Reglas de Oro: Cloro Álcali
Reglas de Oro: Cloro Álcali
Chlor-Alkali
The American Institute of Chemical Engineers (AIChE) and the Center for Chemical Process Safety (CCPS)
express their appreciation and gratitude to all members of the Golden Rules of Process Safety for Specific
Technologies project subcommittee for their generous efforts in the development and preparation of this
important guideline. CCPS also wishes to thank the subcommittee members’ respective companies for
supporting their involvement during the different phases in this project.
Subcommittee Core Team Members:
Chris Devlin, Chair Celanese
Warren Greenfield CCPS Staff Consultant
Denise Albrecht 3M
Walt Frank CCPS Emeritus
Paul Gathright Ascend Performance Materials
David Greganti Dow
Mike Hazzan Acutech
Ng Erm Huay Petronas
Louisa Nara CCPS
Cathy Pincus ExxonMobil
Jatin Shah BakerRisk
Scott Wallace Olin
Subcommittee Chlor‐Alkali Team Members:
Scott Wallace, Lead Olin
Paul Damico Monsanto
Claudia Paarmann Dow
Juergen Merrath Dow
Warren Greenfield CCPS Staff Consultant
The collective industrial experience and know‐how of the team members make this guideline
especially valuable to those who develop and manage process safety programs and management systems.
Before publication, all CCPS guidelines are subjected to a peer review process. CCPS gratefully
acknowledges the thoughtful comments and suggestions of the peer reviewers. Their work enhanced the
accuracy and clarity of this guideline.
Peer reviewers for the Golden Rules of Process Safety for Chlor‐Alkali:
Don Abrahamson Global Process Safety
Jamie Viancos Oxychem
Although the peer reviewers provided comments and suggestions, they were not asked to endorse
this guideline and did not review the final manuscript before its release.
Copyright: American Institute of Chemical Engineers
The Center for Chemical Process Safety was established by the American Institute of Chemical Engineers
in 1985 to focus on the engineering and management practices to prevent and mitigate major incidents
involving the release of hazardous chemicals and hydrocarbons. CCPS is active worldwide through its
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e‐mail [email protected], or visit www.aiche.org/ccps
This document is made available for use with no legal obligation or assumptions (i.e. use at your own
risk). Corrections, updates, additions, suggestions & recommendations should be sent Dr. Anil Gokhale,
Sr. Director CCPS Projects at [email protected]
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site for the current release. https://www.aiche.org/ccps/tools/golden‐rules‐process‐safety
It is sincerely hoped that the information presented in this document will lead to an even more
impressive safety record for the entire industry; however, neither the American Institute of Chemical
Engineers, its consultants, CCPS Technical Steering Committee and Subcommittee members, their
employers, their employers' officers and directors, and its employees warrant or represent, expressly or
by implication, the correctness or accuracy of the content of the information presented in this
document. As between (1) American Institute of Chemical Engineers, its consultants, CCPS Technical
Steering Committee and Subcommittee members, their employers, their employers' officers and
directors, and its employees and subcontractors, and (2) the user of this document, the user accepts any
legal liability or responsibility whatsoever for the consequence of its use or misuse.
Copyright: American Institute of Chemical Engineers
Golden Rules for Chlor-Alkali
Why:
Nitrogen Trichloride (NCl3) is more explosive than ammonium nitrate.
Pure liquid NCl3 is capable of generating a detonation pressure of 543,200 kPa (5361 atm) [1].
A typical chlorine vessel with a wall thickness of ½ inch (1.27 cm) can be fractured with the
detonation of a NCl3 film thickness of 1.5 gm/cm2 [1].
NCl3 is an unwanted by-product commonly found in chlorine manufacturing facilities and chlorine
product. A chlorine producer or consumer has to be aware of NCl3 when handling chlorine because
it should be assumed it is always present.
NCl3 is formed when chlorine produced in the electrolytic process reacts with amines in the brine
feed stream. Precautions should be taken to remove or keep amines out of the electrolytic process
[1].
NCl3 will concentrate/accumulate in the liquid phase as chlorine vaporizes
NCl3 is highly soluble in liquid Chlorine [1].
NCl3 has a higher boiling point than Chlorine and can concentrate as Chlorine is vaporized [1]
[2].
NCl3 concentrations of above approximately 2 wt.% can decompose with rapid pressure rise
and explosive force [1] [2].
Incident History:
An explosion occurred in a purification system due to accumulation of NCl3. The explosion
destroyed the purification system and damaged several other pieces of equipment in the
general area. One chlorine area technician was injured and hospitalized. The explosion resulted
in a chlorine and chloroform emission to the atmosphere. Most equipment fragments came to
rest within a radius of 30 m (100 feet) but some fragments traveled more than 60 m (200 feet).
The entire facility was shut down because of damage to the electrical system caused by the
debris from the explosion [3] [4].
A plant operator was preparing to disconnect a liquid chlorine blowdown drum with a
maintenance technician standing alongside. As the operator closed an isolation valve in the
system, an explosion (caused by detonation of NCl3) occurred in the low point of a flexible
copper tube connecting the liquid chlorine blowdown piping to the liquid filling point on the
drum. The operator and maintenance technician suffered lacerations from fragments of
copper tube and after treatment returned to work on the same day. The Blowdown System
Investigation Team decided that a laboratory analysis of the contents of the precooler was
required to determine the NCl3 concentration. At the completion of the evaporation step and
in the process of dismantling the sample apparatus an explosion occurred. This shattered the
apparatus and knocked the chemist to the floor. The chemist was in hospital for one week and
returned to work approximately two months after the incident [3] [4].
How — General:
Ensure that the NCl3 concentration is kept below the recommended Chlorine Institute and
EuroChlor guidance level for the specific container size being used [1] [4].
Small containers (1 ton or less) are not likely to contain enough NCl3 to spontaneously
decompose and produce significant pressure rise if the product chlorine is within NCl3
acceptable ppm specification levels [4].
Larger containers (greater than 1 ton) need to have much lower initial NCl3 levels if the product
chlorine to be unloaded by evaporation Both Chlorine Institute and EuroChlor recommend
liquid unloading for chlorine containers greater than 1 ton to prevent dangerous
concentrations of nitrogen chloride from accumulating in these large containers [1] [4].
How — Managers:
Identify published guidance on safe handling of NCl3, such as provided by the Chlorine Institute
and EuroChlor, and establish formal internal standards, limits, and procedures for controlling
nitrogen trichloride concentrations [1] [4].
Conduct periodic audits of procedures and standards to ensure they are followed and maintained.
Manage all changes made to manufacturing processes or sources of raw materials, such as with a
formal Management of Change (MOC) system [1].
Establish limits for allowable NCl3 concentrations in the chlorine processes and chlorine product
[1].
Establish limits for allowable nitrogen containing materials (such as amines) in brine systems or
systems feeding into brine systems [1].
Have systems in place to monitor contaminants in brine systems and NCl3 concentrations in
product chlorine [1].
Golden Rule #2: Always understand/know the allowable moisture/water content for the Dry
Chlorine System.
Why:
Dry chlorine systems often use carbon steel as material of construction and higher moisture causes
higher rates of corrosion in carbon steel pipes & equipment [6].
Iron reacts with chlorine to form a protective ferric chloride layer which is very hygroscopic,
this layer needs to stay solid to protect the carbon steel from corrosion. As long as the partial
pressure of moisture in the chlorine gas is less than the vapor pressure of the relevant ferric
chloride hydrate, the hydrate stays in a solid form [7] [8] [9].
The water content, temperature, and pressure of the chlorine gas determine the hydration rate
[7] [8] [9].
Moisture in cold sections of chlorine vapor systems can form hydrates, which can lead to pluggage
or corrosion. Liquid systems are vulnerable to pluggage issues and corrosion due to hydrate
formation
High moisture increases ferric chloride hydrate formation, lowers melting point of layer, and
results in rapid corrosion
Incident History:
A spare chlorine recycle line was put in service while the main line was undergoing
maintenance. Shortly afterwards, it developed a leak resulting in the release of 1,800 lbs. of
chlorine. The subsequent investigation revealed the spare chlorine line had moisture in it,
which resulted in corrosion and subsequent hole in the piping [10].
A tube failure in a heat exchanger allowed water to mix with the chlorine going into a storage
tank. The corrosive liquid began to attack rapidly the steel piping system. Subsequent
investigation showed that the water contaminated liquid chlorine had damaged the valve on
the discharge side of the transfer pump, allowing a continuous supply of chlorine from the
contaminated storage tank to reach the leak. An estimated 70 tons of chlorine escaped. Over
200 persons were examined at a local hospital for respiratory distress and approximately 30
were admitted for treatment. It is estimated that 700 individuals were taken to shelters and
2,000 to 7,000 individuals evacuated elsewhere [11]
During a plant start-up of a metals-chlorine facility, a reaction occurred in the purification tower
causing it to exceed its design pressure and blowing a rupture disc set for 85 psig. Within a few
seconds, the piping around the rupture disc failed, releasing chlorine to the atmosphere. Within
a few minutes, the insulation around the tower melted and caught on fire. The investigation
team concluded that heat was initially generated by a chlorine-water (hydrolysis) reaction. The
rust particles still present in the tower packing helped to catalyze the chlorine and oil reaction,
which also generated heat. With sufficient amounts of water and oil reacting, a spot in the
tower got sufficiently hot to initiate the reaction between the chlorine and the packing [10]
How — Managers:
Identify published guidance, such as provided by the Chlorine Institute and EuroChlor, and
establish formal internal standards, limits, and procedures for controlling moisture concentrations
[7] [9].
Conduct periodic audits of procedures and standards to ensure they are followed and maintained.
Manage all changes made to chlorine processes and related procedures, such as with a formal
Management of Change (MOC) system.
Establish limits for allowable moisture in chlorine (including chlorine air/nitrogen systems) [7] [9].
Have procedures in place for monitoring and testing for moisture.
Ensure training is conducted pertaining to the concerns/hazards of moisture in chlorine and the
allowable moisture limits.
Specify moisture limits and dew point requirements for air and nitrogen used as inerting or
padding gases in dry chlorine systems [6] [14] [15] [16].
Develop procedures to ensure that chlorine systems are kept dry.
Golden Rule #3: Do Not Allow Chlorine to Come into Contact with Organic Oils and Greases.
Why:
Chlorine is a strong oxidizer. It reacts violently with most organic oils and greases and can result in
a fire or explosion especially at elevated temperatures [13] [18].
Chlorine reacting with organic oils and grease can quickly initiate chlorine/steel fires [13] [18].
Small quantities of organics such as grease on a gasket can result in fires, damaging piping,
gaskets, etc. resulting in chlorine releases [13] [18].
Explosions can result if larger amounts of organics come in `contact with chlorine [13] [18].
New piping and equipment when not cleaned properly can contain cutting and fabrication
oils/greases.
Incident History:
Approximately 750 pounds of chlorine escaped when the suction chiller vessel for a chlorine
compressor failed. The failure was caused by an iron-chlorine fire causing a hole in the vessel.
The vessel had just been repacked and the failure occurred during the start-up phase of the
process. Investigators determined that the pall ring packing was contaminated with mineral oil
and moisture on the pall ring packing. The probable cause of the incident was a chlorine/steel
reaction. This reaction was likely caused by elevated temperatures due to the presence of oil
and water, which initially reacted with chlorine [10].
During a plant start-up of a metals-chlorine facility, a reaction occurred in the purification tower
causing it to exceed its design pressure and blowing a rupture disc set for 85 psig. Within a few
seconds, the piping around the rupture disc failed, releasing chlorine to the atmosphere. Within
a few minutes, the insulation around the tower melted and caught on fire. The investigation
team concluded that heat was initially generated by a chlorine-water (hydrolysis) reaction. The
rust particles and oil still present in the tower packing helped to catalyze the chlorine and oil
reaction, which also generated heat. With sufficient amounts of water and oil reacting, a spot
in the tower got sufficiently hot to initiate the reaction between the chlorine and the packing
[10].
How — General:
All equipment and packing must be free of organic materials, oils, and greases before use in
chlorine service [8] [14] [18].
Equipment and components need to be properly cleaned, identified as cleaned, dried, and
packaged prior to chlorine service. A certificate of “cleaned for chlorine service” should be provided
[8] [14] [18].
How — Managers:
Identify published guidance such as provided by the Chlorine Institute and EuroChlor, and establish
formal internal standards and procedures on the use/avoidance of organics in chlorine service [8]
[14] [18].
Conduct periodic audits of procedures and standards to ensure they are followed and maintained.
Conduct periodic audits of suppliers and repair facilities to ensure understanding and compliance
with the “clean for chlorine service” standards and procedures.
Manage all changes made to chlorine equipment and related procedures, such as with a formal
Management of Change (MOC) system.
Establish Quality Assurance procedures that to address positive material identification (PMI) and
control for oils and greases used in chlorine service.
Establish Quality Assurance procedures are in place to inspect and confirm that piping, vessels, and
equipment are “clean for chlorine service” [14] [19] [20]
Ensure that training for “clean for chlorine service” procedures are conducted and for
understanding of the concerns associated with reactivity of chlorine with organic materials.
Why:
Carbon steel will burn (spontaneously) in the presence of chlorine at approximately 250 °C (482 °F)
[18].
The ignition temperature of steel in chlorine depends on several things including surface area and
impurities. For example, dry steel wool will ignite at approximately 50 °C (122 °F) [18].
Typical steam distribution systems in most industrial plants will have temperatures in excess of
200°C (392 °F) and can create chlorine / steel fires in vaporizers and reboilers [15] [16].
Mechanical components can be subjected to localized high temperatures in chlorine compressors
[21].
Incident History:
Approximately 7,900 pounds of chlorine were released when a new multi-stage centrifugal
chlorine compressor failed undergoing its final checkout prior to being started. The chlorine
was released when a 12 inch hole on the compressor developed as a result of a chlorine-iron
reaction. The investigation concluded the fire was initiated due to design issues (clearances too
tight) associated with the new compressor [10].
Welders had just completed welding a short section of two-inch (5.1 cm) carbon steel pipe
attached to a long insulated carbon steel chlorine line. The weld that joined the new section of
piping was about six inches (15.2 cm) from the adjacent thermal insulation that covered the
long chlorine line. After completion, an operator/loader pressurized the long carbon steel line
with dry air and determined it was leak-free. He then opened the valve connecting the new two
inch line to the chlorine gas line. Within seconds the pipe caught fire and the escaping gases
roared like a jet with a brownish-orange plume of ferric chloride. The operator extinguished
the fire by closing the valve which stopped the chlorine feed. The subsequent accident
investigation determined that the fire started, not at the weld, but under the adjacent insulated
pipe which trapped the heat and had not sufficiently cooled [18].
How — General:
Limit operating temperature to below 149 °C (300 °F) for chlorine / carbon steel systems [8] [18].
How — Managers:
Identify published guidance such as provided by the Chlorine Institute and EuroChlor and establish
formal internal standards, limits, and procedures for controlling temperatures for all aspects of
chlorine systems [13] [14] [18].
Conduct periodic audits of procedures and standards to ensure they are followed and maintained.
Manage all changes made to chlorine processes and related procedures with a formal
Management of Change (MOC) system.
Have procedures in place that control (and monitor) operating temperatures including utilities
used for heating chlorine.
Have procedures in place to ensure complete chlorine evacuation has been achieved before
performing hot work on chlorine piping, vessels, and equipment.
Ensure training is conducted pertaining to the concerns/hazards of high temperatures in chlorine
systems and the allowable temperature limits [16].
Include training for maintenance activities such as the hazards of hot work on chlorine systems
and tight mechanical clearance considerations.
Golden Rule #5: Always understand/know the correct materials of construction for chlorine
service.
Why:
Titanium will burn in dry chlorine service [8] [9] [18] [22].
Carbon steel is not suitable in wet chlorine service; will result in severe corrosion [8] [9] [18].
High liquid chlorine pipeline velocities can result in erosion of the protective ferric chloride layer
that forms on carbon steel [9].
Carbon steel has a low temperature limit in chlorine service, -29°C (-20°F), and embrittlement can
be a concern since chlorine boils at -34°C (-29°F) at atmospheric pressure [8] [14] [18].
300 austenitic stainless steel in chlorine service can result in stress corrosion cracking in the
presence of moisture, particularly at ambient or elevated temperatures or in highly stressed parts
such as fasteners / bolts [8] [14] [18].
Carbon steel chlorine piping can exhibit corrosion under insulation (CUI) which is a likely damage
mechanism if the piping is not externally painted and maintained.
Incident History:
A titanium valve was installed in dry chlorine service. The dry chlorine reacted with the titanium
and caused complete failure of the valve resulting in the release of 113 pounds of chlorine. The
valve had a titanium body and Hastelloy C internals. The valve body had identification markings
for both titanium and Hastelloy C. Maintenance personnel thought the valve was Hastelloy C
only and did not recognize the dual metallurgy of the valve [10].
A 1” chlorine hose failed after 59 days of service during routine unloading of a chlorine railcar
and led to the release of 48,000 lbs. of chlorine. The shipping papers for the braided exterior
hose showed C276 Hastelloy but the hose braiding was actually 316 L stainless steel. The user
had no testing capabilities on site to confirm the material of construction for the hose and
relied solely on the hose supplier for the material documentation. The hose failure was due to
stress corrosion cracking of the stainless braiding via permeation of chlorine through the Teflon
inner liner [10] [23].
Five years after installing a 6 inch diameter pipe to transport chlorinated water (approximately
0.2 – 0.8 mg/L (ppm)) for municipal water use, maintenance workers noticed water leaks on
flanged sections of the piping. One hundred fifty (150) stainless bolts were used for the flange
bolting and some of the bolts developed stress corrosion cracking (SCC) which then caused the
flanges to leak [24].
A chlorine leak developed at the weld of an instrument bar stock valve which resulted in a leak
of 227 lbs. of chlorine. The leak was the result of moisture introduction and corrosion under
insulation (CUI) [25].
How — General:
Ensure identification of materials of construction on all parts used in chlorine service [26].
Be aware of the appropriate moisture levels and temperatures for the materials being used [8]
[18].
Consider all aspects of the service such as startup, shutdown, evacuation, etc. when determining
material requirements [14].
Select materials that have adequate strength and maintain ductility at low temperature [14].
How — Managers:
Identify published guidance such as provided by the Chlorine Institute and EuroChlor, and establish
formal internal standards and procedures on proper materials for use in chlorine service [8] [14]
[16] [18].
Conduct periodic audits of procedures and standards to ensure they are followed and maintained.
Manage all changes (such as a formal Management of Change (MOC) system) made to chlorine
equipment and related procedures.
Establish Quality Assurance procedures to address positive material identification (PMI) and
control for materials used in chlorine service [26].
Ensure training is conducted pertaining to operating and maintenance procedures for proper
materials use in chlorine processes.
Why:
Caustic (sodium hydroxide or lithium hydroxide) is a co-product in Cl2 production. The
concentration produced is typically between 30-50% (wt. %).
Caustic reacts vigorously with many hydrocarbons, often explosively.
Reactions between concentrated caustic and acids are extremely exothermic.
Caustic reacts with and rapidly corrodes aluminum, tin, copper, and zinc. Reaction between sodium
hydroxide and any of these materials will produce hydrogen gas which is highly flammable.
Accelerated corrosion and potential stress cracking of equipment can occur depending upon
caustic temperatures and/or concentrations.
When diluting caustic, the heat of dilution can result in high caustic temperatures that can affect
the materials of construction selection.
Hot caustic is very corrosive to skin and eyes.
Welding, cutting, or performing other forms of heat treatment on caustic contaminated metals can
result in stress cracking and the evolution of flammable hydrogen gas.
Incident History:
Accidental contact of 50% sodium hydroxide solution with residual trichloroethanol in a pump
caused an explosion [18].
Caustic spilled from a manual butterfly valve on a caustic recirculation tank. While the operator
was trying to make the valve seat, the stem and handle came out. Caustic sprayed out of
containment, releasing 27,000 lbs. The investigation found that there was a mix-up in the
labeling of valves after the valve was received. It was ordered with 20 other unrelated valves
and not the proper material of construction for the caustic service [18].
A caustic leak was spotted from a sampling port regularly used to sample caustic on an
electrolyzer. About 80 pounds of hot caustic was released. The subsequent investigation
revealed that the fitting between the electrolyzer and the sampling port was not compatible
with the high temperature caustic [10].
How – General:
Before using Caustic with any hydrocarbons, the user should become knowledgeable about the
possible reactions between the substances.
Avoid using aluminum, tin, copper, zinc materials. Reaction between sodium hydroxide and any of
these materials will produce hydrogen gas which is highly flammable.
Don’t allow strong caustic and strong acids to mix. Keep storage tanks separated.
How — Managers:
Identify published guidance such as provided by the Chlorine Institute and EuroChlor, and establish
formal internal standards and procedures on the proper handling of sodium hydroxide [5] [18]
[33].
Conduct periodic audits of procedures and standards to ensure they are followed and maintained.
Manage all changes (such as a formal Management of Change (MOC) system) made to caustic
equipment and related procedures.
Before using sodium hydroxide with any hydrocarbons, become knowledgeable about the possible
reactions between the substances.
Ensure that any possible reactions between caustic and reactive substances are appropriately
controlled, and the possible consequences of such reactions are fully considered in the design of
the system.
Establish Quality Assurance procedures that to address positive material identification (PMI) and
control for materials used in caustic service.
Ensure training is conducted pertaining to the hazards, procedures, and proper materials for use
in caustic systems.
Why:
Hydrogen is a co-product in Cl2 production.
Hydrogen is extremely flammable with a very wide flammability envelope [34].
3% to 93% hydrogen in chlorine
4% to 75% hydrogen in air
Hydrogen requires very little ignition energy (10-2 joules to 10-7 joules) to ignite in the presence or
air or chlorine. Almost any source of ignition (e.g. static electricity) can result in an explosion [34]
[35].
Hydrogen can be evolved when systems containing acid (even in small amounts) are in contact with
certain metals.
Incident History:
Five chlorine/hydrogen explosions in electrolytic cells were reported in a 5 year period.
Fortunately, there were no injuries. However, in two of the incidents, damage to equipment
and production interruptions resulted in an economic loss in the hundreds of thousands of
dollars [10].
An explosion in the hydrogen header occurred during a plant shutdown. The explosion was
caused by insufficient nitrogen purge on the hydrogen header allowing air infiltration. The
explosion caused damage to the hydrogen header, ancillary hydrogen equipment, and damage
to the diaphragms in the cell circuit requiring all the cells to rebuilt [10].
The chlorine production restarted after a one-day shutdown of the chlor alkali plant. An
increase in hydrogen concentration in the chlorine from the membrane electrolysis unit
resulted in an explosion of the drying section. The explosion led to a chlorine leak and also
damaged concentrated sulfuric acid piping causing an acid leak. Twenty workers were
evacuated but none were injured. The drying tower and several pipes and equipment had to
be repaired, keeping the production unit out of service for several weeks [36].
An employee suffered sulfuric acid burns to his face as the result of an explosion in a sulfuric
acid heat exchanger. The incident occurred while the employee was using a torch to remove
corroded bolts from a blank flange on the head of the heat exchanger. The heat exchanger had
been out of service for an indefinite period of time. When the flange opened, the hydrogen that
was a product of corrosion ignited breaking piping and spraying acid [10].
How – General:
Never operate a hydrogen process above an oxygen concentration of 1% (v/v) (25% of lower ignition
limit (LIL)).
Keep hydrogen concentrations at safe levels throughout the chlorine process.
Prevent air from infiltrating hydrogen systems.
Avoid purging with steam; air will be pulled into the header when the system cools, steam
condenses, and a potential vacuum forms.
Purge hydrogen systems, piping, equipment with inert gas before introducing hydrogen.
Maintain proper electrical classifications around hydrogen piping, instrumentation, lighting, and
equipment [37].
Use ridge vents or similar ventilation approaches to prevent hydrogen from pocketing in ceilings.
A damaged membrane or diaphragm can allow H2 from the cathode side of the electrolyzer to mix
with Cl2 on the anode side of the electrolyzer.
How — Managers:
Identify published guidance such as provided by the Chlorine Institute and EuroChlor, and establish
formal internal standards, limits, and procedures for the proper control and handling of hydrogen
and hydrogen concentrations.
Conduct periodic audits of procedures and standards to ensure they are followed and maintained.
Manage all changes (such as a formal Management of Change (MOC) system) made to hydrogen
equipment and related procedures.
Establish limits for allowable hydrogen in chlorine, hydrogen in air, and air in hydrogen.
Establish proper cell room operating and maintenance discipline.
Have detailed standard operating procedures as they relate to hydrogen concentration control.
Provide detailed electrolyzer and cell room pre-start-up checks (e.g., verify membrane or
diaphragm integrity).
Require monitoring methods for hydrogen concentrations in chlorine systems.
Require monitoring methods for oxygen concentrations in hydrogen systems.
Golden Rule #8: Never acidify hypochlorite streams in open to atmosphere systems.
Why:
Lowering the pH of hypochlorite solutions releases gaseous chlorine and can have both onsite and
offsite consequences [38].
The decomposition reaction can be rapid and violent resulting in hot alkaline liquids (splashing and
tank overflows) as well as chlorine gas release [38]. Note: Caustic (sodium hydroxide) chlorine
scrubber systems will contain sodium hypochlorite as the result of the chlorine/caustic reaction.
Over-chlorinating such scrubbing systems will acidify the contents resulting in a violent
decomposition. The scrubber will also cease scrubbing the incoming chlorine, increasing the
chlorine release [38].
Incident History:
A chlorine release at a bleach (sodium hypochlorite) facility occurred as a result of an accidental
mixing of the bleach with an acid. A truck delivering hydrochloric acid was connected by
mistake to a storage tank containing sodium hypochlorite. Chlorine gas began to evolve from
the sodium hypochlorite tank. The operator then realized their error. They shut off the
unloading valve, but was overcome by chlorine fumes and passed out. Two other employees
rescued the operator. All three were admitted to the hospital for treatment, with one fatality –
the operator – a couple of weeks later. Fifteen other individuals went to the hospital for
observation and were later released [10].
An unloading error lead to Inadvertent mixing of sulfuric acid and sodium hypochlorite that
produced a cloud containing chlorine and other compounds that drifted offsite. There was a
significant amount of traffic in the immediate vicinity of the plant and the fire department
blocked nearby intersections to restrict and re-direct drivers from entering the plume. The
county Department of Emergency Management advised 11,000 citizens to shelter-in-place. As
a result of exposure to the cloud produced by the reaction, over 140 individuals, including
members of the public and five employees, sought medical attention. One employee was
admitted to a hospital and released three days later. Five members of the public required
hospitalization with four released within two days and one was released five days later [39].
How – General:
Clearly differentiate unloading and loading connections.
Have administrative controls in place to ensure deliveries get to the right location in the plant.
Remind customers of the serious consequences of such an error.
How — Managers:
Identify published guidance on safe handling of hypochlorite, such as provided by the Chlorine
Institute and EuroChlor, and establish formal internal standards, limits, and procedures for
controlling hypochlorite and acidic streams [13] [38].
Conduct periodic audits of procedures and standards to ensure they are followed and maintained.
Manage all changes made to chlorine equipment and related procedures, such as with a formal
Management of Change (MOC) system.
Ensure training for operators and mechanics includes the hazards and concerns associated with
acidifying hypochlorite solutions [38].
Separate incompatible materials [38].
Periodically review labeling, instrumentation, and connections to ensure proper loading/unloading
connect up [13] [38].
Have procedures in place that control the movement and mixing of hypochlorite and acidic
solutions [13] [38].
Have procedures in place to identify/verify chemical shipments.
Have procedures to confirm whether there is a liquid heel or what the heel might contain before
loading [38].
Make sure drivers (including non-employee drivers) are properly trained in the site procedures and
on the hazards of mixing incompatible materials before allowing them to perform loading or
unloading [38].
Consider supervisor or operator verification of proper connections before allowing loading or
unloading to begin.
Golden Rule #9: Always protect against isolating liquid-full chlorine lines.
Why:
Liquid chlorine has a very high thermal expansion coefficient [12].
Liquid-full lines that are isolated at each end and equipment without adequate relief will see very
high pressures (thousands of psig) with a very small temperature increase [14] [16].
When Chlorine is trapped in a closed system, rising temperatures cause the liquid to expand and
exert pressures that can overcome the pressure rating of the containment system.
The pressure rating of liquid chlorine lines and equipment can be much lower than the pressure
that can result from thermal expansion; gasket, flange, piping and equipment failures (blowouts
and bursting) can be expected, releasing all the chlorine contained [12] [14] [16].
The released liquid chlorine will result in a gas cloud more than 460 times the volume of the liquid
[12].
Incident History:
At around 05:00, a plant employee had completed the loading of a chlorine railcar. The
employee closed the chlorine valves and the employee began to prepare this next railcar for
loading. It was expected that the employee would start loading again within the next hour. At
approximately 06:00, a 375 psig rupture disc in the chlorine railcar loading piping system burst.
The rupture disc should have reduced the pressure in the line by directing the chlorine into the
expansion chamber keeping the chlorine fully contained. However, the wrong rupture disk
holder was used and chlorine was able to escape out of a hole at the back end of the assembly.
110 pounds of liquid and gaseous chlorine were released during the approximately 15 minutes
it took operators responding to the emergency and close the valve that supplied chlorine to
the rail loading area [40].
How – General:
Avoid operations and designs that would routinely trap liquid chlorine.
Develop a standard to address how to isolate liquid filled lines and equipment to prevent over
pressurization.
How — Managers:
Identify published guidance, such as provided by the Chlorine Institute and EuroChlor, and
establish formal procedures for addressing liquid-full chlorine lines [12] [14] [16] [41].
Conduct periodic audits of procedures and standards to ensure they are followed and maintained.
Manage all changes made to chlorine equipment and related procedures, such as with a formal
Management of Change (MOC) system.
Implement procedures and engineering standards that specifically address protecting piping and
equipment from liquid chlorine thermal expansion.
Have robust administrative procedures in place where protective devices such as expansion bottle
are not used.
Put in place formal procedures to monitor/audit engineered and administrative protective systems.
References
[1] Chlorine Institute, "Safe Handling of Chlorine Containing Nitrogen Trichloride, Pamphlet 152,
Edition 4," 2018.
[2] World Chlorine Council (WCC), "Global Safety Team Newsletter, December, Number 12," 2009.
[3] Chlorine Insitute, "Nitrogen Trichloride – A Collection of Reports and Papers, Pamphlet 21,
Edition 7," 2017.
[4] EuroChlor, "Maximum Levels of Nitrogen Trichloride in Liquid Chlorine, GEST 76/55, Edition 13,"
2019.
[5] Chlorine Institute, "Personal Protective Equipment for Chlor-Alkali Chemicals, Pamphlet 65,
Edition 6," 2015.
[6] EuroChlor, "Design and Operation of Chlorine Vaporisers, GEST 75/47, Edition 11," 2019.
[7] EuroChlor, "Corrosion Behaviour of Carbon Steel in Wet and Dry Chlorine, GEST 10 362, Edition
2," 2013.
[8] EuroChlor, "Materials of construction for use in contact with Chlorine, GEST 79 82, Edition 11,"
2013.
[9] Chlorine Institute, "Behavior and Measurement of Moisture in Chlorine, Pamphlet 100, Edition
5," 2018.
[10] Chlorine Institute, "Learning from Experience, Pamphlet 167, Edition 3," 2014.
[11] U.S. Fire Administration, "Massive Leak of Liquefied Chlorine Gas Henderson, Nevada, Technical
Report Series, USFA-TR-052," 1991.
[12] Chlorine Institute, "Chlorine Basics, Pamphlet 1, Edition 8," 2014.
[13] EuroChlor, "The Chlorine Reference Manual, GEST 06/317, Edition 2," 2017.
[14] Chlorine Institute, "Piping Systems for Dry Chlorine, Pamphlet 6, Edition 17," 2020.
[15] Chlorine Institute, "Chlorine Vaporizing Systems, Pamphlet 9, Edition 8," 2018.
[16] EuroChlor, "Transfer of Dry Chlorine by Piping Systems, GEST 73/25, Edition 12," 2018.
[17] Chlorine Institute, "Emergency Response Plans, Pamphlet 64, Edition 7," 2020.
[18] Chlorine Institute, "Reactivity and Compatibility of Chlorine and Sodium Hydroxide with Various
Metals, Pamphlet 164, Edition 3," 2017.
[19] European Industrial Gases Association (EIGA), "Cleaning of Equipment for Oxygen Service, EIGA
Doc 33/18 (or IGC Doc 33/18)".
[20] Compressed Gas Association (CGA), "Cleaning Equipment for Oxygen Service, G-4.1, Edition 7,"
2018.
[21] EuroChlor, "Commissioning and Decommissioning of Installations for Dry Chlorine Gas and
Liquid, GEST 80/84, Edition 6," 2013.
[22] World Chlorine Council (WCC), "Global Safety Team Newsletter, Number 20," December 2011.
[23] US Chemical Safety Board (CSB), "DPC Enterprises Festus Chlorine Release, Report No. 2002-04-
I-MO," May 2003.
[24] Chlorine Institute, "Improper Material of Construction on Highly Chlorinated Water Piping,
Safety Alert," March 2019.
[25] Chlorine Institute, "2018 Performance Indicator Report," June 14, 2019.
[26] API, "Material Verification for New and Existing Alloy Piping, API 578, Edition 3," 2018.
[27] EuroChlor, "Stud Bolts, Hexagon Head Bolts and Nuts for Liquid Chlorine, GEST 88/134," 2018.
[28] EuroChlor, "Experience of Gaskets on Liquid and Dry Chlorine Gas Service, GEST 94/216, Edition
5," 2019.
[29] EuroChlor, "Valves Requirements and Design for Use on Liquid Chlorine, GEST 06/318, Edition
5," 2019.
[30] Chlorine Institute, "Gaskets for Chlorine Service, Pamphlet 95, Edition 5," 2017.
[31] EuroChlor, "Storage of Liquid Chlorine, GEST 73/17, Edition 8," 2019.
[32] Chlorine Institute, "Bulk Storage of Liquid Chlorine, Pamphlet 5, Edition 9," 2017.
[33] Chlorine Institute, "Sodium Hydroxide Solution and Potassium Hydroxide Solution (Caustic)
Storage Equipment and Piping Systems, Pamphlet 94, Edition 5," 2018.
[34] Chlorine Institute, "Explosive Properties of Gaseous Mixtures Containing Hydrogen and
Chlorine, Pamphlet 121, Edition 4," 2016.
[35] EuroChlor, "Hydrogen in Chlorine Safety, GEST 17/490, Edition 1," Jun 2019.
[36] World Chlorine Council (WCC); Global Safety Team Newsletter, "Eurochlor H2 limits, Number
17," March 2011.
[37] National Fire Protection Agency (NFPA), "Recommended Practice for the Classification of
Flammable Liquids, Gases, or Vapors and of Hazardous (Classified) Locations for Electrical
Installations in Chemical Process Areas, NFPA 497," 2021.
[38] Chlorine Institute, "Sodium Hypochlorite Manual, Pamphlet 96, Edition 5," 2017.
[39] US Chemical Safety Board (CSB), "Key Lessons for Preventing Inadvertent Mixing During
Chemical Unloading Operations, No. 2017-01-I-KS," 2017.
[40] Chlorine Institute, "2016 Chlorine Institute Performance Indicator Report, July 24," 2017.
[41] Eurochlor, "Overpressure Relief of Chlorine Installations, GEST 87/133, Edition 6," 2018.
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Golden Rules of Process Safety for: Chlor-Alkali
GR1 - Chlor-Alkali, Jan 2021
Copyright 2021 American Institute of Chemical Engineers
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