Teris LLCWarehouse 201 Incident

Summary of Response and Recovery

North American Hazardous Materials Managers Association (NAHMMA)

September 2005Tacoma, WA

August 2005

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Outline

Facility Background

Incident details

Response details

Lessons learned

What to look for when selecting an end facility.

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Teris- Facility Background

Located in El Dorado, AR Hazardous waste incinerator, fully permitted since 1977 Formerly known as Ensco Inc.; became Teris LLC in 2001 Total site acreage is 370 acres; permitted acreage is 50 acres Operates 2 rotary kilns Can receive vans, bulk tankers and rail Container capacity is 31,196 (55 gal drum equivalents) Bulk capacity is 1,859,444 gallons (RCRA material) Direct burn, drop chute and shredder capabilities Restrictions include radioactives, biologicals and explosives

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January 2nd Incident: Background

Fire occurred in Warehouse 201 at the El Dorado Plant on January 2, 2005 at 8:05AM.

No injuries resulted.

Teris highly trained fire brigade responded within seconds. Although the fire could not be extinguished at Warehouse 201, Teris’ fire brigade stayed with the fire and protected spread to other areas.

Local authorities responded but did not attempt to fight fire.

About 1,500 residents were evacuated within a one mile radius by the City. About 400 residents within a half mile radius were kept evacuated overnight and returned to their home at 4PM on Jan. 3.

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• Contingency Plan procedures followed flawlessly

• Exhaustive air sampling conducted by EPA and Teris within 4 hours of the start of the fire: Air monitoring and wipe tests were all satisfactory below safe health-based thresholds.

• All levels of communication were swiftly activated.

• A substantial communication plan towards the media and the local community was immediately put in place.

• In coordination with insurance company, decision was promptly made to hire a specialized remediation contractor.

January 2nd Incident: Management of the crisis

Response of employees and management was excellent. Shareholders, Media, Community and State agencies communication were handled very well.

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January 2nd Incident – Cause and Origin

Sodium Chlorate (oxidizer) in soil from a train derailment in Watertown, NY in December 2004.

Waste was profiled by Generator as containing only sodium chlorate in soil. Profile not accurate.

Interviews with Teris personnel after incident revealed that some boxes had fuel oil odor, wood and creosote which would have provided a fuel source for the strong sodium chlorate oxidizer.

Conditions allowed for Spontaneous Ignition.

Waste isolated after cause and origin identified also ignited in second fire on January 12th. Teris had isolated all of this waste in a trailer and stored in a remote part of the plant property under constant observation by Fire Brigade.

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Remediation: Update on Current Progress

Hepaco: Memphis, TN was mobilized on January 4th to provide both Fire Brigade and Remedial Response Support.

Remediation Work Plan completed by January 6th, but later replaced by an Amended Partial Closure Plan for Warehouse 201. Plan approved late February.

$11 Million Trust Fund in place since January 25th. In July ADEQ released $10.6 million of this fund since the majority of remediation is complete.

Air monitoring in place through all phases of remediation. Plan includes comprehensive soil sampling on and off-site. All waste and debris has been removed and treated or disposed.

Concrete pad is clean. No organics (including Dioxin) were detected. Only soil sampling program remains.

Daily meetings at 7AM with contractor and ADEQ On-Site Inspector. Daily Report faxed to ADEQ’s Little Rock Office.

Anticipate completion of final Closure Certification Report by October.

Improvements Made Following 201 Warehouse Incident

August 2005

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Background

In 2005, Teris experienced a significant incident involving hazardous waste located at the El Dorado, AR Commercial Incineration Facility.

Involved hazardous waste that spontaneously combusted, without any action or contributing cause related to Teris’ processing or handling. This was confirmed by outside experts.

Teris’ emergency response team managed the incident to isolate and contain the impact.

No injuries resulted. No environmental impact resulted as indicated by extensive Soil, Water

and Air monitoring by a Third Party Testing Firm. Teris’ Strong Financial Assurances resulted in full remediation and

recovery with no impacts to customers or any other party. Open proactive Communications Program with Local Community

throughout incident and recovery.

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Summary of Improvements Implemented in Response to Incident

Increased staffing for Technical Control and Oversight:– Senior Plant Chemist and 2 new Hazard Control Chemist Positions

were created with total focus on identification of hazards. Positions report to Compliance and Operations jointly.

Approval for $6.7 Million Capital for Fire Protection Upgrades. Assignment of 4 Fire Brigade Members to full-time fire watch during the

time period that fire protection upgrades are completed. Completion of a Comprehensive Safety and Fire Prevention Review.

Latter by GE Global Protection and Schirmer Engineering. New Preventive Action Procedure for Abnormal Events, with extensive

use of Causal Tree Analysis for low threshold occurrences. Increased resources given to Quality and Compliance Programs Revisions to the Waste Analysis Plan to test Class 3 Oxidizer Waste

Streams 100% for fuel contamination that might lead to spontaneous combustion.

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Fire Protection Upgrades

Two Levels of Plans– Immediate: In place since Feb. 2005, measures for water

reactives and Oxidizers. Safe Storage Plan for Warehouse 204.

– Near Future (by April 2006): Permanent Storage for Water Reactives and Class 3 Oxidizers. Automatic Fire Suppression for WH 204. Total Budget: $6.7 million.

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Immediate Plan Elements: Warehouse 204In Place Since February 2005

Inventory Restrictions for Water Reactives and Class 3 Oxidizers:– Water Reactives: 100,000 pound limit per NPFA 480. – Class 3 Oxidizers: 40,000 lbs. Separation per NFPA 430 along

North Wall. – Class 4 Oxidizers: No storage; processed when received.

One Rack Storage location for Water Reactives with Isolation Wall, segregation plan. Dry Chemical systems in area. Separation complies with NFPA 480.

Several new Hose Reel Locations around 204. Foam Carts at Drum Pumping Locations, BPA, SHF, Direct Burn, tank

truck unloading. Dual hose station and monitors at all tank locations. Fire watches when processing. Additional Fire Truck acquired. Flammable Cylinders stored in BPA Area isolated from other wastes.

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Testing Improvements

All Class 3 Oxidizers are being sampled and inspected 100% on receipt prior to storage.

Heat content analysis being performed on every shipment to determine if fuel source present.

If result greater than 500 BTU/lb, the material is routed immediately to the Special Handling Facility for immediate processing and wetting. Further analytical may be done also to evaluate hazard.

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Near Future Plan by April 2006

Class 2 Permit Modification Submitted March 20th. ADEQ approval of temporary authorization in April.

Modular Engineered Storage Buildings for Water Reactives and Class 3 Oxidizers. Will be in place by November 2005.– Detached Storage increases NFPA Allowable Quantities.– 6 Modules: Placed on pad near Special Handling Facility. – 192 drums per module or 1,152 total. – 4-Hour Fire Walls, Permanent piped suppression agent. Exceeds

NFPA requirements. Flammable Cylinders in new detached storage area in place now. Automatic Suppressions System for 204 by April 2006. Other upgrades to infrastructure and fire protection systems throughout

plant, including tank systems. Total Cost: $6.7 million. Plan reviewed and approved by two separate third-party fire protection

engineering firms.

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Benefits of Storage Vaults

National Association of Fire Marshals’ Study reviewed fire safety issues with Swimming Pool Chemicals in retail stores. This chemical is of the same family that caused incident at Teris.

Study concluded that current code is not adequate for protection of the public.

Safe design must go beyond the code.

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Storage Vaults Provide Safety Beyond Code

Design is like a Bank Vault! Oxidizers will be stored in isolated vaults away from

all other waste. Vaults have inside compartments with 4-hour rated

fire walls. Compartments will separate oxidizers into smaller lots.

Vaults have hard piped automatic fire detection and suppression systems to quickly detect and extinguish a fire.

Isolation will prevent spread beyond immediate compartment.

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Legal Overview

ADEQ issued an “Investigation Report” in August 2005 covering various findings following the January 2, 2005 Incident in Warehouse 201.

Report notes that “Nothing in this report should be construed as a final decision of ADEQ in this matter.”

Teris is seeing the report and findings for the first time. ADEQ has invited Teris’ response.

No final enforcement action, although following Teris’ response, it is expected that ADEQ will proceed with a Consent Administrative Order.

Nothing in the report changes the conclusion that the cause of the fire was a spontaneous ignition of waste that was not properly profiled by a generator.

None of the allegations would have contributed to the fire, nor do they disagree with the cause and origin reported in Teris’ Incident Report.

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Lessons To Be Learned“What made this a success”

Corporate Ownership– Committed to business (investment of capital)– Financially healthy

Operational Excellence– Policies and procedures in place (with training component)– Third-party accreditation (i.e. ISO 9000/14000 certification)

Continuous Improvement– Environmental Management System– Causal tree analysis (with training component)

Safety – Key Performance Indicator– Look at metrics (TCIR)

Commitment to persist- Plan to Moving Forward

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The Bottom Line…

Accidents Happen

Learn From Them

You (hazardous waste generators) want the end facility you use to be in a position to respond the way Teris has/is responding.