sa ere ccoen MEMO yy CUM Michelle Owenby Travis Blake, Chelsea Meadows. (>> March 22, 2018 (Revised April 9, 2018) Subject: Investigation of October 4, 2017, Explosion at Eastman Chemical Company Background: On October 4, 2017, an explosion occurred in the coal gasification plant at Eastman Chemical Company Kingsport facility (Figure 1). Due to evacuation of the area prior to the explosion, no fatalities or serious injuries were reported. However, residents in the area surrounding the plant were advised to shelter in place for about an hour and those within 4 mile of John B. Dennis Highway and Moreland Drive for about 5 hours. Eastman staff reported a secondary incident (loss of 8-325 Boller 30 instrument air), and review of video footage indicated excess emissions at a third emission source (B-83 boiler stack, see Figure 2). Figure 1: Eastman Explosion Division of Air Pollution Control + William R. Snodgrass Tennessee Tower, 15" Floor + 312 Rosa L. Parks Avenue’ Nashville, TN 37214 + Tel: (615) 532-0554 + Fax: (615) 532-0614» httpif/wvw.tn.gov/environment/ Page 10f7Conservauon MEMO Figure 2: View of Eastman Explosion and B-83 Plume from near John B. Dennis On November 29, 2017, Chelsea Meadows, Preston Pierce, and Travis Blake visited Eastman Chemical Company's Tennessee Operations facility in Kingsport’. The purpose of this visit was to obtain additional information on the October 4 incident, as follows: + Timeline of event © Cause of event, if known ‘© Emissions resulting from the event ‘Evaluation of incident within context of APC rule 1200-03-02-.01(2) (i., malfunction) Evaluation of incident within context of APC rule 1200-03-20-.02(1)(.e., reasonable measures to minimize emissions) Description of October 4 Event: East man’s coal gasification plant (Figure 3) consists of a series of operations designed to produce mixtures of carbon monoxide and hydrogen from coal and to purify the gas stream for manufacturing of methanol and acetic anhydride in subsequent downstream operations. Two of these process Units are of particular interest. * Eastman participants were Steve Gosset, Vera Davis, Pete Lodal, and Sharon Wellman, Tinwer, 1S" Hones $12 Rosa L Pans avenues Naive 1 472 14+ Teh (6155) 332-0055 » Fs: (55) 532.9614 beep Awwentn gowfenvironmenty Page 2of7Environment & MEMO _ - = Figure 3: Coal Gasification Coal slurry preparation (Figure 4) consists of two stirred tanks and associated equipment. Pulverized coal is mixed with water, sodium hydroxide, and specialty chemicals to ensure that the slurry remains evenly mixed. aiease seas ak FH AGASE 11615D GBA ‘Sturryt0 1¢-4 ‘tury 10 26-1 Figure 4: Coal Slurry Preparation Division of Air Pollution Control + William R. Snodgrass Tennessee Tower, 15" Floor + 312 Rosa L. Parks Avenues Nashville, TN 37214 + Tek: (615) 332.0554 + Fax: (615) 532.0614 http://w tn.govenvironment/ Page 3 0f7a oneervanan MEMO In the gasifier train (Figure 5), coal slurry is mixed with pure oxygen and heated under pressure to produce a mixture of carbon monoxide and hydrogen. Strict control of the coal slurry and oxygen feed rates is required, because excess oxygen reacts with the carbon monoxide product to form unwanted carbon dioxide. Excess oxygen also creates a substantial fire/explosion hazard when combined with hydrogen gas. EASTMAn an meas” /Rectisol i Ia “ oe urd wiernoxt Figure 5: Gasifier Train ‘The October 4 incident occurred during a gasifier switch. Because the gasifiers operate under high temperature and pressure (around 1,000 psi and 1,200° C), the gasifiers must be lined with refractory brick to keep the gasifier shell from melting. Two gasifiers are used in parallel (an operating unit and a spare unit), and gasifiers are switched as needed to replace old refractory or for other maintenance. The basic steps of a gasifier switch are as follows: the operating rate of the working gasifier is reduced, and Eastman begins feeding propanol to the spare gasifier’. When the spare gasifier reaches its normal operating pressure, the working gasifier is shut down. Subsequently, Eastman switches from feeding propanol to feeding coal slurry. Following completion of a gasifier switch, the feed lines from the coal slurry tanks to the non-working gasifier must be flushed with water to remove the accumulation of solids from the lines. The piping includes a connection to a high pressure water feed line (not shown in Figure 4), and water is fed through the piping at high pressure (about 100 psi) to remove accumulated slurry. Because coal slurry is being fed to the working gasifier at this time, the piping to the working gasifier is isolated from the water supply via a 10-inch manual ball valve (not shown in Figure 4, see Figure 6 for a typical example). The valve is opened and closed by pulling a chain wheel (see Figure 7 for a typical example). * ropanol is used for startup because until the gasifier Is fully pressurized and the downstream components are brought online, the syngas produced in the gasifier must be flared. Use of propanol reduces SO, emissions during startup. Division of Air Pollution Control » William R, Snodgrass Tennessee Tower, 15" Float + 412 Rosa L. Parks Avenues Nashwille, TN 37214 + Tel: (615) 532-0554 + Fax: (615) 532-0614* http://wwmw.tn.gov/enviconment/ Page 4 0f7lero MEMO Figure 6: 10-inch ball valve (typical") Figure 7: Valve Chain Wheel (typical) ‘The October 4 incident began when the ball valve failed to fully close during water flushing of the slurry feed lines of the non-working gasifier. Water passed through the ball valve at high pressure and into the feed line of the working gasifier. Because the water pressure exceeded the coal slurry feed pressure, the water intrusion stopped all coal slurry feed, and water began to back up into the working slurry feed tank. In the absence of coal slurry feed, oxygen began to accumulate in the system at high pressure and temperature. Eastman personnel observed a series of abnormal phenomena in quick succession, beginning with a dip in gas flow to the Rectisol at 9:24 A.M. Rectisol was isolated and placed in a hold condition at 9:34 AM. and the gasifier was shutdown at 9:38 AM, Abnormal flare behavior was reported between 9:51 and 9:58 AM. after beginning depressurization of Gasifier #1. Ultimately after attempts to depressurize the system at multiple points, a series of explosions occurred in the 12C-9 Shift Gas Separator and process gas header to the Rectisol at 10:50 A.M. Eastman report of deviation: On December 18, 2017, Eastman submitted a deviation report marked as “draft”, which provides much of the same basic information that is described above. Eastman’s report did not include information regarding the failure of the ball valve and stated only that “During a routine switch of gasification units, an equipment malfunction allowed water instead of coal slurry to enter the #1 gasifier.” Reported emissions: Eastman reported the following emissions on November 29. These numbers do not include subsequent emissions from depressurizing the gasifiers and associated operations. ‘+ Hydrogen sulfide: 54 Ib (revised to 53 Ib in the December 18 submittal) ‘+ Sulfur dioxide: 335 Ib * Methanol: possible small leaks but no major release +e, not the actual equipment involved in the Eastman incident. Division of Air Pollution Control + William R. Snodgrass Tennessee Tower, 15° Floor +312 Rosa L_ Parks Avenues Nashvile, TN 37214 Tel: (615) 532-0554 + Fax: (615) 532-0614* http//muw.tn gov/environment/ Page 5 of 7Environment & MEMO ‘onservation Eastman did not estimate the magnitude of particulate matter emissions associated with the explosions. Although PM emissions may have resulted from scattering of insulation or other materials, these emissions would be difficult to quantify Eastman stated that sulfur recovery operations were not compromised by the incident due to isolation of the coal gasification unit. Coal gasification staff were unaware of the B-83 opacity upset observed in video footage, but Eastman submitted a written report of the incident following the site visit. Assessment of incident cause: Failure of an equipment item is generally considered a malfunction event, but failures that are caused by poor maintenance, careless operation, or other preventable upset condition or equipment breakdown are not considered malfunctions. To assess whether a preventable failure occurred, we discussed the coal gasification process hazard analysis (PHA) with Eastman staff “ and considered the possibility of inadequate maintenance or operator error (ie., the operator simply failed to fully close the valve). On February 6, 2018, Travis Blake and Chelsea Meadows met with Steve Gossett and Sharon Wellman via WebEx. This meeting's purpose was to discuss the condition of the valve that failed to fully close, maintenance on the valve, and operator training for proper valve closure. A presentation was prepared by Eastman that contained a P&ID of gasifier feed tanks and associated equipment, and photos of the valve. There was no obvious damage to the valve in the photos shown Photos of the valve were shown both as it was installed and after it was pulled from service and cleaned. Unfortunately, no photos were taken of the valve after it was pulled from service and before it was cleaned. The photo of the valve as installed showed that the vaive exterior was covered in dirt and grime before being pulled, and the position indicator was completely obscured. The photos of the cleaned valve showed that the valve was slightly open when the position indicator was in the “shut” position. The valve was fully closed when the position indicator was a few degrees past “shut’. While it might be concerning that the position indicator was not accurate, it is irrelevant because the indicator was unreadable as installed. Also discussed during the meeting was the procedure operators follow to properly shut the valve. Eastman indicated that there was no written procedure for properly closing the valve, but operators learned on the job from other operators. The typical routine was for the operator to pull the chain until it no longer moved, then hang on the chain with their full body weight to be certain it would not turn anymore. It was noted that the valve was original to the unit, making it over thirty years old, and had undergone routine maintenance as required°. In addition, it was pressure tested after being removed from service and cleaned. A minor gasket leak was detected in one of the air pressure tests, but according to Eastman that does not indicate a “We discussed the PHA solely for the purpose of evaluating the potential ofa preventable fare, not to assess the adequacy of the PHA itself * Eastman staff indicated that other than annual lubrication of the gear mechanism, the valve would require litle maintenance. Our review of, information avaliable from several manufacturers confirms that routine maintenance of oUter valve components is not required under normal ‘operating concitions, Although the gasifier train operates at high temperature and pressure, the operating conditions for this specific valve would be much closer to ambient conditions Division of Ai Pollution Control + Willan R. Snodgrass Tennessee Tower, 15!" Floor + 312 Rosa L, Parks Avenues Nashuille, TN 37214 + Te: (615) 532.0554 + Fas; (615) 532-0614 httpr//ayew.tn govsenvironment Page 6 of 7Environment & Conservation MEMO problem with the valve, The valve was cleaned after being removed from service. An evaluation of the internal components of the ball valve prior to removal or cleaning would be necessary to identify debris or other material that cased blockage. For these reasons, we could not conclude with certainty that buildup of coal slurry or larger debris could have prevented the valve from closing. However, because there was no obvious damage to the valve, routine maintenance was performed, and Eastman found the pressure test satisfactory, this is a likely explanation for malfunction, ‘One additional concern is a possible failure to anticipate water intrusion into the gasifiers. Water intrusion is a known hazard, and introduction of water appears sufficiently foreseeable to include in the PHA®. However, even if water intrusion had been addressed in the PHA, the initiating event (valve failure) was not reasonably foreseeable. Assessment of incident response: Tennessee Comprehensive Rules and Regulations 1200-03-20-.02(1) requires air contaminant sources to take all reasonable measures to minimize emissions during malfunctions, including alternate control systems, changes in operating methods or procedures, cessation of operation until the process equipment and/or air pollution control equipment is repaired, maintaining sufficient spare parts, use of overtime labor, use of outside consultants and contractors, and other appropriate means. The Division has determined that Eastman satisfied the requirements of 1200-03-20-.02(1) by isolating downstream components (e. g., Rectisol and sulfur recovery) during the event and by controlled venting to the existing flare following the event. Eastman has also ceased operation of the coal gasification process until the process equipment is repaired. Eastman has also indicated that the failed manual valve will be replaced with a more reliable automatic valve. Conclusions: The incident cause cannot be resolved with complete certainty, but the available evidence suggests obstruction of the vaive due to slurry or debris intrusion, Because blockage of the valve would be a malfunction pursuant to Chapter 1200-03-20, no enforcement action is recommended for excess emissions resulting from the event. We recommend that Eastman review the PHA to address the hazards associated with water intrusion, Other recommendations: Equipment under repair is typically isolated with blinds (slip plates, spectacle blinds, etc.), which can be secured with lock and chain’. Specific requirements for the use of blinds is beyond the Division's expertise, but Eastman should be encouraged to consider whether blinding would be appropriate during flushing of non-working gasifiers*. The Division also recommends that Eastman consider changes to their standard operating procedures to monitor the slurry tank level and/or that Eastman consider a high-level alarm on the slurry tank. * During the ste vist Eastman sta ncicated thatthe PHA addressed loss of slury fed but not water intrusion. 7 See https:/¥m youtube cemiwatch2time continue=2Bv=48XuhEeWrQ for an example of a blind with lockout capablity and a secondary indicator. * castman staff have indicated that gasifiers must be flushed immediatly upon shutdown, so there may be timing issues that would affect their ability co instal blinds inthe gasifier ines. Nonetheless, the isue shouldbe raised for Eastman’ consideration, Division of Ai Pollution Control + William R Suodgrass Tennessee Tower. 15!" Floor +312 Rosa L. Parks Avenue+ Nashwille, TN 37214 + Tels (615) 532-0554 « Fax: (615) 532.06 14» http/Awww.tn gov/environment/ Page 7 of 7