High voltage limiter with discrete components
You can make it work by providing a negative supply for R1/R2, something like -5V will do. 

But there are probably easier ways, especially if you know why exactly you had part failures. If your failures are due to the divider flashing over, then discrete parts are not going to be all that much more robust. 

I would suggest something more along these lines (concept only at this point), where U1 is an open-collector or drain output dual comparator with low input bias current:







simulate this circuit &ndash; Schematic created using CircuitLab