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FEASIBILITY STUDY, RISK ASSESSMENT,

AND SAFETY PROCEDURES


FOR
CAUSTIC SODA OPERATIONS
PORT OF BAYONNE, NEW JERSEY, UNITED STATES
PORT OF SOUTHAMPTON, UNITED KINGDOM

SEAQUEST PROJECT NUMBER: 6976


PREPARED FOR:
MS. JODY MILLER
LEAD, CREW SAFETY PROGRAM
MARITIME SAFETY AND COMPLIANCE
ROYAL CARIBBEAN CRUISES LTD.
1050 CARIBBEAN WAY
MIAMI, FLORIDA 33132

PREPARED BY:
SEAQUEST TESTING & CONSULTING
5150 SOUTHWEST 48TH WAY, SUITE 610
FORT LAUDERDALE, FLORIDA 33314

AUGUST 15, 2013

5150Southwest48thWay,Suite610,FortLauderdale,Florida33314
Phone:954/7924549,Fax:954/7922221,TollFreePhone:877/2478146,OntheWeb:www.SeaquestTesting.com
AsbestosConsultingBusinessZA304,RadonBusinessRB2184&LeadBasedPaintBusinessFL164181

CERTIFICATION PAGE
FEASIBILITY STUDY, RISK ASSESSMENT,
AND SAFETY PROCEDURES
FOR
CAUSTIC SODA OPERATIONS
PORT OF BAYONNE, NEW JERSEY, UNITED STATES
PORT OF SOUTHAMPTON, UNITED KINGDOM

SEAQUEST PROJECT NUMBER: 6976

PREPARED FOR:
MS. JODY MILLER
LEAD, CREW SAFETY PROGRAM
MARITIME SAFETY AND COMPLIANCE
ROYAL CARIBBEAN CRUISES LTD.
1050 CARIBBEAN WAY
MIAMI, FLORIDA 33132

PREPARED BY:
SEAQUEST TESTING & CONSULTING
5150 SOUTHWEST 48TH WAY, SUITE 610
FORT LAUDERDALE, FLORIDA 33314

AUGUST 15, 2013

_________________________
TRACI-ANNE BOYLE, CIH, CSP
SENIOR PROJECT MANAGER
ii

TABLE OF CONTENTS
PAGE
1

INTRODUCTION

1.1 SCOPE FEASIBILITY STUDY


1.2 SCOPE - ENVIRONMENTAL HEALTH AND SAFETY PROTOCOLS
1.3 PORT AND VENDOR VISITS

1
2
2

ABOUT SODIUM HYDROXIDE (CAUSTIC SODA)

2.1 PHYSICAL PROPERTIES


2.2 OCCUPATIONAL EXPOSURE SUMMARY
2.3 ENVIRONMENTAL SPILL CONSIDERATIONS

3
3
3

FEASIBILITY OF SUPPLY AND DELIVERY METHODS

3.1 CAPE LIBERTY


3.1.1 RAIL CAR
3.1.2 TANKER TRUCK TO VESSEL
3.1.3 BARGE DELIVERY TO VESSEL
3.1.4 TANKER TRUCK TO ONSITE STORAGE TANK
3.2 SOUTHAMPTON
3.2.1 RAIL CAR
3.2.2 TANKER TRUCK TO VESSEL
3.2.3 BARGE DELIVERY TO VESSEL
3.2.4 TANKER TRUCK TO ONSITE STORAGE TANK

5
5
5
14
14
15
15
15
15
20

21

DESIGN CONSIDERATIONS

4.1 GENERAL
4.2 VESSEL
4.3 PORT

21
21
21

23

REGULATORY REQUIREMENTS & RESOURCES

5.1 REGULATORY REQUIREMENTS


5.2 INDUSTRY GUIDELINES

23
23

30

CONCLUSIONS AND RECOMMENDATIONS

iii

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

iv

1 INTRODUCTION
SeaQuest Testing & Consulting (SeaQuest) conducted a feasibility study, risk assessment and
developed preliminary health and safety protocols for introducing caustic soda into the emission
scrubbing process for vessels scheduled to call on the Ports of Bayonne, 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 of
identifying 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 examined
applicable 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 Bayonne
and 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

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 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

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 the
water.
EnvironmentalHealthandSafetyProtocols
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.

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 Fact
Sheet 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 due
to 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 hazard
rating 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 of
the 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. In
the 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

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

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

3 FEASIBILITY OF SUPPLY AND DELIVERY METHODS


Caustic 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 of
IMTT, 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 maximum
number 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 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, 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.

Table1SummaryofVendorInquiries,Bayonne
Reference
Harborchem
JonathanMyers
POBox630
Cranford,NJ07016
JLMyers@harborchem.com
p)908/2727070

SeidlerChemicalCompany
FrancisPenkethman
537RaymondBoulevard
Newark,NJ07105
p)973/4651122,Ext111
fran@seidlerchem.com

Information
Approximately9tanktrucks,eachneedingroughly2hourstobunker,eachtruckholdsabout
4,500gallons.Bargedeliveryisalsoapossibility,althoughnotpractical.Transportintotheport
canbeeasilyarrangedwithproperplanning.
MetwithMr.MyersandPresidentofHarborchem,StephenMaybaumonJuly23.Veryinterested
intheproject.Havethemeansandresourcestosupplythematerialifatankwereonsite.Able
andwillingtocomplywithportrequirements.
Atthisscreeninglevel,Harborchemappearstobeasuitablesupplierforthecausticsoda.The
methodofdeliverywiththisvendorwouldbefromtankertrucktoAbovegroundStorageTank
(AST)attheport.
11Fulltanktruckloads(~3,363gallonspertanker)overa3daymaximum.Wouldsourcethe
materialfromIMTTatthePortofBayonne.AbleandwillingtocomplywithNJandPort
regulations.
Atthisscreeninglevel,SeidlerChemicalCompanyappearstobeasuitablesupplierforthecaustic
soda.ThemethodofdeliverywiththisvendorwouldbefromtankertrucktoASTattheport.

Table1SummaryofVendorInquiries,Bayonne
Reference
BrenntagGlobalMarketing,LLC
JohnSamoylo
AccountManager
p)732/6745186
Jsamoylo@brenntag.com
StevenWatts
ProcessImprovementManager
p)4845756497
swatts@brenntag.com

Information
World'slargestdistributorofliquidcausticsodaandoneofthebiggestintheUS.RentsaLCStank
atIMTTPortinBayonne,lessthan3milesfromtheCapeLibertyterminal.Metwithseveral
representativesofBrenntagonJuly23and24th.TookatouroftheirtankoperationsattheIMTT
port.Havethemeansandresourcestosupplythematerialifatankwereonsite.Ableandwilling
tocomplywithportrequirements.Believethatabargedeliveryisnotpossible.Willingtoassist
withtheplansforbuildingthetanksattheport,andprovideddocumentation(seereference
disk).
Estimatecostoftankinstallationaround$150,000.Estimatedcostforproductperdelivery,"The
costassociatedwithdelivering1truckloadoftheCaustic(approximately48,000LBSor12Dry
ShortTons)willbecloseto$350pertruckload[~$3,500total/delivery].Thisincludesallelements
ofthedelivery(labor,fuel,compressor,hoses,etc.)andequatesto$0.0073/LBor$29/DST."This
doesnotincludethecostoftheproduct(currentpricingisapproximately$60,000/37,000gallons)
Atthisscreeninglevel,BrenntagGlobalappearstobeasuitablesupplierforthecausticsoda.

IMTT
JimPapernik
VicePresidentChemicalSales&Marketing
250East22ndStreet
POBox67
Bayonne,NJ07002
www.imtt.com
p)201/3394992
c)908/4478484
jimpapernik@imtt.com

MetwithMr.PapernikonJuly24thwithrepresentativesfromBrenntagGlobal.Hadatourof
theirtankfarm,includingvarioussecurityandsafetyprecautions.Discussedfeasibiltyofrailcar
deliveryanddirectpipelinetotheport.Neitheroptionbelievedfeasibleduetotheproperties
betweentheIMTTandCapeLibertyTerminals.Mr.Papernikdoesnotbelievebargeisanoption
either,sincehethinksthattheNaOHbargesholdhundredsofthousandsofgallonsofNaOHand
wouldnotbewillingtomakedeliveriesofthesmallquantityneededatthefrequencyneeded.
Mr.Papernikidentifiedthatfractanksmaybeatemporarysolutionuntilapermanentsolution
couldbeimplementedattheport.ConcurswithSteveWattsfromBrenntagthat4smallertanks
wouldbebetterthan1bigtankbecauseofthedesignrequirementsforsuchaheavyanddense
liquid.
ItisbelievedthatallofthevendorscontactedwouldbesourcingtheirNaOHfromIMTT.

Table1SummaryofVendorInquiries,Bayonne
Reference
Veckridge(ChemicalDistributor)
TomorBob
p)973/3441818
WhelpleyConstruction
DaveWhelpley
dwhelpley@wescocm.com
p)2023146456

Information
Cangettherequiredquantity;inandoutoftheportalot,sofamiliarwithportregulations.Did
notreturnrepeatedcallsforfollowupinformation.Noadditionalconsiderationofthisvendoris
recommended.
ReferredtoMr.WhelpleybyAnthonyCaputo,RCCLDirectorofNortheastoperations.Mr.
Whelpley'sfirmisthevendorthatiscurrentlyinthepermittingprocessfortheupgradestothe
Bayonneterminal.Mr.WhelpleyindicatedthatpermittingwiththePortAuthorityisparticularly
onerousandcanbeverytimeconsuming(monthsyears).Heindicatedthatifthestoragetanks
wereanoption,perhapstheycouldbecombinedwiththeterminalimprovementpermittingthat
hehasunderwaytoshortenthetimeline.

KuehneChemical
KenCorolla
kdcarola@kuehnecompany.com
p)7329951144
www.kuehnecompany.com

ReferredtoMr.CarolafromRCCLscurrentbargesuppliers(RayBaldwinwithHarborPetroluem
andRalphDucawithCleanWatersNY)aswellasFranPenkethmanwithSeidlerChemical
Companyforpossiblebargedelivery.SpokewithMr.Carolawhoindicatesthatthisispossibleby
bargebecauseKuehnebothmanufacturescausticandownsitsowncausticbarge.
Mr.CarolaindicatesthatKuehnewouldneedanadvancedscheduleforproperplanning.They
estimatethatthecostper37,000gallondeliverytobeapproximately$15,000/load.Thisdoesnot
includethecostoftheproduct(currentpricingisapproximately$60,000/37,000gallons).
Atthisscreeninglevel,KuehneChemicalappearstoasuitablesupplierforthecausticsoda.They
woulddeliverthematerialbybargetotheship.

Table1SummaryofVendorInquiries,Bayonne
Reference
Ken'sMarineService,Inc.
PatGarrison
SpillSupervisor
11620East22ndStreet
Bayonne,NJ07002
p)201/3390673
c)201/8001409
pat@kensmarine.net

Information
ReferredtoKen'sMarineServicebyAnthonyCaputo,RCCLDirectorofNortheastoperations.Met
withMr.GarrisononJuly24th.Mr.Garrisonprovidedalotofinformationonthesafedesignof
bunkeringthematerialfromabarge.Specifically,sourceflexiblehosingthatmoveswiththeship,
useauniversalconnection(camlock),donothavetheconnectionsoverwater,supportthehose
in3placesusingaboomcrane,andhave3shutoffsinplace.Ensurecontainmentatthebarge
andontheship.
Mr.Garrisonalsodiscussedthehazardsofusingdrypowder.Themostsignificanthazardisadust
explosionandrapidreactionproducingheat.Therewillbeblendingissuesevenwithcirculators
andagitators.
Mr.Garrisondiscussedthatifatankwasinstalledattheport,he'drecommendthatitbe
containedwithinaheatedbuilding.Thebuildingwouldprovideprotectionintheeventofatank
failure,itwouldkeepthepumpsprotectedandthefittingsprotected(whicharetheweaknesses
andmostlikelyplacesforafailuretooccur).
Heiswillingtoassistwiththepreparationoftheneededspillpreventionplan.Ken'sMarineisa
suitablevendortoprovideemergencyresponseservicesintheeventofaspill.

Table2SummaryofContacts,Bayonne

Reference

Information

GeorgeWojnar
PortAuthorityNYNJ
p)973/5782157
gwojnar@panynj.gov

Veryhelpfulcontactforgeneralquestions;willpointyouintherightdirectionwhenneeded.

KimNguyen
PortAuthorityNYNJ
p)973/5782155
knguyen@panynj.gov

RCCLneedstofilloutandsubmittheproperpaperwork(TAAMWA)andtosendtheengineerthat
willbedesigningthetankstomeetwithheraswellasotherNYNJPortofficials.Contactherto
schedule.
ForanytenantstoproposeanyworkonthePortAuthoritysleasedproperty,thePAsTenant
ConstructionandAlterationProcess(TCAP)requiresthefollowings:
1. SubmittheformTAAMWAPh101(attached),togetherwithacoverletter,fromthetenant
(RoyalCaribbean) totheNJMTGeneralManager,Mr.ThomasF.Clyne,describingtheproposed
work,togetherwithsomedrawingsandlocationplan.TheformPh101needstobesignedbythe
Tenant(RoyalCaribbean)anddated.Alltheform,coverletteranddrawingscouldbescannedand
emailedtomeattheaboveemailaddress.
2. Iwillforwardthetenantsemail,coverletteranddrawingstothePAsEngineeringdepartment
fortheirdecisionofwhetherthisisaTAAoraMWA.
3. OnceitisdeterminedtobeaTAA,RoyalCaribbean,thetenant,willneedtohireanArchitector
EngineerofRecords(A/EOR)whoislicensedtopracticeinthestateofNJandNJMTTAAProgram
officewillscheduleakickoffmeetingbetweenthetenant,itsEngineerofRecordsandits
Contractor."
InaphoneconversationwithMs.Nguyen,shecouldnotestimateonhowlongthepermitprocess
wouldtake.Shesaiditdependeduponthethoroughnessoftheapplication.Seereferencediskfor
additionalformsandinstructions.

10

Table2SummaryofContacts,Bayonne

Reference

Information

JeffreySterling
Supervisor
DEPHazardousWasteEnforcement
NorthernRegionFieldOffice
p)973/6564498
BobGomez
NewJerseyDEP
p)609/2923837

ProvidedBobGomez'sContactinformation

GarySobin
DEPDischargePrevention
p)609/2922482

Anyhazardouschemicalinamountsgreaterthan20,000gallonsrequiresaDPCCDCR(Discharge
PreventionContainmentandCountermeasureandDischargeCleanupandRemoval)

NoDEPregulationspertainingtothetransportofsodiumhydroxide;contactDischargePrevention
ProgramwithintheDEP

Anysmallercontainmentsatthesiteoftheholdingtankswillalsobeincludedinthe20,000gallons.
Thereareunloadingarearequirements.
PriitPals
NJAC7:1E2.3"Alltankcarortanktruckloadingorunloadingareasemployedintheloadingor
DEPDischargePrevention
unloadingofhazardoussubstancesshallbeequippedwithsecondarycontainmentoradiversion
p)609/6331152
system,designedandbuiltpursuanttoN.J.A.C.7:1E2.6"
SeeReferenceCDformoreinformation.
Plansfortheholdingtanksneedtobesubmitted180dayspriortooperation.EmailMs.Reddytobe
BethReddy
DEPEngineerwithDischargePrevention& assignedaNJDEPprojectmanagerassoonaswanted.
PermitCoordination
beth.reddy@dep.state.nj.us
USCoastGuardCruiseShipNationalCenter Becausethesodiumhydroxideonboardtheshipisnotcargoandisaconsumable,thereareno
ofExpertise
regulationsthatspecificallypertaintohavingitonboard.
p)954/7672140
Lt.MikeMetz
AnyfurtherquestionsthatmaycomeupshouldbehandledwithLt.MikeMetz.
p)954/7672140ext.1005
Lt.Com.KeithHanley
p)6172238541

11

Table2SummaryofContacts,Bayonne

Reference

Information

ReferredtoDeputyChiefKeithWeaveroftheBayonneFireDepartment.
BayonnePoliceDepartment
http://www.bayonnenj.org/government/de
partmentofpublicsafety/bayonnepolice
department/
SargeantJimAshe
201/8585642
BayonneFireDepartment
DeputyChiefKeithWeaver
201/8586009
FireOfficialChristopherCzuba
201/8586024
foczuba@gmail.com

ChiefWeaverisalsothecity'sEmergencyManagementcontact.ReferredtotheFireOfficial,
ChristopherCzuba.
Mr.Czubaisworkingtoidentifyifanyadditionalrequirementswillapplyfromthefiredepartment.
Theresultsoftheinquirywillbeforwardeduponreceipt.

ReferredtothePortAuthorityPoliceDepartment.
NewYorkCityPoliceDepartment
Precinct1
p)212/3340611
http://www.nyc.gov/html/nypd/html/precin
ct_maps/precinct_finder.shtml
PortAuthorityPoliceDepartment
http://www.panynj.gov/police/
p)800/8287273
SargaentD'Amato
Charles"Chuck"King
cking@panynynj.gov
p)973/5782158

SargaentD'Amatodoesnotbelievethisisapolicedepartmentmatter,butreferredustoMr.King.
Mr.KingindicatedthatthePortAuthorityPoliceDepartmentwillreviewtheapplicationthatis
submittedtothePortAuthorityaspartoftheTAAprocess(seeReferenceDisk).

12

Table2SummaryofContacts,Bayonne

Reference

Information

OfficerMurphyreturnedavoicemailleftforChiefHeacock.Heindicatedthatsincewearenot
CustomsandBorderProtection
http://www.cbp.gov/xp/cgov/toolbox/conta importingthecausticsoda,CustomsandBorderProtectionwouldnotbeinvolved.
cts/ports/nj/4601.xml
p)201/4430408
OfficerMurphy
WaterfrontCommission
PoliceHeadquarters
CarolLaurens
p)212/7429280

RepeatedphonemessagesinJulywerenotreturned.

NationalTransportationSafetyBoard
OfficeofMarineSafety
BillCurtis
p)2023146456

TheNTSBhasnoauthorityoverthesemattersastheyareaninvestigationagency.Iftherewasan
incident,theymaybecalledupontoinvestigateit.

13

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 this
investigation, 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 ground
storage tank that could be installed at the port (see Table 1). The storage tank would be filled
over several days prior to the ships 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 to
the ship.
Personnel bunkering the caustic soda would be wearing full personal protective
equipment, potentially within sight of boarding passengers.
Continuous filling, emptying and storage of the caustic soda provides more opportunities
for spills or accidents.

14

3.2 SOUTHAMPTON
The results of inquiries into vendors for Southampton are provided in Table 3. Based upon the
research 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 Car


There 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 approximately
20 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:
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 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.
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 conduct
additional 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.
15

Table3SummaryofVendorInquiries,Southampton
Reference
Aquachem
OfficeK/RedwitherBusinessCentre
WrexhamLL139XR
01978664077
watertreatmentwaste.co.uk
Contact:
JohnHolt
Chemtek
OrbisEnergy
WildeStreet
Lowestoft
SuffolkNR331XH
Tel:08451543330
Fax:01502539064
Email:sales@chemtek.co.uk
ReAgentChemicals
08009903258
enquiries@reagent.co.uk
AltransLiquidsLtd
SheephouseFarm,UleyRoad
Gloucestershire,FL115AD
England
Ph:01453544940
Email:info@altransliquids.co.uk
Web:www.altransliquids.co.uk

Information
Believedthatdeliveryandtransferdirectlytotheshiptanksbyroadtankerswouldbethebest
method.Originallystatedtheycansupplythequantity,frequencyandmixrequired.However,
subsequently,theywithdrewfromconsideration.Noadditionalconsiderationofthisvendoris
recommended.

Believedthatdeliveryandtransferdirectlytotheshiptanksbyroadtankerswouldbethebest
method.Statedtheycansupplythequantity,frequencyandmixrequired.However,nofurther
contactuponaskingforcredentials.Noadditionalconsiderationofthisvendorisrecommended.

Althoughinitiallytheyappearedinterested,theycannotsupplythequantitiesneeded.Noadditional
considerationofthisvendorisrecommended.
Believesfeasiblewithonsitestoragetank.Veryhelpfulandinterestedintheproject.Statetheycan
supplythequantity,frequencyandmixrequired.Securityandportpermissionsneedtobeverified
fortankeraccess.Estimatedcostsatthistime:0.34perlitre(222.71pertonne).

Atthisscreeninglevel,AltransLiquidsappearstobeasuitablesupplierforthecausticsoda.

Contact:
AnthonyMillard

16

Table3SummaryofVendorInquiries,Southampton
Reference
PBHChemicals
FacilityServices
323WoodsideWay
SpringvaleIndustrialEstate
CwmbranNP445BR
PaulHughes
Ph:07988071248
Email:phughes106@aol.com
SimonHughes
Ph:07540625135
NickHughes
Ph:07734440268

Information
Believesfeasiblewithonsitestoragetank.Statetheycansupplythequantity,frequencyandmix
required.AlsoabletosupplyNaOHinpowderformixingonsite.Securityandportpermissionsneed
tobeverifiedfortankeraccess.

WhittakerTankersBargeCompany
SouthamptonDocks
Ph:02380339989
Mrs.AmyBowd
SalesCoordinator
amy@tuffa.co.uk
http://www.tuffa.co.uk
Tel:+44(0)1889567700
Fax:+44(0)1889567600

Onlyabletodeliveroil.

Atthisscreeninglevel,PBHChemicalsappearstobeasuitablesupplierforthecausticsoda.

Tuffahasprebuilt,preheatedandbundledtankssuitableandavailable.

17

Table4SummaryofContacts,Southampton
Reference
AssociatedBritishPorts(ABP)
OceanGateAtlanticWay
SouthamptonSO143QN
Tel:02380488692
www.abports.co.uk

Information
Formsandrequirementsfortheuseandtransportationofsodiumhydroxidecanbefoundonthe
websiteathttp://www.southamptonvts.co.uk/yachting_and_leisure/notices_to_mariners/
Inparticular,No24of2011(BuilkLiquidsTransferRequestForm),No19of2011(DangerousSubstances
inHarbourArea)andNo10of2011(MarineSafetyManagementSystems)areapplicableandare
includedintheResourceCE.

ABPPortHealthandSafetyAdvisor
ChristopherTurner
cturner@abports.co.uk
ABPHealthandSafetyManager
DavidFox
ABPPortSecurityOfficer
PaulWoods
ABPPortAgent
SteveHeagren

Notparticularlyhelpfulintelephoneoremaildiscussions.

ABPPerryDack
CruisePassengerServicesManager
DocksideHandling
EnvironmentAgency
RomseyDepot
BillScott
EnvironmentalEnforcementOfficer
Ph:03708506506
www.environmentagency.gov.uk/conta
ctus/default.aspx
MaritimeandCoastguardAgencyJohn
Simpson
http://www.dft.gov.uk/mca/
Ph:02380329100

EmailedJune9thandseveralfollowuptelephonecallswerenotreturned.
MetwithMr.WoodsonJune28thinrelationtopotentialforstoragetanktobeerectedattheport.
RCCLwillhavetoapproachABPdirectlytodiscuss,butitispossible.
MetwithMr.HeagrenonJune8th.Veryhelpfulwithhealth,safetyandsecuritymatters.Escorted
duringtheportvisitandprovidedpaperwork,proceduresandsecurityrequirementsforvendors.
MetwithMr.DackonJune28th.HereferredustospeakwithPaulWood,PortSecurity,ABP.

NoconcernsaslongastheNaOHisnotdumpedatseaandanyspillagecontainedandproperly
managed.

Noconcernsprovidingthatportarrangementsareadheredto.

18

Table4SummaryofContacts,Southampton
Reference
BethEvans|Sales&Marketing
Manager|AssociatedBritishPorts
OceanGate|AtlanticWay|
Southampton|SO143QN
Tel:02380488844|Mob:
07730047048|www.abports.co.uk|
www.abparking.co.uk

Information

Ms.EvansindicatedthatpermissionfromABPwouldberequiredtoestablishanabovegroundtankat
thesiteforRoyalCaribbean'suse.SheindicatedthatthefirststepwouldbetocontacttheCityTerminal
Manager,TomDynes(tdynes@abports.co.uk).AfterMr.Dynesunderstandstherequirements,and
determinessuitablespaceisavailable,theycanprovideadditionalinformatononthepermitting
requirementsandcosts.

19

Only regulatory requirements include safe handling procedures and spill response
responsibilities.
Challenges with barge delivery include:
Coordination between fuel barge and caustic barge.
A supplier has not been identified in Southampton that is capable of providing the
material by barge.

3.2.4 Tanker Truck to Onsite Storage Tank


Several vendors were identified that could provide the caustic soda to an onsite above ground
storage tank that could be installed at the port (see Table 3). The storage tank would be filled
over several days prior to the ships arrival. Then the material would be transferred to the ship
when it is in port.
Potential challenges with this scenario include:
Associated British Ports would have to grant approval for the infrastructure needed. The
approval process could take several months or more:
o The tanker trucks will have to back into a containment structure (permanent or
temporary). If temporary, ground support will be needed to deploy for each
delivery. If a permanent containment is constructed, it will have to go through the
Associated British Ports approval process.
o A boom crane would be required to support the hose connection from the storage
tank to the ship.
o The storage tank(s) placement and design would have to be approved.
The material will have to be maintained at a temperature sufficient to prevent freezing. A
redundant power supply may be needed.
The infrastructure would have to be maintained.
The temperature requirement will limit the distance that pipes can travel from the tanks to
the ship.
Personnel bunkering the caustic soda would be wearing full personal protective
equipment, potentially within sight of boarding passengers.
Continuous filling, emptying and storage of the caustic soda provides more opportunities
for spills or accidents.
Benefits include:
It is the only feasible option at this time since a supplier by barge was not identified.
Additional research into delivery by barge is recommended.

20

4 DESIGN CONSIDERATIONS
While there are numerous design considerations that are outside the scope of this investigation,
several were identified that are presented below.

4.1 GENERAL
Based upon information gathered during this investigation, all design considerations must take
into account the temperature at which the material will freeze, approximately 58F (14C). All
storage (storage tanks on board the ship or at the port), transfer equipment, and transportation
equipment must be heated to prevent freezing throughout most of the year at both ports.
In accordance with the specifications prepared by Meyer Werft and supplied by RCCL:
Any part of tank or tank fittings which may come in to contact with caustic soda should
not contain the following metals or alloys: aluminum, magnesium, zinc, brass, and
tantalum. Caustic soda corrodes these metals and the reaction may generate flammable
hydrogen gas. Particularly reaction with aluminum is vigorous. Long term exposure to
caustic soda can deteriorate materials containing silica, e.g. glass. It is recommended to
check suppliers compatibility information regarding gaskets for manholes and flanged
tank fittings. Typically PTFE or EPDM should be used. Viton is not suitable as gasket or
sealing material.
Finally, any areas where the material is transferred must have immediate access to a safety
shower and eye wash station.

4.2 VESSEL
Given the various types of activities that occur while the ships are in port, the ideal location of
connections for bunkering the caustic soda will vary depending upon the type of transfer (either
by barge or aboveground storage tank). Connections that are at the extreme ends of the vessel
may require heated pipe runs over long distances if the above ground storage tanks are at
opposite ends of the vessel. Furthermore, regardless of the transfer method, connections will
have to be accessible on both the port and starboard side to enable connections to the ship
regardless of how it is docked.
It is recommended that one (1) or more Chief Engineers review the plan layout for additional
considerations. For instance, the Chief Engineer aboard the Independence of the Seas noted that
in the event of a leak, the sodium hydroxide could destroy the integrity of equipment within the
hull, such as electricity cabling. Also, the Chief expressed concerns that wind direction may
potentially direct fumes in the direction of passengers.
The design should include a plan for routine maintenance to inspect all tanks, piping, fittings and
connections associated with the handling, storage and use of the caustic soda.

4.3 PORT
In the event that aboveground storage tanks are used, the design and location of the tanks will
have to account for access for tanker trucks within a contained system. The footprint of the tanks
would be minimized if one (1) storage tank were used. However, given the density of the
21

material, 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 preferable
over 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.

22

5 REGULATORY REQUIREMENTS & RESOURCES


Appendix 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 occupational
exposure 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 on
the ocean. An example of a suitable vendor is Kens 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 and
industrial 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.

23

Table5SummaryofRegulations,UnitedStates
Reference

Information

OSHA29CFR1910.132& ProtectiveEquipment,includingpersonalprotectiveequipmentforeyes,face,head,andextremities,
TheChlorineInstitute'sPamphlet65
protectiveclothing,respiratorydevices,andprotectiveshieldsandbarriers,shallbeprovided,used,
GeneralPPERequirementsforCausticSoda andmaintainedforthoseworkingwithandaroundtheSodiumHydroxide.
AllPPEequipmentshouldbechemicalresistantinthefollowingconditions:1050%NaOHSolution
withanambienttemperaturenogreaterthan120degreesFahrenheit.
InitialLineBreak:Head,Neck,Face,Eyes,Hands,BodyandFeet
MaterialSampling:Face,EyesandHands
Loading(employeeisawayfromloadingconnection):Head,Face,EyesandHands
OpenDomeNoProductFlow:Eyes
SodiumHydroxideiscolorlessandodorlessandcausessevereirritationwhenitcomesincontactwith
humantissue.Itcanrapidlycausedamagetotheeyesandskinaswellaswheninhaledoringested.
Extremecautionmustbeexercisedwhenworkingwiththischemical.
OSHA29CFR1910.262(oo)
HandlingCausticSoda

Meansshallbeprovidedforhandlingandemptyingcausticsodaandcausticpotashcontainersto
preventworkersfromcomingincontactwiththecaustic.
1910.5(c)(1) statesthatifastandardisspecificallyapplicabletoacondition,practice,means,method,
operation,orprocess,itshallprevailoveranydifferentgeneralstandardwhichmightotherwisebe
applicable;therefore,29CFR1910.262(oo)prevailsovermoregeneralregulationsthatmay
counteractit.
ProperPPEandotherappropriateequipmentisrequiredtobeprovidedtoemployeesworkingwith
theSodiumHydroxide.

OSHA29CFR1910.262(ll)
ShutoffValvesforOpenTanks&Vats

Emergencyshutoffvalvesforholdingtanksmustbelocatedatadistancewhicheliminatesriskof
comingincontactwiththecausticsodaintheeventofasplash,etc.
ValvesshallconformtotheASMEPressureVesselCode,SectionVIII,unfiredpressurevessels.

24

Table5SummaryofRegulations,UnitedStates
Reference
OSHA291910.20
HazardousWasteOperationsand
EmergencyResponse

Information
Itisrequiredtoeitherhireacompanywithproperlytrainedpersonneltobeoncallortrain
appropriateemployeesin40hourHAZWOPER,inthecasethatthereisanemergency.
Thissectioncoversthecleanupoperationsatuncontrolledhazmatwastesites,emergencyresponse
operationsandaguidelinesforawrittenhealthandsafetyprogram.
~Thewrittenhealthandsafetyprogrammustincludebutisnotlimitedto:organizational
structure,acomprehensiveworkplan,sitespecificsafetyandhealthplan,safetyand
healthtrainingprogram,medicalsurveillanceprogramandstandardoperatingprocedures
forsafetyandhealthinvolvinghazardousmaterials.

OSHA291910.1200
HazardCommunication

Ensuresthatthehazardsofcausticsodaisevaluated,andthatinformationconcerningthehazardsis
transmittedtoemployersandtheemployeesofRCCLthatwillbeworkingwiththehazardous
material.
RelevanthazardcommunicationshouldbeaddedtoRCCL'sexistinghazardcommunication
documents.

EPA40CFR302.4
HazardousSubstances&Reportable
Quantities

ThereportablequantityforSodiumHydroxideis1,000poundswherea50%solutionofNaOH
containsapproximately6.4poundsperUSGallon.
Spillsinexcessofapproximately156gallonsarewillrequirereportingtotheNationalResponse
CenterandtheUSCoastGuard.

EPA40CFR300
NationalOilandHazardousSubstances
PollutionContingencyPlan:
SubpartEHazardousSubstanceResponse

Theorganizationalstructureandproceduresforpreparingforandrespondingtodischargesofoiland
releasesofhazardoussubstances,pollutantsandcontaminants.
Whenspillsinexcessof156gallonsoccur,RCCListofollowtheseguidelinesforproperresponse.

25

Table5SummaryofRegulations,UnitedStates
Reference
46CFRPart147SubpartA
HazardousShips'Stores

33CFRPart153
ControlofPollutionbyOilandHazardous
Substances,DischargeRemoval

49CFR171.15
Immediatenoticeofcertainhazardous
materialsincidents

Information
TheSodiumHydroxidemustbelabeledwiththetechnical/propershippingname,manufacturer'sor
supplier'snameandaddress,hazardclassification(8corrosivematerial),stepbystepproceduresfor
properuse,firstaidinstructionsandthestowageandsegregationguidelines.
Theholdingtanksattheportandonboardtheshipmustbeappropriatelyandthoroughlylabeledin
accordancewiththisregulation.
ThepurposeofthispartistoprescriberegulationsconcerningnotificationtotheCoastGuardofthe
dischargeofoilorhazardoussubstancesasrequiredbytheFederalWaterPollutionsControlAct,as
amended(FWPCA);theproceduresfortheremovalofadischargeofoil;andthecoststhatmaybe
imposedorreimbursedfortheremovalofadischargeofoilorhazardoussubstancesunderthe
FWPCA.
Intheeventofaspill,RCCLshouldrefertothissectionformanagementandcleanup.
Intheeventofaspillofthereportablequantityormore,theNationalResponseCentermustbe
notifiedwithin12hours.
(ReportablequantityforNaOH:1,000lbs.or156.25gallons)

49CFR171.16
Detailedhazardousmaterialsincident
reports

EachpersoninvolvedinthetransportoftheSodiumHydroxidemustsubmitaHazardousMaterials
IncidentReporttotheUSDOTPipelineandHazardousMaterialsSafetyAdministration,intheeventof
anincident.

49CFR172.101
Purposeanduseofhazardousmaterials
table

Thetabledesignatesthematerialslistedthereinashazardousforthepurposeoftransportation.The
tableidentifiesthehazardclassandidentificationnumber.
SodiumHydroxide:
HazardClass8
IdentificationNumberUN1824

26

Table5SummaryofRegulations,UnitedStates
Reference

Information

NJAC7:1E Thischaptercoversthedischargeofhazardoussubstances;includingSodiumHydroxide,forthestate
NJDepartmentofEnvironmentalProtectionofNewJersey.Theserulessetforthguidelinesandprocedurestobefollowedbyallpersonsinthe
GeneralProvisions
eventofahazardoussubstancerelease.Theyalsosetforthcertainregistrations,reporting,design,
operations,andmaintenancerequirementsforownersandoperatorsofmajorfacilitieswhichhandle
hazardoussubstances.
ThisNewJerseyStatuteshouldbereviewedbyallpersonnelinvolvedinworkingwiththeholding
tanksattheportaswellasonboardtheship.
NJAC7:1E1.8
EnvironmentallySensitiveAreas
NJAC7:12
PreventionandControlofDischargesat
MajorFacilities
NJAC7:26E
TechnicalRequirementsforSiteRemediation

ForthepurposesofdesigningandimplementingaDPCCandaDCRplan,theportofBayonneareais
anenvironmentallysensitivearea.
Itisimportanttoreviewthissectionindesigningsiteplans.
Therulesthatareapplicabletotheownersoroperatorsofmajorfacilitiesstoring,transferring,
processingorusinghazardousmaterials.ThisNewJerseystatuteshouldbethoroughlyreviewedas
partoftheholdingtankdesignprocess,ifimplemented.
Thischapterconstitutestheminimumtechnicalrequirementstoinvestigateandremediate
contaminationatanysite.
Anypersonconductingremediationshallcomplywiththischapterandallguidancefoundonthe
NewJerseyDepartmentofEnvironmentalProtectionwebsite.

27

Table6SummaryofRegulations,UnitedKingdom
Reference
Information
DangerousSubstancesDirective(67/548/EEC)
TheseDirectiveshavebeenimplementedintheUKastheChemicals(HazardInformationandPackaging)for
DangerousPreparationsDirective(1999/45/EEC) SupplyRegulations2009(CHIP[2][3]).TheCHIPRegulationswillbefullyrepealedin2015
(http://www.hse.gov.uk/ghs/backgrnd.htm).
NewEuropeanlegislationderivedfromEUGHS (EC)No1272/2008(200920157yrtransperiod)CLPeffectoncompanies.
Classification,LabellingandPackagingof
SubstancesandMixtures2009(CLPRegulations) Ifyouareasupplierofchemicals,youmustclassify,labelandpackageyoursubstancesandmixturesin
accordancewiththeCLPRegulation.Yourobligationsdependuponyourroleinthesupplychain.Suppliers
mayhaveoneormoreoftheseroles:Manufacturersofsubstancesormixtures,Importerofsubstancesor
mixtures,Producerofspecificarticles,Downstreamuser(includingformulatorandreimporter),Distributor
(includingretailer).
Ifyouplaceahazardoussubstanceonthemarket,youmustnotifyECHAofitsclassificationandlabellingwithin
onemonthofplacingthesubstanceonthemarketforthefirsttime.
Forimporters,theonemonthiscountedfromthedaywhenasubstance,onitsownorcontainedinamixture,is
physicallyintroducedinthecustomsterritoryoftheEU.(http://echa.europa.eu/regulations/clp/clpseffecton
companies)
Guidancelinkhttp://echa.europa.eu/documents/10162/13562/clp_introductory_en.pdf
Registration,Evaluation,Authorisationand
RestrictionofChemicals2007(Reach)

ControlofSubstancesHazardoustoHealth
(COSHH)2002

ReachifasupplierisimportingcausticfromoutsideEUtheywillneedtoregisterwithReach.Iftheyare
manufacturingwithinEUandallingredientsarepurchasedfromwithinEUtheydonothavetoregisterwith
REACH.However,ifaningredientispurchasedfromoutsideEUthentheywillneedtoregister.Registerdatefor
quantities>100tonneshouldberegisteredbeforeJune2013.
http://www.hse.gov.uk/reach/resources/basics.pdf
WorksalongsideREACHregulations.RequiressubstancestohaveMSDSsheetsandRiskAssessmentsforstorage
anduse.Mustprovideinformation,instructionandtraining,andhealthsurveillance.

28

Table6SummaryofRegulations,UnitedKingdom
Reference
EuropeanAgreementconcerningthe
InternationalCarriageofDangerousGoodsby
Road.

Information
ADRisanagreementbetweenstatesinEU.ADRapplicableasfrom1January2011.(unece.org)
ADRlinkhttp://www.unece.org/fileadmin/DAM/trans/danger/publi/adr/adr2011/

AccordEuropeanRelatifauTransport
http://www.hse.gov.uk/cdg/regs.htm
InternationaldesMarchandisesDangereusespar
Route1967
(ADRAgreement)

UnitedNationsEconomicCommissionfor
Europe(UN/ECE)
CarriageofDangerousGoodsandUseof
Cameintoforceon1July2009.Theyreplacethe2007regulations.ImplementedthroughADR.
TransportablePressureEquipmentRegulations http://www.legislation.gov.uk/uksi/2009/1348/contents/made
2009CDG2009
HealthandSafetyExecutiveSI2009No1348
Classification,LabellingandPackagingof
SubstancesandMixtures2009(CLP)

TheCHIPRegulationswillbefullyrepealedin2015andreplacedwithCLP2009.
(http://www.hse.gov.uk/ghs/backgrnd.htm)

29

6 CONCLUSIONS AND RECOMMENDATIONS


It 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 global
manufacturers (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 (installation
of 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 RCCL
formerly retain engineers to initiate the design process and engage the port authorities (PANYNJ
and ABP) and regulatory agencies as soon as possible to meet a target date of November 2014.
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 the
implementation 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 accompanying
resource 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.

30

APPENDIX I
PROVIDED DOCUMENTATION

1.1.1.1.1
BGN
774
774
774
774
774

Sheet
M
M
M
M
M

Person in charge:

Kostilew

Owner:

Vessel:

BGN:

DEPT.

NO:

Phone:

+49(0)4961 81-4772

RCL

S.697

774

1000

E-mail

anatol.kostilew@meyerwerft.de

Date:

18.04.2013

List of Included Drawings


Description

1100
1200
1300
1001
1002

General Description
Material and Piping Standards
Monitoring and Alarms via the IAMCS
NaOH 50 % Bunkering, transfer and feed System
NaOH 50 % Bunkering, symboltable and details

Sheet

Description

2.1.1.1.1
BGN
774

1100

General Description

774

1200

Pipe System specification

774

1300

Monitoring and Alarms via the IAMCS

774

1001

774

1002

NaOH 50 % Bunkering, transfer and feed


System
NaOH 50 % Bunkering, symboltable and
details

No.

Drawing No.

1)
2)
3)
4)
5)

752 V 1000
753 V 1000
721 V 1000
724 M 2000
711 M 2004

List of Reference Drawings


Description

Service air
Control air
Technical water
Boiler Wash and Exhaust Gas Cleaning
LT Circle
MWS 0.7--.071
MWS 0.7--.017

List of Alterations
Kind of Alteration

No.

Date

Name

Tel. No.

FG

See marked in grey.

18.04.2013

Kostilew

4772

100 %

Material test 3.2

18.04.2013

Kostilew

4772

100 %

See marked in grey.

18.04.2013

Kostilew

4772

100 %

Updates signed with arrows

18.04.2013

Kostilew

4772

100 %

Updates signed with arrows

18.04.2013

Kostilew

4772

100 %

Name
2.1.1.1.2
Labels

Plotdate: 23.04.2013

Alt.

Operating fluids for exhaust gas cleaning

System:

Armatures

Date

Person in charge:

Kostilew

Owner:

Vessel:

BGN:

DEPT.

NO:

Phone:

+49(0)4961 81-4772

RCL

S.697

774

1100

E-mail

daniel.jamaer@meyerwerft.de

Date:

18.04.2013

System:

Operating fluids for exhaust gas cleaning

Alt.
A

Solution (Caustic) Storage Equipment and Piping System (Edition 3)

GENERAL DESCRIPTION
1.

SPECIFICATION & AOMs

1.1 Specification
Technical Specification SOx Scrubber System Rev. K

3.

EQUIPMENT & CHARACTERISTICS

3.1 HEAT EXCHANGER CAUSTIC SODA TANKS


Plate Heat Exchanger
Capacity:
Imput:

19,3 m/h
180kW

JLM Number: 527.4410


Maker:
GEA Ecoflex GmbH
Type:

NT50M CDS-10

1.2 AOMs
3.2 NAOH STORAGE TK HEAT TRANSFER PUMP
AOM_011
1.3 AOSs
AOS_059 (NOS 05899)
2.

Classification & Regulations

2.1

Classification
Class: Det Norske Veritas
+ 1 A1 Passenger Ship
ECO, F-M, COMF-V (1)
FUEL (380 cSt, 1010 Kg/m,0C), LCS-DC, BIS
EO, NAUT-AW, CLEAN DESIGN

2.2

Regulations
The following rules and regulations apply:
x Newbuilding Specification RCL P09140-C1, Chapter: G3.3 Rules and Regulations, dated 31 March
2011
x General Electrical Requirements S.697 Rev.A, dated 09.02.2012
x Ship flag:
Bahamas (Germany before ship delivery)
x Ship classification: DNV
x DNV:
Vibration class Pt.6 Ch.15 Sec.2, Tables: C9, C10 and C14. The first of each
type of scrubber component will be measured at factory acceptance test.
x IMO:
Marpol Annex VI, especially Exhaust Gas Cleaning System Guidelines, IMO
resolution MEPC.184(59), Scheme B.
x EU:
Sulphur directive 2005/33/EC
If any interpretation of class or Marpol rules is needed, they should be clarified as early as possible.

Plotdate: 23.04.2013

Capacity:
Pressure:

20 m/h
3,0 bar

JLM Number: 527.4420


Maker:
Behrens Pumpen
Type:

SFN 51A G

3.3 CST HEAT. LT Expansion TK


Expansion tank
Capacity:
18,7 l
Oper. Pressure: 6,5 bar

JLM Number: 527.4430


Maker:
Reflex
Type:

reflex 25D

3.4 Alkali Transfer Pump (15P08)


Capacity:
Pressure:

10,0 m/h

Type:

Texel MES-050

16 meters (Caustic Soda)


JLM Number: 527.4250
Maker:
Seikow Chemical Engineering Machinery, LTD
The alkali transfer pump is used to empty the alkali storage tank or one compartment to the other
or to the bunker station e.g. in case of tank service or inspection.
3.5 ALKALI TOPPING UP PUMP (15P18)
Capacity:
Pressure:

3,0 m/h

Type:

TSP MAG-P52 PP/PVDF

11,5 meters (Caustic Soda)


JLM Number: 527.4240
Maker:
3M Pumps
The alkali topping-up pump is used to transfer alkali from storage tanks to small built-in tanks of
bleed-off treatment units.
3.6 ALKALI DOSING PUMP(15P17)

Capacity:
Pressure:

100 l/h

Type:

LK-F47VS

Person in charge:

Kostilew

Owner:

Vessel:

BGN:

DEPT.

NO:

Phone:

+49(0)4961 81-4772

RCL

S.697

774

1100

E-mail

daniel.jamaer@meyerwerft.de

Date:

18.04.2013

0,8 MPa
JLM Number: 527.4230
Maker:
IWAKI PUMPS
The alkali dosing pump is used for pumping the alkali from the alkali storage tank to bleed-off
buffer tank to keep the pH in the bleed-off buffer tank above 4pH.
3.7 ALKALI FEED MODULE 2 (15N04/1 and 15N04/2)
Alkali feed module consists of two pumps. In normal operating conditions one pump is in operation
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.
Pressure:
28,4 meters (Caustic Soda)
JLM Number: 527.4220
527.4210
Maker:
Metso
Type:
0.55kW Motor
Steel Frame: AISI316L or equivalent Piping:
Dry weight: 200 kg
Weight in operation: 300 kg
3.8 Tank outlet valves
See automation chapter 2.1
3.9 Tank instruments
Alkali tank filling line should be led below the minimum service level and should be provided with
vacuum breaker hole at the upper end where anti siphon effect may occur. 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 trucks 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 50C)
Temperature low (set point 20C)
Level low (e.g. 30%)
Level high (e.g. 85%)
Instead of sounding pipe an approved type local hydrostatic level indicator can be used, note that
devices need to be calibrated for caustic soda density.
3.10 Storage tank NaOH
The tank is divided into 3 compartments plus one overflow compartment to be able to handle even
Plotdate: 23.04.2013

System:

Operating fluids for exhaust gas cleaning

Alt.
A

small amounts of alkali. It is also possible to pump between the compartments.


Tank Name
Capacity
NaOH Overflow TK 12S
6,5 m
NaOH Store TK 12S-1
50,9 m
NaOH Store TK 12S-2
57,0 m
NaOH Store TK 12S-3
47,0 m
Tank for 50% NaOH should be dimensioned for specific density of 1.52 t/m3, including hydrostatic
static pressure to air vent head above the bulkhead deck.
Recommended cleaning interval for storage tank is 5 years.
Alkali storage tank air and overflow pipe are led in similar way as normal air and overflow pipes
(e.g. abovebulkhead deck and overboard). Detail 724 M ----1002
3.10.1 Tank coating
Maker:
International Marine Coatings
Type:
Interline 994 (Epoxy Phenolic Tank Coating)
4 System Description
4.1 General
Alkali is automatically added to the scrubbing water circulation when operating in closed loop
mode to maintain the process pH and consequently the SOx removal efficiency. 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 of two chemical
dosing pumps. One pump is normally in operation and the other is stand-by.
The scrubbing water pH is regulated by the amount of alkali added to the circulation. The pH
control uses information of the pH of the scrubbing water as input. The main control is
automatically adjusted based on the measured pH of scrubbing water.
4.1.1 Alkali specification
Wrtsil 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 specification (typical for marine scrubber):
SODIUM HYDROXIDE (NaOH) 50% SOLUTION - TECHNICAL QUALITY
TECHNICAL NAME: SODIUM HYDROXIDE SOLUTION 50% (WATER SOLUTION)
CHEMICAL FORMULA: NaOH (aq)
CAS No.
1310-73-2
EINECS No.
215-185-5
ADDITIONAL TRADE NAME(S):
CAUSTIC SODA 50%, LYE 50%
CHEMICAL COMPOSITION SODIUM HYDROXIDE, Na-OH: 45 52%-weight
CHLORIDE (Cl)
< 0.1%-weight as NaCl

Person in charge:

Kostilew

Owner:

Vessel:

BGN:

DEPT.

NO:

Phone:

+49(0)4961 81-4772

RCL

S.697

774

1100

E-mail

daniel.jamaer@meyerwerft.de

Date:

18.04.2013

NOTE!
Any part of tank or tank fittings which may come in to contact with caustic soda should not
contain the following metals or alloys: aluminium, magnesium, zinc, brass, and tantalum. Caustic
soda corrodes these metals and the reaction may generate flammable hydrogen gas. Particularly
reaction with aluminium is vigorous. Long term exposure to caustic soda can deteriorate materials containing silica e.g. glass. It is recommended to check suppliers 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.

System:

5.

CLASS NOTATION

5.1

ECO Part 6, Chapter 3


PERIODICALLY UNATTENDED MACHINERY SPACE
Does not apply for this system

5.2

Alkali feed module shutdown is connected to the emergency stop. The module is equipped with
drip tray. The drip tray triggers an alarm in case of leakage (LS501at 527.4210 and LS502 at
527.4220)

4.3

Storage tank heating


50% caustic soda is solidifying at temperatures below 12C 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 16C additional heating should be provided. The
recommended storage temperature is between 25 and 35C.
Corrosive properties of caustic soda are aggravated at temperatures above 49C (when carbon
steel is used) and thus caustic soda storage should not have common structures with e.g. heated
fuel oil service and settling tanks.
See automation 3.3
The requirements for the safety
Caustic soda bunkering areas, tanks and sounding pipes, feed module and pipes be provided with
warning signs to ensure that all crew members are aware of the hazards involved in general and in
particular when any maintenance or repairs are made. 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.
Safety showers (with shower and eye wash) be arranged for relevant alkali handling areas, such as
bunker stations, alkali feed module area and bleed-off treatment units. The safety showers should
be clearly marked with dedicated signs. If the safety shower is located out-doors, it must be
insulated and heat traced in order to prevent freezing (Bunker station).

F-M Part 6, Chapter 4


ADDITIONAL FIRE PROTECTION
Does not apply for this system.

5.3

4.2

Operating fluids for exhaust gas cleaning

COMF-V(1) Part 5 Chapter 12


COMFORT CLASS
Does not apply for this system

5.4

FUEL Part 6, Chapter 14


FUEL TREATMENT AND CONDITIONING SYSTEMS
Does not apply for this system

5.5

LCS-DC Part 6, Chapter 9


LOADING COMPUTER SYSTEMS FOR STABILITY AND LONGITUDINAL STRENGTH
Does not apply for this system.

5.6

BIS Part 3, Chapter 1


SHIPS BUILT FOR IN WATER SURVEY
Does not apply for this system.

5.7

E0 Part 6, Chapter 3
EQUIPMENT AND SYSTEM NOTATION UNATTENDED MACHINERY SPACE
Does not apply for this system.

Following personal protective equipment must be worn when handling alkali:


Impervious overalls
Protective clothing
Chemical boots
Safety helmet
Safety goggles or face shield
All locations where alkali is handled are to be provided with good ventilation. See Appendix 1 for
more information of NaOH
Plotdate: 23.04.2013

5.8

NAUT-AW Part 6, Chapter 8


NAUTICAL SAFETY
Does not apply for this system.

5.9

CLEAN DESIGN Part 6, Chapter 12


ENVIRONMENTAL CLASS
Does not apply for this system.

Alt.
A

6.

Person in charge:

Kostilew

Owner:

Vessel:

BGN:

DEPT.

NO:

Phone:

+49(0)4961 81-4772

RCL

S.697

774

1100

E-mail

daniel.jamaer@meyerwerft.de

Date:

18.04.2013

CALCULATIONS

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:
- 7C
Sea water temperature:
+ 0C
Engine room temperature:
+20C
Performance: heating up within 24 h

Tank Name
NaOH Overflow TK 12S
NaOH Store TK 12S-1
NaOH Store TK 12S-2
NaOH Store TK 12S-3
Sum. Store TKs

Heat requirement
5,1 kW
51,5 kW
57,0 kW
47,4 kW
161 kW

Q
m
*
1,16 * /t h

Medium

7.

Heat [kW]

V [m/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

SAFE RETURN TO PORT

Plotdate: 23.04.2013

Operating fluids for exhaust gas cleaning

With regard to Safe Return to Port regulations, the following systems can to be treated:
There are no special regulations because the cleaning system isnt essential for propulsions.

General data

System:

Alt.
A

Plotdate: 23.04.2013

Person in charge:

Kostilew

Owner:

Vessel:

BGN:

DEPT.

NO:

Phone:

+49(0)4961 81-4772

RCL

S.697

774

1200

E-mail

daniel.jamaer@meyerwerft.de

Date:

18.04.2013

System:

Operating fluids for exhaust gas cleaning

Alt.
A

Plotdate: 23.04.2013

Person in charge:

Kostilew

Owner:

Vessel:

BGN:

DEPT.

NO:

Phone:

+49(0)4961 81-4772

RCL

S.697

774

1200

E-mail

daniel.jamaer@meyerwerft.de

Date:

18.04.2013

System:

Operating fluids for exhaust gas cleaning

Alt.
A

Plotdate: 23.04.2013

Person in charge:

Kostilew

Owner:

Vessel:

BGN:

DEPT.

NO:

Phone:

+49(0)4961 81-4772

RCL

S.697

774

1200

E-mail

daniel.jamaer@meyerwerft.de

Date:

18.04.2013

System:

Operating fluids for exhaust gas cleaning

Alt.
A

Plotdate: 23.04.2013

Person in charge:

Kostlew

Owner:

Vessel:

BGN:

DEPT.

NO:

Phone:

+49(0)4961 81-4772

RCL

S.697

774

1300

E-mail

daniel.jamaer@meyerwerft.de

Date:

18.04.2013

System:

Operating fluids for exhaust gas cleaning

Alt.
A

Plotdate: 23.04.2013

Person in charge:

Kostlew

Owner:

Vessel:

BGN:

DEPT.

NO:

Phone:

+49(0)4961 81-4772

RCL

S.697

774

1300

E-mail

daniel.jamaer@meyerwerft.de

Date:

18.04.2013

System:

Operating fluids for exhaust gas cleaning

Alt.
A

Plotdate: 23.04.2013

Person in charge:

Kostlew

Owner:

Vessel:

BGN:

DEPT.

NO:

Phone:

+49(0)4961 81-4772

RCL

S.697

774

1300

E-mail

daniel.jamaer@meyerwerft.de

Date:

18.04.2013

System:

Operating fluids for exhaust gas cleaning

Alt.
A

hWJtilfil

Environmental Technologies

7.

Alkali Feed System

7.1

General

Installation Planning Instructions


7. Alkali Feed System

Alkali is automatically added to the scrubbing water circulation when operating in closed loop mode to
maintain the process pH and consequently the SOx removal efficiency. Typically 50% NaOH (Sodium Hydroxide), 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 of two chemical dosing pumps.
One pump is normally in operation and the other is stand-by.
The scrubbing water pH is regulated by the amount of alkali added to the circulation . The pH control uses
information of the pH of the scrubbing water as input. The main control is automatically adjusted based on
the measured pH of 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 "Corrosive 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 outdoors, 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

ifl@"iiii

Installation Planning Instructions


7. Alkali Feed System

Environmental Technologies

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 information 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'lka'li demand per eng'ine power


80

700

'6 00

GJ

E,
s::

.5!

Q.

ll
I ]!

-L

3.5%5fu e l

3,05fuel
-

2,5%5 fue l
2P 5 ftJe l
1,5%5 fue l

'500

no - - - -+----+-----'

.... ...

.,......-_ __.__.,or:;__

300

.-

2tl0

<(

--

10
0
0

'5000

10000

15000
20000
2 5000
Operating power(kW)

30000

35000

40000

As a rule of thumb the alkali consumption can be estimated to be 5 liters/MWh per fuelS%.

7.3

Storage
Onboard storage capacity is dictated by the following parameters: vessel autonomy, alkali consumption
and vessels operation profile and area.

7-2

Meyer Werft 697 - Scrubber - a4


14 March 2013

ik/t9Jt11M Environmental Technologies I

Installation Planning Instructions


7. Alkali Feed System

Figure 7.4 Alkali consumption per consumed fuel, when using 50% caustic soda

Alka li demand per fuel consumption


2000
- 3, 5%Sfu~ l

lSOO

_1600

'E

1400

1200

3,0% 5 fue l

- - 2,5 % 5 fue l
2,0%5 fue l
1,5%5 fue l

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

"" 1000
t:

...

....

- - - --

800

. . .
400 +-----~----~~~-h~~~~~---+=r~-~-----4.------~----~
, --~
600

200

.-

0
0

2000

4 00

6000

00

10000

12000

14000

16000

1 000

20000

Fuel consumption (ton)


Required storage tank capacity can be calculated e.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 dependent 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 49C 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 materials containing silica e.g. glass. It is recommended to check supplier's compatibility information

Meyer Werft 697 - Scrubber- a4


14 March 2013

7-3

k@ij!i

Installation Planning Instructions


7. Alkali Feed System

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

Tank coating
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 70C

Specific gravity
Film thicknesses

400 J.Jm

Colours

Limited selection

Pre-treatment

Sa2V2 (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
10C and at least 3C 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


Coating for buffer and alkali tanks

7-4

Product

Teknos lnerta 280

Description

Used as coat in epoxy systems inside kerosene and oil tanks. Withstands aliphatic hydrocarbons, alkaline solutions and acids.

Temperature

Withstands +70C in immersion

Specific grafity

1.5 kg/1

Film thicknesses

500 J.Jm

Colours

Red , green or white

Pre-treatment

Sa2Y2 (ISO 8501-1)

Surfaces

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 3C above the dew point.
The temperature of the ambient air, surface or paint should not fall below + 10C.

Drying times

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

Thinner

Teknosolv 6560

Primer

Teknos lnerta 280

Finish

Teknos lnerta 280

Meyer Werft 697 - Scrubber- a4


14 March 2013

lf/N'Irilfti Environmental Technologies

Installation Planning Instructions


7. Alkali Feed System

Table 7.3 Example products for tank coating from Tikkurila


Coating for buffer and alkali tanks
Product

Tikkurila TEMALINE BL TES

Description

Two component, solvent free epoxy coating. Suitable to be used as a heavy duty coating on
steel and co ncrete surfaces exposed to chemical and mechanical stress in immersion. Good
resistance to acids, alkali and salts in immersion . Suitable for coating of lead-free tanks.

Temperature

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

Specific gravity

1.4 kg/1(mixed)

Film thicknesses

500 iJm

Colours

Red and green

Pre-treatment

Sa2Y2 (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

Primer

TEMALINE BL

Drying times

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

Finish

TEMALINE BL

Product

SIGMASHIELD 460 (LT)

Description

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

Coating for buffer tank

Temperature
Specific gravity

1.5 kg/1

Film thicknesses

Min 400 iJm

Colours

Black - gloss (light colours on request)

Pre-treatment

Sa2Y2 (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 15C 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 Thinner 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 12C 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 16C additional heating should be provided. The recommended storage temperature is between 25 and 35C . Corrosive properties of caustic soda are aggravated at temperatures above
49C {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 coefficients 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 .

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7-5

Installation Planning Instructions


7. Alkali Feed System

RMiJijld Environmental Technologies I

If heat losses from the tank are remarkable, heating with water circulation in carbon steel coils can be used.
To avoid corrosion of heating coils external surface, inlet water temperature should remain below 49C.
For 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 of 300 mm from tank bottom and located so that thermal agitation 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 (25C} and the
arithmetic mean temperature of incoming I outgoing circulating water. Mean heat transfer coefficient from
water coils to caustic soda can be estimated to 60 W/(m2 x 0 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


When anywhere in the alkali 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 installation 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 45C, if provided with heating)
Temperature low (set point 20C, 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 of 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.

7-6

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i?fUiifii Environmental Technologies I

Installation Planning Instructions


7. Alkali Feed System

Figure 7.5 Caustic soda storage tank fittings

TI

I HD

HOLE

Alkali storage tank air and overflow pipe are led in similar way as normal air and overflow pipes (e.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.

FROM NaOH
STORAGE TANK

7.7

Alkali feed module


Alkali feed module consists of two pumps. In normal operating conditions one pump is in operation 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

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Installation Planning Instructions


7. Alkali Feed System

Type:

Chemical dosing

Motor:

Approx 0.55 kW

Frame:

Steel

Piping :

AISI316L or equivalent

Dry weight:

200 kg

Weight in operation:

300 kg

Width :

900mm

Depth:

700 mm

Height:

1950 mm

fiiQibJ

Environmental Technologies

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 quantity 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

pH control of the bleed-off buffer tank


To keep the pH in the bleed-off buffer tank above 4pH there will be alkali feed to bleed-off recirculation
line. 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 m3Jh

7-8

Motor:

1.1 kW

Weight:

37 kg

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IMJti!fii Environmental Technologies I

Installation Planning Instructions


7. Alkali Feed System

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 acqu ire the chemical according to the following specification .
50% NaOH solution specification (typical for marine scrubber):
SODIUM HYDROXIDE (NaOH) 50% SOLUTION -TECHNICAL QUALITY
TECHNICAL NAME:

SODIUM HYDROXIDE SOLUTION 50 % (WATER SOLUTION)

CHEMICAL FORMULA:

NaOH (aq)

CAS N:o

1310-73-2

EINECS N:o

215- 185-5

ADDITIONAL TRADE
NAME(S):

CAUSTIC SODA 50%, LYE 50%

CHEMICAL COMPOSITION
SODIUM HYDROXIDE, Na- 45 ... 52 %-weight
OH
CHLORIDE (CI)

< 0.1 %-weight as NaCI

7.13 Drawings
DBAC471142DBAC471141-

Alkali feed module ..... ..... ..... ........................ ..... .............. ... ... ............... ....... ..... ... .. 7-1 0
Alkali feed module ................................................................. .. ... .. ..... ..... ........ ... ... 7-11

DBAC458743 -

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

DBAC4587 43
DBAC458676
DBAC458676
DBAC458669
DBAC458669

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

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7-9

APPENDIX II
HAZARDOUS SUBSTANCE FACT SHEET SODIUM HYDROXIDE

I. . . . .....!!!!!IHazardous Substance Fact Sheet

Right to Know

common Name:

SODIUM HYDROXIDE

Synonyms: Caustic Soda; Lye; Sodium Hydrate


Chemical Name: Sodium Hydroxide
Date: May 2001

Revision : April2010

Description 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 .
~Transfer 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 Hotline: 1-877-927-6337
National Response Center: 1-800-424-8802

CAS Number:

1310-73-2

RTK Substance Number:

1706

DOT Number:

UN 1823 (solid)
UN 1824 (solution)

EMERGENCY RESPONDERS >> SEE LAST PAGE

Hazard Summary
Hazard Ratin~:~
HEALTH
FLAMMABILITY
REACTIVITY
CORROSIVE
DO NOT USE WATER

NFPA
3
0
1

NJDOH

Hazard Rat(ng Key: 0-mrmma/; 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
should not be exceeded at any time .
~

which

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.

Page 2 of6

SODIUM HYDROXIDE
Determining Your Exposure
~

Read the product manufacturer's Material Safety Data


Sheet (MSDS) and the label to determine product
ingredients and important safety and health information
about the product mixture.

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.

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.

Medical

~You

have a right to this information under the New Jersey


Worker and Community Right to Know Act and the Public
Employees Occupational Safety and Health (PEOSH) Act
if you are a public worker in New Jersey, 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. 12:100-7) 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


Acute Health Effects
The following acute (short-term) health effects may occur
immediately or shortly after exposure to Sodium Hydroxide:
~

~
~

Contact can severely irritate and burn the skin and eyes with
possible permanent eye damage (corneal opacities) , 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:
Cancer 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.

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 of6
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 of 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).
3

"' Where the potential exists for exposure over 2 mg/m , 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.
3
"'Exposure to 10 mglm is immediately dangerous to life and
3
health . If the possibility of exposure above 10 mg/m 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.

SODIUM HYDROXIDE
Spills and Emergencies
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.
.,. DO NOT USE WATER OR WET METHOD.
.,. Ventilate and wash area after clean-up is complete.
.,. DO 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: rtk@doh .state.nj.us
Web address: http://www. nj.gov/health/eoh/rtkweb

The Right to Know Hazardous Substance Fact Sheets


are not intended to be copied and sold
for commercial purposes.

SODIUM HYDROXIDE

Page 5 of6

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.

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 i~ 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.

ERG is the Emergency Response Guidebook. It is a guide for


emergency responders for transportation emergencies
involving hazardous substances.

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.

Emergency Response Planning Guideline (ERPG ) values


prov1de estimates of concentration ranges where one
reasonably might anticipate observing adverse effects .

A reactive substance is a solid, liquid or gas that releases


energy under certain conditions.

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.
'
Ionization Potential 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.

STEL is a Short Term Exposure Limit which is usually a 15mlnute exposure that should not be exceeded at any time
during a work day.
A 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 o~ 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 Health!

Right to Know Hazardous Substance Fact Sheet

-.-..,~-

Emergency
Responders

Otick 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

HAZARD DATA
Hazard Rating

Firefighting

Reactivity

3- Health

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 .

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.
Sodium Hydroxide can attack IRON, COPPER, PLASTICS, RUBBER
and COATINGS.

0- Fire
1 - Reactivity
DOT#:
UN 1823 (solid)
UN 1824 (solution)
ERG Guide #: 154
Hazard Class: 8
(Corrosive)

PHYSICAL PROPERTIES

SPILL/LEAKS
Isolation Distance:

Odor Threshold:

Odorless

Spill (solid): 25 meters (75 feet)


Fire: 800 meters (1/2 mile)

Flash Point:

Noncombustible

Spill (liquid) : 50 meters (150 feet)

For Sodium Hydroxide in solution absorb liquids in dry sand , 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.
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.

Vapor Density:

2.1(air=1)

Vapor Pressure:

0 mm Hg at 68F (20C)

Specific Gravity:

2. 1 (water = 1)

Water Solubility:

Soluble

Boiling Point:

2,534F (1 ,390C)

Melting Point:

604F (318C)

Molecular Weight:

40

EXPOSURE LI MITS
3

OSHA:
2 mg/m , 8-hr TWA
3
NIOSH: 2 mg/m , Ceiling
3
ACGIH : 2 mglm , Ceiling
3
10 mg/m
IDLH:
The Protective Action Criteria values are:
3
3
PAC-2 = 5 mglm
PAC-1 = 0.5 mg/m
PAC-3 = 50 mg/m 3

H EALTH EFFECTS
Eyes:

Severe irritation, burns and possible eye


damage

Skin:

Irritation and severe burns

Inhalation:

Nose, throat and lung irritation with coughing


and severe shortness of breath (pulmonary
edema)

PROTECTIVE EQUIPMENT
Gloves:

Butyl , Nitrile, Neoprene, PVC, SilverShieldI4H, 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 - Full facepiece APR with High efficiency filters


3
>10 mglm - SCBA

FIRST AID AND DECONTAMINATION


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

PRELIMINARYRISKASSESSMENTFORTHEUSEOFCAUSTICSODAINANENGINEEXHAUST
STACKSCRUBBINGSYSTEM
1. PROLOGUE

ThisriskassessmentisreferredtoasaPreliminaryRiskAssessmentbecauseit
pertainstoaprocessthatiscontemplatedforusebutdoesnotpresentlyexist.Should
theprocessbeimplemented,thisriskassessmentwouldrequirereviewandpossible
modificationtocomportwithanydetails,informationderivedfromspecificjobsafety
analysesandothercharacteristicsoftheprocessthatarepresentlyunknown.

ThefollowingriskassessmentcitesseveralUnitedStatesFederalOccupationalSafety
andHealthRegulations(OSHA)applicabletoworkersinvolvedintheprocessbeing
considered.Althoughtheregulationsmaynotberequiredforworkersemployedin
internationalwaters,theseregulationsarebasedonsound,stateoftheartindustrial
hygieneprinciplesthatprovideasafeandhealthyenvironmentforworkers.

2. INTRODUCTION

Theprocessinconsiderationinvolvesadding50%CausticSodasolutiontothescrubbing
waterofanAlkaliFeedSystemoperatinginclosedloopmodeforthepurposeof
removingacidsulfurgasesfromenginestackemissions.CausticSoda,orSodium
Hydroxide,isahighlycorrosivechemicalandcontactwiththissubstancecanseverely
irritateandburntheskinandeyesleadingtopossibleblindness.Thepotentialhazards
ofworkingwithCausticSodamakeitimportantthatallpersonshandlingCausticSoda
knowandfollowstrictproceduresforsafety.Thispreliminaryriskassessmentwill
addressthefollowingissues:
a. HazardIdentification
b. ProtectiveMeasures
c. RegulationsApplicabletoCausticSoda
d. RiskAssessment
e. RiskManagement
f. ResidualRiskSummary

3. HAZARDIDENTIFICATION

a. ProductIdentification
i. Synonyms:CausticSoda,SodiumHydroxide,Lye,SodiumHydrate
ii. ChemicalFormula:NaOH
iii. CASNumber:1310732
iv. RTKSubstanceNumber:1706
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b.

c.

d.

e.

v. DOTNumber:UN1823(solid),UN1824(solution)
vi. HazardousWasteNumber:D002
vii. CausticSodaisontheRighttoKnowHazardousSubstancesListwhich
requiresemployersusingthismaterialtocomplywiththeFederalOSHA
HazardCommunicationStandard(29CFR1910.1200).
ProductDescription
i. Solidstate:odorless,whitesolid,absorbsmoisturefromair
ii. 50%Solution:odorless,clear
WorkplaceExposureLimits
i. OSHA:Thelegalairbornepermissibleexposurelimit(PEL)is2mg/m3
averagedoveran8hourworkshift.
ii. NIOSH:Therecommendedairborneexposurelimit(REL)is2mg/m3,
whichshouldnotbeexceededatanytime.
iii. NIOSH:Theairborneconcentrationlikelytocausedeathorimmediateor
delayedpermanentadversehealtheffectsorpreventescapefromsuch
anenvironment(IDLH)is10mg/m3.
iv. ACGIH:Thethresholdlimitvalue(TLV)is2mg/m3,whichshouldnotbe
exceededatanytime.
PotentialHealthEffects
i. Inhalation:Maycauseirritation(possiblysevere),chemicalburns,and
pulmonaryedema.
ii. Skincontact:Maycauseirritation(possiblysevere)andchemicalburns.
iii. Eyecontact:Maycauseirritation(possiblysevere),chemicalburns,eye
damage,andblindness.
iv. Ingestion:Maycauseirritation(possiblysevere),chemicalburns,nausea,
andvomiting.
v. Note:Theseverityoftissuedamageisafunctionofitsconcentration,the
lengthoftissuecontacttime,andlocaltissueconditions.Afterexposure
theremaybeatimedelaybeforeirritationandothereffectsoccur.This
materialisastrongirritantandiscorrosivetoallhumantissue.
FirstAid
i. EyeContact:Immediatelyflusheyeswithadirectedstreamofwaterfor
atleast15minutes,forciblyholdingeyelidsaparttoensurecomplete
irrigationofalleyeandlidtissues.Washingeyeswithinseveralsecondsis
essentialtoachievemaximumeffectiveness.GETMEDICALATTENTION
IMMEDIATELY.
ii. SkinContact:Immediatelyflushcontaminatedareaswithwaterfroma
safetyshower.Removecontaminatedclothing,jewelry,andshoes
immediately.Washtheaffectedskinfor15minutes.Iftheeyeshavenot
beenexposeddonotremoveyourgogglesuntilyourheadandhairhas
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beenthoroughlyrinsed.Washcontaminatedareaswithsoapandwater.
Thoroughlycleananddrycontaminatedclothingbeforereuse.Discard
contaminatedleathergoods.GETMEDICALATTENTIONIMMEDIATELY.
iii. Inhalation:Ifadverseeffectsoccur,removetouncontaminatedarea.Give
artificialrespirationifnotbreathing.Ifbreathingisdifficult,oxygen
shouldbeadministeredbyqualifiedpersonnel.Ifrespirationorpulsehas
stopped,haveatrainedpersonadministerbasiclifesupport(Cardio
PulmonaryResuscitation/AutomaticExternalDefibrillator)andCALLFOR
EMERGENCYSERVICESIMMEDIATELY.
iv. Ingestion:Nevergiveanythingbymouthtoanunconsciousorconvulsive
person.Ifswallowed,donotinducevomiting.Givelargeamountsof
water.Ifvomitingoccursspontaneously,keepairwayclear.Givemore
waterwhenvomitingstops.GETMEDICALATTENTIONIMMEDIATELY.
v. NotestoPhysician:Theabsenceofvisiblesignsorsymptomsofburns
doesNOTreliablyexcludethepresenceofactualtissuedamage.
Probablemucosaldamagemaycontraindicatetheuseofgastriclavage.
f. StabilityandReactivity
i. Reactivity/Stability:Stableatnormaltemperaturesandpressures.
ii. ConditionstoAvoid:Mixingwithwater,acidorincompatiblematerials
maycausesplatteringandreleaseoflargeamountsofheat.Willreact
withsomemetalsformingflammablehydrogengas.
iii. SodiumHydroxidereactswithSTRONGACIDS(suchasHYDROCHLORIC,
SULFURICandNITRIC);WATER;torapidlyreleaseheat.
iv. SodiumHydroxidereactswithMETALS(suchasALUMINUM,LEAD,TIN
andZINC)toformflammableandexplosiveHydrogengas.
v. SodiumHydroxidecanformshocksensitivesaltsoncontactwith
NITROGENCONTAININGCOMPOUNDS(suchasNITROMETHANE).
vi. SodiumHydroxideisnotcompatiblewithOXIDIZINGAGENTS(suchas
PERCHLORATES,PEROXIDES,PERMANGANATES,CHLORATES,NITRATES,
CHLORINE,BROMINEandFLUORINE);CHLORINATEDSOLVENTS;
AMMONIA;andORGANICMATERIALS.
g. AccidentalReleases
i. Evacuatepersonnelandsecureandcontrolentrancetothearea.
ii. Wearappropriatepersonalprotectiveequipmentrecommendedin
section4below.
iii. Completelycontainspilledmaterialwithdikes,sandbags,etc.
iv. Vacuumupforreuseordisposal.
v. Carefullydiluteremainingmaterial
vi. Neutralizewithweakacid(aceticacid)ifnecessary.

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vii. Accidentalreleasestotheenvironmentmaytriggerreporting
requirementstofederal,stateandlocalauthoritiesifthresholdlimitsare
exceeded.ThethresholdlimitforCausticSodais1,000lbs.
viii. IntheU.S.,spillreportstotheNationalResponseCenter(1800424
8802)willcomplywithfederalreportingrequirementsunderCERCLAand
SARAregulations.TheCoastGuardmayalsoneedtobenotifiedunder
theCleanWaterAct.
ix. Ifemployeesarerequiredtocleanupspills,theymustbeproperly
trainedandequipped.TheOSHAHazardousWasteOperationsand
EmergencyResponseStandard(29CFR1910.120)mayapply.
h. FireEmergency
i. FireHazard:CausticSodaisnotflammable
ii. ExtinguishingMedia:Usemediaappropriateforsurroundingfire.
iii. FireFighting:Movecontainerfromfireareaifitcanbedonewithoutrisk.
Coolcontainerswithwater.
iv. Ifemployeesareexpectedtofightfires,theymustbetrainedand
equippedasstatedintheOSHAFireBrigadesStandard(29CFR
1910.156).

4. PROTECTIVEMEASURES

a. PersonalProtectiveEquipment
i. EyeProtection:Wearchemicalsafetygoggleswithafaceshieldto
protectagainsteyeandskincontactwhenappropriate.Providean
emergencyeyewashfountainandquickdrenchshowerintheimmediate
workarea.
ii. SkinandBodyProtection:Wearchemicalresistantclothingandrubber
bootswhenpotentialforcontactwiththematerialexists.Contaminated
clothingshouldberemoved,thendiscardedorlaundered.
iii. HandProtection:Wearappropriatechemicalresistantgloves
iv. ProtectiveMaterialTypes:Naturalrubber,Neoprene,Nitrile,Polyvinyl
Chloride,Viton
v. RespiratoryProtection:ANIOSHapprovedrespiratorwithN95(dust,
fume,mist)cartridgesmaybepermissibleundercertaincircumstances
whereairborneconcentrationsareexpectedtoexceedexposurelimits,
orwhensymptomshavebeenobservedthatareindicativeof
overexposure.Ifeyeirritationoccurs,afullfacestylemaskshouldbe
used.Arespiratoryprotectionprogramthatmeets29CFR1910.134must
befollowedwheneverworkplaceconditionswarrantuseofarespirator.

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Wherethepotentialforhighexposureexists,suchascleaningstorage
tanks,useaNIOSHapprovedsuppliedairrespiratorwithafullfacepiece
operatedinapressuredemandorotherpositivepressuremode.For
increasedprotectionuseincombinationwithanauxiliaryselfcontained
breathingapparatusoranemergencyescapeaircylinder.
b. OtherProtectiveMeasures
i. Eyewashfountainsshouldbelocatednearallcausticsodahandlingareas.
ii. Safetyshowersshouldbelocateddirectlyabovetheeyewashfountains.
iii. Eyewashandsafetyshowersshouldbedesignedtocomplywith29CFR
1910.151(c)MedicalServicesandFirstAid.
iv. DikingabletocontaintheentirevolumeofCausticSodainthesystem
shouldbeinstalled.

5. REGULATIONSAPPLICABLETOCAUSTICSODA

a. PrivatesectorworkersinNewJerseyarecoveredbyFederalOSHA.
b. 29CFR1910.1200HazardCommunicationStandardrequiresthatemployees
beinformedofchemicalhazardsintheirworkplace.Somehighlightsofthe
standardfollow:
i. Employersmustdevelopandimplementawrittenhazardcommunication
programandmakethatprogramavailabletoemployees.
ii. Theprogrammustlistallhazardouschemicalsknowntobeinthe
workplaceandtellemployeesaboutnonroutinetasks(suchascleaning
outtanks)thatmightexposethemtothehazardouschemicals.
iii. Containersofhazardouschemicalsmustbelabeled.Thelabelmust
identifythechemical,itsmanufacturerandappropriatehazardwarnings.
Employeesmustbetrainedtoreadsuchlabels.
iv. Employersmusthaveamaterialsafetydatasheet(MSDS)foreach
hazardouschemicalinitsworkplace.TheMSDSmustinclude(among
otherthings)theidentityusedonthecontainerlabel;commonnameand
namesofchemicalingredientsinthehazardouschemical;physicaland
chemicalcharacteristics(suchasvaporpressureandflashpoint);physical
hazards(suchaspotentialforfire,explosionandreactivitytoother
substancesthatareincompatible);healthhazards(suchassignsand
symptomsofexposure);howthechemicalcanenteryourbody;
permissibleexposurelimits;whetherthechemicalwillcausecancer;
precautionsforsafehandlinganduse(includingprotectivemeasures);
emergencyandfirstaidprocedures;whentheMSDSwaspreparedorlast
changed;thenameandtelephonenumberofthemanufacturerorother

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sourcethatcanprovideadditionalinformation(includingemergency
procedures).
v. TheMSDSsmustbereadilyaccessibletoemployeesduringeachwork
shift.Employeesmustbetaughttousethem.
vi. Employeesmustbeinformedofthelocationofhazardouschemicals.
vii. Employeesmustbetrainedinhowtodetectthepresenceofahazardous
chemical;itshealthhazards;andprotectivemeasures(includingwork
practices,personalprotectiveequipmentandemergencyprocedures).
c. EPCRASection311312EmergencyPlanningandCommunityRighttoKnowAct
of1986appliestoanyfacilityatwhichahazardouschemical,asdefinedbythe
OccupationalSafetyandHealthAct,ispresentinanamountexceedinga
specifiedthreshold.ThethresholdforCausticSodais10,000lbs.Suchafacility
mustsubmitamaterialsafetydatasheet(MSDS)foreachhazardouschemical
whichmeetsorexceedsaspecifiedthresholdquantityatthefacility,tothestate
emergencyresponsecommission,theLocalEmergencyPlanningCommittee,and
thelocalfiredepartmentwithjurisdictionoverthefacility.Reportingthresholds
arecodifiedin40CFR370.10.
d. CERCLASECTIONS102a/103ComprehensiveEnvironmentalResponse,
Compensation,andLiabilityActof1980Accidentalreleases
i. CERCLAReportableQuantityforCausticSoda:1,000lb.(note:thisiswell
belowtheprojectedweeklyuse).
ii. IfareleaseisreportableunderCERCLAsection103,notifytheNational
ResponseCenterat(800)4248802or(202)4262675.TheCoastGuard
mayalsoneedtobenotifiedundertheCleanWaterAct.
e. 29CFR1910.120OSHAHazardousWasteOperationsandEmergencyResponse
Standard(HazWOPER)
i. Thisstandardappliestoemergencyresponseoperationsforrelease,or
substantialreleasethreat,ofhazardoussubstanceswithoutregardto
locationofthehazard.
ii. CertainrequirementsmustbecompliedwithundertheHazWOPER
standard.Theserequirementsincludeawrittenemergencyresponse
plan,training,controlandcleanup.
iii. EmergencyResponsePlanmustaddressthefollowing:
a. preemergencyplanningandcoordinationwithoutside
respondingagencies,i.e.,fire,EMS,police,etc.;
b. personnelroles,linesofauthorityandlinesofcommunication;
c. emergencyrecognitionandprevention(whatconstitutesan
emergencyandhowtopreventtheoccurrence);
d. safedistancesandplacesofrefuge;
e. sitesecurityandcontrol;
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f. evacuationroutesandprocedures;
g. decontaminationprocedures;
h. emergencymedicaltreatmentandfirstaid;
i. emergencyalertsandresponse;
j. personalprotectiveequipmentandemergencyequipment;
k. engineeringcontrols;
l. airmonitoring
m. critiqueofresponseproceduresandfollowup.
iv. Trainingrequiredforanyemployeewhorespondstoanemergency.
SectionQofthestandardspecifiesthetrainingrequirements.Theyare
brokendowninto5levelsthataretiedtospecificduties.
a. Level1:FirstResponderAwareness
b. Level2:FirstResponderOperations
c. Level3:HazardousMaterialsTechnician
d. Level4:HazardousMaterialsSpecialist
e. Level5:OnSiteIncidentCommander
v. ControlandCleanup
AtleasttwoLevel2techniciansarerequiredtoslowandcontrola
hazardousspillasspecifiedin29CFR1910.120(HazWOPER),which
mandatesabuddysysteminthesecircumstances.Additionally,atrained
Level5IncidentCommandermustbepresent.
Oncethespilliscontained,itmustbestoppedatthesource,cleanedup
anddisposedofproperly.
f. 29CFR1910.156OSHAFireBrigadesStandard
Ifemployeesareexpectedtofightfires,theymustbetrainedandequippedin
accordancewiththeFireBrigadesStandard.
g. 29CFR1910.132PersonalProtectiveEquipmentGeneralrequirements
requiresprotectionforemployeeseyes,face,headandextremitiesinthe
presenceofhazardsthatrequiresuchprotection,including,butnotlimitedto,
chemicalhazardsandhazardsencounteredthroughabsorption,inhalationor
physicalcontact.
h. 29CFR1910.133PersonalProtectiveEquipmentEyeandfaceprotection
requiresprotectionagainstliquidsandotherhazardstotheeyesandface.
i. 29CFR1910.134PersonalProtectiveEquipmentRespiratoryprotection
includes(amongotherpertinentsubjects)theselection,fittingandcarefor
respiratorsandinstructionstoemployeesabouttheuseofrespirators.The
employershallberesponsiblefortheestablishmentandmaintenanceofa
respiratoryprotectionprogramwithrequiredworksitespecificproceduresand
elementsforrequiredrespiratoruse.Theprogrammustbeadministeredbya
suitablytrainedprogramadministrator.
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j.

29CFR1910.151(c)MedicalServicesandFirstAidrequiressuitablefacilities
forquickdrenchingorflushingoftheeyesandbodyintheworkareafor
immediateemergencyuse,wheretheeyesorbodyofanypersonmaybe
exposedtoinjuriouscorrosivematerials.

6. RISKASSESSMENT
CausticSodafallsunderthecategoryofHazardousSubstanceaccordingtoOSHAs
HazardCommunicationStandard,29CFR1910.1200.Itwasprojectedthat
approximately37,000gallonsof50%CausticSodasolutionperweekwouldbeutilized.
Thisquantityisequivalentto447,700lbs.ofsolutionweightor223,850lbs.Caustic
Sodadryweight.Anoffsettothehazardsinvolvedintheuseofthissubstanceinthis
particularapplicationisthefactthatthescrubbingsystemconsistsofaclosedloop
mode,whicheliminatespotentialemployeeexposuretosplashingoftheliquidand
aerosolformationundernormalconditionsofoperation.However,CausticSodawillbe
directlyhandledbyemployeesinvolvedwithunloadingtanktrucks,bunkeringareas,
tanks,soundingpipes,feedmoduleandbleedofftreatmentunits.Additionally,
potentiallygreaterexposuretocausticsodaisprobableforemployeeschargedwiththe
taskofcleaningstoragetanks.Itisconceivablethatsuchanactivitycouldproduce
significantcausticsodaaerosolinhalationexposure.

7. RISKMANAGEMENT
Basedontheriskassessmentofthevariousconditionsdefinedinsection6,the
followingriskmanagementmeasuresarerecommended:
a. Trainingonthesafehandlingofthematerialmustbegiventoeveryemployee
involvedinthehandling,storageanduseofthematerial.
b. Periodicsurveillanceofthestoragetanks,fittings,pipingandconnectionsfor
evidenceofwearisrequired.
c. Safetyshowersandeyewashesshouldbeconvenientlylocatedandreadily
accessiblenearallareaswhereCausticSodawillbehandled.
d. Safetyshowersandeyewashesshouldbeclearlymarkedwithdedicatedsigns.
e. Thefollowingpersonalprotectiveequipmentmustbewornwhenhandling
CausticSoda;
i. Closefittingsafetygogglesandchemicalresistantgloves
ii. Additionalclothingandequipmentmayberequired.Ajobsafetyanalysis
foreachtaskinvolvingdirecthandlingofCausticSodaneedstobe
conductedtodeterminetheproperpersonalprotectiveequipmentfor
thetaskbeingperformed.Theseriskmanagementoptionsinclude:
a. Hardhat
b. Chemicalresistantapron
c. Fullfaceshield(inadditiontoclosefittingsafetygoggles)
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d. Chemicalresistantboots
e. Chemicalprotectivesuit(jacketandpants)
f. Fullchemicalprotectivesuitwithhoodandairsuppliedrespirator

8. RESIDUALRISKSUMMARY
BasedonthenatureofCausticSodasolutionhazards,itsuseintheclosedloop
scrubbingsystemandselectionofappropriateriskmanagementtools,itcanbe
concludedthattherisktoworkersandtheenvironmentcanbeclassifiedasminimal.

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APPENDIX IV
RESOURCE DISK
Available as a Separate Submittal