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ESCAMBIA PLANT INC. INTEROFFICE MEMORANDUM To: M. R. Chmura pfOifljR. E. Davis Re: Monthly Status - November Area ,lB11 Hazards Review Dote: 3 December 1980 Copies: R- L- Duggan R. E. Jones T. J. Regan The formal and final report was issued in November on the hazards review conducted in Area "B" in October 1980. A CE for all modifi cations, except relocating the Wet Bay control room, has been sub mitted for Management signatures and approval. The estimate for relocating the Wet Bay control room will take approximately one more month to complete. RED: dl R. E. Davis AP00036294 PROCESS HAZARDS REVIEW ESCAMBIA AREA B AP00036295 SUMMARY A Process Hazards Review of the Escambia Area B plant was completed. The plant was divided into five main areas and the major hazards were identified. The review group used the fault tree analysis and the failure mode and effect analysis to evaluate the hazards. A total of 52 hazards were identified and 45 recommendations for corrections and control measures were made. There were 27 recommendations made for equipment changes, 12 for inspection, PM and process/procedure changes and 6 recommendations for studies to be made. The following table lists the 5 areas of the plant, and the number of hazards identified in each. AREA HAZARD the hazards considered NUMBER OF HAZARDS IDENTIFIED AN Ammonia Release 20 Material Exposure Vessel Rupture 3 7 Supply Failure 3 Decomp, of AN 1 Urea Ammonia Release 2 Vessel Rupture 3 Solutions Ammonia Release 4 Prills NH^ Release 2 Decomp, of AN 1 Material Exposure 4 General General 2 Total 52 A complete list of the hazards identified and recommendations made are contained in the following pages of this report. AP00036296 PROCESS HAZARDS REVIEW ESCAMBIA AREA B I. INTRODUCTION A process hazards review was completed during the week of October 13-17, 1980. The review studied the Escambia Area B plant to identify potential hazards and recommend appropriate corrective or control measures. II. SCOPE The review included four production areas: Ammonium Nitrate, Urea, Solutions and Prills. The bulk and bag warehouses were also Included in the study. Along with the boundry limits set above, consideration was also given to steam, CC^, Nitric Acid, Ammonia and electricity. The scope of the review included these items: 1. Systematic analysis of each segment of the process with respect to the effects of equipment failure, instrument failure, utility failure, and operator error. 2. Consideration of potential handling or processing problems with respect to raw materials, intermediates and final products. 3. Consideration of the adequacy of materials of construction. 4. Consideration of the adequacy of existing process control and alarm systems. 5. Recommendation of corrective or control measures. III. PROCESS DESCRIPTION Area B is divided into four interrelated production units: Urea, Ammonium Nitrate (AN), AN Prills and Urea-AN-Ammonia Solutions. Urea is produced by the reaction of carbon, dioxide and ammonia at high pressure and moderate temperature. Carbon dioxide gas is supplied to the urea autoclave at 2900 psig. Ammonia liquid is supplied from the "A" Area ammonia plant storage spheres at 280 psig and is pumped to 2900 psig by a four stage reciprocating compressor in Area B. Ammonia is fed to the urea autoclave in a stoichemetric excess to carbon dioxide. The reaction of ammonia and carbon dioxide consists of two steps. The first reaction is the formation of ammonium carbamate and essentially goes to completion. The second is the hydrolysis of ammonium carbamate to urea and water and is only partially completed. The net reaction is exothermic and heat is removed by condensate in the autoclave tube bundle. - 1- AP00036297 III. PROCESS DESCRIPTION (cont'd) The reactants leave the autoclave andJgo to the flash separator at 50 psig where the unreacted ammonia is flashed off to the urea off gas header at 25 psig. The bottoms from the flash separator go to the decomposer heater where the unreacted ammonium carhamate is decomposed back to ammonia and carbon dioxide. The products then go to the decomposer separator where the amrrfonia, carbon dioxide and water vapor are flashed off and enter the urea off-gas header. The urea product, 92% urea solution, goes out the bottom to the urea-ammonium nitrate mixer and to UAN storage or to the urea masar solution storage tank. Urea production capacity is approximately 60 TPD. Ammonium nitrate is produced by the reaction of 56% nitric acid and ammonia gas. Nitric acid is received from the nitric acid plant and is stored in two day tanks. From the day tanks it is pumped to a nitric acid preheater and on to the No. 1 and/or No. 2 neutralizer. Ammonia liquid is received from the ammonia plant storage spheres at 280 psig. The ammonia is vaporized using cooling tower return water in a vaporizer and superheated using steam in the superheater. The ammonia is fed to the No. 1 and/or No. 2 neutralizers with or without urea off-gas. Conversely, urea off-gas can be fed to the No. 1 and/or No. 2 neutralizer with or without ammonia gas. A weak AN solution from the AN prill plant reclaim system is also fed to the neutralizers. The reaction of ammonia and nitric acid is exothermic and heat is removed by the vaporization of water iii the reaction mass to produce process steam. The No. 1 neutralizer operates at 0 to 10 psig and some of the process steam is used to preheat the nitric acid feed to both neutralizers. The No. 2 neutralizer operates at atmospheric pressure. From the neutralizers the 83% AN product overflows to the 83% AN surge tank where it is pumped to storage, to the low concentrator, to the UAN mixer or to the solutions plant. AN prills are produced by prilling a 99.8% molten AN solution. 83% AN is pumped from storage or production to the low concentrator, where the con centration is increased to approximately 95%. The low concentrator consists of a thermosyphonreboiler, a vapor disengagement tank and a barometric condensor, which is supplied by cooling tower water. The low concentrator operates at approximately one-half atmosphere, and the product overflows to the 95% AN seal tank. From the seal tank the 95% AN is pumped to storage , to the UAN mixer, to the solutions plant or to the high concentrator. The high concentrator consists of a falling film evaporator, an air preheater, and a 99.8% AN surge tank. The falling film evaporator uses steam on the shell side and hot air from the air preheater on the tube (process) side to strip the water from the AN melt. Permalene, a patented prill hardening additive, is added to the 95% AN solution on the distribution tray in the falling film evaporator. The 99.8% AN solution melt gravity flows from the evaporator to the 99.8% AN surge tank from where it is pumped through a concentric pipecondensate flash cooler and. into the 99.8% AN head tank at the top of the prill tower. From the head tank the 99.8% AN either flows to a single prill plate where it is prilled in the prill tower, or overflows to the 95% AN seal tank. Air is pulled into the prill tower counter-current to the falling prills by one centrifugal and eight bifucator fans. The centrifugal fan pulls 'primary' air through the CFCA shroud and then through the Heil;high differential pressure venturi scrubber. Air exhaust from the high concentrator is also pulled through the Heil scrubber along with the prill tower shroud exhaust. The eight bifucator fans by-pass the CFCA shroud. The solid prills are collected at the tower base by a pebble collector belt and are transferred via conveyor belts and bucket elevator through an oversize classifying screen, -2 AP00036298 III. PROCESS DESCRIPTION (cont'd) a rotatry drum pre-dryer, dryer and cooling drum, an undersize classifying screen and a clay coating drum where kaolin clay is added to coat the prilled product. From the coating drum the finished prills are carried via conveyor belt and bucket elevator to the bagging hoppers or to hulk storage. The solutions plant presently only blends four primary products. They are: ammonium nitrate (AN) solutions, urea-ammonium nitrate (UAN) solutions, ammonium nitrate-ammonia (Bay-Sol) solutions and ammonia-water (Aqua) solutions. UAN solution is blending continuously from urea production and adjustments are made to meet specifications in the No. 2 and No. 3 mix tanks. Bay-Sol solutions can be blended batchwise in the No. 3 and No. 4 mix tanks. Aqua solutions are blended batchwise in the Aqua solution mix tank. IV. REVIEW TEAM The Review Team consisted of: 1. H. J. Smith - Chemicals Group Safety 2. Lee J. Howard - Process Engineering - Industrial Chemicals 3. R. J. Shaw - Industrial Chemical Technology 4. R. E. Davis - Production Superintendent - Area B - Escambia 5. Dave Elliott - Production Engineer - Area B - Escambia 6. Bill Rockwell - Production Supervisor - Area B - Escambia 7. Ralph Scott - Process Engineer - Escambia 8. Lorn Paxton - Maintenance Engineer - Escambia V. METHOD The Area B plant was divided into five general areas for review. They were: Ammonium Nitrate, Urea, Solutions, Prills and General. A discussion was held to determine what hazards existed and which ones would be considered. Listed below are 13 hazards or concerns which were identified and the priority in which consideration was given to them. Listed beside each hazard are the areas of the plant where it was felt the hazard could occur. Hazard Area of Plant Affected 1) Ammonia Release 2) Decomposition of AN (Fire, Explosion) 3) Nitric Acid Exposure 4) Equipment Rupture 5) Hot AN Exposure 6) Loading (Spill Exposure) 7) Dust Exposure 8) Hot Urea Exposure 9) COj Exposure 10) Permalene Products Exposure 11) Storage 12) External Fire 13) Supply Failure AN, Urea, Solutions, ] AN, Prills in Process, AN Urea, Solutions, Prills Urea, Solutions, Prills Solutions Prills, Storage Prills AN, Urea AN - 3- AP00036299 Category: | [Equipment Changes | {Procedural Changes, Inspection & PM Items [ |cng Studies t {Rejected Action Items from Hazard Review General Status as of. Pago 14 of Action Status Pages 1, 19 Management A ctio n Needed Hqzard 50. Wet Bay Control Room health and safety hazard (people can get trapped there) 51. Confined AN in old 83% AN Tank 52. Gas Exposure in elevator L -IQO lO. Di l. u </) a. a. < Responsi bility Recommendations Cost Est. H H 1 A Davis 50. Relocate control room to west side ground level of wet bay w g ->4e-->o<6oom.aHo/ IuLoLEUaOWQn> 10/82 HL A Elliott 51. Remove old 83% AN Tank 15, D0( 6/61 MH Elliott 52. Install air bottle with 10 min. air supply in elevator. 1000 3/61 Remarks (Include Estimated Costs) Being estimated - Cost may be $500M to $1. 5MM AP00036300 Management A c tio n Needed Category: I Equipment Changes [ jprocedural Changes, Inspection i PM Items | )ng Studies { {Rejected Action Items from Hazard Review Material Exposure Status as of_ Pago 13 of Action Status Pages 1, 19 Hazard 48. Nuisance Dust Exposure in Dry Bay and Storage 49. Fozraaldahyde exposure > _Oo *o" +"-* 4J S- L> 6, A. < Re spoils ibf.tity Cost Recommendations Est. LH 2A Elliott/ H. J. Smith 48- Initial Dust Monitoring to determine personnel exposing levels. 49* Change procedure for use to make safe o. oi a/ ci. wtc--. ote_>ma ttoi-- <eo-> 12/80 Remarks (Include Estimated Costs) AP00036301 I AP00036302 Category; * [Equipment Changes | {Procedural Changes, Inspection i PM Items | (Eng Studies | {Rejected Action Items from Hazard Review Material Exposure Hazard 44. Overflow of 83% AN Storage Tank 45. NO emissions from Nitric Acici Tanks 46. Leaks in nitric acid line pumps aid piping 47 Leaks in Permalenc handling system vao>>>i oot-. ao**-.- <uc Response hi.11 ty Recommendations. Cost Est. L M ) A Elliott 44. Investigate installation of high level alarm on 83% AN Tank-not safety item but equipment insulation loss 5000 L H 2 A Elliott 45. Vent tanks to Heil Scrubber 5000 HH 1A Rockwell 46. a) Replace NA line flanges with heavy duty flanges b) Purchase 2 acid suits c) Purchase 2 pumps 10000 LM 3A Rockwell 47. Install eye wash near Permalene mixing area for Sulfuric Acid 2000 3/81 1/81 3/81 f Managemetv A c tio n Reeded Category: | jEguipment Changes \ (Procedural Changes, Inspection & PH Items 1 jgng Studies I Rejected Action I terns from Hazard Review Supply Failure Status as of Page 10 of Action Status Pages 1, 19 Mqzard 39. Overflow Nitric Acid Supply Tank 40. Vessel Rupture due to high steam supplypress ure 41. Overflow of NA Tanks due to power failure in Area KBn only TJ *- C > o -r- <U i~ L. J t/> n. a. <n Responsi- , .,\. UUTty Cost Recommendations Eat. PI M 1 A Elliott 39.a)Instail 2 position high level alarm on NA 10,000 tank b)ReIocate 2* shut off 1,000 valve to tank 40. Same as #24 and 25 2000 HL Elliott 41. Add to emergency procedures provision to block in nitric acid tanks coafol u0. u05o 3/81 3/81 Remark* (Include Estimated Costs) AP00036303 i' f / Management A c tio n Needed ategory; |` {Equipment Changes | [Procedural Changes, Inspection 4 PH Items J |Eng Studies 1 [Rejected Action Items from Hazard Review Decomposition of AN Status as of ____________1, 19 ' Page II ofPages Action Status Excessive Heat Input of High Pressure Steam Sensitization of AN by contamination Responsi bility Recomjendations Cost Scott 42. Evaluate 350# Steam to limit pressure LH 2A Rockwell Scott/ Elliott 43.a)Install catch pans for oil and grease on trunnion rollers of drying drums b)Install separator in NH^ line to Permalene to remove oil. 2000 2000 rx ai E *-> On] oa u o. s- B O OM u.oo Remarks (Include Estimated Costs) 3/81 3/81 3/81 AP00036304 9 Category: | {Equipment Changes | "^Procedural Changes, Inspection S PM Items Action Items from Hazard Review |Eng Studies t |Rejected , StatfSfc-. jli" .Pages 1, 19 Management A ction Needed Hqzafd 37. Release of NH* from atmos. ven\ from surge tank or spacing in surge tank with low level ;s. mixinf of Permalene <o t- o o - -m a. a. .< Responsihinty Est. Recommendations Cost L M 3 A Rockwell 37. a) Operator training 1000 b) Install low level alarm on level transmitters at surge tank LM 3 A Rockwell 38. Install exhaust fan from mix tank 2000 AP00036305 >CI GZ UO^DV I C^aoiUd | ^ CL N *HUW**i I 2 I 3: Ve) 2 X so | T3 c a-4 3 eCc '3, 'e -| 33 J ver 3 T3 UJ w a3. t wl <si 4 S jjwOc2Q! f*V Is Z Xp4 S JcMr C=_O o AP00036306 iteg#ry: f {Equipment Changes f Procedural Changes, Inspection & PM Items | ]Eng Studies I '^Rejected Management A ction Needed Action Items from Hazard Review Vessel Rupture - Urea Plant Hazard Rupture of Autoclave Rupture of K,Q. Drum and Decomposer Separator Rupture of Flash Separator XI 4J -o o >- o 4-> co 5D. So. u < Responsi bility Recommendations. HL 2 HL 2 HL 2 30. Continue annual PM check and daily inspections 31. PM on valves BPCV 9 and RV 32. PM on valve PC-7 PCV-4 and PSV 31508 AP00036307 Category; ( |Egviprnent Changes [[^Procedural Changes, Inspection & PH Items | |ng Studies 1 [Rejected ____________i. is_____ Page ^ -0f__ ____ Pages Action Items from Hazard Review Ammonia Release - Urea Action Status Management Action Needed H^iard 18. Operation of Relief Valves '9. Leaks in Equip, t Piping 01 DO O*- T+Jiwo n(-. Qt.- L> Responsi bility Recommendations HM 11 M 28. Same as #20 b 29. Same as #17 nj Oi Mf-rO*. O COe n-m) mUO - 1MA 441J1 u0> O-. 0> 1O Oe 10 KlcJO Remarks (Include Estimated Costs) AP00036308 AP00036309 0 fi 3 a a3i j ^ (Category: c'"i J .-3 a>a>: UO J.13V | < a i. rNo ^iH.^eqoad I ^ iEo. /f;j.a3Aas I Equipment Changes j {Procedural Changes, In s p e c tio n 8 PM Itenis | ^ [ ng S tudies I [R ejected o 3 3 AP00036310 Category; | |Egu1praent Changes | [procedural Changes, Inspection 4 PN Items { Ung Studies | [Rejected , StatK IS of Pago j of Action Items from Hazard Review Vessel Rupture - AN Action Status Hazard >> r- +rJ- _Tc- +J c: *O-A -rOtj oi- *Ov- >01 O U cl *r- au. -uM < Responsihility .Recommendations Cost Est. 21. Rupture from Thermal Expansion #1 Neutraliser of piping that can be blocked in H- - B Scott 21. Study-determine if materials are subject to thermal expansion 12. Rupture of fl Neutralizer L L 3 A Elliott 22. Inspect rupture discs annually Verify if R.D. is adequate size 13. Rupture of vaporizor, super heater on bypass heater 14. Rupture of high concen trator i5. Rupture of storage heaters 83% Nitric-Acid ^0 H L 2 A Elliott H L 2 A Elliott H L 2 A Elliott 23. Install relief devices 5000 24. on steam line 25. on two heaters 83% AN Lower "D" heater to 150# steam Investigate lowering steam header relief pressure vf~i OE .fUJ 0k1E0.V41 con O O <o H U Q U.UQ Pages U 19 Management A ction Reeded AP00036311 Catefpry; [^Equipment Charges [^Procedural Changes, Inspection i PM Items | |Eng Studies | ^Rejected Status as of ________ j\ t ]g Page 2 ofPages Action Itans from Hazard Review Ammonia ReJase (AN Plant) i <V M Hazard +-> >> _c *r- C 01 o > oj (/) o Cik.. +- 4. u CL- *C Responsi bility Recommendations Cost Est. 10. Auto clave let down valve fails open LL 3 10. No action. n. Flash separator flow control fails open LL 3 11. No action. 12. Ammonia flow set high and pH control fails LL3 12. P.M. (See Hazard 3) 13. Excess IlHj due to controller failure on vaporizer LL 3 13. No action 14. Steam supply loss to super heater 15. Failure of control valve TRC 50-7 to super heater 16. flow set too high to process L L 3 A Elliott LL 3 LM3 14. Install low temp, alarm on exit of NH- in superheater 15. Same as 14 2000 16. Install high and low alarm on NH^ flow 2000 Action Status I i Management A c tio n Needed i Category: | [Equipment Changes | "[Procedural Changes, Inspection 6 PH Items [ Ung Studies [ Rejected Action Items from Hazard Review Ammonia Release - AN Plant States 13 of Pagc^^bf .Pages 1, 19 Management A c tio n Needed Hazard 4^ Responsi i/> n. o- ve fai;11ty Cost Recommendations. Fst. 7. Leaks in equipment and piping a) Flanges HM Welds HM Metal failure Valve packing ^ Pump seal failure Failure of tubes due to corrosion in super heater allowing NH^ into condensate LM Water vaporizer tube failure allowing NH^ in CTW Return :o. Release of NH^ from relief valves to NHj weigh tank L M3 HM1 17. a) No action b) No action c) No action d) No action e) No action 18. No action required Elliott 19- No action 2Q-Wlnstail orifice plate on NH, line to weigh tank Rockwell (bXnstall tail pipes on relief valves to get gas away 500.00 AP00036312 Category: | jEquipwent Changes | [Procedural Changes, Inspection & PM Items | [Eng Studies | ~[Rejected Management A ction Needed Action Items from Hazard Review Ammonia Release (AN Plant) Atmospheric Hazard j _cs o J- O 1. ( Responsi ble 1 ty Cost Recommendation; Est. Manual Valve Leak or open in error on 83% Surge Tank Manual Valve Leak or open in error on Ammonia Vent Stack pH controller fails on Neutralizer and Surge Tank Vent Nitric Acid Pump Failure Manual Valve Closed on Nitric Acid Line LM oe wd LH oi wg h LH oi wg il LM oe wd LL oo ww 3 2 A Rockwell Z 3 3 Nitric Acid Flow Control Valve Fails Closed Low Level in Nitric Acid Storage Tank Line Failure-Corrosion Leaks on Nitric Acid Line Line Pluggage LM oe wd LM oe wd LM oe wd LL oo Ww 3 3 3 3 1. No action requiredoperator training 2. Raise stack to height of 10* 500 3. P.M. 4. P.M. 5. No action required. 6. No action required. 7. No action required. 8. No action required. 9. No action required. io *J Q O UrUaWw--0- V v- e *> i- e ** McUon Uo- Oo Qjo AP00036313 I AP00036314 AP00036315 /S J (X M AP00036316 INTEROFFICE MEMORANDUM To Dlstributl on From M. R. Chmura Distribution: K. E. Arnold R. R. Baker J. J. Baliker P. L. T. Brian T. L. Carey J. L. Cost J. F. Dempsey J. K. Derby A. J. Diglio M. W. Ferris P. Fong, Jr. R. E. Gadomskl J. U. Gentile A. E. Greene W. D. Greer R. . Jones &s> ,T 0 - Date 25 September 1980 Schedule-Process Hazard Reviews and formal Plant Safety and Industrial Hygiene Audits_______________________ (Location. Organisation, or Dapartmanl) Chemicals Manufacturing (Location, Organisation, or Dapartmant) M. C. Lee J. F. Marschhauser A. K. McMillan E. F. Moherek R. W. Ormsby D. J. Orr F. J. Ryan R. C. Sander J. A. Saner J. M. Scigliano .H. J. SmithW. J. Stueben J. A. Sykes J. T. Wharton J. M. Wrba The attached two schedules show dates for Process Hazards Reviews (PHR's) and formal Plant Safety and Industrial Hygiene Audits scheduled for Fiscal 1981. A total of twenty three (23) PHR*s have been scheduled. Each facility will receive at least one formal Safety and Industrial Hygiene Audit In Fiscal 1981. These formal audits will monitor safety performance and identify areas where improvements are indicated. Informal audits will also be conducted where needed. Martin R.Chmura MRCrbkl Attachments: 1. Schedule for Process Hazard Reviews. 2. Schedule for Formal Safety and Industrial Hygiene Audits. (3201 AP00036317 SCHEDULE FOR FORMAL SAFETY AND indOstrial HYGIENE AUDITS CHEMICALS GROUP"25 SEPT. 80 Location Calvert City Paulsboro City Of Industry Mi ddlesex St. Gabriel Pasadena Escambia Cleveland Elkton S. Brunswick Employee Safety 6-10 Oct. 80 WJS 10-14 Nov. 80 JWG/HJS 8-12 Dec. 80 JWG 12-16 Jan. 81 HJS 19-23 Jan. 81 WJS 9-13 Feb. 81 WJS 9-13 Mar. 81 WJS 11-15 May 81 WJS 8-12 June 81 WJS 13-17 July 81 WJS Industrial Hyqlene 25-29 Aug. 80 JWG/HJS (completereport Issued) 10-14 Nov. 80 JWG/HJS 8-12 Dec. 80 JWG 12-16 Jan. 81 HJS 19-23 Jan. 81 JWG 9-13 Feb. 81 HJS 9-13 Mar. 81 JWG 11-15 May 81 JWG 8-12 June 81 JWG 13-17 July 81 HJS Enqineerinq Safety 6-10 Oct. 80 MRC 10-14 Nov. 80 JWG/HJS 8-12 Dec. 80 JWG 12-16 Jan. 81 HJS 19-23 Jan. 81 MRC 9-13 Feb. 81 MRC 9-13 Mar. 81 MRC 11-15 May 81 JWG/WJS 8-12 June 81 JWG/WJS 13-17 July 81 WJS/HJS Kev to Auditors < WJS - Bill Stueben JWG - Joe Gentile HJS - Joe Smith MRC - M. R. Chmura AP00036318 (2) ' Faci1ity/Process/Product Calvert City - Catalyst Plant Escambia - Methylamlnes City of Industry - Total Plant Dates Scheduled 7-11 Sept. 81 7-11 Sept. 81 J&e ^ w 14 - 18 Sept. 81 On Hold: Calvert City - PVC Escambia - PVC Notes: (1) Use common team members (2) Use common team members AP00036319