Update - Key Excerpts From 97 Pages of EPA Documents

KEY EXCERPTS FROM 97 PAGES OF EPA DOCUMENTS

Abstracted and compiled by Attorney William S. Daniel

June 24, 2005 1645 hrs: A five square-block area had been evacuated. Breached
gas cylinders and metal fragments had been sent through the air in all directions as
much as 900 feet from the facility in all directions. Several homes and off-site vehicles were impacted, and some small fires started, but no one was injured. The fire had started near a truck trailer holding cylinders of acetylene. These apparently exploded causing further explosions of cylinders of propane and propylene. More than one hundred additional acetylene cylinders which had not exploded were venting and burning through pressure relief fuse plugs, small holes hear the tops of the cylinders. The fire department was allowing these cylinders to burn out rather than extinguishing them, so that flammable vapors would not accumulate and create more explosions.

June 25, 2005: MDNR [Missouri Department of Natural Resources] returned to the site to tour the facility with a Praxair representative and the St. Louis Police Department Bomb and Arson Squad. This further confirmed that acetylene, propane and proplyene were the primary chemicals released. Acetone was also released as
it is mixed with the acetylene. Praxair also related that samples for asbestos had been collected. Apparently acetylene tanks contain a filler material that stabilizes the acetylene. It is primarily made up of calcium silicate, but sometimes can contain asbestos as a binder, especially in older cylinders. Praxair provided results as soon as they were available later that day. They indicated that asbestos was present. It is
probable that some of this material was deposited off site. Praxair hired Shaw Environmental and the Bellon Environmental Company for assessment and cleanup.

Background: Local emergency management personnel had issued an evacuation of
nearby businesses and residential areas due to smoke and potentially hazardous emission from the site.

Figure 2. The Praxair facility is an industrial gas supplier. Industrial gases include propane, nitrogen, helium, oxygen, acetylene, hydrogen, carbon dioxide and other specialty gases. Newswire photograph of Praxair facility showing boiling liquid expanding vapor explosion (BLEVE) of gas storage containers.

Some of the compressed cylinders were lined with asbestos-containing materials,
which were released to the environment during the incident.

there is a potential for a release that could cause adverse environmental or human health impacts.

There was a release of asbestos-containing materials to nearby residential properties, industrial facilities, streets, and parking lots.

A release of asbestos-containing materials to the environment occurred as a result of the fire at this facility.

The area where the asbestos-containing material was deposited is considered a
facility as defined by the NCP. A FACILITY is defined as any building, structure...or any site or area, where a hazardous substance has been deposited.

Asbestos is classified as a hazardous substance.

Concentrations of chrysotile asbestos up to 25% were detected in bulk samples from
debris originating from the site. DOES THE QUANTITY OR CONCENTRATION
WARRANT RESPONSE? YES X . [40 CFR 300.410(e)]

HAS A PRP [Potentially Responsible Party] BEEN IDENTIFIED? YES X
Praxair Distribution, Inc., has assumed liability for the incident and is coordinating
environmental cleanup activities in conjunction with the Missouri Department of
Natural Resources (MDNR).
Praxair Distribution Inc.
39 Old Ridgebury Road
Danbury, CT 06810-5113
1-800-PRAXAIR

There was a release of asbestos-containing materials to the area surrounding the Praxair facility.

Asbestos-containing materials are suspected to have been released to surface soils
near the site.

SUSPECTED RESPONSIBLE PARTY Organization: PRAXAIR COMPANY,
ST. LOUIS, MO.
2210 Chouteau Ave.
St. Louis, MO 63103-3009


Community Impact due to Material: YES

EVACUATIONS: YES Who Evacuated: EVERYONE

release of hazardous substances.

Release Began: 06.24.05 Time 15:14

Release Discovered: 06.24.05 Time 15:15

Release Ended: 06.24.05 Time 17:15

[Two (2) hours releasing hazardous substances]

Chemical Name: Asbestos Containing Materials

Physical State at Time of Release: Solid

Total Quantity of Chemical Released: 157,700 lbs.

Indicate the weather conditions at the time of the release. Temperature
(Fahrenheit): 93

Cloud Cover: Mostly sunny

The fire started in the back of the property in the flammable gas storage area.

Did any quantity of the released material migrate off the facility boundaries: Yes.

Are chemical(s) involved in this release included in any permit issued to the facility?
No.

The fire started in the flammable cylinder storage area in the yard of the plant.
Some acetylene cylinders which were involved in the fire exploded and released
their filler material. Some of the filler material, from older acetylene cylinders
(older than 1985) contains about 25% asbestos balance calcium silicate.

General Public Evacuated 4 blocks area around the plant
Indicate the environmental effects that occurred as a result of the release:
Vegetation damage
Soil contamination

The asbestos containing material is an integral part of the internal filler of acetylene cylinders. Under normal conditions of use and processing, there is no release or
exposure of this material to the public or to employees.

Primary product or service [of Praxair]: Repackaging and wholesale distribution of
the industrial gases Acetylene, Ammonia, Argon, Carbon Dioxide, Nitrogen, Propane,
and Propylene.

210,000 lbs. [is] the maximum amount, in pounds, of the released material that you
[Praxair] have on hand at any one time at your facility [so this June 24, 2005 incident released 157,700 pounds, which is 74.76% of the maximum amount that Praxair had on hand at any one time at its facility].

Did the released material reach a wastewater treatment plant? Yes.

formalized hazard evaluation was performed prior to this release at the process or
storage area within your [Praxair’s] facility where the accident occurred [back in]
Sep. 2003 [but] material release was not taken into consideration as the study’s criteria was primarily focused on releases of flammable gases resulting in fires and
explosions. [Per] Hassan Rahal, Manager of Environment and Health, Mississauga,
Ontario, Canada [and] Randall Brittingham, Division General Manager, August, 04,
2005 [who signed off on the Facility Certification].

24 June 2005 a large explosion and fire occurred at the Praxair facility located at
2341 Hickory, St. Louis, MO.

Figure 4. Historical Aerial Photo of Praxair facility [showing 2300 LaSalle Street
directly across the street to the immediate west of the Praxair facility].

Some compressed cylinders had burst and scattered flaming debris, igniting nearby parked automobiles, wooden fences, and yards. The force of the explosion had also
broken windows in nearby homes, and some of the scattered debris damaged walls
and fences at surrounding properties.

Also on site were...Praxair personnel and their response contractor, Phillips Environmental Services.

Following the fire, it was learned that some of the acetylene tanks had been lined with
asbestos-containing material that was released to the environment during the incident.
Asbestos-containing debris from the site was found on surrounding streets, rooftops,

parking lots and yards. Up to 25% chrysotile asbestos was detected in samples of the debris collected by MDNR; consequently, Praxair had to address asbestos abatement activities, as well as other environmental and public health issues, as per
MDNR’s Hazardous Substance Emergency Declaration #050624-1530, dated July
1, 2005 (see Appendix C). Asbestos removal and remediation were subsequently conducted by The Shaw Group Inc. and Bellon Environmental Company, under contract to Praxair.

However, asbestos was detected in samples of debris originating from the site littering nearby streets, rooftops, and yards. Consequently, qualified companies contracted by Praxair conducted followup abatement and cleanup.

Based on visual observations and sampling data, a release of asbestos-containing
materials to the environment (nearby residential and industrial properties) was documented. MDNR subsequently issued a Hazardous Substance Emergency Declaration, directing the potentially responsible party (PRP), Praxair Distribution,
Inc., to address environmental and health problems associated with the fire. Consequently, Praxair initiated cleanup activities in response to this directive.

Figure 2 Site Layout [by] Tetra Tech EM Inc. [shows the intersection of LaSalle
Street and Missouri Avenue directly across the street to the west from the Praxair
facility, which is located between Chouteau Avenue to its north and Hickory Street to its south].

photograph shows fire-fighting efforts along Missouri Avenue, near the facility’s
west lot.

photograph shows acetylene cylinders burning at the site.

photograph of the south lot shows facility’s proximity to neighboring residences.

photograph shows a burned automobile near the south lot.

photograph shows a damaged abandoned building [which is the west side of the
Historical Building at 1109 Missouri Avenue showing its extensive damage from
the exploding cylinders that were launched like missiles that crashed through the
walls of this building, entering from Praxair on the east and exiting out the west].

photograph shows an acetylene cylinder and asbestos-containing debris in a street
near the site.



State of Missouri Department of Natural Resources July 1, 2005 written Hazardous
Substance Emergency Declaration [issued to] Mr. Wayne Yakich, Praxair Distribution, Inc., 39 Old Ridgebury Road, Danbury, CT 06810. As you are aware,
the incident resulted in breached acetylene gas cylinders that contain asbestos material. Investigation of the incident and Praxair Distribution Inc. sampling conducted at the site confirmed that asbestos material was released during the incident. The department’s independent samples collected on Thursday, June 20, 2005, indicated the continued presence of friable asbestos in materials/debris located off-site of the facility. [MDNR ordered Praxair to] Continue the removal of any asbestos containing material, debris, or any other hazardous materials discovered
off-site.

NUMBER OF WORKERS AT THE FACILITY OR ADJACENT FACILITIES WHOSE CONTAMINATION IS SUSPECTED: Approximately 70.

06/16/2006 U. S. Chemical Safety Board, Washington, D.C.: gas released by a
pressure relief valve on a propylene cylinder ignited. As a result of the fire, dozens of exploding cylinders were launched into the surrounding community and struck nearby homes, buildings, and cars, causing extensive damage and several small fires.
Fortunately, residents escaped injury from the falling fragments. CSB investigators
noted the accident occurred on a hot summer day with a high temperature of 97 degrees F in St. Louis. At Praxair, cylinders were stored in the open on asphalt, which radiated heat from the direct sunlight, raising the temperatures and pressure of the gas inside the cylinders. At approximately 3:20 p.m., a propylene cylinder pressure relief valve began venting. CSB investigators believe static electricity, created by escaping vapor and liquid, most likely ignited the leaking propane. Praxair security camera video shows the initial fire spreading quickly to other cylinders.
Exploding cylinders - mostly acetylene - flew up to 800 feet away, damaged property, and started fires in the community. The fire could not be extinguished until most of
the flammable gas cylinders were expended. An estimated 8,000 cylinders were destroyed in the fire, which took five hours to control. The investigation determined
that the pressure relief set points, specified in industry standards, are too low for proplyene and may allow the gas to begin venting during hot weather - well below the pressures that could damage the cylinders. Not only are the specified set points too low for propylene, the CSB found some valves begin releasing gas even before the pressure reaches the set point. Each time a pressure relief valve opens, its performance deteriorates - making it more likely to vent gas at too low a pressure in the future. CSB lead investigator Robert Hall said: “The key lesson learned in our
investigation is that the combination of high ambient temperatures and relief valves
that open at too low a pressure increase the risk of catastrophic fires at these facilities.”

The CSB bulletin lists three similar fires at gas repackaging facilities that were reported to be caused by leaking propylene containers since 1997. First occurred at
another Praxair facility in Fresno, California just a month after the St. Louis accident.

Mark A. Smith, EPA: “I understand initiating cause might be from a propane tank,
either overfilled or fell to the ground and then broke & found ignition source (heat index was close to 100 degrees that day). I believe that CSB is investigating.”

Vehicles in Trucking company’s parking lot were set ablaze from falling debris
[immediately north of 2300 LaSalle, directly across the street from the restaurant;
per St. Louis Post-Dispatch]. Aerial view of the area affected by the Praxair explosions. Many of the gases Praxair supplies to customers are highly flammable, particularly acetylene, hydrogen and oxygen. The company’s facility on Chouteau is a cylinder gas plant, which fills gas cylinders for clients ranging from hospitals to welding facilities.

WSD