Earlier quoted context omitted.
The answer to grandfathering things in is not to give them an indefinite examption from the rules; instead, give them, say, a 10 year period of exemption, giving the owner enough time to fix the defect and to spread the expense of doing so over time. It's not perfect, but eventually everything ends up being fixed.
It depends a lot on context. That's certainly a reasonable approach in some situations. However in this instance it's not clear to me that there's any possible way to comply with modern regulations. My impression is that in general it isn't permitted to keep massive tanks of hazardous industrial chemicals 500 feet from residential housing units in the middle of the city. I think this is an example where it might have…
That Methyl Methacrylate Tank
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Re: That Methyl Methacrylate Tank
#162(also waaaay down on the list of uses at https://en.wikipedia.org/wiki/Poly(methyl_methacrylate) but I thought that first link was clearer. Look for "In semiconductor research and industry, PMMA aids as a resist in the electron beam lithography process.")
Re: That Methyl Methacrylate Tank
#163> "I look forward to the eventual incident report for the root causes of this one - assuming that we do such things any more here in the #$%@! Golden Age in which we find ourselves - because that, too, will make things safer going forwards. One hopes." If there's no after action report, we'll never get a good episode of Well There's Your Problem on this incident, and that would be a loss for both engineering and podc…
Re: That Methyl Methacrylate Tank
#164Earlier quoted context omitted.
Sure it can. So can Vitamin C though. The overall point remains the same: the toxicity, both short and long term, of MMA, is comparable to lots of everyday substances that are both commonly eaten and inhaled. It just isn't that toxic as far as chemicals go. That doesn't mean it would be like great for you but calling it "highly toxic" is tremendously overblown and doesnt serve anyone well to claim. Let's save the hig…
It produces highly toxic byproducts when it burns thus the exposure concerns.
Re: That Methyl Methacrylate Tank
#165Here's a fascinating postmortem analysis of two similar incidents, Styrene and Butyl Acrylate: https://iomosaic.com/docs/default-source/papers/polymerizati... From fuzzfactor's comment with lots of other great info: https://news.ycombinator.com/item?id=48252245
IIRC there was some report of a "gas leak" to begin with and that could very well have been it.
I can only imagine what it's like to be one of the shift operators down there on the pavement around the tanks and pipes on a daily basis, in their flame-retardant coveralls and hardhats. Based on my vivid experience working with similar operators as I took official samples from tanks usually located in much bigger tank farms.
MMA smells so sharp that any leakage from a valve or pipe fitting gets attention much more so than other flammable liquids, for instance things like paint removers, alcohol or acetone which smell very faint by comparison. I expect that the workers had gotten accustomed to a fairly clean air environment without serious toxicity levels, and would estimate that a leak of about 1 drop per minute from a flange would be easily identified and fixed. Not only to keep the neighbors from complaining, but to keep the workers from gagging when they walk closer to that location.
If the first sign of trouble was physical tank bulging and/or suddenly stinking up the whole place with lots of MMA vapor (like from an upper tank rupture) when there is no sign of leakage on the ground, that pretty much qualifies as a "gas leak". Once the smell was no longer prominent, I would say that polymerization was well underway and there was not as much free monomer available to build up more pressure or even evaporate very much after that. If there's warm liquid MMA open to the atmosphere, you will smell it downwind.
It might be a stretch to say that "nature takes its course" when synthetic monomers spontaneously polymerize like this, but that's what some of them do best that sets them apart.
From what I understand, in the uninhibited pure monomer it doesn't take that many PPM of monomer molecules to become "activated" in some way before the chain reaction of them with remaining molecules eventually accelerates to completion. Which may be why such a low concentration of inhibitor works so well, but inhibitor must be well-dispersed within the liquid and there must be enough circulation to avoid local depletion of the inhibitor due to stagnant contact with as yet unidentified unexpected initiators. Not only should it be easy to get a random 1 liter sample from a tank (of such non-viscous material) at any time, the single sample should ideally be highly representative of the entire tank contents. Due to the way the liquid is handled in bulk going in & out of the tank, as well as any additional circulation to insure good mixing of incoming cargo, or after boosting inhibitor amounts when only a few carefully measured pounds or kilos of the concentrated inhibitor is dumped into the bulk monomer to keep it from going below spec.
The inhibitors have been selected to be very strong and effective at what they do so it doesn't require a high concentration, and the downstream processors can more easily overcome the inhibitor effect and produce plastics using different and milder polymerization initiator techniques when there is not an excess of inhibitor.
Once it gets polymerizing past that minuscule little inhibitor, from that point it's like there is no inhibitor at all. So there is some possibility that this is a fairly worst-case runaway polymerization event where the full amount of caution was rightfully warranted. Even though it would have to be considered fairly benign compared to a whole tank of the liquid monomer dispersing through the neighborhoods, or going up in a fireball, which is always a risk anyway :\
Under storage, it really is tremendous force that the inhibitor is holding back, considering how badly outnumbered it is by the 99.9% of everything else in the tank that wants to spontaneously react with itself otherwise. When the inhibitor is only about 20 PPM, which in percent is 0.0020%, in these cases percent by weight. IOW 20 lbs of MEHQ crystals dissolved in every million lbs of MMA liquid, or in metric 20 kilos of inhibitor for every million kilos of cargo.
Now usually the lowest inhibitor concentration will be at the chemical plant that produces the monomers, and it may go into bulk storage the same way when fresh material is moving through the system adequately. From there, vessels, rail cars and trailers often have different amounts of additional inhibitor added in order to boost levels according to purchase agreements of the different industrial consumers.
Often by contractors such as companies I have worked for who store the inhibitor concentrate as agents for the client, and can sample industrial tanks & test in the lab to routinely determine inhibitor concentration. Then carefully measure according to requirements and be the third party that certifies the new concentration after our field operator physically adds the additional dose to the tank.
For something like vessels and rail cars you just can't expect their cargo samples to accurately reflect a recently boosted inhibitor value, the small amount of inhibitor concentrate won't be adequately mixed with the rest of the bulk monomer before the ship leaves the dock or the train leaves the terminal. So it has to be certified by careful physical addition while being supported by good lab data to begin with. You expect lab readings to match the certificate after the ship gets overseas or the rail car gets across the country.
Now measuring low PPM is not always easy but you get better after a while.
Much better for me because I got to start doing it my own way as soon as I could, after first establishing as many of the predecessor techniques as possible for reference, but people still wanted more reliable results and so did I since the beginning. Ever since then, doing the continuous improvement thing for more decades than you normally get.
Things I will work with, repeatedly ;)
Re: That Methyl Methacrylate Tank
#166Earlier quoted context omitted.
>Because the US chemical industry has been effectively unregulated for a century and can do whatever it pleases. And yet I bet if I look there's actually a ton of regulation. >Chemical A is found to be cancerous Chemical A is assumed to be cancerous by the state of California, you mean?
Are you alleging that California claims stuff to be carcinogenic without evidence? Do you have a supposed motive? Any evidence? Whilst it's a bit of a meme, isn't it just true that a lot of stuff is carcinogenic.
California has set such a low threshold that one cannot take their label seriously about anything. It applies to nearly everything, making it effectively a useless warning.
Re: That Methyl Methacrylate Tank
#167> "I look forward to the eventual incident report for the root causes of this one - assuming that we do such things any more here in the #$%@! Golden Age in which we find ourselves - because that, too, will make things safer going forwards. One hopes." If there's no after action report, we'll never get a good episode of Well There's Your Problem on this incident, and that would be a loss for both engineering and podc…
Given the disruption this has caused in Orange County I would expect to eventually get a slick US Chemical Safety Board video on it.
John Childgey's "Causality" podcast[0] covers stuff like this, and I'm sure he'll eventually cover it.
Re: That Methyl Methacrylate Tank
#168Earlier quoted context omitted.
> Why wouldn't there be passive protection systems designed in? Because the US chemical industry has been effectively unregulated for a century and can do whatever it pleases. There's a neutralizing chemical that could have been injected to stop the exothermic reaction in its tracks. They didn't have it on site. A "response team" (likely a contractor that responds to chemical emergencies) did, but by the time they sh…
Complaining about the Chevy Cruze like that is hilarious . Did you go out of your way to pick up a particularly harmless example? What about all the other cars that kill significantly more people by design ? Like, I don’t know, any SUV or pickup truck? In that context, picking on the rather innocent Cruze seems a bit obtuse.
AFAIK there were no similar ignition switch failures or associated deaths with the Cruze (or other >2011 model year vehicles), although I think it might have been part of the recall.
Re: That Methyl Methacrylate Tank
#169Re: That Methyl Methacrylate Tank
#170Earlier quoted context omitted.
In California, this is absolutely not the case. Regulations are strict, chemical emissions are heavily restricted and proper disposal of chemicals via specialized companies at great expense. Chemical companies have no need of formulating new versions because everything causes cancer under prop 65. They absolutely have numerous permits for chemicals, your claim that they don't denies reality. This case probably fell t…
The plant was built after the houses but likely well before we had anything resembling modern safety regulations regarding such things. It was presumably grandfathered in for no reason other than that arbitrarily putting someone out of business after the fact is generally frowned upon. https://news.ycombinator.com/item?id=48254291 That company (GKN Aerospace) was recently fined $900k by California for various violati…
It's par for the course of many US companies and likely others outside the US. I have been in a lot of manufacturing/industrial facilities and find a lot of machismo coupled with greedy asshole bosses/owners/managers. You wind up with corporate culture of "keep your head down, do as your told, don't question, and get paid."
It leads to a normalization of deviance where you end up with resentful workers who don't give a shit. Then when things go wrong, management can then easily blame them for their crappy work ethic and fire them. Then hire a new person to demoralize in exchange for money. It's a scam really.
The only way to curb that behavior is to hold people responsible but we seem to be incapable of doing that because the people who need to be held responsible have too much money and power.