Document 2RZYoRzvk96wLwMo0oaBkqRRp

September 26, 1991 Gerald Wagner Bldg 2511 cc: Doyle Haney Response to Chlorinated Methanes 2 year Reactive Chemical Process Review 1. The autoignition temperature of Shell Thermia C hot oil is 340 C. If this autoignition temperature requires us to take special precautions other than what we already have in place, please notify us. 2. With the current reactor design and system pressure rating , it is not possible to incorporate Stade's reactor technology. However, a new reactor will be installed with the expansion project in 1993 that will incorporate the Stade design. 3. The reactive chemical consequences of Thermia C oil contacting with zinc chloride and mercuric chloride were studied in the reactive chemical lab. No thermal activity was detected under the experimental conditions. 4. Reactive chemical testing between grafoil graphite gasket material and dry chlorine was generated in Texas at the request of the Chloralkali Technology Center. Grafoil GHP, Grafoil GTR and Flexseal were tested with dry chlorine. All tested acceptable for dry chlorine service. The specific reactive chemical data can be found in reports RCT-88-094, RCT-88-0486, and RCT-88-0677. 5. One second data collection and display is physically limited. Disk drives can not store data at that rate and the software packages ar competing for CPU time. The closest method that can achieve this rate is the Fast Data Logger on the GPI package. It can log data to memory based on 3600 one second memory storage and is limited to 50 data points. Any longer data storage time would cause other system packages to suffer in response time. Only a system totally dedicated to one second data collection could be expected to retrieve and retain one second data for a useful period of time. At this time we have no plans to install such a system unless the committee deems it as necessary to prevent reoccuring reactive chemical incidents. Bruce Miles CMP Production Supervisor CONFTDFNTTAI DO 00655? TyPe Area General REACTIVE CHEMICAL Recommendations: 1. Due to reactivity concerns, titanium parts are not allowed in the Methanes bloc The current trend toward centralization of maintenance and spare parts increas* the risk of inadvertently importing titanium into the block. It may be beneficial communicate this issue and associated hazards with the appropriate personnel a Solvents/EDC 1 and central warehouse. Description .`Titanium Parts Action Again, Methanes does not allow titanium parts in the block and the equipment replacement spare parts have been scrutinized to ensure that no specify titanium. This policy has been well communicated to maintenance personnel in the block. The Centralized Maintenance Organization must address this and similar issues from a safety training perspective. We will work with the CHM group to develop and execute this training Response Scope Change: Responsibility Bmce Miles Checkpoint Date: If 93 Timing: 02/93 Status: Complete Report Created on 11/9/94 DOW CONFIDENTIAL CONFIOFNTTAI Kecord# 88 006553 TyP* Area General REACTIVE CHEMICAL Recommendations: .2 Make sure that the concentration of ammonia that is used for detecting chlorine leaks is below the concentration that causes flash fires. Description.02 leak detection Action The Plant will verify with the Tech Center the safe level of amonia in an aqueous solution to ensure that the concentration is below that which cause flash fires. Stock amonia solutions will be purchased at the proper concentration. Response Scope Change: A stock solution of 6% ammonia is being supplied by Lang's. A communique was issued to CMP personnel on the potential problems with incorrect ammonia solutions. The communique was copied to the CMP reactive chemicals files for future training and review. Responsibility Kevin Kelley Checkpoint Date: 12/92 Timing: 01/93 Status: Complete Report Created on 11/9/94 DOW CONFIDENTIAL r.ONFTDFNTTAI Record# 89 DO 006554 TyPe Area General REACTIVE CHEMICAL Recommendations: 4. Make sure that an appropriate insulation is being used on R-250A/B. Leakage hot ("225 degrees C) Shell Thermia C oil onto a high surface area insulation su as fiberglass is a flammability concern. Description:R250 Insullation Action Foamglass is being replaced on the R250's with mineral wool. The foamglass has been found to be a poor insullation choice for this installatic because of poor mechanical integrity. The poor insullation yields high f corrosion rates on the vessel walls internally and the resulting potential fo a leak. We reviewed the use of mineral wool with the Reactive Chemical Dept, and with the Tech Center. It was agreed that if the proper precautions were taken to ensure that flange leaks on the oil nozzles did nc have a path to the vessel wall, then mineral wool could be used in this application. Inspection of the reactors for oil leaks was added to the operator rounds as an added precaution. Response Scope Change: Responsibility John Sacks Checkpoint Date: Timing: 10/92 Status: Complete Report Created on 11/9/94 DOW CONFIDENTIAL CONFTDFNTTAl Record# 90 DO 006555 Area General REACTIVE CHEMICAL Recommendations: 5. Consider indoctrinating contract personnel on-the reactivity hazards of alumini in contact with chlorinated organics. Description .-Aluminum Hazards Action We will include aluminum hazards along with the titanium hazard trainin; included in reactive chemical follow-up item 1 above. ( Response Scope Change: Responsibility Bmce Miles Checkpoint Date: 1/ 93 Timing: 02/ 93 Status: Complete Report Created on 11/9/94 DOW CONFIDENTIAL CONFTDFNTTA, Record# 91 DO 006556 Tne Area General REACTIVE CHEMICAL Recommendations: .6 Review the instrumentation/controls for the PSA systems and make sure that adequate lines of defense are in place for avoiding run-away oxidations. Peihap oxygen analyzers should be installed on each system. Description.Oxygen in PSA's Action |Adequate alarms and shutdown's based on temperatures are already in plat lin the Mod V. We are currently installing a oxygen analyzer in PSA 177C Response Scope Change: Responsibility Steve Ledoux Checkpoint Date: 2/93 Timing: 04/ 93 Status: Complete Report Created on 11/9/94 DOW CONFIDENTIAL CONFTDFNTTAI Record# 92 00 006557 TyPe Area General REACTIVE CHEMICAL Recommendations: 3. Review your sodium thiosulfate system and evaluate the potential for STS inadvertently contacting low pH liquids--perhaps in the shot pond STS reacts with HCL at less than 2 pH and releases sulfur dioxide gas. An incident recentl occurred at the CPE plant involving leakage of 1400 lbs of 15% STS from a corroded pipe into a storm water system. The storm water then mixed with a waste HCL stream and released sulfur dioxide gas to the atmosphere. Four worker were treated at medical for S02 inhalation. Description:STS System Action The STS level is monitored in the absorber tower by an analyzer and pose a low risk of contact with low pH liquids. There is a possibility of a leak from piping; but we feel there are adequate operator rounds in that area t< prevent an occurence such as the one at CPE. Response Scope Change: Responsibility None Checkpoint Date: Timing: 10/92 Status: Complete Report Created on 11/9/94 DOW CONFIDENTIAL OONFTDFIMTIAL Record# 93 DO 006558 Area General Recommendations: 7. Review the list of leak repair compounds for the Methanes plant and make sure is current. Description: Action Response Scope Change: Responsibility Checkpoint Date: Timing: Status: Complete Report Created on 11/9/94 DOW CONFIDENTIAL CONFTDFNTTAl Record# 94 DO 006559