Document R23oGLRY45bYYpZQmK16oGRJk

Cfemetive Chemicals cevdiew heJtd iSttiy tl, ll#91 Polyethylene C Plant --2 year process review Project rep: Michael Olsen Attendees: Mark Mitchell, John Monroe, Frank Travis, Robert Moore, Brian Vitt, Michael Myers, Mike Sticklen, Mike Nevsom, Dave Mihalik, Buck Bailey, Scott Villiams, D.V Leblanc, George Shofoluve, Gerald Vagener The Reactive Chemicals Committee is very appreciative of the effort you and the entire Poly C staff put into this reactive chemicals review. Obviously there was a tremendous amount of work which went into the preparation. The presentation was very well organized. Concerns: 1. Update compatibility chart for Poly C Plant (some suggestions below) Chlorine: Yellow--Dowtherm A, Ethylene, Fuel gas, Heptane, hydrogen, Isopar Octene -1, hexane. Green--Erucyamide, Irgamox 10,10, 2-octanol, Note: Perhaps these should all he red Trethylaluninum--some alcohols are explosive with TEA--methanol, ethanol 2-popanol -carbon tet mixtures are explosive--you use chlorothene In your plant and also freon--do these react also? -some amides are explosive such as diethylforamide--may suspect reaction with oleanide or possibly Erucamide Titanium tetrachloride and activated aluminum may be a problem Answer: All of the MSiDS sheets have been compiled and plans are to work with the Poly C RW and plant support personnel to develop a new chart using the Texas developed reactivity chart program. 2. The reactive chemicals consequences of using non-compatible absorbent materials for cleaning up spills was mentioned. Special problems have been encountered within Dow with activated carbon and with cellulose base absorbents. Before using absorbents make sure adequate reactive chemicals test data exists to assure compatibility. The problem is a fire resulting from spontaneous oxidation. Answer: POLY C is presently using only one type of absorbent material, 3M Brand Oil Sorbent. No problems have been experienced. There are no plans to chauge to any other. The only testing found was RCT-86-0306, Oil Absorbent Paid vs Dowtherm A. Change would require a Management Change Approval. 9/21/92 RXCOM REPLY.RC TXT DOW CONFIDENTIAL 3. A review of tab vt-ormge mod handling should be conducted to identify reactive <3heicals hazards* For example, are there any old chemicals stored by Poly C which may be shock sensitive due to peroxide formation? Vith regards to proper labeling and chain of custody, a suggestion was made to contact Steve Caldwell in the RAD Analytical labs for for information on EPA Good Lab Practices. Answer: A review of the stored chemicals revealed none that were old. The proper labelling of all chemicals has been accomplished. 4. ARC test should be performed on the Vanadium oxytrichloride/Titanium tetrachloride mixture to identify reactive chemical hazard potential which may result from long term storage. Answer: Sandra Lange/Lee Spencer checking rx chem files for any testing that has been performed vith VTi mix. Can also check with Akzo to see if they have info on long term storage of VTi that is exposed to heat from sunlight. The MLT to HEC-3 conversion has happened. Therefore, no longer will use VTi and will not store. Therefore, N/A. S. Hike dyers mentioned that Aluminum Alkyls have a tendency to precipitate from solution in cold weather and Knot re^dissolve. The precipitate tends to be chemical active and could pose a reactive Chemicals hazard. Texas Aklyls should be contacted for their input to this potential problem.. Answer: Barney Daigle of Texas Alkyls had tests conducted on BEM 2346 15 wtX in heptane and BEH 15 wtX in heptane for stability at low temperature. The tests were carried out by Ms. Minnie Christal at their TAI laboratory in Deer Park, Texas. Samples were stored at -10 Deg C for 3 days. No precipitation, discoloration, or any noticeable change was observed at the end of the test. 6. Consider expediting the installation of different size unloading nozzles for BEM and EADC tank trucks. Ansver: Different mating flanges have been installed on the BEM tank trucks and off-loading plant flanged oomrswections. The BEM flanges have one male dowel and one female insert at 130 degrees from one another. The EADC flanges are normal raised face flanges. The male dowel would have to be broken off of the BEM flange to mate it to the EADC flange. This should be sufficient to alleviate this potential operating error of off-loading the wrong raw material to the wrong tank. 9/21/92 RXCOM REPLY.RC TXT DOW CONFIDENTIAL DO A 017517 CONFIDENT TAI... 7. Review depad procedures for mkoad&og aAky'ls.* Specifically, what would be the reactive chemical conseqweuQes Ojf Jftot closing the manual nitrogen valve after offloading? Answer: Regulator on depad line is bypassed during unloading of Mg alkyl truck. Concern is that drum could go flat and flare header could back into the drum causing rx chem incident with BEN. Vill look at available options to prevent this such as a regulator set above flare header pressure on the depad bypass line. 8. All pertinent reactive chemicals test data generated for the Poly C process should be kept on file at Poly C. Answer: The block reactive chemicals contact, Mike Olsen, attended training on accessing the "Dow Reactive Chemicals System", a part of the Dow Camps Menu System. A listing of all of the pertinent testing has been downloaded to the Poly C Group Vax Account, PYCPROJ. The management at Poly C agreed that access to the listings and electronic database were the most effective and efficient method of compliance. 9. Review the PSV sizing calculations for D301 and D303 and make sure that inadvertent mixing of EADC and BEM were considered. Are gaseous products generated during the exotherm? Answer: This scenario is not credible based on the following reasoning and compliance with the Corporate Relief Design femnai guidelines for sequential events to constitute a credible scenario. The following are the things that would have to go wrong to crosstie BEM and EADC. ASSUME: EADC truck is here -- Try to unload into BEM header 1. The operator has to hook up to wrong unloading hose. The BEM hose has a male dowel pin and a female hole at 180 deg to each other on the flanged connection. The operator would have to break off the male pin to fit the hose onto an EADQ truck. 2. The material is incorrectly identified. When the ID is run, the results come as a weight X of A1 or Mg in the solet ion. This Analysis is ran 'by a lab operator before the trodk is unloaded. The lab operator has to confirm that the material is within specifications before it can be unloaded. 9/21/92 RXCOM REPLY.RC TXT DOW CONFIDENTIAL 00 A 0175]ft CONFIDENTIAL 1M>. Make sure that rt&e pad (fl.ov witch (a permissive for unloading calcium stereate) i$ m ttoe critical instrument list. In situations where direct loading of calciua stearate into the top of D401 and D402 are mandated make sure procedur $ are adequate for assuring a nitrogen purge during loading. This is all aimed at reducing the dust explosion potential. Answer: The flow switch is on the critical instrument list. The procedures have been reviewed and are adequate. 17. A comment was made that the tube temperature in E511 approaches 280 deg C when the system is pressured to 400-500 psig. Reevaluate the potential for a ethylene decomposition. Answer: A plot of Pressure vs. Temperature for the decomposition limits for ethylene (obtained from high pressure LDPE process) indicates that at the range of pressures and temperatures experienced for the LLDPE process, we are well within the safe region. No problems associated with reaching 280 deg C at 400-500 psig in E-511 as far as ethylene decomposition. 18. Make sure that the proper insulation is being used in the Dowtherm area. Some insulation materials can cause spontaneous oxidation problems and even fires if hot Dowtherm from a leak is dispersed throughout. Answer: Foam glass insulation is the material of choice and is employed. 19. Investigate the reactive chemicals potential of the portable waste trailer that is routinely used for waste containment within Poly C. Answer: The potential is there. There is a procedure, S0L/0CT-P8, in place to minimize the hazard. In addition, a project is being investigated to eliminate the use of the waste trailer. 20. Develop a reactive chemicals compatibility chart for lab chemicals. Answer: This will require some long term prioritizing. Currently, the compatibility chart update for the process is the first priority. 9/21/92 RXC0M REPLY.RC TXT DOW CONFIDENTIAL DO A 017510 cNFTDNTta(9 21. In the calcium jkftvesittgate the reactive chemicals potential for loss of calcium stearate to <the process with lov reactor efficiencies and high ATE usage. Answer: Addressed during side-arm only trial. Some ATE carried over from devos made it to bottom of tover...from 80 ppb to 1 ppm after 4 days. Some is thermally decomposed in 2nd rx and exchangers, some could go vith polymer and be killed by the pelletizer water. ATE does decompose to a non-pyrophoric species. Possibly, after weeks could build up in column bottoms and be hazardous if sampling at this point. There are purges of column bottoms to D-809 once per shift (twice a day). At these purge rates, there has been no known experience of problems. The only two incidents in the CAMPS database are fires due to improper disposal. All of the above answers were supplied by Poly C staff and operations personnel. This list of questions and answers has been continually updated as information became available and priorities dictate. This is the status as of this date. Michael P. Olsen Production Specialist Polyethylene C September 21, 1992 00 A 017520 confidential