KAISER
ALUMINUM
KAISER ALUMINUM & CHEMICAL CORPORATION

 

August 5, 1999



United States Coast Guard
Environmental Response Group
1615 Poydras, 7th Floor
New Orleans, LA 70012
Fax (504) 733-1820

Martin Briton
Steven Mason
United States Environmental Protection Agency
Region VI
1445 Ross Avenue
Suite 1200
Dallas, Texas 75202

Sir or Madam;

     Pursuant to 42 U.S.C. §9603, 33 U-S.C. §1321 and 40 C.FR §302.6, and in the spirit of full cooperation and disclosure, Kaiser Aluminum & Chemical Corporation (the "Company") hereby submits a supplemental report on the above-referenced incident. On the afternoon of July 5, 1999, a representative of the Company initially notified the National Response Center that a reportable quantity of sodium hydroxide (> 1000 lb.) might have been released to the environment at approximately 5:30 a.m. C.D.T. on that date as a result of an explosion in the Alumina Digestion Area at the Company's facility at 1111 Airline Highway, Gramercy, Louisiana.

     The company immediately began investigating the power failure which initiated the incident, and as soon as possible in the aftermath of the explosion, the Company began a further investigation. When Company representatives eventually gained access to inspect the damage, it appeared that some structures adjoining the Digestion Area might have contained asbestos-material (ACM). At approximately 10:00 am. C.D.T. on July 8, 1999, a company representative telephoned the NRC to provide additional information that an unknown quantity of friable asbestos (> 1 pound) might have been released at the site. This information was also provided by telephone directly to Mr. Mar-tin Briton and Mr. Steven Mason at U.S. EPA's Region VI office.

     The purpose of this report is to update information relating to the July 5 releases, based on the Company's current knowledge, best information and belief. This report is not intended to address the issue of the off-site impact of this incident , if any.

     While it is not yet possible to fully quantify the releases which resulted from the explosion, because federal and state authorities have limited access to affected areas, and because sampling and analytical efforts are incomplete, the Company now believes that:

     Without waiving any applicable legal privileges regarding the investigation conducted by and on behalf of Kaiser and its counsel Kaiser provides the above and the following information consistent with its and the governments' policies regarding voluntary reporting. It appears that the cause of the explosion was a power distribution interruption that caused process flow pumps to cease operating. This power interruption could not be remedied in a timely manner and resulted in an overpressure situation, and explosion, believed to have been initiated in the last sealed vessel (blow off tank) in the Digestion Area (which contains 14 sealed vessels connected in a series to input materials, react them and reduce pressure and temperature, while recycling heat and liquids as alumina is chemically extracted from the bauxite ore).

     The following conditions also were discovered by Kaiser's investigation: (1) a partial blockage of the 36-inch discharge pipe from the last sealed vessel (blow off tank) in the digestion process to the open top, relief tank; (2) flash tank pressure relief valves were "blocked in" (disengaged) prior to and at the time of the incident on flash tanks 6 through 9; (3) prior to and at the time of the incident flash tank 7 was operating at pressures above the pressure relief valve setting; and (4) an automatic steam input shut off valve to the bauxite slurry steam pump leading to the desilicator vessel (V#0) was discharged prior to and at the time of the incident, but was manually closed by an employee within minutes of the power failure.

     To the extent that any of these conditions might constitute a violation of any requirement of law, the Company is making this report of those potential violations under applicable statutory provisions and EPA's Final Policy Statement on Incentives for Self-Policing, 60 Fed. Reg. 66706 (Dec. 22, 1995) subsequent interpretive policy, and other, similar self-reporting guidelines. The Company discovered these conditions as a result of its voluntary due diligence in investigating the incident, which the Company initiated even before government investigators were on-site. The Company is reporting these potential violations without delay and will take corrective action within 60 days. If more time is needed the Company will apprise EPA and other agencies as soon as this fact becomes clear, in any case within 60 days of the date of this letter.

     The Company's investigation of the incident is continuing. We cannot predict at this time precisely how long the investigation will take or what conclusions will be reached, We intend to provide a detailed report to the agencies if significant new information is obtained. The Company also is cooperating fully with the Federal Mine Safety and Health Administration and other federal and state authorities having jurisdiction over the incident to develop and implement: a remediation plan and fully investigate the incident to prevent any future occurrences. We will update this report as warranted by the progress of the investigation and we would be glad to answer any questions or provide any additional information you may require.

 

Signature of              
William Kirsch
General Manager		 Sincerely,

Signature of              
Peter N. Bibko
Environmental Mgr.



cc: B. Farrier, LDEQ
      B J. Pritchard, LDEQ
      Ronald Mayeaux, Louisiana State Police
      L Ratliff, MSHA, I-cad Investigator
     Mark Melicki Esq., MSHA Solicitor's Office

_____________________________________________________

1Tentative conclusion based primarily on the following information and assumptions provided by Kaiser personnel about 180,000 gallons of bauxite slurry was present in digestion tanks and associated piping at the time of the incident; concentration of "free caustic" or NaOH in the slurry was about 3% (by weight); approximately 54,000 pounds Na0H released to the environment by the incident; although it appears that most NaOH was released to the curbed concrete lined process area, it would appear that some NaOH was released outside the curbed area

2 Tentative conclusion based upon pH monitoring and observations by Kaiser personnel and a consultant. As confirmed by the visual observation of Kaiser personnel and Tyler Ginn of the LDEQ, an earthen dam had been placed across the east ditch (as well as other drainage ditches) and contents were being pumped back into the surge lake within 2-3 hours after the incident.

3 Although a pH of about 10.1 was monitored just outside the process ditch, north of Airline Highway, no evidence of adverse impact attributable to a release of NaOH was noted by either Kaiser personnel or LDEQ observers(J. Myers and T. Ginn) suggesting no significant impact and that only a relatively small amount, if any, of NaOH had been released to the wetlands. The pH of 10. 1 can be attributed to naturally occurring algae, as has been observed in the past, and is not necessarily attributable to the incident.

4 Based primarily upon the following information and observations provided by Kaiser personnel: no release from the immediate Digestion Process Area resulted due to the incident because all ACM had been removed from Digestion Area tanks and associated piping, as part of an on-going asbestos abatement program well before the date of the incident. An indeterminate amount of ACM was observed to have become dislodged from equipment outside of the Digestion Area and released to the plant site. Although we do not know how much ACM was made friable after becoming dislodged, available information suggests that the amount released to the environment in the vicinity of equipment exceeded 1 pound. A detailed analysis is underway and additional information will be provided when it is available.