Teknosolv 6560

Teknos lner ta 280

Teknos lnerta 280

Meyer Werft 697 - Scrubber- a4

14 March 2013



lf/N Irilfti Environmental Technologies



Table 7 3 Example products for tank

co

ati

ng

from Tikkurila

Coating for buf fer and alkali tanks

Product

Tikkurila TEMALINE BL TES

Description Two component, solvent free epoxy coating. Suitable to be used as a heavy duty coati

ng

on

steel and concrete surfaces exposed to chemical and mechanical stress in immersion. Good

resistance to acids, alkali and salts

in

immersi

on

. Suitable for coating of lead-free tanks.

Temperature Withstands + 150°C dry heat and +60°C in immersion

Specific gravity 1.4 kg /1 mixed)

Film thicknesses

500

iJm

Colours Red and green

Pre-treatment Sa2 Y ISO 8501-

1)

Surfaces

All surfaces must

be

dry.

The

temperature of the ambient air, surface or paint should not fall

below+1ooc during application and drying. Relative humidity should not exceed 80 . The

surface temperature of the steel should remain at least soc above the dew point.

Thinner

Thinner 10S1 or acetone

Pr imer TEMALINE BL

Drying times

Dust dry after 8 hours. Touch dry after 12 hours. Fully cured after 7 days.

Finish TEMALINE BL

Coating for buffer tank

Product

SIGMASHIELD 460 (LT)

Description

Two component high solids glass flake reinforced polyamine adduct tar free epoxy coating.

Temperature

Specific gravity 1.5 kg /1

Film thicknesses Min 400

iJm

Colours

Black - gloss (light colours on request)

Pre-treatment

Sa2 Y ISO 8501-1)

Surfaces

All

surfaces should be clean and

free

from contamination.

The

surface should

be

assessed

and treated

in

accordance with

ISO

8504. 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. Curing to hardness takes longer

in

lower temperatures and

complete resistance will be reached when temperature increases. Maximum relative humidity

during application and curing is 85 .

Thinner

Sigma Th inner 91-92

Drying times

Overcoating interval min

16

hours.

Touch

dry after S hours. Fully cured after 7 days.

Primer

SigmaCover 280 min 50

iJm

)

Finish

7 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. If the tank temperature

is expected

to

drop below 16°C

additional

heating

should

be

provided. The recommend ed storage

temper-

ature is

between 25 and

35°C.

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.g. heated fuel o il service and settling tanks. Also other heat sources that may locally increase temperature

inside the tank

to exceed the

before

mentioned

value (e.g.

exhaust gas

or

steam

pipes)

should

be

isolated

from

tank structures.

Storage tank heating requirement can be determined by calculating heat transfer through each tank

boundary.

The same

heat

transfer coeffic

ients

through

the external tank

walls

that are

typically used

for

heavy fuel oil are applicable. In some cases external tank insulation

could

be considered

to

reduce heat

losses .


14 March

2013

7-5




7

Alkali Feed System

RMi ijld


If heat losses from the tank

are

remarkable, heating with water circulation in carbon steel coils can be used.

To avoid corrosion o heating coils external surface, inlet water temperature should remain below 49°C.

Fo r example, returning LT cooling water can be utilized for heating and heating coils can be connected in

parallel to the central cooler. 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. Coils should be installed

to an approximate height

o

300 mm from tank bottom and located so that thermal agitat ion pattern will

occur.

Heating coils should be positioned to provide heating particularly

in

suction pipe area. Heating coil dimen

sioning is based on the differential temperature (t-.t) between the lower storage temperature (25°

C}

and the

arithmetic mean temperature o incoming outgoing circulating water. Mean heat transfer coefficient from

water coils to caustic soda can be estimated to 60 W/(m2 x C}, if turbulent flow conditions can be achieved.

An alternative heating method is to provide a separate caustic soda circulation through an external heat

exchanger. Thus the heating media can be low pressure steam or high temp heat recovery water. In these

cases the appropriate heat exchanger material should be selected, for example nickel. If heat losses are

moderate, also external electric heating can be used. Heating elements are adhesive and attached directly

to the tank wall under the insulation. Also in these cases the specified heating elements should not exceed

maximum surface temperature.

7 6 Storage tank fitting and instruments

7-6

When anywhere

in

the alkal i system (bunkering , transfer, feed} the lines are located below the alkali storage

tank level, the storage tank should be equipped with a quick closing valve. The alkali feed module shut-off

valve should be installed before alkali feed modules 15N04 and possible other alkali pumps.

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. Diameter is according to in

stallation specific system diagram. Each connection below the maximum surface level should be provided

with safety quick closing valves.

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. Piping should

be

sloped downwards

without pockets. It is recommendation to use seal paste for pipe fillers. Filling pipe material recommendation

is AISI 316L or black steel DIN 2448. Transport trucks are provided with several different connection types

depending

on

supplier and country. Adapters may be required.

After bunkering the transport truck's delivery hose and the filling line are to be cleaned with compressed

air and flushed with water. Also the tanks in the truck are to be cleaned with water. Therefore compressed

air and water connections should be located near to bunkering stations.

Caustic soda storage tank should be provided with the following alarms:

Temperature high (set point 45°C, if provided with heating)

Temperature low (set point 20°C, if relevant)

Level low (e.g. 30

)

Level high (e.g. 85 )

Caustic soda storage tank should be provided with the following indications:

Local level gauge (hydrostatic type with sensor isolating valve). Sight glasses are not recommended.

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.

Instead o sounding pipe

an

approved type local hydrostatic level indicator can be used, note that devices

need to

be

calibrated for caustic soda density. Relevant classification society 's rules concerning sounding

requirements should be verified.


14 March 2013



i fUiifii


Figure 7.5 Caustic soda storage tank fittings

T

I

H

HOLE

Installation Planning

Instructions

7. lkali Feed System

Alkali storage tank air and overflow pipe

are

led in similar way as normal air and overflow pipes

e

.g. above

bulkhead deck and overboard).

To

prevent spraying of alkali , the air pipe end should be protected by a

plate or similar means.

Figure 7.6 Example of spray protector plate for alkali storage tank air and overflow pipe .

7 7

lkali feed module

F

ROM

NaOH

STORAGE T NK

Alkali feed module consists

of

two pumps.

In

normal operating conditions one pump

is in

operati

on

and

the other pump in stand-by. The complete module includes also valves , sensors and filters.

To

prevent any

splashes in case of leakages the module is equipped with doors and drip tray. To minimize the suction line

length the preferred location of the alkali feed module

is

near the storage tank. Module connection A

vertical location to

be

max 1000 mm above bottom of alkali storage tank.

Number: One module per scrubber

Meyer Werft 697 - Scrubber-

a4

14

March 2013

7-7





Type:

Motor:

Frame:

Piping:

ry

weight:

Weight in operation:

Width :

Depth:

Height:

Chemical dosing

Approx 0.55 kW

Steel

AISI316L or equivalent

200 kg

300 kg

900mm

700 mm

1950 mm

f¥iiQib


I

Alkali feed module shutdown

is

connected to the emergency stop. The module is equipped with drip tray.

The drip tray drainage should be arranged with one of the following alternatives:

Alternative 1 automatic quick closing valve. 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. Drip

trays are to be of adequate capacity to receive such leak quanti ty which may escape from the system

prior to closing of the quick closing valve including quantity

in

the supply pipe. Leak detection and

quick closing system are to be of fail to safe type. Such drip trays are without drainage.

Alternative 2 automatic drainage to safe tank. Vertical conditions permitting drain pipes from the

drip trays are conducted freely flowing back to the NaOH storage tank or any other suitable tank .

Such drain pipes should be of adequate size and provided with heating where necessary to avoid

stiffening of the caustic soda. A sensor

in

the drip tray triggers

an

alarm

in

case of leakage.

Alternative 3 alarm. A sensor

in

the drip tray triggers an alarm

in

case of leakage.

7.8 p 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. The main components

in

the bleed-off buffer tank pH control are alkali dosing pump and

pH

sensor.

The

pH

will be measured from the recirculation line and the alkali is only dosed if the pH

is

below the set

value.

7.9 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. Selected pump type is self-priming.

Capacity : 100 1/h

Motor: 0.25 kW

Weight: 14

kg

7.10 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. 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. Selected pump type

is

self-priming. 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 1.5 meters.

Capacity: 3 m h

Motor: 1.1 kW

Weight: 37

kg

7-8 Meyer Werft

697

Scrubber-

a4

14

March 2013



IMJti fii Environmental Technologies

I

7 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.g. in case of tank service or inspection. Selected pump type is self-priming. 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.

5 meters.

Capacity: 10 m3/h

Motor: 3.7 kW

Weight: 84 kg

7 12 Alkali specification

Wartsila scrubber system typically uses 50 NaOH solution as neutralizing agent in the process. The

customer/operator should acquire the chemical according to the following specification .

50 NaOH

solution specific tion

(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

EINECS N:o

ADDITIONAL TRADE

NAME(S):

CHEMICAL COMPOSITION

1310-73-2

215-185-5

CAUSTIC SODA 50 ,LYE 50

SODIUM HYDROXIDE, Na- 45 . .. 52 -weight

OH

CHLORIDE (CI) < 0.1 -weight as NaCI

7 13 Drawings

DBAC471142-

DBAC471141-

DBAC4587

43 -

DBAC4587 43 -

DBAC458676 -

DBAC458676 -

DBAC458669 -

DBAC458669 -

Alkali feed module .. ... ..... ..... ................ ........ ..... .............. ... ... ............... ....... ..... ... .. 7 1

0

Alkali feed module .................... ........... ............ .................. ....

..

...

..

..

...

...

..

......

..

.

..

...

7 11

Alkali transfer pump ............ .................. ........... ..... ....

..

...... ............. .......... ........ 7

-12

Alkali transfer pump manual ..

...

.

..

...

...

.... .... ........

..

.

..

.... .

...

.........

...

...... ...... ....

...

..... ..

7 13

Alkali dosing pump .... ... ..... ... .... ............. .. .... ... .... ......... ....... .... ...... ... ............... .. ... .

7 18

Alkali dosing pump manual .

.. ..

.. .

...

.. ........

...

................... ..........

... ..

... .....

.. ..

........ .

..

.

7 19

Alkali topping-up pump ............ .... .. ..... ......... ...... .. ... ... .... ...... .. .... ...... ..... ............. ..

7 60

Alkali topping-up pump manual ...... ...... .. ... ........ .... ..... .. .. ..... ... .

..

...... ... .. .......... .. ....

7

61


14 March 2013

7-9



APPENDIX II

HAZARDOUS SUBSTANCE FACT SHEET – SODIUM HYDROXIDE



I I Right

to

Know

.... Hazardous Substance Fact

Sheet

common Name: SODIUM HYDROXIDE

Synonyms: Caustic Soda; Lye; Sodium Hydrate

Chemical Name: Sodium Hydroxide

Date: May 2 1

Revision : April2010

Descript ion

and Use

Sodium Hydroxide is an

odorless, white solid that absorbs

moisture from the air. It

is

used to make textiles, cellophane,

and pulp and paper,

in

soaps and detergents, and for etching

and electroplating.

Reasons

for

Citation

Sodium Hydroxide is on the Right to Know Hazardous

Substance List because it

is

cited by OSHA, ACGIH , DOT,

NIOSH, NFPA and EPA.

This chemical

is on

the Special Health Hazard Substance

List.

SEE G LOSSARY

ON

PAGE

5

FIRST

AID

Eye Contact

Quickly brush off excess chemical from the face .

Immediately flush with large amounts of water for at least 30

minutes, lifting upper and lower lids. Remove contact

lenses, if worn , while flushing. Seek medical attention

immediately.

Skin Contact

Quickly remove contaminated clothing. Immediately blot or

brush off excess chemical and wash gently with large

amounts water for at least 30 minutes. Seek medical

attention immediately.

Inhalation

Remove the person from exposure.

Begin rescue breathing using universal precautions) if

breathing has stopped and CPR if heart action has stopped .

~ r a n s f e r

promptly to a medical facility .

Medical observation

is

recommended for 24 to 48 hours after

overexposure, as pulmonary edema may be delayed .

EMERGENCY NUMBERS

Poison Control 1-800-222-1222

CHEMTREC: 1-800-424-9300

NJDEP Hotl ine: 1-877-927-6337

National Response Center: 1-800-424-8802

CAS Number:

RTK Substance Number:

DOT Number:

1310-73-2

1706

UN

1823 solid)

UN

1824 solution)

EMERGENCY RESPONDERS » SEE

LAST

PAGE

Hazard

Summary

Hazard R a t i n ~ ~

NJDOH

NFPA

HEALTH

-

3

FLAMMABILITY

-

0

REACTIVITY

-

1

CORROSIVE

DO

NOT USE WATER

Hazard Rat ng Key: 0-mrmma/; 1=s/rght; 2=moderate; 3=senous;

4=severe

Sodium Hydroxide can affect you when inhaled and by

passing through the skin .

Sodium Hydroxide is

a HIGHLY CORROSIVE CHEMICAL

and contact can severely irritate and burn the skin and eyes

with possible eye damage.

Contact can irritate the mouth, nose and throat.

Inhaling

Sodium Hydroxide

can irritate the lungs. Higher

exposures may cause a build-up of fluid

in

the lungs

pulmonary edema), a medical emergency.

Repeated exposure can lead to permanent lung damage.

Sodium Hydroxide in

contact with water or moisture may

generate enough heat to ignite combustibles.

Workplace Exposure Limits

OSHA: The legal airborne permissible exposure limit PEL) is

2 mg/m

3

averaged over

an

8-hour workshift.

NIOSH: The recommended airborne exposure limit REL) is

2 mg/m

3

which should not be exceeded at any time.

ACGIH : The threshold limit value TLV)

is

2 mg/m

3

which

should not be exceeded at any time.

The above exposure limits are for air levels only. When skin

contact also occurs, you may be overexposed, even though

air levels are less than the limits listed above.



SODIUM HYDROXIDE

etermining

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.

For each individual hazardous ingredient, read the New

Jersey Department of Health Hazardous Substance Fact

Sheet, available on the RTK website

(www.nj.gov/health/eoh/rtkweb) or

in

your facility s RTK

Central File or Hazard Communication Standard file .

~ o u 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, and under the

federal Occupational Safety and Health Act (OSHA) if you

are a private worker.

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 .

The federal OSHA Hazard Communication Standard (29

CFR 1910.1200) and the PEOSH Hazard Communication

Standard (N.J.A.C. 2 :100-7) require employers to provide

similar information and training to their employees.

This Fact Sheet

is

a summary of available information

regarding the health hazards that may result from exposure.

Duration of exposure, concentration of the substance and other

factors will affect your susceptibility to any of the potential

effects described below.

Health Hazard Information

cute 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), causing

blindness.

Contact can irritate the mouth , nose and throat.

Inhaling Sodium Hydroxide can irritate the lungs causing

coughing and/or shortness of breath. Higher exposures may

cause a build-up of fluid

in

the lungs (pulmonary edema), a

medical emergency, with severe shortness of breath.

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:

ancer Hazard

According to the information presently available to the New

Jersey Department of Health, Sodium Hydroxide has not

been tested for its ability to cause cancer

in

animals.

Page 2 of

Reproductive Hazard

There is no evidence that Sodium Hydroxide affects

reproduction. This

is

based

on

test results presently

available to the NJDOH from published studies .

Other Effects

Sodium Hydroxide can irritate the lungs. Repeated

exposure may cause bronchitis to develop with coughing,

phlegm , and/or shortness of breath.

Repeated exposure can lead to permanent lung damage.

Med

ical

Medical Testing

For frequent or potentially high exposure (half the PEL or

greater), the following are recommended before beginning

work and at regular times after that:

Lung function tests

If symptoms develop or overexposure is suspected, 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. Medical tests that look for

damage already done are not a substitute for controlling

exposure.

Request copies of your medical testing. You have a legal right

to this information under the OSHA Access to Employee

Exposure and Medical Records Standard (29 CFR 1910.1 020).

Mixed Exposures

Smoking can cause heart disease , lung cancer,

emphysema, and other respiratory problems . It may worsen

respiratory conditions caused by chemical exposure. Even if

you have smoked for a long time , stopping now will reduce

your risk of developing health problems.



SODIUM HYDROXIDE

Workplace Controls and Practices

Very toxic chemicals, or those that are reproductive hazards or

sensitizers, require expert advice on control measures

if

a less

toxic chemical cannot be substituted. Control measures

include: (1) enclosing chemical processes for severely

irritating and corrosive chemicals, (2) using local exhaust

ventilation for chemicals that may be harmful with a single

exposure, and (3) using general ventilation to control

exposures to skin and eye irritants. For further information

on

workplace controls, consult the NIOSH document on Control

Banding at www.cdc.gov/niosh/topics/ctrlbanding/.

The following work practices are also recommended :

' Label process containers.

' Provide employees with hazard information and training.

' Monitor airborne chemical concentrations.

'

Use engineering controls if concentrations exceed

recommended exposure levels.

' Provide eye wash fountains and emergency showers.

' Wash or shower if skin comes in contact with a hazardous

material.

' Always wash at the end

of

the workshift.

'

Change into clean clothing if clothing becomes

contaminated.

' Do not take contaminated clothing home.

' Get special training to wash contaminated clothing .

'Do

not eat, smoke, or drink

in

areas where chemicals are

being handled, processed or stored .

' Wash hands carefully before eating, smoking , drinking,

applying cosmetics or using the toilet.

In addition, the following may

be

useful or required:

' Use a vacuum to reduce dust during clean-up.

DO

NOT

DRY SWEEP.

Personal Protective

Equipment

The OSHA Personal Protective Equipment Standard (29 CFR

191

0.132) requires employers to determine the appropriate

personal protective equipment for each hazard and to train

employees on how and when to use protective equipment.

The following recommendations are only guidelines and may

not apply to every situation.

Gloves and Clothing

'Avoid

skin contact with Sodium Hydroxide. Wear personal

protective equipment made from material which can not be

permeated or degraded by this substance. Safety

equipment suppliers and manufacturers can provide

recommendations

on

the most protective glove and clothing

material for your operation.

' Safety equipment manufacturers recommend Butyl, Nitrile,

Neoprene, Polyvinyl Chloride, Silver Shield®/4H®, Viton and

Barrier® as glove materials for Sodium Hydroxide

in

solution and Tychem® SL, and Responder®, and

Trellchem® HPS and VPS, or the equivalent, as protective

clothing materials for Sodium Hydroxide

solid

or

solution.

' All protective clothing (suits , gloves, footwear, headgear)

should be clean, available each day, and put on before work.

Page 3

of

Eye Protection

'

Wear eye protection with side shields or goggles.

'

Wear a face shield along with goggles when working with

corrosive, highly irritating or toxic substances.

Respiratory Protection

Improper use

o

respirators is dangerous Respirators

should only

be

used if the employer has implemented a written

program that takes into account workplace conditions,

requirements for worker training , respirator fit testing, and

medical exams, as described

in

the OSHA Respiratory

ProtectionStandard (29 CFR 1910.134).

' Where the potential exists for exposure over 2 mg/m

3

use a

NIOSH approved negative pressure, air-purifying, particulate

filter respirator with

an

N, R or

P1

00 filter. More protection is

provided by a full facepiece respirator than by a half-mask

respirator, and even greater protection is provided by a

powered-air purifying respirator.

'Leave the area immediately if (1) while wearing a filter or

cartridge respirator you can smell , taste, or otherwise detect

Sodium Hydroxide (2) while wearing particulate filters

abnormal resistance to breathing

is

experienced,

or

(3) eye

irritation occurs while wearing a full facepiece respirator.

Check to make sure the respirator-to-face seal is still good.

If it is , replace the filter or cartridge.

If

the seal is no longer

good, you may need a new respirator.

'

Consider all potential sources

of

exposure

in

your workplace.

You may need a combination of filters, prefilters or cartridges

to protect against different forms of a chemical (such as

vapor and mist) or against a mixture

of

chemicals.

' Where the potential for high exposure exists, use a NIOSH

approved supplied-air respirator with a full facepiece

operated in a pressure-demand or other positive-pressure

mode. For increased protection use

in

combination with an

auxiliary self-contained breathing apparatus or

an

emergency escape air cylinder.

'Exposure to 10 mglm

3

is

immediately dangerous to life and

health. If the possibility of exposure above 10 mg/m

3

exists,

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.

Fire

Hazards

If employees are expected to fight fires, they must be trained

and equipped as stated in the OSHA Fire Brigades Standard

(29 CFR

191

0.156).

' Extinguish fire using an

agent suitable for type of

surrounding fire. Sodium Hydroxide itself does not burn.

'POISONOUS

GASES ARE PRODUCED

IN

FIRE.

'

Use water spray to keep fire-exposed containers cool. DO

NOT get water inside containers.

' Sodium Hydroxide

in

contact with water or moisture may

generate enough heat to ignite combustibles.



SO IUM HY ROXI E

Spills

and

mergencies

If employees are required to clean-up spills , they must be

properly trained

and

equipped. The OSHA Hazardous Waste

Operations and Emergency Response Standard 29 CFR

1910.120) may apply.

If

Sodium Hydroxide

is

spilled or leaked, take the following

steps:

. .

Evacuate personnel and secure and control entrance to the

area.

. .

Eliminate all ignition sources

. . For Sodium Hydroxide

in

solution absorb liquids

in

dry

sand, earth, or a similar material and place into sealed

containers for disposal.

. .

Collect solid material in the most convenient and safe

manner and place into sealed containers for disposal.

. . O NOT USE WATER OR WET METHOD.

. .

Ventilate and wash area after clean-up is complete.

. . O NOT wash into sewer.

. .

It may be necessary to contain and dispose of

Sodium

Hydroxide as a HAZARDOUS WASTE. Contact your state

Department of Environmental Protection DEP) or your

regional office of the federal Environmental Protection

Agency EPA) for specific recommendations.

Handling and Storage

Prior to working with

Sodium Hydroxide

you should be trained

on its proper handling and storage

. . Sodium Hydroxide reacts with STRONG ACIDS such as

HYDROCHLORIC, SULFURIC and NITRIC); WATER; and

MOISTURE to rapidly release heat.

. . Sodium Hydroxide

reacts with METALS such as

ALUMINUM , LEAD, TIN and ZINC) to form flammable and

explosive Hydrogen gas

. . Sodium Hydroxide can form shock sensitive salts on

contact with NITROGEN CONTAINING COMPOUNDS

such as NITROMETHANE)

. . Sodium Hydroxide

is not compatible with OXIDIZING

AGENTS such as PERCHLORATES, PEROXIDES,

PERMANGANATES, CHLORATES, NITRATES,

CHLORINE, BROMINE and FLUORINE); CHLORINATED

SOLVENTS; AMMONIA; and ORGANIC MATERIALS

. . Store

in

tightly closed containers

in

a cool , well-ventilated

area away from WATER and MOISTURE

. . Sodium Hydroxide can attack IRON, COPPER, PLASTICS,

RUBBER and COATINGS.

Page 4 of6

Occupational Health Information

Resources

The New Jersey Department of Health offers multiple services

in occupational health. These services include providing

informational resources, educational materials, public

presentations, and industrial hygiene and medical

investigations and evaluations.

For more information please contact:

New Jersey Department of Health

Right to Know

PO Box 368

Trenton,

NJ

08625-0368

Phone: 609-984-2202

Fax: 609-984-7407

E-mail: [email protected]

Web address: http://www. nj.gov/health/eoh/rtkweb

The Right to now Hazardous Substance Fact Sheets

are

not intended

to

be

copied

and sold

for commercial purposes

.



SODIUM HYDROXIDE

GLOSSARY

ACGIH is the American Conference of Governmental Industrial

Hygienists. They publish guidelines called Threshold Limit

Values (TLVs) for exposure to workplace chemicals .

Acute Exposure Guideline

Levels (AEGLs) are established

by the EPA. They describe the risk to humans resulting from

once-in-a lifetime, or rare, exposure to airborne chem icals.

Boiling point is the temperature at which a substance can

change its physical state from a liquid to a gas.

A

carcinogen is

a substance that causes cancer.

The CAS number is unique, identifying number, assigned by

the Chemical Abstracts Service, to a specific chemical.

CFR

is

the Code of Federal Regulations , which are the

regulations of the United States government.

A combustible substance is a solid , liquid or gas that will burn.

A corrosive substance is a gas, liquid or solid that causes

destruction of human skin or severe corrosion of containers .

The

critical

temperature

is

the temperature above which a

gas cannot

be

liquefied, regardless of the pressure applied .

DEP is the New Jersey Department of Environmental

Protection.

DOT is the Department of Transportation, the federal agency

that regulates the transportation of chemicals .

EPA is the Environmental Protection Agency, the federal

agency responsible for regulating environmental hazards.

ERG is the Emergency Response Guidebook. It

is

a guide for

emergency responders for transportation emergencies

involving hazardous substances.

Emergency Response Planning

Guideline

(ERPG) values

prov1de estimates of concentration ranges where one

reasonably might anticipate observing adverse effects .

A fetus

is

an unborn human or animal.

A flammable substance is a solid, liquid , vapor or gas that will

1gmte eas1ly

and burn rapidly.

The flash

point is

the temperature at which a liquid or solid

g1ves off vapor that can form a flammable mixture with air .

IARC is the International Agency for Research on Cancer a

scientific group.

Ionizati on Potent ial is the amount

of energy needed to

remove an electron from an atom or molecule. It is measured

in

electron volts.

IRIS is the Integrated Risk Information System database on

human health effects that may result from exposure to various

chemicals , maintained by federal EPA.

Page 5

of

LEL or Lower Explosive Limit, is the lowest concentration of

a combustible substance (gas or vapor) in the air capable of

continuing an explosion.

mg/m3 means milligrams of a chemical in a cubic meter of air.

It is a measure of concentration (weighUvolume) .

A mutagen is a substance that causes mutations. A mutation

is

a change

in

the genetic material

in

a body cell. Mutations

can lead to birth defects, miscarriages, or cancer.

NFPA is the National Fire Protection Association. It classifies

substances according to their fire and explosion hazard .

NIOSH is the National Institute for Occupational Safety and

Health. It tests equipment, evaluates and approves

respirators, conducts studies of workplace hazards, and

proposes standards to OSHA.

NTP

is the National Toxicology Program which tests chemicals

and reviews evidence for cancer.

OSHA is the federal Occupational Safety and Health

Administration , which adopts and enforces health and safety

standards.

PEOSHA the New Jersey Public Employees Occupational

Safety and Health Act, which adopts and enforces health and

safety standards in public workplaces.

Permeated is the movement of chemicals through protective

materials.

ppm means parts of a substance per million parts of air. It

is

a

measure of concentration by volume in air

Protective

Action

Criteria (PAC) are values established by

the Department of Energy and are based on AEGLs and

ERPGs. They are used for emergency planning of chemical

release events.

A reactive substance

is

a solid, liquid or gas that releases

energy under certain conditions.

STEL

is

a Short Term Exposure Limit which

is

usually a

5

mlnute exposure that should not be exceeded at any time

during a work day.

A teratogen is a substance that causes birth defects by

damaging the fetus.

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 explosion.

Vapor

Density

is

the ratio of the weight of a given volume of

one gas to the weight of another (usually Air , at the same

temperature and pressure.

The

vapor pressure is

a force exerted by the vapor

in

equilibrium with the solid or liquid phase of the same

substance. The higher the vapor pressure the higher

concentration of the substance in air.



I

e lth Right to Know

Hazardous

Substance Fact Sheet

. . . ~ «

mergency

esponders

tick

Refnnce

Common Name: SODIUM HYDROXIDE

Synonyms: Caustic Soda; Lye; Sodium Hydrate

CAS No: 1310-73-2

Molecular Formula: NaOH

RTK Substance No: 1706

Description: Odorless, white solid that absorbs moisture from the air

H Z

RD D

T

Hazard Rating Firefighting

Reactivity

3- Heal th Extinguish fire using an agent suitable for type of

Sodium Hydroxide reacts with STRONG ACIDS (such as

0- Fire

surrounding fire. Sodium Hydroxide itself does HYDROCHLORIC, SULFURIC and NITRIC); WATER; and MOISTURE

not burn.

to rapidly release heat.

1 -

Reactivity

POISONOUS GASES ARE PRODUCED

IN

FIRE.

Sodium Hydroxide reacts with METALS (such as ALUMINUM, LEAD,

Use water spray to keep fire-exposed containers

TIN and ZINC) to form flammable and explosive Hydrogen gas.

DOT :

cool. DO NOT get water inside containers .

Sodium Hydroxide can form shock sensitive salts on contact with

UN 1823 (solid)

Sodium Hydroxide

in

contact with water or

NITROGEN CONTAINING COMPOUNDS (such as NITROMETHANE).

UN 1824 (solution)

moisture may generate enough heat to ignite Sodium Hydroxide is not compatible with OXIDIZING AGENTS (such

combustibles .

as PERCHLORATES, PEROXIDES, PERMANGANATES,

ERG

Guide

: 154

CHLORATES, NITRATES, CHLORINE, BROMINE and FLUORINE);

Hazard Class: 8

CHLORINATED SOLVENTS; AMMONIA; and ORGANIC MATERIALS.

(Corrosive)

Sodium Hydroxide

can attack IRON, COPPER, PLASTICS, RUBBER

and COATINGS.

SP

IL

L LE KS

PHYSIC L PROPERTIES

Isolation Distance:

Odor Threshold:

Spill (solid): 25 meters (75 feet) Spill (liquid) : 50 meters (150 feet)

Flash Point:

Odorless

Noncombustible

2.1 air=1)

ire: 800 meters (1/2 mile)

For Sodium Hydroxide

in

solution absorb liquids in dry sand, earth ,

or a similar material and place into sealed containers for disposal.

Collect soli material in the most convenient and safe manner

and place into sealed containers for disposal.

DO NOT USE WATER OR WET METHOD.

DO NOT wash into sewer.

Neutralize water spills with a dilute acid .

Sodium Hydroxide is hazardous to the environment, especially

water organisms.

E

XPOSURE LI MITS

OSHA: 2 mg/m

3

8-hr TWA

NIOSH: 2 mg/m

3

Ceiling

ACGIH: 2 mglm

3

Ceiling

IDLH: 10 mg/m

3

The Protective Action Criteria values are :

PAC-1 = 0.5 mg/m

3

PAC-2 = 5 mglm

3

Eyes:

Skin

:

Inhalation:

PAC-3 = 50 mg/m

3

H

E

L

TH

EFFECTS

Severe irritation, burns and possible eye

damage

Irritation and severe burns

Nose, throat and lung irritation with coughing

and severe shortness of breath (pulmonary

edema)

Gloves:

Vapor Density:

Vapor Pressure:

Specific Gravity:

Water Solubility:

Boiling Point:

Melting Point:

Molecular Weight:

0 mm Hg at 68°F (20°C)

2.1 (water = 1)

Soluble

2,534°F (1 ,390°C)

604°F (318°C)

40

PROTECTIVE

EQUIPMENT

Butyl , Nitrile, Neoprene, PVC, SilverShield®I4H®, Viton and

Barrier® (>8-hr breakthrough for

Sodium Hydroxide in

solution

Coveralls: Tychem® SL and Responder®, and Trellchem® HPS and VPS

(>8-hr breakthrough for Sodium Hydroxide solid or solution

Respirator: <1 0 mg/m

3

- Full facepiece APR with High efficiency filters

>10 mglm

3

- SCBA

FIRST ID ND DECONT MIN TION

Remove the person from exposure.

Quickly

brush off excess chemical from the face . Flush with large amounts

of

water

for at least 30 minutes. Remove contact lenses, if worn. Seek medical attention

immediately.

Quickly remove contaminated clothing. Immediately blot or brush off excess

chemical and wash with large amounts of water for at least 30 minutes. Seek

medical attention immediately.

Begin

artificial respiration if breathing has stopped and CPR if necessary.

Transfer promptly to a medical facility.

Medical observation is recommended as symptoms may be delayed.

April2010



APPENDIX III

PRELIMINARY RISK ASSESSMENT



Appendix III – Page 1

SeaQuest Testing & Consulting – Preliminary Risk Assessment

PRELIMINARY

RISK

ASSESSMENT

FOR

THE

USE

OF

CAUSTIC

SODA

IN

AN

ENGINE

EXHAUST

STACK SCRUBBING SYSTEM

1. 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. Should

the process be implemented, this risk assessment would require review and possible

modification to comport with any details, information derived from specific job safety

analyses and other characteristics of the process that are presently unknown.

The following risk assessment cites several United States Federal Occupational Safety

and Health Regulations (OSHA) applicable to workers involved in the process being

considered. Although the regulations may not be required for workers employed in

international waters, these regulations are based on sound, state of the art industrial

hygiene principles

that

provide

a safe

and

healthy

environment

for

workers.

2.

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. Caustic Soda, 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. The potential hazards

of working with Caustic Soda make it important that all persons handling Caustic Soda

know and follow strict procedures for safety. This preliminary risk assessment will

address the following issues:

a. Hazard Identification

b. Protective Measures

c. Regulations Applicable to Caustic Soda

d. Risk Assessment

e. Risk Management

f. Residual Risk Summary

3.

HAZARD

IDENTIFICATION

a. Product Identification

i. Synonyms: Caustic Soda, Sodium Hydroxide, Lye, Sodium Hydrate

ii. Chemical Formula: NaOH

iii. CAS Number: 1310‐73‐2

iv. RTK Substance Number: 1706





v. DOT Number: UN 1823 (solid), UN 1824 (solution)

vi. Hazardous Waste Number: D002

vii. 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 1910.1200).

b.

Product Description

i. Solid state: odorless, white solid, absorbs moisture from air

ii. 50% Solution: odorless, clear

c. Workplace Exposure Limits

i. OSHA: The legal airborne permissible exposure limit (PEL) is 2 mg/m3

averaged over an 8‐hour work shift.

ii. NIOSH: The recommended airborne exposure limit (REL) is 2 mg/m3,

which should not be exceeded at any time.

iii. 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.

iv. ACGIH: The threshold limit value (TLV) is 2 mg/m3, which should not be

exceeded at any time.

d. Potential Health Effects

i. Inhalation: May cause irritation (possibly severe), chemical burns, and

pulmonary edema.

ii. Skin contact: May cause irritation (possibly severe) and chemical burns.

iii. Eye contact: May cause irritation (possibly severe), chemical burns, eye

damage, and blindness.

iv.

Ingestion: May

cause

irritation

(possibly

severe),

chemical

burns,

nausea,

and vomiting.

v. Note: The severity of tissue damage is a function of its concentration, the

length of tissue contact time, and local tissue conditions. After exposure

there may be a time delay before irritation and other effects occur. This

material is a strong irritant and is corrosive to all human tissue.

e. First Aid

i. Eye Contact: Immediately flush eyes with a directed stream of water for

at least 15 minutes, forcibly holding eyelids apart to ensure complete

irrigation of all eye and lid tissues. Washing eyes within several seconds is

essential to

achieve

maximum

effectiveness.

GET

MEDICAL

ATTENTION

IMMEDIATELY.

ii.

Skin Contact: Immediately flush contaminated areas with water from a

safety shower. Remove contaminated clothing, jewelry, and shoes

immediately. Wash the affected skin for 15 minutes. If the eyes have not

been exposed do not remove your goggles until your head and hair has





been thoroughly rinsed. Wash contaminated areas with soap and water.

Thoroughly clean and dry contaminated clothing before reuse. Discard

contaminated leather goods. GET MEDICAL ATTENTION IMMEDIATELY.

iii. Inhalation: If adverse effects occur, remove to uncontaminated area. Give

artificial respiration if not breathing. If breathing is difficult, oxygen

should be

administered

by

qualified

personnel.

If

respiration

or

pulse

has

stopped, have a trained person administer basic life support (Cardio‐

Pulmonary Resuscitation/Automatic External Defibrillator) and CALL FOR

EMERGENCY SERVICES IMMEDIATELY.

iv. Ingestion: Never give anything by mouth to an unconscious or convulsive

person. If swallowed, do not induce vomiting. Give large amounts of

water. If vomiting occurs spontaneously, keep airway clear. Give more

water when vomiting stops. GET MEDICAL ATTENTION IMMEDIATELY.

v. Notes to Physician: The absence of visible signs or symptoms of burns

does

NOT

reliably

exclude

the

presence

of

actual

tissue

damage.

Probable mucosal damage may contraindicate the use of gastric lavage.

f. Stability and Reactivity

i. Reactivity/ Stability: Stable at normal temperatures and pressures.

ii. Conditions to Avoid: Mixing with water, acid or incompatible materials

may cause splattering and release of large amounts of heat. Will react

with some metals forming flammable hydrogen gas.

iii. Sodium Hydroxide reacts with STRONG ACIDS (such as HYDROCHLORIC,

SULFURIC and NITRIC); WATER; to rapidly release heat.

iv. Sodium Hydroxide reacts with METALS (such as ALUMINUM, LEAD, TIN

and ZINC)

to

form

flammable

and

explosive

Hydrogen

gas.

v. Sodium Hydroxide can form shock sensitive salts on contact with

NITROGEN CONTAINING COMPOUNDS (such as NITROMETHANE).

vi. Sodium Hydroxide is not compatible with OXIDIZING AGENTS (such as

PERCHLORATES, PEROXIDES, PERMANGANATES, CHLORATES, NITRATES,

CHLORINE, BROMINE and FLUORINE); CHLORINATED SOLVENTS;

AMMONIA; and ORGANIC MATERIALS.

g. Accidental Releases

i. Evacuate personnel and secure and control entrance to the area.

ii. Wear appropriate personal protective equipment recommended in

section 4 below.

iii. Completely contain spilled material with dikes, sandbags, etc.

iv.

Vacuum up for reuse or disposal.

v. Carefully dilute remaining material

vi.

Neutralize with weak acid (acetic acid) if necessary.





vii. Accidental releases to the environment may trigger reporting

requirements to federal, state and local authorities if threshold limits are

exceeded. The threshold limit for Caustic Soda is 1,000 lbs.

viii. In the U.S., spill reports to the National Response Center (1‐800‐424‐

8802) will comply with federal reporting requirements under CERCLA and

SARA regulations.

The

Coast

Guard

may

also

need

to

be

notified

under

the Clean Water Act.

ix. If employees are required to clean up spills, they must be properly

trained and equipped. The OSHA Hazardous Waste Operations and

Emergency Response Standard (29 CFR 1910.120) may apply.

h. Fire Emergency

i. Fire Hazard: Caustic Soda is not flammable

ii. Extinguishing Media: Use media appropriate for surrounding fire.

iii. Fire Fighting: Move container from fire area if it can be done without risk.

Cool

containers

with

water.

iv. If employees are expected to fight fires, they must be trained and

equipped as stated in the OSHA Fire Brigades Standard (29 CFR

1910.156).

4. PROTECTIVE MEASURES

a. Personal Protective Equipment

i. Eye Protection: Wear chemical safety goggles with a face shield to

protect against eye and skin contact when appropriate. Provide an

emergency eye

wash

fountain

and

quick

drench

shower

in

the

immediate

work area.

ii. Skin and Body Protection: Wear chemical resistant clothing and rubber

boots when potential for contact with the material exists. Contaminated

clothing should be removed, then discarded or laundered.

iii. Hand Protection: Wear appropriate chemical resistant gloves

iv. Protective Material Types: Natural rubber, Neoprene, Nitrile, Polyvinyl

Chloride, Viton

v. Respiratory Protection: A NIOSH approved respirator with N95 (dust,

fume, mist) cartridges may be permissible under certain circumstances

where airborne

concentrations

are

expected

to

exceed

exposure

limits,

or when symptoms have been observed that are indicative of

overexposure. If eye irritation occurs, a full face style mask should be

used. A respiratory protection program that meets 29 CFR 1910.134 must

be followed whenever workplace conditions warrant use of a respirator.





Where the potential for high exposure exists, such as cleaning storage

tanks, use a NIOSH approved supplied‐air respirator with a full face piece

operated in a pressure‐demand or other positive‐pressure mode. For

increased protection use in combination with an auxiliary self ‐contained

breathing apparatus or an emergency escape air cylinder.

b.

Other Protective

Measures

i. Eyewash fountains should be located near all caustic soda handling areas.

ii. Safety showers should be located directly above the eyewash fountains.

iii. Eyewash and safety showers should be designed to comply with 29 CFR

1910.151(c)—Medical Services and First Aid.

iv. Diking able to contain the entire volume of Caustic Soda in the system

should be installed.

5. REGULATIONS APPLICABLE TO CAUSTIC SODA

a. Private sector workers in New Jersey are covered by Federal OSHA.

b. 29 CFR 1910.1200—Hazard Communication Standard—requires that employees

be informed of chemical hazards in their workplace. Some highlights of the

standard follow:

i. Employers must develop and implement a written hazard communication

program and make that program available to employees.

ii. 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.

iii.

Containers of

hazardous

chemicals

must

be

labeled.

The

label

must

identify the chemical, its manufacturer and appropriate hazard warnings.

Employees must be trained to read such labels.

iv. Employers must have a material safety data sheet (MSDS) for each

hazardous chemical in its workplace. The MSDS must include (among

other things) the identity used on the container label; common name and

names of chemical ingredients in the hazardous chemical; physical and

chemical characteristics (such as vapor pressure and flash point); physical

hazards (such as potential for fire, explosion and reactivity to other

substances that are incompatible); health hazards (such as signs and

symptoms of

exposure);

how

the

chemical

can

enter

your

body;

permissible exposure limits; whether the chemical will cause cancer;

precautions for safe handling and use (including protective measures);

emergency and first aid procedures; when the MSDS was prepared or last

changed; the name and telephone number of the manufacturer or other





source that can provide additional information (including emergency

procedures).

v. The MSDSs must be readily accessible to employees during each work

shift. Employees must be taught to use them.

vi. Employees must be informed of the location of hazardous chemicals.

vii.

Employees must

be

trained

in

how

to

detect

the

presence

of

a hazardous

chemical; its health hazards; and protective measures (including work

practices, personal protective equipment and emergency procedures).

c. EPCRA Section 311‐312‐‐ Emergency Planning and Community Right‐to‐Know Act

of 1986‐‐ applies to any facility at which a hazardous chemical, as defined by the

Occupational Safety and Health Act, is present in an amount exceeding a

specified threshold. The threshold for Caustic Soda is 10,000 lbs. 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,

the

Local

Emergency

Planning

Committee,

and

the local fire department with jurisdiction over the facility. Reporting thresholds

are codified in 40 CFR 370.10.

d. CERCLA SECTIONS 102a/103‐‐ Comprehensive Environmental Response,

Compensation, and Liability Act of 1980—Accidental releases

i. CERCLA Reportable Quantity for Caustic Soda: 1,000 lb. (note: this is well

below the projected weekly use).

ii. If a release is reportable under CERCLA section 103, notify the National

Response Center at (800) 424‐8802 or (202) 426‐2675. The Coast Guard

may also need to be notified under the Clean Water Act.

e.

29 CFR

1910.120

‐‐ OSHA

Hazardous

Waste

Operations

and

Emergency

Response

Standard (HazWOPER)

i. This standard applies to emergency response operations for release, or

substantial release threat, of hazardous substances without regard to

location of the hazard.

ii. Certain requirements must be complied with under the HazWOPER

standard. These requirements include a written emergency response

plan, training, control and cleanup.

iii. Emergency Response Plan must address the following:

a. pre‐emergency planning and coordination with outside

responding agencies,

i.e.,

fire,

EMS,

police,

etc.;

b. personnel roles, lines of authority and lines of communication;

c.

emergency recognition and prevention (what constitutes an

emergency and how to prevent the occurrence);

d.

safe distances and places of refuge;

e. site security and control;





f. evacuation routes and procedures;

g. decontamination procedures;

h. emergency medical treatment and first aid;

i. emergency alerts and response;

j. personal protective equipment and emergency equipment;

k.

engineering controls;

l. air monitoring

m. critique of response procedures and follow‐up.

iv. Training‐‐required for any employee who responds to an emergency.

Section Q of the standard specifies the training requirements. They are

broken down into 5 levels that are tied to specific duties.

a. Level 1: First Responder Awareness

b. Level 2: First Responder Operations

c. Level 3: Hazardous Materials Technician

d.

Level

4:

Hazardous

Materials

Specialist

e. Level 5: On‐Site Incident Commander

v. Control and Cleanup

At least two Level 2 technicians are required to slow and control a

hazardous spill as specified in 29 CFR 1910.120 (HazWOPER), which

mandates a buddy system in these circumstances. Additionally, a trained

Level 5 Incident Commander must be present.

Once the spill is contained, it must be stopped at the source, cleaned up

and disposed of properly.

f. 29 CFR 1910.156‐‐ OSHA Fire Brigades Standard

If employees

are

expected

to

fight

fires,

they

must

be

trained

and

equipped

in

accordance with the Fire Brigades Standard.

g. 29 CFR 1910.132—Personal Protective Equipment—General requirements—

requires protection for employees’ eyes, face, head and extremities in the

presence of hazards that require such protection, including, but not limited to,

chemical hazards and hazards encountered through absorption, inhalation or

physical contact.

h. 29 CFR 1910.133—Personal Protective Equipment—Eye and face protection—

requires protection against liquids and other hazards to the eyes and face.

i. 29 CFR 1910.134—Personal Protective Equipment—Respiratory protection—

includes (among

other

pertinent

subjects)

the

selection,

fitting

and

care

for

respirators and instructions to employees about the use of respirators. 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. The program must be administered by a

suitably trained program administrator.





j. 29 CFR 1910.151(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, where the eyes or body of any person may be

exposed to injurious corrosive materials.

6.

RISK

ASSESSMENT

Caustic Soda falls under the category of “Hazardous Substance” according to OSHA’s

Hazard Communication Standard, 29 CFR 1910.1200. It was projected that

approximately 37,000 gallons of 50% Caustic Soda solution per week would be utilized.

This quantity is equivalent to 447,700 lbs. of solution weight or 223,850 lbs. Caustic

Soda dry weight. 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, which eliminates potential employee exposure to splashing of the liquid and

aerosol formation under normal conditions of operation. However, Caustic Soda will be

directly

handled

by

employees

involved

with

unloading

tank

trucks,

bunkering

areas,

tanks, sounding pipes, feed module and bleed‐off treatment units. Additionally,

potentially greater exposure to caustic soda is probable for employees charged with the

task of cleaning storage tanks. It is conceivable that such an activity could produce

significant caustic soda aerosol inhalation exposure.

7. RISK MANAGEMENT

Based on the risk assessment of the various conditions defined in section 6, the

following risk management measures are recommended:

a. Training on the safe handling of the material must be given to every employee

involved in

the

handling,

storage

and

use

of

the

material.

b. Periodic surveillance of the storage tanks, fittings, piping and connections for

evidence of wear is required.

c. Safety showers and eye washes should be conveniently located and readily

accessible near all areas where Caustic Soda will be handled.

d. Safety showers and eye washes should be clearly marked with dedicated signs.

e. The following personal protective equipment must be worn when handling

Caustic Soda;

i. Close fitting safety goggles and chemical resistant gloves

ii. Additional clothing and equipment may be required. 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. These risk management options include:

a. Hard hat

b.

Chemical resistant apron

c. Full face shield (in addition to close fitting safety goggles)





d. Chemical resistant boots

e. Chemical protective suit (jacket and pants)

f. Full chemical protective suit with hood and air supplied respirator

8.

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, it can be

concluded that the risk to workers and the environment can be classified as minimal.



APPENDIX IV

RESOURCE DISK

Available as a Separate Submittal

caustic soda feasibility study

Documents