United States
                   Environmental Protection
                   Agency
Air and Energy Engineering
Research Laboratory
Research Triangle Park NC 27711
                   Research and Development
EPA/600/S8-87/034n Sept. 1989
&EPA         Project  Summary
                   Prevention  Reference  Manual:
                   Chemical Specific, Volume  14:
                   Control of Accidental
                   Releases of Phosgene

                   D. S. Davis, G. B. DeWolf, S. F. Penrod, and J. D. Quass
                    Interest in reducing the probability
                  and consequences of accidental tox-
                  ic chemical releases that might harm
                  workers within  a  process facility or
                  people in the surrounding community
                  has prompted  preparation  of  this
                  manual and a  series of companion
                  manuals on the control of accidental
                  releases of toxic chemicals. This
                  manual, on phosgene, is one of sev-
                  eral chemical-specific Prevention Re-
                  ference Manuals.
                    Phosgene is a highly reactive and
                  corrosive liquid that has an IDLH (Im-
                  mediately  Dangerous to Life  and
                  Health) concentration of 2 ppm, mak-
                  ing it an acutely toxic hazard.
                    To reduce the risk of an accidental
                  release of phosgene,  the potential
                  causes of releases in facilities handl-
                  ing phosgene must be identified. The
                  phosgene manual provides examples
                  of such causes, as well as of mea-
                  sures  that may be taken to reduce
                  the accidental release  risk. Such
                  measures  include  recommendations
                  on plant design practices; prevention,
                  protection, and mitigation techno-
                  logies; and operation and mainten-
                  ance  practices. Cost estimates of
                  prevention, protection, and mitigation
                  measures are provided.
                    This Project Summary was devel-
                  oped by EPA's  Air and  Energy Engi-
                  neering Research Laboratory,  Re-
                  search Triangle Park, NC, to announce
                  key findings of the research project
                  that is fully documented in a separate
                  report of the same title (see Project
                  Report ordering information at back).
Introduction
  Increasing concern about the potential-
ly disastrous consequences of accidental
releases of toxic chemicals has prompted
preparation of a series of manuals  for
regulators and industry personnel on  the
prevention of accidental releases of toxic
chemicals.  The  manual on phosgene is
one of several chemical-specific manuals
that address  issues associated with  the
storage, handling, and process operations
involving toxic chemicals as they  are
used in the U.S.
  In the U.S. and abroad, few significant
releases of phosgene have  occurred;
however, in Hamburg, Germany, in 1928
a phosgene storage tank failed, killing 10
people, and in LaPorte, Texas, in 1969 an
accidental phosgene release at a chemi-
cal plant injured 2 people.
  Phosgene is manufactured commer-
cially by reacting carbon  monoxide with
chlorine over a carbon catalyst. Most of
the phosgene produced is used captively
at the production facility, although it is
also shipped in  150-lb (68kg) and 1-ton
(907 kg) cylinders. In  the U.S., 85% of
the phosgene produced is used in  the
manufacture of  isocyanates,  which  are
precursors of polyurethane foam and rub-
ber. Phosgene is also used  in the pro-
duction  of  polycarbonates and specialty
chemicals such as herbicides, pesticides,
dyes, and Pharmaceuticals.


Potential Causes of Releases
  Phosgene releases can originate from
many sources, including ruptures in proc-
ess  equipment, separated flanges, actu-

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ated relief  valves or rupture discs, and
failed pumps or compressors. Phosgene
is not explosive or flammable; however, it
is highly reactive and highly toxic when
inhaled. When  inhaled, phosgene slowly
hydrolyzes to  hydrochloric  acid  in  the
respiratory system.
  The  reactivity of  phosgene makes  it
corrosive. Evaporators and metering and
control equipment are especially sensi-
tive if they are  in intermittent use where
moisture might enter the system. Either
liquid or vapor phosgene releases can
occur.  Failures  leading to accidental re-
leases of phosgene can be due to proc-
ess, equipment, or operational causes.
  Possible process causes of phosgene
releases include:
• Overpressure of any storage or proc-
  ess vessel containing phosgene, caus-
  ed by decomposition of phosgene to
  hydrogen chloride and carbon dioxide
  from contamination with water;
• Overpressure of  storage  or process
  vessels  containing phosgene caused
  by contamination  of  other phosgene
  reactive materials;
• Excess  phosgene feed   leading  to
  overfilling or overpressuring of equip-
  ment;
• Loss of agitation  in batch reactor sys-
  tems;
• Loss of cooling or temperature control
  of reactor systems resulting in thermal
  decomposition; and
• Loss of pH  control in caustic  slurry
  reactors resulting in the decomposition
  of  phosgene to  carbon dioxide and
  hydrochloric acid, which  could result
  in  overpressure and  an  accidental
  release.
  Equipment-caused accidental releases
result from hardware failure  (e.g., exces-
sive stress due to  improper fabrication,
construction, or installation); weakening of
equipment  from excessive  stress, exter-
nal  loading,  or corrosion;  mechanical
fatigue and shock; creep failure in equip-
ment subjected to  extreme  operational
upsets, especially excess  temperature;
stress corrosion cracking; and all forms of
corrosion.
  Operation-caused accidental  releases
result from incorrect operating and main-
tenance  procedures or human errors
such as:  overfilled storage vessels; errors
in loading and  unloading procedures;  in-
adequate maintenance; lack of inspection
and non-destructive testing  of vessels
and piping to detect corrosion weakening;
and incomplete knowledge of the prop-
erties of a specific  chemical or of the
process or chemical system.


Hazard Prevention and Control
  The  prevention of accidental releases
depends on a combination of technologi-
cal, administrative, and operational prac-
tices that apply to the design, construc-
tion, and  operation  of facilities where
phosgene  is  stored and used. Important
areas to be considered are process de-
sign, physical plant design, operating and
maintenance  practices, and protective
systems.
  The primary focus of process design is
on how the process is controlled in terms
of the  basic  process  chemistry  and the
variables of flow, pressure, temperature,
composition,  and level. The process de-
sign must be  evaluated to see how devia-
tions from  expected  design conditions
might start a  series of events that could
result in an accidental release. A review
of the variables of process  design might
lead to suggested  modifications  that
would enhance the integrity of the proc-
ess, such as changes  in quantities of ma-
terials used, process pressure and temp-
erature  conditions, unit operations used,
the sequence  of operations,  process
control  strategies, and the  instrumen-
tation used.
  Physical  plant  design involves plant
equipment, siting and  layout, and trans-
fer/transport facilities. The most important
considerations  in selecting  equipment
construction materials for phosgene  ser-
vice are the  temperature and  moisture
content of the phosgene. Temperature is
important because phosgene decompos-
es  to carbon monoxide and chlorine at
high temperatures, and most metals will
ignite at a given temperature in the pres-
ence of chlorine. Moisture  content is
important  because  moist  or wet phos-
gene  hydrolyzes to  hydrochloric  acid,
which is very corrosive. Dry phosgene is
not considered corrosive.
  Because of the large inventories  con-
tained in phosgene storage vessels, they
are one of the most hazardous parts of a
phosgene system. A variety of safety fea-
tures are usually incorporated into phos-
gene storage vessels. Overpressure  pro-
tection devices are routinely  routed to a
containment vessel or to a caustic scrub-
ber. With liquid phosgene, overfilling and
overheating are important because of the
liquid's  high  coefficient  of  thermal
expansion. Since there is  no  way to
contain a  phosgene discharge  from
vessels used to transport phosgene  (150-
and 2000-lb cylinders),  great care  muj
be taken in transporting and storing thes
vessels; exposure to temperatures abov
125°F (52°C) must be avoided.
  Overfilling can be prevented  by usini
level sensing devices, pressure relief de
vices, and  adequately trained personne
Selection of such devices must take int
account the corrosiveness of phosgene
especially in contact with  moisture.  Con
tainers  should  be  valved to  allow th
vessel to be isolated from the process t
which the phosgene is being fed.
  The design  of piping systems shoul
be  simple, minimizing  the number c
joints  and connections.  Pipes  should b
sloped,  and drainage should be provide
at low points. When applicable, an expan
sion chamber should  be installed t
prevent  a rupture caused  by thermal e>
pansion.
  The siting of facilities  and  individu;
equipment  should  minimize  personn<
exposure during a release. Ready ingres
and egress should  be  available in  a
emergency. Large  inventories  of phos
gene should be kept away from  potenti;
sources of fire or  explosion.  Phosgen
piping should  not be located adjacent I
other  piping  under high pressure c
temperature. Storage facilities  should b
segregated from the main process an
from control rooms, offices, utilities, sto
age, and laboratory areas.
  Protection technologies for phosgeni
or those measures taken to capture <
destroy  the chemical if it has  breache
primary containment, include enclosure
scrubbers,  incinerators, and flares. Enck
sures can  capture  phosgene  spilled <
vented  from storage or process equi|
ment, thereby  preventing  immediate di;
charge  of  the  chemical to the  enviroi
ment. Although specially designed encli
sures for  phosgene service  have n
been  widely  used, such containme
structures  equipped  with monitorir
equipment  and alarms might be appropi
ate. The enclosures should be gastig
and have  a ventilation system  designe
to draw  in air when  the building is vente
to a scrubber. The bottom  section
such a  building should be liquidtight
retain spilled liquid phosgene.
  Scrubbers are a traditional way to al
sorb toxic  gases from process  stream
Types of scrubbers that might be appr
priate for phosgene include spray towei
packed  bed scrubbers, and Venturis.
  Incinerators  can  be  used to  contr
phosgene releases from vents and  pre
sure  relief discharges,  from  proce
equipment, and from   secondary  co

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tainment  structures.  Phosgene dis-
|harges could be mixed with fuel and air
  a thermal oxidation unit to convert the
toxic  vapor to  carbon monoxide and
chlorine since phosgene decomposes  to
these gases at 1,472°F (800°C). The
system must be constructed of corrosion-
resistant materials. Also,  an  acid-gas
scrubber would  be needed to remove the
hydrogen chloride and  chlorine from the
vent gases.
  Flares must  be  so  designed  that  a
large  phosgene  release would  not over-
whelm them and lead to a flame blowout
or to  a temperature insufficient to  com-
pletely destroy  the  phosgene. An acid-
gas scrubber would  also  be required  for
this system.
  If a large release of phosgene  occurs,
workers must be rescued from the imme-
diate  vicinity of the accident and people
downwind of the release must be evacua-
ted. The effects of the released chemical
on the plant and community must be mit-
igated by  such  measures  as physical
barriers,  water  sprays and fogs, and
foams, where applicable. Such  mitigation
measures  divert, limit,  or disperse the
chemical that has been spilled  or releas-
ed to  the atmosphere.
  The foregoing techniques for prevent-
ing, containing,  or mitigating an acciden-
al release  of phosgene must also  be
supported by management safety policy,
training, and proper operating and main-
tenance procedures.

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D. S.  Daws, G. B. DeWolf, S. F. Penrod, and J. D. Quass are with Radian Corp.,
  Austin, TX 78766.
T. Kelly Janes is the EPA Project Officer (see below).
The complete report, entitled "Prevention Reference Manual: Chemical Specific,
  Volume 14: Control of Accidental Releases of Phosgene," (Order No. PB 89-155
  0481 AS; Cost: $21.95, subject to change) will be available only from:
        National Technical Information Service
        5285 Port Royal Road
        Springfield, VA 22161
        Telephone: 703-487-4650
The EPA Project Officer can be contacted at:
        Air and Energy Engineering Research Laboratory
        U.S. Environmental Protection Agency
        Research Triangle Park, NC 27711
United States
Environmental Protection
Agency
Center for Environmental Research
Information
Cincinnati OH 45268
Official Business
Penalty for Private Use $300

EPA/600/S8-87/034n
        00006583

        "fP
         CHICAGO

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