Document 4aYpDMEb7GNdQO0ob98Ne7NXj

MONSANTO CHEMICAL C^.tPANY Location: Texas City, Texas Date November 3 1959 Subject : Process Hazard Committee Report Safety Board To J. S. Putnam Early In 1959 a complete and massive report was prepared showing the status of the various items listed by the Process Hazard Committee. Many of these items have been completed or otherwise disposed of and this letter is a summary of the present status. Each general operating supervisor was contacted concerning his particular group of items and present status was determined. The Items on the attached list are grouped into six catagories: 1. Those con?>leted. 2. Those which supervision considers nonhazardous. 3. Those which supervision considers non-Justi fiable for hazard correction. 4. Those for which a continuous program or schedule Is now in existence. / 5. i Those not done. i/ V 6./ Those that are in active progress toward ^-- correction. I consider the first four of the above catagories to be "completed" Items because either the work has actually been completed or Is not going to be done, or is of such a nature that it requires continuous vigilance and will not reach a status of being completed. It is suggested that. If smother such comprehensive Pro cess Hazard Report is to be prepared, the items in these four catagories be dropped from that future report and only the items in catagories five and six be included. CLG:It Attachment C. L. Gilmore SC 16667 LAM023936 I. THOSE COMPLETED Item No. Description 5 Fire protection for south tank farm. 18 Portable pumps without re lief valves protecting suction and discharge. 25 Air purge failure on non-explosion proof analytical instruments can create explo sion. 27 Fire Water Supply 28 Inadequate fire protection at propane storage. 36 Loss of all refrigeration engines at same time. 45' Alkylation liquor (AL)- water separator. 46 Reaction mixture separator 52 HC1 feed control 57 Vacuum operation 58 Salt water failure 59 Area Control valves 63 Age of unit 67 Hydrogen flare system 71 Introduction of organic impurities 73 Converter Flame-out 76 Soot Filters 78 Polymer In Compressor 79 Compressor House 80 Water entrainment into compression SC 16668 LAM023937 Item No. 82 84 96 99 101 102 106 107 110 111 114 116 121 125 128 132 133 136 137 138 139 140 141 TTACHMENT PAGE 2 Description Vacuum Columns (18D7 and 8) Acetylene Distribution System Acid Scrubber (19D4) Rerunning off-speclfication HCN HCN Storage Bypassing Control Valves Reaction Inhibitors Proposed Catalyst System Reactor Spiking Waste Organic Surge Tank (20T16) HCN Vaporizer EDC reactor (23V1) l) Upset can relieve Cls to main VCM flare (C2H2 present main flare). C0H2 Separator (22S3) I; Vessel relieves through RD to atmosphere. Cracking separator (22S1) coke plugging makes RV undependable VCM storage (22T9)-Insufficient level gauges. CB column (22D8) Corrosive service. Refrigeration turbine (22DT1) Acid unit (department 21) deteriorating. Communications -- One phone in control room. CgH^ and C^g communication easily interrupted. VCM compressor (22C2) - No HV on positive dis placement compressor Possible cross connection with sanitary water to contaminate drinking HgO. Reactor (26R1) maintenance decontamination pro blem. SC 16669 LAM023938 Item No. 149 154 162 166 167 170 171 173 181 183 190 191 192 193 194 195 196 197 198 207 208 209 211 216 ATTACHME. PAGE 3 Description TBA Tank Cars CO Concentration In Area Product Separator (41S17) Peroxide Storage Product Separator (41S17) Proposed use of chilled water In department 4l. Building Evacuation Styrene tar feed line General Electric Turbines Styrene Rack, organics in soil. Pressure Cells RPU Little RPU Pilot Plant - EMA Pilot Plant - Cyanuric Chloride Pilot Plant - Oxidative Chlorination Pilot Plant - General High pressure testing Low pressure testing Car and Loading Grounding Operational Procedures and Training not Ready. HCN Shipping Piping Around 20P134 SC Pressurizing 7D2 and 7D3 16670 LAM023939 ATTACHMENT PAGE 4 Item No. 217 218 219 220 221 222 226 228 229 230 Description Department 5 vent system Department 7 vent system Department 8 common vents 16K1 has no relief valve Department 16 expansion contemplates methanol brine system. Oxygen Compressor Fire Drainage Ethylene In Cooling Tower Low pressure Polyethylene Pilot Plant Oxidative Chlorination, 1/29/58 II NON-HAZARDOUS 2 Use of plant air system for respiratory masks 4 Out-of-date flow sheets 6 Inavailabillty of nitrogen for purge purposes during oxygen plant shutdowns 10 Flame arrestors 14 Reciprocating engine protectivedevices. 30 Flammable mixture can occur in quenchers during decoking 34 Spill and fire at liquid ethylene storage tank spreading widely because of no fire wall. 37 Emergency disposition of butane In case of tank rupture. 38 Valves In acetylene systemcontain copper bearing alloys, which can produce copper-acetylide which is spontaneously explosive. 16671 LAM023940 Item No. 43 44 5z^ 48 49 50 51 55 70 72 81 83 86 87 88 90 93 108 109 113 117 118 126 ATTACHMENT PAGE 5 Description Unable to purge acetylene lines during emergencies. Ethylene feed pressure control Temperature control on alkylators Pressure relief of alkylators Ethylene feed control Alkylated liquor line from orifice washers to separator Reaction mixture scrubber Vent System Air Intake (for plant air) Excess nitrogen In Oxygen Off-gas flare system Oxygen Analyzers Product Acetylene Column (18D5) Adsorber (l8Dl) Oas Holder Reactor Interlock Spent Catalyst AN Storage AN Storage Light Ends Column Surge Tank (20T10) Reactor Relief SC Cycle Gas System CgHg driers (22A1) l) Possible to Inject urj ucd ujf human error Into hot (275cC) 2) Possible to send C2H2 mixed with NO to boiler house through human error. 16672 LAM023941 Item Ho, Description ATTACH1L_.VT PAGE 6 127 131 142 146 147 148 163 164 165 179 185 187 202 224 Reaction off-gas flare has standard type flame arrestor but must bum some C2H2 VCM storage (22T4). Three rundowns in 3lngle tank wall. Explosive mixture In flare due to Og andC^h low conversion. Lime Slake r TEA Product Column (25D1) TBA Storage Xylol Handling Experimental superpressure line. Recycle Gas Waste gas line from department 18 LPG Truck Rack - Fire Hazard. Empty Transport Containers Contain Explosive Mixtures. Chlorine Barge Uploading Single means of access or exit from the cold boxes. III NO JUSTIFICATION 33 Rupture of compressor discharge line can cause fire and spill. 66 Salt Water failure 77 Recycle Gas Control 94 Reactor Cone 97 HCN Stripper SC 16673 LAM023942 ATTACHMENT PACE 7 Item No, 103 115 l6l 172 175 177 185 186 Description Unit Cyanide Vent Acetylene System Compressor House Oilfield bollerB Expansion joints In steam distribution system. Qas shut-off valve LPQ Truck Rack --Fire Hazard VCM and Chlorine Tank Car Rack Near Residences. IV CONTINUOUS 3 Identification of material In piping by color code. 7 Unauthorized personnel entering operating areas. 9 Railroad cars dispatched to railroad shops In contaminated condition. 11 Priority of expansions vs. existing plant engineer ing and research work. 12 Field Communications 16 Routine Inspection of turbine over-speeds not followed. 17 Routine relief valve Inspection not followed. 20 Minimum job training of Operators 23 Equipment Is being operated at above design conditions. 24 Caustic piping 29 Wystemlc poisoning of personnel by lead oxide In lead pot area. SC 16674 LAM023943 ATTACHMENT PACE 8 Item No. 31 32 42 53 /yC 5* 60 62 65 95 104 105 123 130 134 156 l6o 174 176 178 182 184 189 199 200 Description Failure of reciprocating engine parts due to old age. Pyrophoric polymer Is made In 1D3 stripper. Sparks from Dept. 1 and 10 flare can start fires on ground and on near-by wooden build ings. Finely divided aluminum Off-gas water scrubbing towers Condition of piping In department 5-7 Storage tank polymerizations Main condenser HCN absorber (19D5) "Buddy" System Area Sump 23T5 vapor space explosive Cracker condenser (22E4) tube leaks to CTW side Air In organic columns on shutdown Methanol Storage. Tank Blanketing. Area Spill Alarm Mixed gas control Emergency air compressors 16675 Control valve servicing Chlorine distribution Acid loading lines In poor condition. Dock and Bay Area Fire Protection In adequate . Shop testing and repair Gas cylinder handling LAM023944 AT CHMENT PAGE 9 Item No. 201 203 204 214 223 Description Drum Handling Acetaldehyde Tank Car Loading HCN Tank Car Loading Explosive mixture In tanks and towers Oxygen Line Labeling In Pipe Hacks V NOT DONE Item No. Description Comments 16 Routine Inspection of turbine over- Action on this Item speeds not followed. not decided on nor Justification developed. 61 Runaway polymerizations Status unknown 64 Relief System Hazard exist, but re peated studies Indicate excessive cost to correct. 68 Salt Water Failure Hazard exist, but re peated studies indicate excessive cost to correct. 91 Test Ignitor 92 Main Flare No comments Entrainment exists, no change on procedure yet. 112 Acetylene Feed Control Engineering study to be made. Research work completed. 119 Acetylene Compressor No action as yet. 120 Acetylene Stripper No action as yet. 129 Quench tank (22T18) HV dis Engineering study re charges to atmosphere on west quired, no priority. side of distillation structure. 143 Plant Sewers 144 Reactor SC 16676 Sewer model unsuccessful a) Completed b)Not done LAM023945 Ar CHMENT PAGE 10 Item No. Description Comments 144 Continued 145 HJT-HCN Mix Tank 150 Hydrolyze r 158 Relief Venting 205 MVA Concentration in 20E44 212 Alkylation liquor (AL) - water separator 232 Fire Water Supply c) Not Done d) Nat done e) Not done No Action No Action Originally considered no hazard, but with expansion,needs re evaluating. No test as yet No comments VI ACTIVE 1 Use of Sanitary water for pro Completion date cess purposes. January 1, i960 8 Fire Alarm System System has been changed and an operable better system being investigated . 13 Momentary fuel gas failures cause a) Completed explosions in direct fired vessels, b) No Justification c) No hazard d) Active Responsibility of Utilities Section. 19 Operating and Design Manuals Manuals in various de out of Date. grees of completeness. Continuous item once brought up to date. 21 Expansion of units produces Various plant expansions undersized relief valves. now in progress. 16677 LAM023946 Item No. 26 35 56 69 74 75 85 89 98 100 122 124 135 ATTACHMEN PAGE 11 Description Pipe racks Use of drummed methanol creates sources cf fire while drum is open Benzene column, 4D1 Air intake (for Oxygen Plant) Converter Stacks Soot Higher Acetylene Stripper (18D4) NH3 Storage Polymerization control by acid Inhibition Waste Streams Off-Gas System Chlorine Storage EDC-HoO separator (22S7); H2O saturated with organics goes to sewer. Comments Signs are being re quested and Installed. Will be Installed. Engineering study required. Tech Services has com pleted study, report and evaluation in pro gress. Engineering Study Long term study - Progress Now testing analyzer Valves exist on vertical tank, RVs plan similar for horizontal tank. Inhibitor system completed. Polymerization hazards under study. Evaluation In progress In department 24. HV In early i960. Chromatograph Instrument Is under study. 1) Not Justifiable 2) Completed 3) Active 4) Continuous Another tank to be Installed. SC 16678 LAM023947 Item No. 151 152 153 155 157 159 168 169 180 188 210 213 215 225 227 ATTACHMT ? PAGE 12 Description Hydrogenation Unit Linde Unit Waste Gas Line Waste Gas Header Compressor House High Pressure Piping Polyethylene Storage Polyethylene Dust Instrument Air Old Seatrain Tanks in Poor Repair Acetaldehyde Rundown Tanks Reaction Mixture separator Sulfur pots Vacuum Trip on Peed Gas Com pressors (31C5) Catalyst Spill SC Comments a PAFE Approved b PAFE Approved c Completed a) Continuous b) Active c) Active Awaiting approval Awaiting approval Awaiting approval Considered no personal hazard probable, however, test program in progress. Study in Progress Study in Progress 30 lb. System study. Tanks being sold Research Study in Pro gress. Engineering Study in Progress. Target Date November 1959 Part of expansion work 1) Research work dis continued. 2} Completed 3) Active. Approval requested Requires fire training. Grounds and testing pro gram will become active soon. 16679 LAM023948 Item No. 231 ATTA" 'VENT PAGE 13 Description General Problem of transmlsslon system seems to Indicate a thorough safety study Is needed. Comments Engineering study SC 16680 LAM023949