United States
                   Environmental Protection
                   Agency
Air and Energy Engineering
Research Laboratory
Research Triangle Park NC 27711
                   Research and Development
EPA/600/S8-87/0340 Sept. 1989
f/EPA         Project  Summary
                   Prevention  Reference  Manual:
                   Chemical  Specific,  Volume  15:
                   Control of Accidental
                   Releases of Sulfur  Trioxide

                   D. S. Davis, G. B. DeWolf, K. E. Hummel, and J. D. Quass
                    The accidental release of a toxic
                   chemical at Bhopal, India, in 1984 was
                   a milestone in creating an increased
                   public awareness of toxic release
                   problems.  As a result of other,
                   perhaps less  dramatic incidents in
                   the past, portions of the chemical in-
                   dustry were aware of this problem
                   long before this event These same
                   portions of the  industry have made
                   advances in this area. Interest in re-
                   ducing the probability  and conse-
                   quences of accidental toxic chemical
                   releases that might harm  workers
                   within a process facility and people
                   in  the  surrounding  community
                   prompted the preparation of a series
                   of technical manuals addressing ac-
                   cidental releases of toxic chemicals.
                   This project summary is for a chem-
                   ical specific  manual for  sulfur
                   trioxide (SO3). The manual summariz-
                   es information to aid regulators  and
                   industry personnel in identifying  and
                   controlling release hazards associ-
                   ated with SO3.
                    Reducing the risk associated with
                   an accidental release of SO3 involves
                   identifying  some of the potential
                   causes of accidental releases that
                   apply to the process facilities that
                   handle and store the chemical. In this
                   manual, examples of potential causes
                   are identified  as are measures that
                   may  be taken to  reduce   the
                   accidental release risk.  Such mea-
                   sures include recommendations on
                   plant design and maintenance prac-
                   tices. Conceptual cost estimates of
                   example 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
  The accidental release of a toxic
chemical, methyl isocyanate, in  Bhopal,
India, in 1984 was a milestone in creating
an increased public awareness of toxic
release problems. There have been other
less dramatic incidents of toxic chemical
release in  the past,  and  the chemical
industry was aware of this problem long
before  this event.  Safety and  loss
prevention  has long been a standard part
of industry  activity, and over  the years
industry has made many advances in this
area. There is renewed interest, however,
in reviewing technology and procedures
for preventing, protecting against, and
mitigation of accidental releases.
  As an aid to regulators and industry
personnel  charged with  reducing the
probability and consequences of acciden-
tal toxic chemical releases, a series  of
technical manuals were prepared that
address prevention, protection, and  miti-
gation measures for releases. This chem-
ical specific manual  on  sulfur trioxide
(S03) is part of that series.
  S03 is a commodity chemical,  pro-
duced by the catalytic oxidation of sulfur
dioxide (SO2).  Data on the production  of
S03 are not available but, based on the
relative production of surfactants, a use

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of 300 million Ib (136 million kg) per year
of SO3 is estimated for recent years. The
primary use  of S03  is  as a sulfonat-
ing/sulfating agent to produce  anionic
surfactants, including linear alkylbenzene
sulfonates,  alcohol  sulfates, and alcohol
ether sulfates.
  Storage systems for liquid SO3 include
55-gal. (0.21m3) drums and bulk storage
tanks.
  In  addition to anhydrous S03, oleum
(fuming sulfuric acid composed of  sulfu-
ric acid and S03) is also used. This man-
ual focuses primarily on anhydrous S03,
but some considerations  also apply  to
oleum.

Potential Causes of Releases
  Anhydrous  S03  is  a clear,  colorless,
oily liquid with a strong, acrid odor. Liquid
S03  begins to freeze at  around  90°F
(32°C).  S03 is hygroscopic and fumes
upon  exposure to  moist  air. Traces  of
water or sulfuric acid  can catalyze  the
polymerization of   liquid  S03  to  solid
forms that are difficult to remelt.
  Because  liquid anhydrous SO3 has a
large coefficient of  thermal expansion, an
overpressurization  hazard exists if stor-
age  vessels have  insufficient expansion
space or if pipelines full of liquid  S03 are
sealed at both  ends. In these situations,
thermal expansion  of the liquid can  result
in containment failure from the hydrostat-
ic pressure exerted by the liquid.
  Failures leading  to accidental releases
may be broadly classified as due to proc-
ess,  equipment, or operational  causes.
Causes discussed  below  are intended to
be illustrative, not exhaustive.
•  Excess  organic feed  to a  sulfona-
   tion/sulfation reactor leading to exces-
   sive  exothermic reaction, combined
   with failure of the cooling system;
•  Backflow of process  reactants to a
   S03 feed tank;
•  Inadequate  water  removal  from
   organic feeds to the sulfonation/sulfa-
   tion  process over a  long period  of
   time, leading to  progressive corrosion;
• Excess  feeds  in any part of  the
   system, leading to overfilling  or over-
   pressuring equipment;
• Loss of temperature control in cooling
   units (reactor)  or heating  vents
   (vaporizer); and
• Overpressure in S03  storage vessels
   due  to  overheating   or overfilling.
   These  situations  may  be caused  by
   exothermic reactions from contamina-
   tion, fire exposure, or unrelieved over-
   filling.
  Equipment causes  of accidental re-
leases result from  hardware  failures.
Some possible causes include:
•  Excessive stress due to improper fab-
   rication, construction, or installation;
•  Failure of vessels at normal operating
   conditions due to weakening of equip-
   ment from excessive stress, external
   loadings,  or  corrosion. Overheating is
   also a possibility, especially for sulfon-
   ation reactors or S03 vaporizers;
•  Mechanical fatigue and shock  in  any
   equipment. Mechanical fatigue  could
   result from age, vibration, or stress cy-
   cling, caused by pressure  cycling, for
   example.  Shock could occur from col-
   lisions with moving equipment such as
   cranes, or other equipment in process
   or storage areas;
•  Thermal fatigue and shock in sulfona-
   tion reactors  or heat  exchangers;
•  Brittle  fracture in any equipment, but
   especially in  carbon steel equipment
   subjected  to extensive  corrosion
   where  hydrogen embrittlement  from
   hydrogen  release   by sulfuric  acid
   attack may have occurred. Equipment
   constructed of high  alloys, especially
   high strength alloys selected to reduce
   the  weight  of  major  process
   equipment,  might be   especially
   sensitive  where  some  corrosion  has
   occurred,  or  severe   operating
   conditions are encountered;
•  Creep failure in equipment subjected
   to  extreme operational upsets,  espe-
   cially  excess temperatures. This  can
   occur  in equipment subjected to a fire
   that may  have caused damage before
   being brought under control; and
•  All forms  of  corrosion. External cor-
   rosion from fugitive  emissions  of sul-
   furic acid mist could lead to  equip-
   ment weakening.
  Operational  causes  of accidental re-
leases are a result of incorrect operating
and  maintenance procedures of  human
errors, including:
•  Overfilled storage vessels;
•  Improper process system operation;
•  Errors in loading and unloading proce-
   dures;
•  Inadequate maintenance   in  general,
   but especially on water removal unit
   operations, pressure  relief systems,
   and other preventive and protective
   systems;
•  Lack of inspection and nondestructive
   testing of vessels and piping to detect
   corrosion weakening; and
   Incomplete knowledge  of the proper
   ties of a specific chemical, of the pro
   cess, or of the chemical system.
Hazard Prevention and Control
  Prevention of accidental releases relie
on the proper design, construction,  am
operation of facilities where SO3 is storei
and used and on the  protective system
that guard against an accidental release.
  Process  design  involves  the  basi
chemistry of a  process  and how  thi
chemistry is affected by the variables  c
flow, pressure, temperature, compositior
and quantity. Any aspect  of  a  proces
may be modified to enhance the  integrit
of the  system.  Such  changes could ir
volve the quantities of materials, proces
pressure and temperature conditions, th
sequence of  operations,  process contn
strategies, and the instrumentation used.
  Physical  plant  design covers  equip
ment,  siting  and  layout, and  tranj
fer/transport facilities.  Mild steel is ger
erally satisfactory  for storage and har
dling of  S03. Where moisture  may b
present, or for pumps, valves, and oth<
areas of high turbulence, Alloy  20,  3C
SS, or 316  SS is recommended.  Gaske
or packing  should be made of a fluon
carbon material.
  The  siting  and layout of any  facilii
handling S03 and of individual equipme
items should  be designed to reduce  pe
sonnet  exposure during a release. Sitir
should  allow  ready ingress and  egre:
and take advantage of barriers  that n
duce release  exposures.  Considerab
distance between  large  inventories  ar
sensitive  receptors is desirable.  Tt
ground  under process equipment  ar
storage vessels should be sloped so th
fire water and liquid  spillage  flow aw;
from equipment into drains. Storage fac
ities should be located in  cool, dry, we
ventilated areas.
  Because heat  causes signified
thermal expansion of S03 and can lead
thermal decomposition, piping,  storai
vessels, and other equipment should r
be located adjacent to piping contain!
flammable  materials, hot process pipir
equipment, or other sources  of direct
radiant heat. Special consideration shoi
be given to the  location of furnaces a
other permanent sources of ignition in t
plant.
  Protection technologies for containrru
and neutralization include  enclosures a
scrubbers.  Enclosures would capture z
S03 spilled or  vented  from  storage
process equipment, containing the spill
liquid until  it could be transferred to otl

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containment  and discharged  at  a
 ontrolled rate  or  to  scrubbers  for ab-
 jrption.
  Scrubbers can also  be  used for
controlling SO3 releases. S03,  which  is
soluble in sulfuric acid, can be absorbed
into  sulfuric acid in  scrubbing devices
such as spray towers,  packed  bed scrub-
bers, and Venturis.
  If  an  accidental  release  occurs,
mitigation technologies can  reduce the
consequences.  Such  measures  include
physical barriers, water sprays and fogs,
and foams that will divert,  limit, or dis-
perse  the released  chemical  to the
atmosphere. Since S03 reacts exother-
mically with water, water sprays or water-
based foams should be used with caution
when controlling vapors  from  a spill.
Spills  may also  be absorbed  onto
expanded clay or diatomaceous earth.
  Since  accidental releases of  toxic
materials result not only from deficiencies
of  design but  also from  deficiencies  of
operation, safe operation of plants  using
S03  requires  competent,  experienced
managers and staff trained in  the proper
way to handle and store SO3.

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D. S. Daws, G. B. DeWolf, K. E. Hummel, 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 15: Control of Accidental Releases of Sulfur Trioxide," (Order No. PB 89-
  155 055AS; 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/S8-87/0340
                                          *GE«CY

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