Document 5kR5e1XEJOxYgrJpj1aONjx9N

**.r Monsanto r. J. A. Glass - LPSS March 29, 1977 cc Safety and Property Protection Survey Texas City Plant - August 26-20, 1976 G. W. Bostick P. E. Brubaker J. E. Clark G. A. Danner G. W. Daues W. C. Fuller H. M. Lacy N. L. Marsh R. C. Martini D. W. Metten C. M. McCullough G. T. Ryan R. L. Stuart J. G. Trafton Attached is a copy of last year's SPP survey for the Texas City plant. Some progress reports have been received on the items listed. I would like to suggest that we review the status of the recommendations included in this report at the next Plant Manager's Safety Board meeting scheduled for April 20. We will place it on the agenda as a reminder. vf Att. J. A. Glass c SC 002896 LAM004104 *HOV iftAtdt A COCATIPMi T. W. Lawrence/II. W. Morgan - S&PP - St. Louis - F2WA *Tt * September 3, 1976 ,tCT safety and PRoperty Protection Survey - Texas City Plant . August 16-20, 1976 TO Mr. P. E. Brubaker ____ Texas City - 1890 CCi E. N. Brasfield - E3NG J. A. Glass 1890 E. H. Jones - 1890 R. L. Miller/E. G. Volz l ' , W'J * 'V* ' This report summarizes observations that were made during our recent safety and property protection survey of the Texas City Plant. It also includes the status of outstanding recommendations from previous surveys. It was noted that of the 11 outstanding recommendations, 9 have been satisfactorily completed, the other two recommendations are still under consideration. It was unfortunate that almost simultaneous v/ith our arrival at the plant, the crisis with the large scale ammonia leak occurred. However, this incident did give us an opportunity to evaluate the emergency response. It is our opinion that your disaster control plan functioned well. There was demonstrated good coordination between the control center and the field and all safety concerns were properly addressed and managed. The plant's Team Approach to Safety 'is having an apparent positive impact on the plant's overall safety performance. Of particular note is the Unit/Craft safety team concept. Our discussions in the plant revealed that this concept is an effective mechanism for dealing with the safety concerns originating from the field. There were many other positive observations made during the five day exposure to your plant. These included a good level of house keeping being maintained in all areas of the plant including shops and laboratories. Good hazard highlighting was noted throughout the plant and of particular note is the non-skid treatment applied to most exterior stairs. It was also noted that good attention has been given to the guarding of mechanical hazards. The program for cleaning, inspection and dispensing personal protective equip ment is excellent and operating people reflect a high degree of confidence in the reliability of the personal protective equipment that is issued. C * . w c v. \/7 sc 002897 i ns'c r- ,js " LAM004105 Texas City Survey -2- September 3, 1976 NEW RECOMMENDATIONS: 76-1: Emergency Shower Head-Acetic Acid Department The standard emergency shower heads in the Acetic Acid Department are one inch by two inch reducing couplings to provide a more spot-type deluge. However, a field demonstration revealed a very erratic discharge of very questionable character. It is recommended that these reducing couplings be replaced with conventional emergency shower heads. Hoist Practices The following hoist deficiencies requiring attention were noted: a. The capacity of the hoist in the control valve testing building and the Oxo-Alcohol/Phthalic Esters Department was greater than the capacity of the hoist trolley or the hoist support. Hoist of matching or lesser capacity should be provided for these areas. b. Several of the hoists receiving rather infrequent use show signs of long periods without service or inspection. This coupled with the natural atmospheric corrosion leaves some doubt about the reliability of these hoists. The overhead hoist in the HCN Department is an example. It is recom mended that the hoist inspection program be evaluated to ensure that all hoists are being thoroughly inspected on an interval that will assure their reliability. c. The jury-rigged pulley hoist which has been installed in the HCN Department should be dismantled. 76-3: TBA Reactor Vent It was noted that pressure was indicated on the section of the vent line between a rupture disc and a pressure relief valve. This condition should be investigated and corrected. The practice of installing rupture disc and prssure rel -f valves in -'ies is generally discouraged bi ?P. It is recognized :.,at in isolated cases this may the ~ly . .-actical solution ro such problems as ven:. ~uli. *. He ..ever, in such ins - ~ces it becomes imper - ive rhat m-.asure-' are taken - ensure that pressure is not . nitted between the two relieving devices, since this c:,i significant!; :hange the u!Senate relieving pressure. SC 002898 LAM004106 ------- Texas City Survey -3- September 3, 1976 76-4: 76-5: HCN Manufacturing and Storage Area It was noted that the housekeeping/maintenance level of the HCN Manufacturing and storage area was not up to the par of the plant. While the future of part of this facility may be short lived, it is imperative that it continues to receive special attention. It is also recommended that consideration be given.to inerting the vapor space in the HCN storage tanks for added fire protection. Lactic Acid-Light Fixture Guards It was noted that the incandescent light fixtures on the reactors are without the wire metal guards. This is required to meet the electrical classification for this area and it is recommended that this extra protection from physical damage be provided. 76-6: Mobil-Therm Bypass - Phthalic Department A temporary bypass/filter system was noted in this area. The piping system did not seem to be adequately supported. The piping was not plumb or level and it was not possible to determine whether this was due to strain or whether it had been installed in this manner. Additionally, there c was some evidence of an earlier material spill. This high temperature heat transfer fluid has a high loss potential and it is important that temporary installations receive the same installation considerations as a permanent installation. 76-7: 76-8: Nitrogen Connections A large number of utility stations have been provided throughout the plant where connections for steam, air,' water and nitrogen are available. These utility con nections all employ a crows foot connection except in the Phthalic Anhydride Department. There the nitrogen con nection employs a distinctly different connector. This certainly minimizes the potential for dangerous cross connections between nitrogen and other utilities. It is recommended that this practice be considered for all other areas of the plant. Hydroc~n Excess Flow valve - HDPE A hypaas has beer sro ided around the excess flow valve :.n. the hydrogen loading system. It is recommended that the *alve in the typass be staled in the closed position to easure that t..e function of the exc=:.s flow valve is not defeated. SC 002899 LAM004107 Texas City Survey -4- September 3, 1976 76-9: HDPE - Finish Area This area has a high potential for dust fires and explosions. Efforts to reduce this loss potential should be complemented by considering automatic sprinkler protection for the entire finishing building. 76-10: . Maintenance Shop Practices Several maintenance shop operations were observed that could lead to personal injury or harmful exposure. It is recommended that these be reviewed and corrective action taken. a. Welding operations were being performed on benches and on bench vises. Barrier screens were not high enough to protect nearby workers and other people passing by. b. Welding operations were being performed without the benefit of local exhaust. c. Two men were at a machine piercing holes in angle iron pieces. One man was holding the angle iron pieces near the point of operation while the second man operated the control buttons. Facilities should be provided to support the work such that encroachment on the point of operation would be avoided. d. Paint spraying was being performed away from the spray booth with other workers in the area unprotected by respirators. 76-11: Pressure Testing Valves and Control Instruments It was determined that relief valves and other pressure control components were being gas pressure tested without the benefit of barrier protection for the person performing the test. Under the present conditions, catastrophic failure of the valve body would endanger the life or lives of persons in the area. It is recommended that the existing test chamber be used for all gas pressure testing except in lesser exposures where satisfactory protection may be provided with barrier shielding. SC 002900 LAM004108 Texas City Survey -5- September 3, 1976 76-12: Foot Protection Program It is recommended that consideration be given for mandatory foot protection program covering all industrial exposures, i.e., manufacturing, maintenance, storerooms and laboratory. 76-13: Fire Brigade Coverage Considering the potential for large loss fires and the need to make a prompt initial reponse to any developing fire, it is recommended that around-the-clock fire brigade coverage consisting of at least two fully trained firemen be inaugurated. These men should be capable of moving initial response apparatus to the scene and, supplemented by other on-shift personnel, making an initial attack on the fire. CONTINUED RECOMMENDATIONS: 75-2: Methanol Reformer Firing Safeguards The firing train for the methanol reformer should be upgraded to include: a. Double block valves with an intermediate bleed valve in the fuel gas supply line. Present installation includes only one block valve. b. Interlocking system which proves burner cocks closed before' main gas supply can be opened, c. Elimination of the non-interlocked manual reset feature on the solenoid valve in the air line to the air-to-open safety shutoff valve in the gas supply. It should not be possible to open the main gas valve, even with a reset handle, until all interlocks are satisfied. Status: Corrective measures are being developed. 75-3: Flammable Dust Accumulation - HDPE Heavy deposits of polyethylene dust were noted in several areas of Department 35, High Density Polyethylene. Accumulations in the enclosed building areas in the pelletizing area were of particular concern and would be conducive a major se?*ndary explosion, should the due . be shaken >ose from t. building structure. Better dus rontrol an. more freque : cleaning is recommended. SC 002901 LAM004109 Texas City survey -o- septemoer j, iy/b Status; This problem still exists, however, a number of improvements have been introduced. Efforts to further reduce the dust accumulation are being taken. COMPLETED RECOMMENDATIONS: 72-6: 74-4: 74-5: 74- 6: 75- 1: 75-4: 75-5: 75-6: 75-7: Flammable Liquid Containers Emergency Eye Bath Locations Gates for Platform Railing Openings Guarding of Couplings, Shafts, Belts Pedestal Fans Sprinkler Clearance - Research 2 Ladder Inspection Biennial Safety Audits Ramp - HDPE Analyzer House Dock Fire Protection and Pulleys and /jb Thomas W. Lawrence, Jr. `^Jarv^y W. Morgan SC 002902 LAM00411