Text For Citation: 02 Item/Group: 001B Hazard: CHEMICAL

Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to the hazards of runaway chemical reactions which were not controlled by existing chemical processing equipment: BLDG 266: THE EMPLOYER FAILED TO PROVIDE ADEQUATE CHEMICAL PROCESSING EQUIPMENT AND SAFETY SYSTEMS TO CONTROL A VIOLENT CHEMICAL REACTION WHICH DETONATED AND/OR DEFLAGRATED WHEN CHEMICALS WERE ALLOWED TO REACT AND CAUSE A RUNAWAY REACTION WITH THE EVOLUTION OF A TOXIC GAS. AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE METHOD TO CORRECT THIS HAZARD IS TO CONDUCT A CRITICAL REVIEW OF THE CHEMICAL PROCESSING SAFETY SYSTEMS REQUIRED TO DESIGN AND/OR REDESIGN AND CONSTRUCT AND/OR RECONSTRUCT AN EXPERIMENTAL EXPLOSIVES MANUFACTURING SYSTEM THAT PROVIDES MAXIMUM SAFETY FOR EMPLOYEES. THE REVIEW, DESIGN AND CONSTRUCTION WILL INCLUDE BUT NOT NECESSARILY BE LIMITED TO THE FOLLOWING: A. AN OXIDIZER ADDITION SYSTEM THAT IS CONTROLLED INSTRUMENTALLY AS WELL AS MANUALLY AND IS 1. INTERLOCKED WITH THE REACTOR AGITATOR SHAFT TO AUTOMATICALLY SHUT DOWN THE ADDITION IN THE EVENT OF AGITATION LOSS TO PREVENT THE CONCENTRATION OF REACTANTS IN ONE AREA OF THE REACTOR, THAT COULD SUDDENLY AND VIOLENTLY REACT CAUSING A RUNAWAY CHEMICAL REACTION WHICH COULD DETONATE AND/OR DEFLAGRATE. 2. INTERLOCKED WITH CHILLING SYSTEM (CITY WATER AND/OR GLYCOL) TO STOP OR RETARD THE REACTION TO PREVENT DETONATIONS AND DEFLAGRATIONS CAUSED BY SUDDEN INCREASE IN TEMPERATURE. 3. INTERLOCKED WITH A PRODUCT HIGH TEMPERATURE SENSOR TO SHUT DOWN THE ADDITION PROCESS IN THE EVENT OF A RAPID EXOTHERMIC REACTION THAT IS NOT BEING CONTROLLED BY THE CHILLING SYSTEM. 4. INTERLOCKED WITH A PRODUCT LOW TEMPERATURE SENSOR TO SHUT DOWN THE ADDITION SYSTEM IN THE EVENT OF A TEMPORARY (AS ON START UP, FOR EXAMPLE) ENDOTHERMIC CONDITION TO PREVENT THE CONCENTRATION OF REACTANTS WHICH COULD SUDDENLY REACT AND DETONATE OR DEFLAGRATE ONCE THE IDEAL REACTION TEMPERATURE IS ACHIEVED. 5. INTERLOCKED WITH BUILDING ELECTRICAL AND COMPRESSED AIR SYSTEMS SO THAT LOSS OF SERVICE WILL SHUT DOWN ADDITION SYSTEM. B. INSTRUMENTATION AND RECORDING SYSTEM THAT WILL SENSE AND PERMANENTLY RECORD TIME AND CRITICAL PARAMETERS INCLUDING BUT NOT LIMITED TO: 1. PRODUCT TEMPERATURE 2. COOLING JACKET INLET AND OUTLET TEMPERATURES 3. REACTOR PRESSURE (POSITIVE AND NEGATIVE) 4. AGITATOR REVOLUTIONS PER MINUTE 5. OXIDIZER ADDITION RATE 6. CITY WATER LINE PRESSURE 7. GLYCOL LINE PRESSURE 8. OPENING AND CLOSING OF DROWN VALVE 9. AIR LINE PRESSURE 10. GAS EVOLUTION IN THE REACTOR C. A MULTIPHASED EMERGENCY RELIEF SYSTEM SIZED AND DESIGNED ACCORDING TO RECOGNIZED CURRENT TECHNOLOGY SUCH AS THAT PUBLISHED BY THE DESIGN INSTITUTE OF EMERGENCY RELIEF SYSTEMS (DIERS) OF THE AMERICAN INSTITUTE OF CHEMICAL ENGINEERS. D. AN AUTOMATIC AND MANUAL DROWN SYSTEM BASED UPON CRITICAL TEMPERATURES AND PRESSURES. THE VALVING SHALL BE "FAIL SAFE" IN THAT THE VALVE IS NORMALLY OPEN AND IF FAILURE OF THE CONTROL SYSTEM SHOULD OCCUR THE VALVE WILL FAIL IN THE OPEN POSITION ALLOWING THE CONTENTS OF THE REACTOR TO DUMP AND THE REACTION BE QUENCHED. THE AUTOMATIC VALVE SHALL BE SO DESIGNED THAT IT CANNOT BE EASILY MANUALLY OVERRIDDEN. E. ALL CRITICAL PARAMETERS WILL BE ALARMED WITH VISUAL OR AUDIBLE ALARMS TO WARN EMPLOYEES OF IMPENDING DANGER AND ALLOW THEM SUFFICIENT TIME TO TAKE APPROPRIATE ACTION TO PROTECT THEMSELVES. F. REMOTE OPERATION. ALL CRITICAL OPERATIONS (OXIDIZER ADDITION FOR EXAMPLE) MUST BE AUTOMATED AND CAPABLE OF BEING OPERATED FROM A REMOTE, SAFE LOCATION. MONITORING OF THE REMOTE OPERATION SHALL BE DONE BY CLOSED CIRCUIT TELEVISION. THE REMOTE SYSTEM MUST BE UTILIZED WHENEVER A NEW OR REVISED PROCESS IS ATTEMPTED AND MUST BE CONTINUALLY USED UNTIL THE EMPLOYER CAN DEMONSTRATE THAT THE CHEMICAL REACTIONS INVOLVED IN THE PROCESS CAN BE CONTROLLED BY THE EXISTING SAFETY SYSTEMS. G. ALL INSTRUMENTS, RECORDERS, ALARMS AND CONTROLLERS WILL BE CALIBRATED QUARTERLY. IN THE EVENT THE SAFETY SYSTEM IS DISRUPTED, ALL COMPONENTS WILL BE CALIBRATED BEFORE THE PROCESSING SYSTEM IS USED AGAIN. H. A BACK-UP AGITATION SYSTEM SHOULD BE DEVELOPED, WHEREBY IF THERE IS LOSS OF ONE AGITATION SYSTEM, THE OTHER WOULD CONTINUE TO OPERATE TO PRESENT BUILD UP OF REACTANTS WHICH COULD CAUSE DETONATION.