ENVIRONMENTAL REFERENCE MANUAL § Imperial Oil ProductsDivision Distribution DistributionOperations e ENVIRONMENTAL REFERENCE MANUAL Imperial Oil ProductsDivision Distribution November 16, 1992 TO: Attached Distribution List FROM: SUBJECT: J. S. Whitelaw Environmental Reference Manual Enclosed is your guide to environmental risk reduction strategies, options and methods concerning these parts of our Distribution facilities/operations : underground piping, underground steel tanks, terminal effluents , tank lot spills, and floating roof vapour suppression . Regulatory and economic factors continue to influence our risk reduction efforts and given today's business climate, we must continue to be prudent in our environmental plans and strategies. Please take the time to review the requirements outlined in this guide and contact me if you want any clarification . Thank you. - ~ a:;;itelaw Operating Pract ices Manage r Distribution Operations cc : J. D. Lanoue Enclosure ENVIRONMENTAL REFERENCE MANUAL Distribution List Operating Practices Manager 111-1037 (J.S.Whitelaw) Environmental Advisor Environmental Advisor Environmental Advisor Environmental Advisor Environmental Advisor Dartmouth MEDU Finch Edmonton Lougheed Loss Control Advisor Pipeline Div., EPE-Calgary Senior Terminal Manager Senior Terminal Manager Senior Terminal Manager Senior Terminal Manager Senior Terminal Manager Senior Terminal Manager Senior Terminal Manager Senior Terminal Manager Senior Terminal Manager Senior Terminal Manager Senior Terminal Manager Dartmouth St. John's, Nfld. Quebec Montreal East MEDU Ottawa Finch Winnipeg Edmonton N.W.T. (Edmonton Terminal) Lougheed Operations Support Manager Eng ineering Support 111-1032 (J. D. Lanoue) 111-1011 (P. Schwanen } @ ENVIRONMENTAL REFEREN E MANUAL ImperialOil ProductsDivision Distribution July 30, 1993 TO: FROM: SUBJECT: Att ch d Distribution List J . S. Whit I w Ozone Depleting Materials, ERM Revision #1 Compliance with legislative requirements is our priority when it comes to the use of ozone depleting substances , such as fluorocarbons and halon, in our operation . The enclosed ERM updates (Section 8.1, 8.2 and 8.3) outline the strategy and risk reduction options in complying with government regulations, as well as our commitment to do our share to help prevent the destruction of ozone layer . Please review the requirements in this new ERM section and contact me if any further information is required. J. S. Whitelaw Operating Practices Manager Distribution Operations ENVIRONMENT AL REFERENCE MANUAL Distribution List Operating Practices Manager 111-1037 (J.S.Whitelaw) Environmental Advisor Environmental Advisor Environmental Advisor Environmental Advisor Environmental Advisor Dartmouth MEDU Finch Edmonton Lougheed Loss Control Advisor Pipeline Div., EPE-Calgary Senior Terminal Manager Senior Terminal Manager Senior Term inal Manager Senior Terminal Manager Senior Terminal Manager Senior Terminal Manager Senior Terminal Manager Senior Term inal Manager Senior Terminal Manager Senior Terminal Manager Senior Terminal Manager Dartmouth St. John's, Nfld. Quebec Montreal East MEDU Ottawa Finch Winn ipeg Edmonton N.W.T. (Edmonton Terminal) Lougheed Operations Support Manager Engineering Support 111- 1032 (J. D. Lanoue) 111-1011 (P. Schwanen) ENVIRONMENTAL REFERENCE MANUAL November 1992 9 Imperial Oil Products Division Distribution Dlltrlbutlon Oplnitlonl ENVIRONMENTAL REFERENCE MANUAL TABLE OF CONTENTS 1. UNDERGROUND PIPING 1. Strategy 2. Risk Reduction Options 3. Concerns 4. Risk Reduction Methods 5. Resurfacing 6. Pipeline Replacement 7. Monitoring Wells 2. UNPROTECTED UNDERGROUND STEEL TANKS 1. Strategy 2. Risk Reduction Options 3. Replacing U/G Unprotected Steel Tanks 4. Risk Reduction Methods 5. Provincial Requirements 3. TERMINAL EFFLUENT QUALITY 1. Strategy 2. Risk Reduction Options 3. Risk Reduction Methods 4. TANK LOT SPILL PREVENTION I. Strategy 2. Risk Reduction Options JULY 1993 Rev. #1 erm-Oa.doc Page 1 of 2 TITLE SECTION SUBJECT ENVIRONMENTAL REFERENCE MANUAL 1: UNDERGROUND PIPING 2: RISK REDUCTION OPTIONS OPTIONS • IMPLEMENT A LEAK DETE TI N PRO ,RAM. • IF A LEAK OCCURS: • Clamp the pipe. • Check as ociat d pipe for corrosion. • If warranted, begin planning process to resurface piping. • CONDUCT REGULAR INSPECTIONS OF CATl 1001 PROTECTION SYSTEM. • ASSESS PIPING CONDITION (IF EXPOSED THROUGH · MAINTENANCE ACTIVITIES). NOVEMBER 1992 Page 1 2-1 TITLE ENVIRONMENTAL REFERENCE MANUAL SECTION 1: UNDERGROUND PIPING SUBJECT 3: CONCERNS CONCERNS • UNDETECTED HYDROCARBON RELEASE AND SOIL CONTAMINATION. • POTENTIAL OF EXTERNAL LIABILITY IF THE HYDROCARBON TRAVEL OFF-SITE . DRIVING FORCES • NO LEGISLATIVE REQUIREMENTS. • MOST TERMINALS ARE 30+ YEARS OLD. • INSTALLATION TECHNIQUES ROUTINELY DAMAGE PORTIONS OF THE PROTECTIVE COVERINGS. • UNDERGROUND LEAKS ARE DIFFICULT TO DETECT AND SOIL CONTAMINATION CAN BE EXTENSIVE BEFORE LEAKAGE IS RECOGNIZED. • SOIL DECONTAMINATION IS EXPENSIVE AND TIME CONSUMING. • BURIED STEEL PIPING WILL CORRODE OVER TIME . NOVEMBER 1992 Page 1.3-1 l N Ill NMI NI I 1H 11 IO Nl I MANIIAI llNlH II ,I{ llNI> l' IPIN( 11' K 111l>U( II N Ml 11101>', It l I 11 11 N • <'()N 'l'INUl i, ANNUAi . ii • ( ONTINl Jll: l'Rt\l''f'I DIV\UUC' TEST ING 01 · MAHINE LJNl~S. 'I · ( I• 11 l)RAUU Al.LY TESTIN F. · n ·l'NI\I Pll'l · l INE S. IN 'UJD INC, Till ~ FOLLC WIN 1'1IP() lJ ,II P 1(111'1'OF W t•:11 • 1-. t' th, 'c I s rrn UNE S if lht· 1111 · is 1110 1 • Lhun 30 yc.:ars old. ·u,s if th· tin· is I ·ss than O years old. • IMPLl t MENT PRA Tl E • LEAK T ·STIN SIT l lYI PC C RB N TRAN FER LINES ANNUALLY . INTERNAL IN PECTIONS • ll· I lPIN l ' ·,, P D URlNG MAINTENANCE/CONSTRUCTION rt lTl • , ARRAN • FOR A METALLURG ICAL ASSESSMENT . CORROSION MONITORING • lMPRE • • • ·D URRENT: M nth! Reading nnual ystem Inspection ACRfFICIAL ANODE: onduct System In pection every two years. • IN TALL CATHODIC PROTECTION ON UNDERGROUND PIPELINES EXTERNAL TO SITE. NOVEMBER 1992 Page 1.4- 1 TITLE ENVIRONMENTAL REFERENCE MANUAL SECTION 1: SUBJECT 5: UNDERGROUND PIPING RESURFACING CONSIDERATION FOR RESURFACING • Site environmental sensitivity • Age of facilities • Soil corrosivity • Leak testing • Other active projects, e.g., vapour recovery GUIDELINES FOR RESURFACING UNDERGROUND PIPING Steel in the presence of moisture and air will oxidize quickly . Piping buried in soil will corrodeover time. The objective of this strategy is to present undetected leakage of hydrocarbon for subsurface piping . • There is no anticipation that all underground hydrocarbon transfer piping will be or can be raised above ground. • The long term outlook is to plan for the resurfacing of the hydrocarbon transfer lines to our tank truck and tank car loading racks. • The remaining external pipelines need to be assessed immediately: • Consideration should be given to installing a leak detection system. • Hydraulic testing to 1-1/2 times the operating pressure is required once every three years until the line is 30 years of age, annually after that. • The lines need to be cathodically protected and a documented annual assessment of the cathodic protection provided. NOVEMBER 1992 Page 1.s-1 TITLE ENVIRONMENTAL REFE RENCE MANUAL SECTION 1: UNDERGROUND PIPING U J CT 6: PIPELINE REPLACEMENT U/G PIPELINE REPLACEMENT RANKING GUIDELINES OR.JE TIV ld ~mif Uf pip lin 'S that n · d to b replaced on a priority basis while maintaining a phas d appr ach to expenditures. BENEFIT • Unifom1 approach available to all • Efficient management approval process • Risk reduction • Long and short term plan (capital/maintenance budget/work allocation) • Environmental protection OPTIONS Follow the steps listed below to develop a prioritized U/G pipeline replacement program: 1. FORM a team with representatives from inspection, technical, process , mechanical and other departments as required. Then, the Team will: 2. CONDUCT a site-wide survey to prioritize the risk level of all U/G pipelines on the site. 3. USE Table 1 to rank each pipeline to determine the relative priority for replacement. NOVEMBER 1992 Page 1.6-1 , 1 11111 1 t, l lN111I H 11 lllNl I '11'lNl I 'II 'I I INI 111I 'I /\ L I Ml NI Ol'TIONS trn11t'd) ·L l)l)l'lll\lFNT1ht· 1cs11lts , usinp Tahk lJSI• lht· n suits in T 1hk , to cl ·vrlop a long rang· pip ·linc p1op111111str.11'/' (1. 1 ·placement . OHT IN llt l't1dmsc111t·11t from sitt 111a11agcm nt and cc11tralplanning position capital hudgcl items us r ·quir ·d . RESPONSIUlLITY R1..·sponsihili1to prepare individual proj ·ct implementation memoranda (PIM) •sts with R ·tincri ·s/Distribution/Retail. Page 1.6-2 - NOVEMBER 1992 z 0 < m s: CD Table 1 UNDERGROUNDPIPELINE REPLACEMENT RANKINGGUIDELINES m :n ' NoProt~,on J Co,rosive J Non CO•1 2 m :n G) :n 0 C z 0 ""O 3 =ij z G) 4 5 ""O =ij m r zm :n 'Risk Priori1y Measure(RJ= (Probabili1y'Safe1y•Environmcn1)+ (0.2'Probabili1y'Cos1 Bcncli1) Rank Rank Rank Rank Rank m "U £: () lnluprttation : R 22 MmorR1"sk Sum 1'WT% CONSEQUENCES Rc·evalua1ewithin4+ ears un css the cost benefit is Jar c coough to bejustifiedon ilS o m ~ m z -I Moderate Risk Rc-evaJua1cwithin2-4 years unless the cost bcncfil is largeenoughto be ju.stifiedon its own, or considerde1ection(leak dctec&ors . line thicknesssamplingmethodsfor uniformand non uniformsoil environmcn1)/mitigal.ionmelhodsif enviroomemoc safely consequenceis high. High Risk Replace wilhinaycar. Section 1.6: UNDERGROUND PIPING: PIPELINE REPLACEMENT HOW TO USE TABLE 1 1. Calculate the probability of developing a leak. The age of the pipe , routing, corrosivity of the soil and product have to be considered. 2. Rank the consequences of the leak from the safety, environment , cost benefit points of view . 3. Calculate risk priority measure using the formula in Table 1. Interpret the results using the guidelines in Table 1. Example: Date Available : Age ........... . Routing ...... . Soil. ........... . Product... ... . Soil. ........... . Line Duty ... 11 to 20 Underground W Protection Corrosive Mogas Permeable Soil Transfer Line Calculation: 1. Calculate the probability of developing a leak. Age ..... ..... . Routing ...... Soil. ...... .... . Product ..... . 11 to 20 Thick Coating/Non Mainted CP Corrosive Mogas Probability of developing a leak is moderate . Ranking. ..... 3 Sum 1·WT% 20 40 30 .lQ 100 2. Calculate the consequences of developing the leak. Safety ....... Mogas is light HC. In the presence of ignition source , it can start a fire. Ranking ................ ........... 4 Environment Permeable soil off site Ranking ........ .... ................ 4 Cost Benefit HC Loss Ranking ...................... ...... 1 3. Calculate risk priority measure . A=(3•4•4)+3•1 = 51 Moderate Risk - re-evaluate within 2 to 4 years. Page 1.6-4 NOVEMBER 1992 z < m 0 Table 2 PIPELINE REPLACEMENT PLAN s: ID m :a ~. DESCRIPTION (0 (0 I\) Product loc1llon l .... RISK Size p s E ~ COST(K$) C II lludg,1 Prior v.. App,or. Clpilal EJpenu C Maint. e.q,.,... z 0 m :n G) :n 0 C z 0 -u =u z G) -u =u m r z m :n m -u ~ () m s::: m z -; -u lll co 1s Y•• Tori"! i~ :i; z ;,_ r 0 WA -{ (/) ALBERTA "'O r= r SASKATCHEWAN "'O MANITOBA m < m ONTARIO :n 1992 Latest 1992 2000 1992 2000 WA z-{ 6 z NIA JJ QUEBEC en ::,;; JJ NOVASCOTA m 0 C NEWBRUNSWI CK 0 NEWFOUNOLA.NO 6 z -{ 0 '1) -{ PE I z 0 NWT s: YA= YearLegislated < m 6 z (/) =Yeartar eledfor compliance TARGET Rel.ERM4.2·2 ClJ m JJ CD CD I\) .' ' ---I ~ '~ z 0 < m ~ CD m :n TANK LOT SPILL PREVENTION COSTING TOOL FOR PLANNING TANK INSPECTIONS 1• 1· UAXJMUM CONCENTRATIONS IN THE LOWER FRASER VALLEY (LFV) REGION NOVEMBER 1992 Page 5.5-7 St3ct1on5.5: VAPOUR SUPPRESSIO N: TANK LOCAT IONS ~ Major US VOC/NO . Source Regions .-, Region within 100 km ol lloJ U.S. Source (SW llow) ~- I r \ I MAI N e OUEBl!C NEW YOflK PENNSYLVANIA WINDSOR-QUEBEC CORRIDOR AND LOCATION OF MAJOR U.S. VOCJNO. SOURCE REGIONS NEAR THE GAEA T LAKES Page 5.5·8 NOVEMBER 1992 TITLE ENVIRONMENTAL REFERENCE MANUAL SECTION 6: 1: SUBJECT VAPOUR RECOVERY STRATEGY STRATEGY • MEET LEGISLATIVE REQUIREMENTS . • No change in current practices . STATUS • • OPERA TING UNITS FUNCTIONING AT : • Finch Terminal • Lougheed Terminal CONSTRUCTION COMPLETE AT ST. GEORGE IN Q3 1992. NOVEMBER 1992 Page 6.1-1 TITLE ENVIRONMENTAL REFERENCE MANUAL SECTION 7: P.C.8. SUBJECT 1: STRATEGY STRATEGY STATUS NOVEMBER 1992 Page 7.1-1 • €3) ~~ENVIRONMENTAL REFERENCE MANUAL Imperial Oil ProductsDivision Distribution July 30, 1993 TO: FROM: SUBJECT: Attached Distribution List J . S. Whitelaw Ozone Depleting Materials, ERM Revision #1 Compliance with legislative requirements is our priority when it comes to the use of ozone depleting substances , such as fluorocarbons and halon, in our operation. The enclosed ERM updates (Section 8.1, 8.2 and 8.3) outline the strategy and risk reduction options in complying with government regulations , as well as our commitment to do our share to help prevent the destruct ion of ozone layer . • Please review the requ irements in this new ERM section and contact me if any further information is required . J. S. Whitelaw Operating Practices Manage r Distribution Operations ,. ENVIRONMENTAL R FERENCE MANUAL DI trlbutlon List Op ting Pr ctic 111-1037 (J.S.Whitelaw) Environm nt I Advisor Environm ntal Advisor Environmental Advisor Environmental Advisor Environmental Advisor Dartmouth MEDU Finch Edmonton Lougheed Loss Control Advisor Pipeline Div., EPE-Calgary Senior Senior Senior Senior Senior Senior Senior Senior Senior Senior Senior Terminal Terminal Terminal Terminal Terminal Terminal Terminal Terminal Terminal Terminal Terminal Manager Manager Manager Manager Manager Manager Manager Manager Manager Manager Manager Operations Support Manager Eng ineering Support Dartmouth St. John's, Nfld. Quebec Montreal East MEDU Ottawa Finch W innipeg Edmonton N.W.T. (Edmonton Terminal) Lougheed 111-1032 (J. D. Lanoue) 111-1011 (P. Schwanen) ENVIRONMENT AL REFERENCE MANUAL TABLE OF CONTENTS I. UNDERGROUND PIPJN(, l. Strategy 2. Risk Reduct.ion Options 3. oncerns 4. Risk Reduction Methods 5. Resurfacing 6. Pipeline Replacement 7. Monitoring Wells 2. UNPROTECTEDUNDERGROUNDSTEELTANKS 1. Strategy 2. Risk Reduction Options 3. Replacing U/G Unprotected Steel Tanks 4. Risk Reduction Methods 5. Provincial Requirements 3. TERMINAL EFFLUENT QUALITY 1. Strategy 2. Risk Reduction Options 3. Risk Reduction Methods 4. TANK LOT SPILL PREVENTION 1. Strategy 2. Risk Reduction Options JULY 1993 Rev. #1 erm-Oadoc Page 1 of 2 ,. lA L O CONT NTS 5. VAPOUR SUPPRESSION - FLOATING ROOF I. 2. 3. 4. 5. Slrnlcgy Risk Rcduclion Oplion lnstull111ion Planning Co I lmpacl Tank Locations 6. VAPOUR RECOVERY 1. Strategy 2. 7. P.C.B. I. Strategy 2. 8. OZONE DEPLETING MATERIALS 1. Strategy 2. Risk Reduction Options 3. References Page 2 of 2 JULY 1993 Rev . # 1 ,. TITLE ENVIRONMENT AL REFERENCE MANUAL SECTION 8: OZONE DEPLETING MATERIALS SUBJECT 1: STRATEGY STRATEGY o We will meet legislative requirements. o Ozone depleting substances should be removed from our operations where practical. o Ozone depleting substances should lli!1be used except where there are no practical alternatives. o Where ozone depleting substances are used, discharges to the environment during maintenance or testing are not permitted. o Equipment containing ozone depleting substances should be labelled and maintained so as to minimize discharges and fugitive emissions. JULY 1993 Rev. #1 erm -8 .doc Page 8.1-1 of 1 1111l • I ·II N I NVIII 1NMI NI AL IH 11 fl NCr MANUAL I NI I I Pl I ING MA r RIALS lJll 11 IIISk. Ill lJUCIION N l nN' ll Fl11nrn· 1rbons nr' commonly used as a cooling agent in refrigerant t quit lllt'nt: I la Ion is us 'cl as a fire suppressant. \ hen fluoro arbons and I Ialon (also referred to as ozone depleting subst 1n cs or OD ) arc released into the environment, they rise to the upp 'r atmosph re where they de troy the ozone layer. zon layer acts as a shield that protects the earth against ultraviolet radiation that can cause skin cancer and vegetation damage. The RISK REDUCTION OPTIONS Only certified technicians will be allowed to handle, service and repair refrigeration equipment. Venting of refrigerant CFCs (chlorofluorocarbons), HCFCs (hydrochlorofluorocarbons) and HFCs (hydrofluorocarbons) will be prohibited, i.e., office airconditioners, refrigerators, vehicle air conditioners, Halon fire suppression systems. o Replace Halon 1211 hand extinguishers with hand CO 2 extinguishers. o Existing fixed Halon fire suppression systems should be set to trigger on manual only, not automatic. Fire detection and alarm systems should be reviewed to ensure adequate notification of alarm. DISPOSAL o Disposal of equipment containing ozone depleting substances (ODS) must be undertaken to meet legislative requirements or through accepted industry practices. JULY 1993 Rev. #1 erm -Badoc Page 8.2-1 of 1 ,. TITLE ENVIRONMENTAL REFERENCE MANUAL SECTION 8: OZONE DEPLETING MATERIALS SUBJECT 3: REFERENCES ENVIRONMENTAL ENGINEERING & OPERATING PRACTICE (EEOP) REPORTS ON CFCs AND HALON The following documents are provided here primarily as a reference to ozone depleting substances used in our own Distribution terminals but demonstrates the alignment being achieved among Exxon affiliates in environmental area: • Update to EEOP-8 (pages 1 to 8) - produced by Exxon Chemical Company, Environmental Technical Services, Baytown, Texas. • Interim Report (pages 1 to 3) - produced by ER&E specific to Halons. JULY 1993 Rev. #1 11rm-8b.d oc Page 8.3-1 of 1 CH Ml l Mf NY l NVIHUNMt NI HlAIIH AIHYDfPf MAH u lw1 RECEIV D t-c:-h n1.1 ry I I , 199\ Ualo and.Ct Distribution: Enclosed arc an update to EEOP-8 and an Interim Report produced by R&E specific to Halons. EEOP-8 has been reVIscdto incorporate the recommendationsof the Interim Report. Please note that during replacement, all CFC and related compound arc to be handled or removed by appropnatc vendors so as not to be released to the atmosphere. As members of the ECOIC Technology Subcomm11tcc,we believe the recommendations of the Intcnm Repon arc supportable. Because CFC refrigerants do not have safety implications, we have not reviewed any suggested alternatives for recommendation. Environmentll Technical Services (ETS) docs have several papers on refrigerant altcmanves which arc available upon request. Although spcctfic recommendations have not been made on refrigerants, sites arc urged to discuss altemanvcs with their suppliers. We arc willing to help-tf needed. If you have any qucstJons or comments, please don't hesitate to contact your OIC representative, Ray (713) 425-2593 PROFS ID BCBREO (HOUECA) or Dick (713) 425-2358 PROFS ID BTCRPH (BAYTOWNC). Sincerely, R. P.Hcrbst rph/pdp Enclosure EVVKJ'QU PO Bo• 400. 81Y1own. Tuas n52H)400 Fu 1713> 425 ,2802 , EEOP 8 EXXON CHEMICAL ENVIRONMENTAL ENGINEERING & OPERATING PRACTICE OZONE DEPLETING MATERIALS (CFCs and HALONS) PAGE 1 OF 7 ISSUE 1 FEBRUAJl Y 1993 PROPRIETARY INFORMATION For Authorized Company Use Only 1.0 APPLICABILITY This Environmental Engineering & Operating Practice (EEOP) sets a minimum for Exxon Chemical facilities. A more stringent standard may be required by local regulations ·or risk considerations . The DESIGN requirements contained in Section 6 of this EEOP arc to be followed for all new firefighting, air conditioning and refrigeration cquipmcnL The OPERATIONS AND MAINTENANCE requirements in Section 7 apply to all sites using ozone depleting materials. Any exceptions must be approved by the appropriate Operations Integrity Committee (OIC) . 1n accordance with the Operations Integrity Management Practices (OIMPs), site management must decide when existing firefighting, air conditioning and refrigeration equipment should be upgraded to meet this EEOP. Maximum benefit should be taken of opportunities arisint from maintenance, revamp, retrofit and ·tumarounl 1'11 IIN( MAii lllAI' (( 'I< 1111 IIAI ON ) Ol'HtA'l IN< PK Cl f('L I 14 Whc:-t1N.(llipntttll ()(IIJUnt11 n ODM 'I c-111pllrclfm m.a 11tr11.,,wr , 11 , 111,-:: re llcd with the ni.,t('rt I of lowc t ow,lflooring of manned control rooms. LowFreguencyof fire in ControlHouses We have also reviewed our Hazard Loss lnfonnation System (HUS) 8021 Reports since 1951 IO sce if we could establish how high our fire rislc has been in control rooms, some of which may have installed fixed Halon systems. We were able to locate three relatively minor with control rooms. Actually two were in the electrical equipment fires that were associa1cd substation/switch equipment room of the control house and in another case, an oily rag c:ausc.d a minor fire. In all cases, the fires were minor and capable of being extinguished with portable extinguishers. Consideringthe number of control houses Exxon has in operation and the total number of years of operation, this appears to be an excellent fire record and does not justify the cost of fixed extinguishing systems. Over-Use of HaJons As a general statement, it appears that we have over-used Halon 1301 in the past. Halon is a very clean and effective extinguishing system that does not have any toxic problems if people were exposed during a discharge at a 6% concentration. Many insurance inspectors recommended total flooding systems where previously only hand extinguishers were provided . 1 H we er. in retrospect, some fixed systems were installed that could have been adequately protected with hand extinguishers. As a case in point. Marsh & McLennan Protection Consultants previously conducted the insurance surveys for Exxon Risk:Management. They consistently recommended total flooding Halon systems for the complete control house whereas we only recommended fire detectors and porublc fire extinguishers. After many confrontationsand some prodding by Risk Management, we reluctantly agreed to a compromise position of installing fixed Halon in only the subftooring area. Not all affiliates agreed with this approach. Exxon Chemical-Central Engineering Department (CED) were especially vocal in their objections to using fixed Halon systems so we madethis an asterisk it.emin BP4-3- 1 which means that each affiliate has an option to accept or reject the Halon rcqui.-emcnt. The actual minimum BP requirement has been hand extinguishers with the fixed system an individual option. Many people overlook this and believe the basic minimum is a fixed system in the control room subflooring area when, in fact, it is not our minimum. CurrentRecommendation For ControlRoomSubf)oor Based primarily on our excellent (very low) fire loss experience of three minor fires in control rooms going back to 1951 and also the lower risk today due to fire retardant cabling coupled with lower power requirements, our current recommendation remains the same. That is, to install fast response fire detectors in the subfloor area with relianceon hand extinguishers instead of fixed systems. There is also a growing trend in the industry to reduce the number of fixed extinguishing systems as many realize that Halons have beenover-used. The use of a fixed extinguishing system should bejudged on the risks involved including fire history, if it can be established. HalonHandExtiniuishcr Ra,Jaccmcnt We recommend that existing Halon 1211 hand extinguishers be replaced with currently available agents. For indoor use, we recommend CO2 extinguishers based on the ease of clean up as dry chemical extinguishers create a severe clean up problem indoors. On the other hand, dry chemical extinguishers arc much more effective as compared to CO2 and we recommend that dry chem be used outdoors where clean up is not a problem. We also recommend that fire training with Halon extinguishers be stopped. LeaveExjstia& fixedHalonSystemsAsIs ForNow For downstream operations, the most common place where Halon is currently usedis in the subflooring area of control rooms. We believe it is acceptable to leave these existing units in place. However, each location should develop plans to implement a phase down strategy recognizing environment, regulatory and pric:e'supply considerations. Existing fixed systems should be on manual relc:1se and not automatic . Also, no actual discharge tests should be conducted. HALON.llP'r 2 INERGEN PotentialHaJonRCJ.lJaccment One potential replacement for Halon that is currently marketed is an inert gas mixture called INERGEN. The name is derived from INERt gas and nitroGEN and is a mixture of approximately 52% nitrogen, 40" argon and 8~ carbon dioxide. The distributors of this gas claim it is safe to breath when the oxygen concentration in a flammable mixture is reduced to about 12.5~ which is required for extinguishment. We have issued SOC Communication 2-92 dated March 30, 1992 questioning this safety claim. Exxon Biomedical Sciences, Inc. stated, ·There is no evidence that INERGEN is safer than other asphyxiant gases (such as CO2) .• The communication goes on to state that if INERGEN is proposed to protect an occupied space by flooding, it should be handled like CO2: that is, evacuation before release with positive pressure supplied air respiratory protection required before re-entry. Conclusion andRecommendations • From an overall standpoint, we recommend following the Shell position which essentially says they will not use Halons. We recommend not installing any new Halon fixed systems except for essential use as defined by Exploration and Production Forum. • Install fire/smoke detectors with alarms in subfloor areas in manned control rooms and use hand portable CO2 extinguishers. • Replace Halon 1211 extinguishers with CO2 indoors and dry chemical outdoors. • For high fire risk areas such as gas turbine enclosures (and other areas not open to personnel), use CO2 or maybe high velocity water sprays (the latter needs more review). • Continue to evaluate Halon replacement alternatives as part of our 1993 R&D program. Some of the areas we have talked about investigating include: + + + + + Acceptability of alternate extinguishing agent to Halon. The effectiveness of high velocity and high pressure water sprays. Use of passive protection (fire resistant materials, fire walls, fireproofing). Very early hydrocarbon leak/smoke/fire detection sensors. Water damage protection for electrical/electronic equipment enclosures if water sprays used. R.F. Murphy December 11, 1992 3