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Designing and installing automated systems for chemical unloading   Other than a particulate filter, the fresh air intake that supplies
        areas provides additional safeguards to unloading processes as the   air to the control room does not include filtration or cleaning
        systems automatically shut down valves supplying chemicals to bulk   systems to effectively remove the chlorine gas or other gases from
        or day tanks in the event of an unintended reaction or tank overflow.   the outside air. Though shutting off ventilation systems during a
        At MGPI, such an automatic shutoff device would have stopped the   toxic release can the reduce impact on control room occupants,
        flow of sulfuric acid that was reacting with the sodium hypochlorite   the cloud had entered through the Mod B building intake before
        in the bulk tank long before emergency responders closed the   operators became aware of the release. MGPI had outdoor air
        discharge valve on the Harcros truck nearly 45 minutes later.   monitors near the Mod B tank farm to detect concentrations of

                                                                propylene oxide only. If the propylene oxide concentrations reached
        5.3    MOD B VENTILATION                                a predefined set point, an alarm would sound in the control room

        The CSB found that the pre-incident design of the Mod B   and operators were required to shut down the ventilation system
        building and ventilation system allowed for the intake of   per the emergency action plan. The HVAC intake system had no
        the cloud produced by the reaction, which forced operators   toxic gas alarms that would have warned operators to don escape
        to evacuate. Because the gases produced by the reaction   respirators before the gases could enter through the vents.
        overwhelmed the operators in the control room, they were forced

        to evacuate and did not have time to retrieve their emergency   In 2003 the CSB investigated a release of chlorine gas from the
        escape respirators to protect them from respiratory hazards   Honeywell International, Inc. (Honeywell) chemical plant in Baton
        associated with even higher chemical concentrations outside.   Rouge, Louisiana, which resulted in injuries to seven workers and
                                                                the issuance of a shelter-in-place advisory for residents within
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        The Mod B building has a positive pressure control room,   a 0.5-mile radius.   The chlorine was released from a failed
        designed only to prevent harmful gases from the adjacent indoor   coolant system and, as in the MGPI incident, entered an occupied
        process area from entering the control room. Positive pressure is   control room through the ventilation system. The CSB found
        achieved by maintaining a higher air pressure in the control room   that the Honeywell release lasted 3.5 hours, partly because
        than in the indoor process area. MGPI’s heating, ventilation, and   operators were forced to evacuate the area before they could

        air conditioning (HVAC) system for Mod B has a 4-ton air handler   diagnose the problem and isolate the source of the leak.
        with a high-speed motor that draws air from two intakes located
        on the exterior of the Mod B building. One of these intakes is   As with MGPI, the Honeywell control room was positive pressure and
        located on the first level of the structure, adjacent to the tank farm   designed to prevent the infiltration of hazardous gases. However,
        and bulk chemical transfer area. A gauge constantly reads and   unlike the Mod B building at MGPI, which only maintained positive
        compares the air pressure inside the control room to that in the   pressure relative to the production area, the Honeywell control
        production area. If the pressure in the control room drops below   room was designed to maintain a higher pressure than the outside

        that in the production area, an alarm alerts operators to evacuate.   atmosphere. Because Honeywell attempted to prevent vapors from
                                                                outside entering the control room, the ventilation system intakes
        Although MGPI designed the control room to protect      were located at the highest point of the plant to pull in fresh air. The
        occupants from harmful vapors inside the production area,   CSB found, however, found that the positive pressure control system
        design considerations did not include protecting occupants   did not protect personnel or equipment during the 2003 release.
        from harmful gases or vapors from outside the building.   At Honeywell, the CSB observed holes and gaps in the HVAC intake
        Because MGPI received and stored a number of hazardous   ducts located on the roof, which allowed chlorine to be drawn into
        chemicals in the chemical unloading area and tank farm,   the building during the release. In addition, the Honeywell control
        any vapors from tank trucks unloading or from any vents or

        pressure release devices on the tanks could enter the control   85   CSB. Honeywell Chemical Incidents. August 8, 2005. http://www.csb.gov/
        room through any doors, open crevices, or air intakes.     investigations/completed-investigations/?F_InvestigationId=54 (accessed October 3,
                                                                   2017).
        24  CSB MGPI Processing Case Study
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