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Compressed Gas Emergency

Response Containment Vessels


Eugene Y. Ngai
In the US major legislation has been passed affecting the way fugitive emission incidents are dealt with and
is forcing companies to do more to implement quick and safe responses. For the compressed gases, the
device which can fulfill many of these requirements are Emergency Response Containment Vessels (ERCV)
from Solkatronic Chemicals Inc. This article describes the recent legislation and then outlines Solkatronic's
specific response.

S ince the mid 1980s the US Regulatory Community


has been trying to minimize the potential for public
exposure to Hazardous Materials by regulating
every phase of a substance's life cycle. These can be
broadly defined as five distinct phases:
Manufacturing,
Storage,
Transportation,
Use,
Disposal.
Since 1985 major legislation has been passed by Federal,
State, and Local Government Agencies affecting the way
fugitive emissions or Haz Mat incidents are dealt with and
is forcing companies that handle, transport or store
Hazardous Materials to do more preplanning and
communicating with the public. Some of these include:
OSHA - 29 CFR 1910.120 / 120 (Hazardous Waste
Operations and Emergency Response Regulations). Train-
ing and preplanning requirements for Emergency Re-
sponse Teams at RCRA and Hazardous Material facilities.
HM - 126C (Emergency Response Communication
Standards). US Department of Transportation regulation
(effective December 31, 1990) for the shipment of all
Hazardous Materials requires the inclusion of technical
names, emergency response information on shipping
Solkatronic E R C V in action
papers, and 24 hour assistance telephone number. Other
transportation regulations include HM-126F requiring
training of all employees preparing a shipment of for 137 highly hazardous chemicals and for any flammable
Hazardous Materials. liquid or gas in quantities of 10,000 pounds or more
SARA Title III (Emergency Planning and Community (excluding those used as fuel).
Right to Know). US EPA regulation requiring the Uniform Fire Code Article 80. A model Fire Code by the
development of site specific Emergency Response Plans Western Fire Chiefs Association detailing the facility
for all facilities handling greater than the threshold levels requirements for use and storage of Hazardous Materials
of 403 Hazardous Materials. To be developed with the above the exempt amounts. Requirements include: detec-
LEPC and local First Responders. Part 311 of the tion, containment and/or scrubbing of a worse-case leak
regulations also details ER training similar to OSHA. for largest container. Hazardous Materials Management
NJ Toxic Catastrophe Prevention Act. A 1988 NJ Plan (HMMP) and Hazardous Material Inventory State-
regulation requiring manufacturers, storers or users that ment (HMIS) may also be required.
handle greater than the threshold quantity of 104 EHS Santa Clara County Toxic Gas Ordinance. Originally,
(Extremely Hazardous Substances) to prepare a written California Assembly Bill 1021, which was adopted by all
Risk Analysis on all phases of an operation involving the the communities in Santa Clara County California in 1989.
substance. This Risk Management Plan (RMP) is reviewed Primary focus is on compressed gases and places
by a consultant to insure that there is minimal risk to the additional requirements to Article 80 in the storage and
public. The initial EHS list has been expanded to an use of gases based on their MHI (Material Hazard Index)
additional 200 + substances. values.
OSHA Process Safety Management. A 1992 U.S. Of these, the last two are attempts by the Fire
regulation requiring a risk assessment similar to NJ- Community to regulate the manufacturing, storage, and
TCPA for facilities handling above the threshold amount use of Hazardous Materials. In almost all communities
i ' f { ,
IZ 7, : i •

Highly ~,,,~i~
{)xidizcr.
(ol-ro>i\,..
Asphyxia**~
('arcinogemt
Radioactive.
With m a n y hax, illg tin,re than one of these hazards. With
the exception of Oxidizer ~tnd Radioactive, the ERCVs by
Solkatronic Chemicals Inc. can be used to safely con,am
all of these. Once contained in the ERCVs, the t,iS DOT
Exemptions g10323 for Model #5501 and #105t)4 for
Model #5502 allow these to be sent back to the gas
supplier or to a disposal c~mlpany via a contracted carrier
o r compan} Iruck f~,!-c~m~rolled leak mitigation

throughout the USA the FiTc l)epartmcp~i:. ,~cla;~i~.


have become the first responders 1~ : ~ , ii~t/ \'l.~i
Two sizes
T,ao sizes are offered, Model 5501 for cylinders smaller
incident. The task they are faced with i>, ¢,vc~\~hcltnm&4..
than 17 liters (8" dia x 30" with cap) and Model 5502 for
when one considers the 10,000 ~,r more chetnic;l{,, ihal .it,.?
cylinders smaller than 50 liters (11: dia x (~" with cap). Both
m routine use.
have been designed to safely contain the sudden release of
Article 80, which was finalized in 1987 by the Western
pressure from these cylinders. Model 55(/I has a working
Fire Chiefs Association after t~o years of dedicated effort
pressure of 1480 psig while Model 55(12 has a working
by Fire Department representatives and consuhants, was
pressure of I100 ps,g.
the first major attempt to give local communities ;~
Model 5501 has an internal volume ol ~0.24 liters. If ,~
mechanism to control the handling and t, se of all
leaking 16-liter cylinder with a 2100 psig mixture ~s
Hazardous Materials. For many Western states, this
inserted, the theoretical equilibrium pressure would be
became effective in 1988 when they' adopted the 1988
1104 psig. The dead volume taken up by the cylinder
Uniform Fire Codes.
positioners and cylinder steel will add another t0~!~,
All of the other model code associations in the USA
increasing this to 1216 psig. For Model 5502, which has
followed suit with their version of a Hazardous Materials
an internal volume of 131.4 liters, a 2100 psig mixture m a
(;ode using Article 80 as a template. l-he Southern
40 liter cylinder will have a theoretical equilibrium pressure
Building Code Congress International in July It), 1990,
of 774 psig and an adjusted pressure of 853 psig
adopted their version as Chapter 22 m the Standard Fire
One of the basic tenets in ER incident preplanning is the
Prevention Code. The Building Officials and Code
ability to rapidly bring a situation under control in a sati:
A d m i n i s t r a t o r s International Inc. ( B O C A ) i n 1992
manner. The ERCVs offer that capability by being use,
adopted it as Article 23 in September, lt)92
friendly. They were designed by the Solkatronic Chemicals
Inc. Emergency Response Team to be used with a
Response minimum of problems. A trained two-man ER Team can
What is common to all of these is the need to develop a load either ERCV (#5501 or #5502) with a cylinder, close
quick and sate response to Hazardous Material incidem~ the flange, and start the purge gas in a matter of minutes.
that ca.n occuli even suited up m Level "A" protection.
On Site, Fhe vessels are highly mobile and can easily be moved to
In Transportation, the desired location by 2 people wearing the appropriate
In Storage, PPE (Personal Protective Equipment). To minimize field
At Customer Site. adjustlnents, the flange seat was designed to hold two "O"
One device cannot offer the universal cure to all Haz Rings (Viton and Buna N) so that one is compatible with
Mat problems. An effective ER Team will have a wide the product to be contained. Purge valves on both ends
variety ot" devices on hand to use, depending on the allow for quick and efficient purging in the field. For safe*',
immediate situation. reasons, the Model #5502 cart also has 'normally on' disc
For the compressed gases, the device which can fulfill brakes.
many of these requirements are Emergency Response
Containment Vessels (ERCV) from Solkatronic Chemicals
Inc. These are ASME Section VIII Division 1 coded
Emergency scrubber
For the toxic and highly toxic compressed gases, U FC
vessels which are DOT approved for transportation while
Article 80 requires the installation of an Emergency
containing a leaking gas cylinder.
Scrubber that is capable of handling the catastrophic
Well over a 200 different gases and liquids are packaged
leak of the contents of the largest cylinder m these areas
in compressed gas cylinders. In addition, many of these are
also mixed together in various concentrations to suit a used or stored and exhaust it at I 2 I D L H to the-
atmosphere. ]'he scrubber, gas detection and ventilation
particular process or need. Besides presenting a pressure
systems must bc tied into standby or emergency p o w e r
hazard, the cylinders contain substances which can be:
Flammable. This applies to all facilities that handle and/or store above
the exempt amounts of the gases.
Pyrophoric.

IIiiiiii iiiiiiiiill
Hydride Gases (ASH3, PH3),
Risk analysis Pyrophoric Gases (Sill4, B2Ho),
On the surface, these requirements appear to be realistic Oxidizing Gases (NO, NO2).
and will be of great value in minimizing public exposure to because they require different scrubbing solutions and/or
Haz Mat leaks. A risk analysis would reveal, however, that methods. It then must switch on the appropriate devices in
the requirements are justified only for manufacturing and a matter of seconds. If separate scrubbers are used for
use. These are the only times that the cylinder valve will be each, the capital and maintenance cost will be a severe
open, the cylinder cap removed and the vapor tight cap/ burden. More importantly, the installed systems can lead
plug removed. In this position, the valve is wide open and to a false sense of security since they may not work when it
failure of any one of the many pipe connections or is needed since all of the systems will require routine testing
components in a piping system from the cylinder to the and maintenance.
process could release significant quantities of gas. A gas cylinder would have 3-4 potential leak points, all
Statistically, the odds of a leak happening is increased of which in storage would be of a very low flow rate since
with the addition of more fittings or components. Article the cylinder valve is not open.
80 attempts to minimize the probability and impact of In the absence of the external events described earlier,
these events by requiring: the potential leaks are as follows:
Ventilated Enclosures, • A leak through the vapor-tight cap or plug would
Welded or other Approved Connections, require both the valve seat to be loose or damaged and
Coaxial Tubing for long runs, the vapor-tight cap or plug to be loose. It is unlikely that
Emergency Shut-off Valves, both could become fully loosened for a large leak to
Gas Detection, occur with the cylinder cap on.
Gas Treatment Systems. • For a packed valve, a leak could occur at the stem but,
again, this would also require the valve seat to be loose
Leaks or damaged.
• For valves with a pressure-relief device, a small leak
An informal review of gas industry data on leaks support
could occur through the threads if it is damaged or not
the conclusion that leaks, if they are to occur, happen
installed properly.
primarily in manufacturing and use. The remaining
• A thread leaker could develop at the valve threads into
incidents are almost all transportation incidents in which
the cylinder. A large leak could only occur if the valve is
cylinders have been violently tossed around because they
damaged or not properly installed. It is unlikely that this
were not properly secured or from vehicular accidents or
would go undetected in the filling process. The more
fires.
common event is a small leak ( < 10 cc/min.).
For many gas storage facilities at user and supplier sites,
All of these potential leaks would be detected immediately
the requirements for emergency scrubbing and power is
by the gas detection system required by the codes. The site
overkill for the potential risk. Of all the incidents, gas
ER Team would then use an ERCV to contain the leaking
storage accounts for < 1%. and these are generally small in
cylinder for shipment back to the supplier or disposal
nature. The catastrophic failure envisioned by Article 80 is
company for final leak mitigation procedures. If it is at a
an unlikely event without a severe external event such as a
gas supplier site, this would buy valuable time in setting up
fire or explosion. In either of these events, the scrubber
controlled disposal. This would be more effective than
would be rendered useless. The Washington State Article
having emergency scrubbers, cabinet and power in a
80 study group in 1989 also viewed the requirements to be
storage area.
costly and impractical.
Many of the Fire Codes are beginning to recognize this
For small storage facilities (typical electronic fab), the
alternative. The State of Oregon, during the adoption of
scrubbing system will become very complex if a variety of
Article 80 in 1989, added the exception (80.303.(a) 6.D.iv):
gases are stored. If only one scrubber is used, it must be
"Upon approval of the chief, it can be demonstrated that
capable of rapidly distinguishing between:
alternate means are capable of managing any release that
Alkaline Gases (NH3),
would not create an immediate threat to life or property"
Acid Gases (HC1, C12),
which would allow the substitution of ERCVs for
scrubbers.
Basic Building
More specifically, the Southern Building Code Congress
International in 1990 adopted the exception (408.4.2.7.2)
to the Southern Building Code:
"Cylinder containment device or system may be accepted
in lieu of the treatment system, for cylinder storage, when
approved by the Fire Official".
The State of Washington in adopting Article 80 added
the exception (80:303 (c) 3 B).
"A cabinet or exhausted enclosure need not be provided for
leaking cylinders if a US DOT approved cylinder contain-
ment vessel is provided."
In 1990 the Uniform Fire Code Committee of the
Western Fire Chiefs Association approved the following
Approximate areas of code influence exception to Article 80:(80.803 (c) 3 Special Provisions):

[liiiiiHliiMiii ii i iiiHiiitl
<,] ~?

5'pecificaLions
DOT E x e m p h o n # [': 10504
>ff _. N<;,
Volume (without cylinder)
34 6 gallons (1:31 4 liters}

Weight ( e m p t y ) 945 Ibs

Height (overall) 38"

Width {overall) 28

Length (overall) 7 9 '


K~..L@e h
~LEessure Vessel
ASME S e c t i o n VIII Division Front \,"le w
Length (overall) 7 9
( i n t e r n a l ) 74"
D , a m e t e r ( o u t e r ) !2 7 5
( i n n e r ) 11 "75'
"fA 106 Grade C C a r b o n Steel
Working P r e s s u r e 1100 psig
H v d r o t e s t P r e s s u r e 1680 psig
Operating Temp -2OF to 130F
- At &G "- . , t -
F'i~ nge
Double BoIL q u i c k O p e n i n g By . . . . . . . .

Tube T u r n s
('a r bon Steel
Chain and S p r o c k e t DrF,'e
[)Hubie "O' Ring Seal
[nyqde Viton
Outside Bun~, N

~Ide vlc w

Compressed gas emergency containment vessels

".., or approved containment vessels are provided that they cabinets or exhausted enclosures or where toxic gases are
are capable of fully containing a release". provided with:
In the July, 1991 meeting of the Western Fire Chiefs a. Approved containment devices that are capable of fully
Association, the following revision was approved for the containing a release are available at an approved location on
1991 Uniform Fire Code under 80.803 (c) 3 Special site.
Provisions: b. Trained personnel are available at an approved location on
E X C E P T I O N : A cabinet or exhausted enclosure need not site, and
be provided for leaking cylinders if all cylinders are stored c. Such containment devices are capable of being transported
within gas cabinets or exhausted enclosures, or if approved to the leaking cylinder.
containment vessels capable of fully containing a release and At the September, 1992, meeting, this was not approved:
trained personnel are available at an approved location. Such however, there were a number of challenges by members to
vessels shall be capable of being transported to the leaking adopt it. Areas of influence throughout the USA by the
cylinder locations. three model code associations are shown in the figure.
On March 27, 1991, the Santa Clara County Fire Chiefs The use of ERCVs is fast becoming recognized in the
Association Hazardous Materials Subcommittee adopted United States as being one of the important leak
consensus guidelines for the Toxic Gas Ordinance for containment devices available for compressed gases.
Section XI:
Encapsulating equipment designed to contain high-pres- Eugene Y. Ngai,
sure cylinders and their contents, as approved by the Fire VP Corporate Development Health, SaJety and Environment,
Chief, shall be acceptable in meeting the intent of providing a Solkatronic Chemicals lnc,
gas cabinet or exhausted enclosure for leaking gas cylinders. 30 Two Bridges Rd.,
At BOCA, the High Hazard Committee recommended Fai(/}eht,
the adoption of similar language in Article 23 Section F- NJ 07004-1530 USA.
2303.3.8.1 Exception 2: Telffhx: I l l (20])882 7900 / 7967.
A cabinet or exhausted enclosure is not required for
leaking cylinders where all cylinders are stored within gas