VALERO KROTZ SPRINGS SHG #13

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Approved 04/27/95

PYROPHORIC IRON SULFIDE DEPOSITS

I. PURPOSE

To ensure the safety of Valero and contractor personnel and equipment when opening equipment
that may contain pyrophoric iron sulfide deposits.

II. SCOPE

When opening any piece of equipment that has been exposed to H
2
S in the absence of oxygen,
this equipment should be treated as pyrophoric.

For tank, tower, exchanger, and miscellaneous equipment cleaning this guideline addresses
steps that should be taken to safely eliminate the hazards of pyrophoric deposits. Steps may
include steaming, waterwashing or chemical cleaning.

III. DEFINITIONS

Pyrophoric iron sulfide deposits are formed in process equipment when hydrogen sulfide (H2S)
reacts with metal surfaces in atmospheres with little or no oxygen. These deposits will oxidize
rapidly when exposed to air and can produce sufficient heat to ignite hydrocarbon-air mixture.

IV. RESPONSIBILITY

All Valero and contractor personnel will comply with the requirements of this SHG. Area lead
technicians and supervisors will be responsible for assuring compliance with these requirements.

V. DRUM/TOWER PREPARATION

A. In order to keep potentially pyrophoric surfaces wet until the LEL is less than 10%, all
items outlined below must be done in sequence:

1. Steam and water wash towers. Steam drums. This should be done until clear
steam is observed at the vents.
2. Install isolation blinds.
3. Steam and water wash towers for a minimum of one hour. Steam drums for one
hour.
4. Block in steam and cool down drum or tower, then block in water.
5. Using an explosimeter, test for oxygen and hydrocarbon levels. THE O
2
LEVEL
MUST BE 21% FOR ACCURATE LEL. Check at a drum vent or bleeder. Open
and check the top manway of a tower.

a. If drum or tower tests at or above 10% LEL, close any open manway,
steam, and/or water wash for a minimum of one hour.
b. If drum or tower tests 10% LEL or lower, proceed to next step.

6. Open manway on a drum and immediately install a full fog nozzle and completely
wet down the drum. Open the bottom manway of a tower. Test for hydrocarbon
level.
7. Install and turn on a grounded air mover on top of the drum or tower.
8. After a minimum of one hour, turn off the air mover and test for hydrocarbon level.
VALERO KROTZ SPRINGS SHG #13
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Approved 04/27/95


a. If drum or tower is at or above 10% LEL return to step 5.a.
b. If hydrocarbon level is less than 10% LEL, open manways, as needed,
checking the hydrocarbon level at each manway. If the hydrocarbon level
at any manway is found to be above 10% LEL, resume water washing for
a minimum of one hour.

NOTE: IT IS DIFFICULT TO REMOVE PYROPHORIC MATERIAL
FROM DEMISTER PADS; EXERCISE CAUTION.

B. Equipment which cannot be steamed or waterwashed or where special hazards exist, will
be kept inert or free of oxygen. This equipment will be chemically cleaned before it is
exposed to oxygen.

VI. EXCHANGER CLEANING PREPARATION:

A. When Cleaning the Tube Side:

1. Steam out exchanger.
2. Isolate exchanger.
3. Steam out exchanger - tube side until steam is clear.
4. Pull channel cover (dollar plate) and keep tubes wet.
5. Clean tubes.

B. When Pulling the Exchanger Bundle:

1. Steam out exchanger.
2. Install isolation blinds.
3. Steam exchanger for a minimum of one hour.
4. Remove dollar plate on exchanger with water spray available.
5. Remove bell head from exchanger with water spray available.
6. Proceed with removing bundle from shell while keeping bundle wet as it is pulled.
7. After bundle is pulled, thoroughly water wash it before removing from area or
leaving it unattended.
8. Thoroughly water wash shell immediately after removing bundle.

NOTE: IT WILL BE NECESSARY TO PERIODICALLY SPRAY THE
BUNDLE WITH WATER UNTIL IT IS THOROUGHLY CLEANED.
VALERO KROTZ SPRINGS SHG #13
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Approved 04/27/95

VII. CATALYST HANDLING

A. At this facility, catalysts that are considered pyrophoric are unoxidized naphtha
hydrotreating and isom hydrotreating catalysts. At the end of the normal unit shutdown
procedures reactors containing these catalysts will be kept under a nitrogen atmosphere.

1. Follow normal vessel opening procedures.
2. When the vessel is open, start a flow of nitrogen into vessel preferably through a
nozzle at the opposite end of the vessel from the open manway. This can be
supplemented with a nitrogen hose inserted through the manway.
3. Regulate nitrogen flow to maintain a slight positive pressure on the vessel.
Nitrogen use can be minimized by covering the open manway when access is not
required.
4. Remove any required internals under the inert atmosphere confined space entry
procedure.
5. Remove the blind flange from the catalyst dump nozzle along with any packing or
inserts.
6. Catalyst should be loaded directly into appropriate drums through a sock. Prior to
filling the drum, a fist-sized piece of dry ice should be placed in the drum to
displace oxygen.
7. Fill the drum and immediately cover and seal it.
8. Vacuuming of pyrophoric catalyst should not be done unless specialized
equipment designed for this purpose is used.

VIII. TANK PREPARATION

A. Tanks which may contain pyrophoric material will require the following steps in addition to
tank cleaning procedures:

1. Atmospheric storage tanks

a. Strip the tank from the water draw and install blinds. Spray water on tank
flanges while installing blinds and air mover.
b. Pull top manway and install a grounded air mover.
c. Start air mover on slow roll.
d. Position a grounded fire water nozzle at shell manway.
e. Remove shell manway cover and immediately fog the interior of the tank.
f. Increase the speed of the top air mover.
g. From the outside of the manway, water wash the interior of the tank and
keep the interior surfaces wet.
h. Water wash the tank from the outside until no further cleaning progress
can be made. Inside cleaning will follow. Cleaning and wetting will
continue until tanks test 10% LEL or lower.
i. The floor of the tank will be kept wet until the tank is clean.
j. If the tank cannot be declared gas free at the end of a regular work day,
the tank should be sealed until the next day for further cleaning. Tanks
that cannot be sealed should be worked on until declared gas-free.


2. Pressurized Storage Tanks

VALERO KROTZ SPRINGS SHG #13
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Approved 04/27/95

a. Prepare tanks and install blinds on tank.
b. Remove the blind flange or pressure relief valve on a nozzle on top of the
tank.
c. Steam or water fill the tank.
d. Drain the tank and cool as needed.
e. Install a grounded fire hose nozzle in the top nozzle provided and start
water spray.
f. Remove the top manway cover and install a grounded air mover on slow
roll.
g. Remove the bottom manway cover and drain water from the tank.
h. Increase the speed of the top air mover.
i. Continue water washing until the tank is gas-free.

NOTE: CHECK WITH ENGINEERING TO CONFIRM STRUCTURAL
ADEQUACY BEFORE FILLING ANY VESSEL WITH WATER.


IX. MISCELLANEOUS EQUIPMENT

A. Many pieces of miscellaneous equipment may contain pyrophoric material and may be
taken out of service individually. Some examples are float columns, strainers, and
pumps. Various precautions can be taken on different pieces of equipment, such as:

1. Isolate equipment.
2. Equipment can be steamed out where practical.
3. Have water flush available for flushing equipment when it is dismantled or
removed.
4. Thoroughly clean equipment if possible.
5. Use nitrogen purge.

X. HANDLING AND DISPOSING OF PYROPHORIC MATERIAL

A. Pyrophoric iron sulfide deposits removed from various process equipment will be handled
in the following manner:

1. Pyrophoric material shall stay wet at all times.
2. Material collected will be placed in metal drums and covered with water.
3. Drums will be dated and labeled as pyrophoric by operations.
4. The Environmental Department will be notified for disposal.