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DESIGN SAFETY

Engineering Design for Safety:


PETROCHEMICAL
PROCESS PLANT
DESIGN
CONSIDERATIONS By MARK D. HANSEN

I
t’s Monday morning. You’re sitting in your office drinking a cup of coffee. It’s quiet
and peaceful. The company president strolls in and you exchange stories about the
weekend’s activities. Nonchalantly, he asks, “Based on what you know, what would
you do if you had the opportunity to design a brand new facility?” You pause,
knowing there isn’t an infinite supply of money, and ask, “What’s my budget?”
“Enough to do the really important things,” he responds.
The opportunity to innovatively design-in an inherently safe workplace and design-out
hazards doesn’t come along every day. It’s a process that requires much research and fore-
thought. Before embarking on such an effort, the design team must determine the level of
acceptable risk; identify the budget available so that funds will be spent wisely; identify
applicable standards; research historical data from management of change (MOC) proce-
dures, process hazard analyses (PHAs) and pre-startup safety reviews (PSSRs) to identify
items that can be designed out; and review incident/accident investigation reports that have
identified root causes and outlined engineering changes implemented to prevent recurrence.

20 PROFESSIONAL SAFETY AMERICAN SOCIETY OF SAFETY ENGINEERS


SETTING THE STAGE five percent of the total budget (in this sectional valves and hydrants. In addition,
One of the most important steps in this case, $1 to $5 million). This allocation the following factors should be considered.
process is to determine the level of would include all safety-related sys- •Size underground piping and pumps
acceptable risk. Risks can be evaluated tems—from fire water systems to control to handle two adjacent incidents.
qualitatively and/or quantitatively. room design. Using the dollar value of •Loop mains should not be less than
Qualitative risk analysis is the most PHAs, MOCs, PSSRs and incident/acci- eight inches in diameter.
widely used method. The risk matrix is a dent recommendations can provide cost •Use electrically driven fire pumps
common approach (Figure 1). Although justification for this budget. Engineering with 100-percent diesel backup.
based on intuitive reasoning and the economy principles can facilitate cost-jus- •Site fire pumps at two locations.
engineer’s experience, this technique can tification exercises, while sales and profit •Design the overall system to work
help determine the relative risk of each margin data can illustrate cost avoidance for a minimum of eight hours at full
incident scenario and identify risk-reduc- (Table 7). This budget also includes use of capacity, with additional capacity at
tion methods. The objective is to deter- economies of scale, such as using similar reduced rates.
mine how the severity and/or frequency equipment for alarm systems, firefighting Design Criteria
of identified hazards can be mitigated. equipment and gear, and operating pro- •NFPA 24, Installation of Private Fire Service
For example, installing water spray sys- cedures and training systems. Mains and Their Appurtenances
tems, reducing hazardous material in- •NFPA 20, Installation of Centrifugal Fire Pumps
ventory or improving flare system design RESEARCH APPLICABLE STANDARDS •NFPA 14, Installation of Standpipe and Hose
can help reduce risk from high to moder- Researching applicable design stan- Systems
ate or moderate to low. dards for recommended guidelines and
Quantitative risk analyses are per- criteria is a challenge. Myriad standards Electrical Reliability
formed using engineering techniques and may be involved—ranging from those Electrical power service design for a
computer models that analyze an incident developed by American National Stand- process unit should include:
scenario in order to determine its impact. ards Institute (ANSI) and American Petro- •dual primary service feeds with two
Such analyses assess what damage may leum Institute (API), to those promulgated main breakers and a tie breaker with
occur from a fire, explosion and/or toxic by National Fire Protection Assn. (NFPA) power drawout main;
release and how frequently it will occur. and American Society for Testing and •tie and feeder distribution panel
Potential impacts (e.g., fatalities, injuries, Materials (ASTM). To facilitate this proc- breakers;
equipment loss, environmental damage) ess, sample design recommendations and •automatic transfer system for main
are systematically estimated to determine criteria follow. and tie breakers, with capability for man-
an incident’s magnitude and severity. ual transfer;
The level of acceptable risk must be Process Area Layout •emergency power generation or bat-
weighed against historical information The use of “inherently safe” practices tery system with uninterruptable power
regarding similar incidents within the should be incorporated early in the de- supply that can provide for safe shut-
industry. For example, several serious sign process. Standard siting practices in- down of the process.
incidents—causing considerable human clude the following. Locations that require classified elec-
casualties and large property losses— •Provide good access to all areas by trical installations should be identified
have occurred in the last 15 years, leading wide-surface roads that form a gridded according to Article 500 of the National
to greater attention being focused on network; this permits firefighting from Electrical Code (NEC). This code also
facilities that use, manufacture, store or any side. specifies the class and group of equip-
handle highly hazardous materials. •Locate heaters and fired equipment ment required in those areas. Conduit
If one examines the impact of several upwind (based on prevailing winds) of seals must also be installed as outlined.
recent incidents in the process and refin- process equipment.
ing industries (as summarized in Tables 1 •Point horizontal tanks away from Cable Trays
through 6), the significant financial losses equipment or occupied buildings. Where possible, cable trays should be
and business interruption costs caused by •Buildings designed to house flam- routed away from potential fire exposures.
such accidents become clear. As these mables should be open structures. Installations should be located so as to
data show, one can cite myriad reasons to •Locate process areas at least 150 feet allow ready access for repair or removal.
design-in safety and design-out hazards. from tankage and utility areas. Other key design features:
•Locate flare stacks at least 175 feet •Run power and instrument cables in
DETERMINING THE BUDGET downwind of any floating roof tanks. separate trays.
Another key step is to identify the •Locate all service buildings outside •Locate cable trays above pipeways
overall budget for constructing the new potential blast areas when feasible. and take measures to prevent them from
facility. For example, suppose the budget being used to support other equipment.
is $200 million; assume that this total Fire Water System •Protect trays that traverse high-poten-
includes the costs of material, labor, prop- Fire water should be supplied to each tial fire areas either by fireproofing, or with
erty, permitting, engineering drawings process block and tank farm from a grid- flame shields or water spray systems.
and documentation. ded fire main system. This system should •At cable penetrations, select a UL-
With all costs included, the safety bud- be installed according to applicable NFPA listed fire seal whose rating is at least
get should be (as a general rule) one to standards and have many well-located equivalent to the wall rating.
JANUARY 2000 21
One of the most important steps in this
process is to determine the level
of acceptable risk.
•Ensure that cable jackets satisfy UL- •horizontal and vertical pipe rack E-84) materials for stacks, louvers, fill,
1277 flame test. supports up to at least the first level. drift eliminators and sheathing.
Design Criteria A three-hour-rated protection should •Provide a minimum fire break sepa-
•NFPA 70, NEC Articles 318 and 500 be provided on all steel structures and ration of 50 feet from process areas.
•API 2030, Guidelines for Application of Water equipment supports; a one-hour-rated •Provide combustible gas detectors.
Spray Systems protection should be provided on cabling •Provide lightning protection (con-
•API 2218, Fireproofing Practices in Petroleum and piping supports. nected to a grounding system) on cooling
and Petrochemical Processing Plants Design Criteria towers located in fields not surrounded
•API 2218, Fireproofing Practices in Petroleum by taller buildings or structures.
Fireproofing and Petrochemical Processing Plants Design Criteria
Fireproofing should be provided on all •NFPA 214, Standard on Water-Cooling Towers
load-bearing structural steelwork to full Cooling Towers
height, including fin-fan support struc- A pre-design assessment should be Fire Suppression Systems
tures. This protection should cover: performed to identify the business inter- An integrated system of hydrants,
•exterior vessel support skirts, legs, ruption exposure presented by loss of a monitor nozzles and water spray systems
lugs and anchor rings; cooling tower. Based on results, cooling should be installed within each process
•interior skirt surfaces if flanges or towers that are constructed of com- unit to support both automatic and man-
valves are located inside skirt or if the po- bustible materials or containing com- ual firefighting efforts. The location and
tential for updrafts exists within the skirt; bustible fill materials should be protected concentration of monitor nozzles and
•horizontal members and cross-brac- in the following ways. water spray systems depends on the
ing (if load-bearing); •Utilize low-flame spread (per ASTM degree of unit congestion, nature of haz-

FIGURE 1 Risk Matrix


Probability of Success A. Frequent (1) B. Probable (2) C. Occasional (3) D. Unlikely (4)
Event likely to occur Event likely to occur Event likely to occur once Event unlikely
Category once or more per year once every several years in a facility’s lifetime but not impossible

I. Catastrophic (1)
Personnel: life-threatening
Environment: large, uncontrolled
release 1 2 3 4
Equipment: major damage resulting
in loss of unit

II. Critical (2)


Personnel: severe injury
Environment: moderate, uncontrolled
release 2 4 6 8
Equipment: moderate, resulting in unit
downtime

III. Marginal (3)


Personnel: lost-time injury
Environment: small, uncontrolled
release 3 6 9 12
Equipment: minor damage resulting in
unit slowdown

IV. Negligible (4)


Personnel: minor injury
Environment: small, controlled release
4 8 12 16
Equipment: negligible damage

High: Requires Action Moderate: Further Study Required Low: Investigate as Time Permits

22 PROFESSIONAL SAFETY
TABLE 1 Review of Serious Industrial Losses
INCIDENT IMPACT
Baton Rouge, LA – December 1989 $43 million damage; damage to off-
Refinery pipeline rupture site houses
Pasadena, TX – October 1989 $500 to $725 million damage;
Petrochemical – Vapor cloud explosion severe business interruption
St. Croix, Virgin Islands – September 1989 $60 million damage; extensive
Refinery (Hurricane Hugo) damage to storage tanks •Dike tanks individually. Where mul-
Martinez, CA – September 1989 $50 million damage, massive tiple tanks are contained within a single
Refinery – H2 and hydrocarbon release firefighting effort dike, an intermediate curb (minimum of
18 inches) should be provided between
Morris, IL – June 1989 $41 million damage; 40 acres of individual tanks.
Petrochemical – Vapor cloud explosion plant damaged Design Criteria
Richmond, CA – April 1989 $90 million damage; two years to •NFPA 30, Flammable & Combustible Liquids
Refinery - H2 gas fire repair plant Code
Antwerp, Belgium – March 1989 $77 million damage; business Process Pumps
Petrochemical – Column exploded interruption of $267 million These guidelines should be observed
when installing process pumps that han-
ards involved and types of equipment to •Locate monitors at least 50 feet from dle flammable/combustible liquids.
be protected. General design guidelines the nearest hazard or use motor-operated •Pumps should have double mechan-
include the following. remote-controlled devices. ical seals, with compatible barrier fluid.
•Provide fixed monitor coverage so •Install water spray systems over ves- •Pumps should be located outside
that process areas which require protection sels, pumps and compressors that han- containment dikes.
can be reached by two monitor streams. dle/store: •Water spray protection should be
•Set design radius for the monitor •flammable or combustible liquids provided over critical pumps; such pro-
streams at 81 feet. above 500ºF or their auto-ignition tection should activate automatically
temperature; through the temperature and/or flamma-
TABLE 2 Loss Trends •flammable or combustible liquids ble gas detection systems.
5-Year Intervals at greater than 500 psi; Design Criteria
PERIOD NUMBER LOSSES •liquefied flammable gas. •NFPA 15, Water Spray Fixed Systems for Fire
•Perform modeling of fire water Protection
OF LOSSES ($BILLIONS) system performance to ensure that ade-
59-63 6 0.15 quate water supply, pump pressure and Emergency Isolation Valve
64-68 13 0.48 flow rates are available to provide cover- An emergency isolation valve (EIV) is
69-73 24 0.51 age needed. a protective device that isolates piping or
74-78 30 1.18 Design Criteria equipment in the event of a dangerous
•NFPA 15, Water Spray Fixed Systems for Fire situation. It should provide automatic as
79-83 45 1.29
Protection well as remote actuation by one of the fol-
84-88 32 1.54 •NFPA 11, Standard for Low-Expansion Foam lowing methods:
and Combined Agent Systems •air, nitrogen or hydraulic pressure to
TABLE 3 Loss Distribution •API 2030, Application of Water Spray Systems open with spring to close; air or nitrogen
Type of Complex for Fire Protection in the Petroleum Industry connection to the EIV should be made
OPERATION PERCENT LOSSES with a melt-out tubing so that it functions
Drainage and Diking as a fusible link;
($MILLIONS) Unit drainage system should slope •heat-actuated with spring to close;
Refineries 40 40.1 from the center of the process unit to •pneumatic operation;
Petrochemical 17 34.4 perimeter trenches and/or impound- •electrically operated.
Terminals 13 25.8 ment basins. Other key guidelines: Other guidelines:
Plastics/Rubber 9 23.8 •Ensure that paved surfaces have •Ensure that all components of the
Chemical 8 18.5 at least 1 percent slope (2 percent for EIV assembly can withstand 15 minutes
Natural Gas 7 52.2 unpaved surfaces). of fire exposure.
Pipelines 2 45.6 •Grade paving away from pipe •Provide an alternate power supply
Miscellaneous 4 24.6 racks. where necessary.
•Where feasible, remote im- •Ensure that pneumatic EIVs have
TABLE 4 Cause of Losses pounding should be located 50 sufficient air for two valve strokes; they
feet away with good drainage; should also have a dedicated emergency
CAUSE PERCENT LOSSES this is preferred to diking. reservoir for closing.
($MILLIONS) •Slope surfaces within dikes for •Label EIV controls, which should be
Mechanical Failures 41 36.0 at least five feet or to the tank wall, operable from the control room and from
Operational Error 19 38.6 whichever is less. a safe location.
Unknown 17 25.9 •Design diking/containment •Locate EIVs as close as possible to
Process Upset 10 40.7
systems to handle the largest spill vessel/equipment flanges.
potential plus the associated fire- •Make provisions that allow for on-
Natural Hazard 5 43.2
water load. Minimum system line testing without process disruption.
Design Error 4 60.5 capacity should be 110 percent of EIVs should be located:
Sabotage/Arson 4 19.0 the largest vessel volume. •at battery limit of production units;
JANUARY 2000 23
TABLE 5 Equipment Involved in Cause
EQUIPMENT PERCENT LOSSES
($MILLIONS)
Piping 31 41.9
Tanks 17 40.5
Reactors 13 28.5
Miscellaneous 9 34.7
Process Drums 7 25.5
•Ensure that the enclosure is •around furnaces and compressors;
Marine Vessels 6 32.0 positively pressurized to 0.10 •above hydrocarbon pumps;
Unknown 5 25.0 inches of water. •at main unit sewer outlet.
Pumps 5 19.2 •Locate the air inlet for the Design Criteria
Heat Exchanger 3 24.0 ventilation system above the •NFPA 70, National Electrical Code
Process Towers 3 53.8 building. •ANSI/ISA-RP 12.13, Part II, Installation, Opera-
Heaters/Boilers 1 28.8 •Install self-closing external tion and Maintenance of Combustible Gas
doors that have the same pres- Detectors
sure resistance as the control
TABLE 6 Ignition Source room walls. Fixed Vibration Monitoring
•Blastproof criteria should be A pre-design assessment should be
SOURCE PERCENT LOSSES designed for life safety to with- conducted on each piece of rotating
($MILLIONS) stand the following overpres- equipment that will be installed to deter-
Unknown 53 38.5 sure loadings: 10 psi for 20 mine the potential for business interrup-
Open Flame 12 32.0 milliseconds; 3 psi for 100 mil- tion exposures created by loss of such
Chemical Reaction 9 26.0 liseconds. equipment. The assessment should also
Electrical Equipment 5 16.5 Design Criteria consider the potential for a life-threaten-
Internal-Combustion •API 2510, Design and Construction of ing situation or serious environmental
6 49.0
Engine LPG Installations impact. Based on results, such equipment
Auto-Ignition 4 34.1 •FM Data Sheet 7-45S, Process Control should be fitted with fixed vibration
Lightning 3 39.1 Houses monitoring. It should be noted that while
Hot Surface 3 39.4 equipment designated as critical tends to
Smoke Detection Systems have high horsepower (> 500 hp), the hp
No Ignition 3 18.7
Smoke or heat detectors by itself is not a prerequisite for criticality.
Sabotage/Arson 2 43.5 should be installed in the follow- Design Criteria
Static 1 14.5 ing areas: control rooms; MCC •API 670, Vibration, Axial Position and Bearing
Cutting/Welding 1 16.0 rooms; battery rooms; below Temperature Monitoring Systems
raised floors with significant •API 678, Accelerometer-Based Vibration
•around all critical process equipment runs of cable; online process analyzer Monitoring Systems
(e.g., reactors, furnaces); buildings/sheds; and gas turbine houses.
•where inventories of flammable or All site alarms should be routed to the Storage Tanks
combustible liquids in a single vessel or control room. The design of atmospheric (up to 0.5
interconnected vessels exceed 10,000 gal- Design Criteria psig) and low-pressure (up to 15 psig) stor-
lons (including storage areas); •NFPA 72E, Standard on Automatic Fire Detectors
age tanks should conform to referenced
•where inventories of liquefied flam- API standards. High-pressure vessels
mable gases in a single vessel or intercon- Combustible Gas Detection should be designed according to the ASME
nected vessels exceed 1,300 gallons Combustible gas detectors should be Boiler and Pressure Vessel Code. Protec-
(including storage areas). located near rotating equipment and in tion, level alarms and tank spacing should
Design Criteria other areas that may contain significant conform to the following guidelines.
•API 2510, Design and Construction of LPG quantities of flammable liquid and •Locate storage areas at least 150 feet
Installations hydrocarbon vapor. Specific locations from other hazardous areas. Recom-
may include: mended tank-to-tank separation criteria is:
Control Room Design •control room intake, interlocked to <10,000 barrels (bbls) = 0.5 diameter
As part of the initial design phase, the shut down the ventilation system at 25 10,000 to 50,000 bbls = 1.0 diameter
team should consider locating the control percent LEL; >50,000 bbls = 1.5 diameter
room away from potential blast areas, •near exchangers, reactors and dryers; 250,000 bbls = special consideration
based on applicable modeling. If not feasi- •around storage and process drums; •Equip those tanks that store more
ble, these guidelines than 25,000 gallons
should be followed.
TABLE 7 Sales Required to Cover Losses of Class 1 flammable
•Take steps to en- Yearly Incident Profit Margin liquids with indepen-
sure that all materials Costs 1% 2% 3% 4% 5% dent high (HLA)
of construction are $1,000 100,000 50,000 33,000 25,000 20,000 and high level alarm
non-combustible. 5,000 500,000 250,000 167,000 125,000 100,000 (HHLA) systems. The
•Provide hydrocar- 10,000 1,000,000 500,000 333,000 250,000 200,000 alarms should signal
bon and toxic gas de- 25,000 2,500,000 1,250,000 833,000 625,000 500,000 at 30 and 15 minutes,
tection on return-air 50,000 5,000,000 2,500,00 1,667,000 1,250,000 1,000,000
respectively, prior to
intake. It should be overfill based upon
100,000 10,000,000 5,000,000 3,333,000 2,500,000 2,000,000
designed to alarm and the maximum pump-
shutdown ventilation 150,000 15,000,000 7,500,000 5,000,000 3,750,000 3,000,000 ing rate to a constant-
at 25 percent LEL. 200,000 20,000,000 10,000,000 6,666,000 5,000,000 4,000,000 ly attended location.
24 PROFESSIONAL SAFETY
As these data show, one can cite
myriad reasons to design-in safety
and design-out hazards.
Alarms should also be interlocked to per- emergency. To facilitate this, the control “Chemical Process Safety Management.”
mit pump and isolation valve shutdown. system should feature: Section 304, Clean Air Act Amendments of
•Install foam systems in all cone and •numerous terminal display units; 1990.
internal floating roof storage tanks. •reliable valve position indicators; The Environmental Protection Agency.
•Pipelines should incorporate all •software fault tolerance; “Prevention of Accidental Releases.” Section
welded construction in immediate sphere •built-in system redundancy and 301, paragraph 1, Clean Air Act Amend-
or tank areas. failover; ments of 1990.
•Locate the pumps outside the con- •programming capability for complex Guidelines for Hazardous Evaluation Pro-
tainment areas. control and shutdown actions; cedures. 2nd ed. New York: American
Institute of Chemical Engineers, 1992.
•Install and interlock remote-operated •installed hardware to permit on-
Guidelines for Technical Management of
isolation valves to allow actuation by the stream trip testing with final element and Chemical Process Safety. New York: Center for
fire/gas detection systems. shutdown testing. Chemical Process Safety, American Institute
Design Criteria of Chemical Engineers, 1989.
•API 650, Welded Steel Tanks for Oil Storage CONCLUSION Hawks, J.L. and J.L. Mirian. “Create a
•API 620, Design and Construction of Large, At first glance, this may seem like an Good PSM System.” Hydrocarbon Processing.
Welded, Low-Pressure Storage Tanks abundance of information and design cri- Aug. 1991.
•API 2021, Fighting Fires In and Around teria to monitor and incorporate. The Krembs, J.A. and J.M Connolly. “Analysis
Flammable and Combustible Liquid design team will likely reach a point of Large Property Losses in the Hydrocarbon
Atmospheric Storage Tanks where it may not be able to verify that and Chemical Industries.” Presentation at
•API 2510A, Design and Construction of LPG every minute detail has been designed 1990 NPRA Refinery and Petrochemical
Gas Installations into the new facility. At some point, the Plant Maintenance Conference.
•NFPA 11, Standard for the Installation of Low- engineering and design phase must stop Lees, F.P. Loss Prevention in the Process
Expansion Foam and construction must begin. Industries. London: Butterworth, 1980.
During the design stage, as the team “Large Property Damage Losses in
Pressure Relief Valves/Rupture Disks works through these tasks, it should view Hydrocarbon-Chemical Industries: A 30-
Design criteria for these valves/disks its mission as akin to eating an elephant. At Year Review.” 13th ed. New York: M&M
is detailed in the referenced API stan- Protection Consultants.
times, it may appear the team will never
dards. Although allowed by code, use of O’Lone, E.J. “Datapro, Document Imag-
finish. But each day, a bit more gets done,
rupture disks by themselves are discour- ing Systems, Management Issues.” Client/
until the project is complete. In the end, Server Computing. June 1993: 1-8.
aged in tanks that contain highly haz- these efforts will be rewarded by the satis- NUS Training Corp. “OSHA’s Process
ardous materials because they do not faction of knowing that potentially life- Safety Management of Highly Hazardous
close after opening; this may result in threatening hazards have been designed Chemicals in Plain English.” Gaithersburg,
continuing release of toxic materials to out, and safety has been designed in. 䡲 MD: NUS Training Corp., undated.
the atmosphere. Other key considera- Renshaw, F.M. “A Major Accident Pre-
tions in the area: REFERENCES vention Program.” Plant/Operations Prog-
•Provide redundancy for safety valves Alderman, J.A. “PHA-A Screening Tool.” ress. July 1990.
to permit on-line removal and testing. Presentation at 1990 Health & Safety Sherrod, R.M. and M.E. Sawyer. “OSHA
•Provide rupture disks with a positive Symposium. 1910.110 Process Safety Management: Its
means of detecting a failure or rupture, American Petroleum Institute. Manage- Effect on Engineering Design.” Presentation
through one of the following methods ment of Process Hazards. API Recommended at System Safety Conference, July 1991.
(listed in order of preference): Practice 750. Washington, DC: API, 1990.
•continuity check that constantly Bird, F.E. and G.E. Germain. Practical
monitors resistance across the disk; Loss Control Leadership. Atlanta: Institute
Publishing, 1990. Mark D. Hansen, P.E., CSP, CPE, is director, envi-
•excess flow valve, provided an envi- ronmental safety and health, for Weatherford
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International Inc., located in Houston. A profession-
•pressure gauge located down- ess Safety: A New Culture.” Presentation at
al member of ASSE’s Gulf Coast Chapter, he has
stream of the disk. Occupational Safety & Health Summit, more than 16 years’ experience in the field of safety.
Design Criteria 1992.
•API RP 520, Sizing, Selection and Installation of Dept. of Defense. System Safety Program
Requirements. MIL-STD-882C. Washington,
Pressure-Relieving Devices in Refineries
•API RP 521, Guide for Pressure-Relieving
DC: DOD, 1993. READER FEEDBACK
Dept. of Labor. “Process Safety Manage-
Systems ment of Highly Hazardous Chemicals, Did you find this article interesting
•NFPA 30, Flammable and Combustible Liquids Explosives & Blasting Agents.” 29 CFR and useful? Circle the corresponding
Code 1910.119. Washington, DC: U.S. DOL, Occu- number on the reader service card.
pational Safety & Health Administration,
Process Control 1992. YES 28
Hardware devices and software control E.I. duPont deNemours & Co. Process SOMEWHAT 29
systems should be able to provide safe, Risk Reviews Reference Manual. Wilmington,
efficient control under normal process con- DE: E.I. duPont, 1998.
NO 30
ditions, as well as a timely response in an The Environmental Protection Agency.

JANUARY 2000 25

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