Document 2Nd441V7E7qrn8wwQXeYnx6r6
To: Ron Bryan -- L.C. VCM
nteroffice `ommunication
From: Oate:
Harold Kramer July 22, 1985
Subject: L.C. VCM EPA CONSENT DECREE ESTIMATES
VIS1A
The following EPA Consent Decree Budget Estimates are attached for your review. These estimates are based on your list of potential projects transmitted to GED on July 15, 1985, plus projects added by Pat Fetizanan.
Project No.
VC-08-006 VC-08-008 VC-08-009 VC-08-011 VC-08-014 VC-08-015 VC-08-016 VC-08-023 VC-08-028 VC-08-029 VC-08-031 VC-08-032
Description
^Tank Farm Vent Eductor
/Vent Flow Feed Forward /Flame Temperature Control / Standby Blower Operations / Flame Arrestor Instrument Rev. /Restriction Orifice v^HCL Column Control
/Direct Chlorination Reactor Feed
/Auto Tiebreaker
/.Oxygen Analyzers
^
^Wet Vent & D.C. Vent Flow Alarms v/
/S-102=Flow Indication & Alarm v'
Subtotal
$K
$ 73.5 23.0 20.5 7.0
- 28.5 0.5
97.0 8.5
67.0 29.0 -
6.5 5.0 $366.0
VC-08-021
Burner Modification (Scope has changed, estimate will be completed at a later date.)
Please note that these estimates are in the format according to the Stipulated Penalties agreement. They also do not include the normal 10-15% contingency which is normally included and spent on Budget Quality Estimates, per Conoco's request.
If there are any questions, comments, or additional designs that need to be included, please advise.
Harold E. Kramer
018/HEK Copies to: (w/att.) GWI-JES-PFF-JRC-HEK
C Si CCR 000021036
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S ^s> CCR 000021037
William L. McClain
VIOIA
Distribution
04* 7-1-85
Please call if you have any problems with the attached.
fyjJLL /*we) Bill
are
Attach.
Distributions Dick Conrad John Friend Harry Garrison Jack Stoner Estela Wackerbarth
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STIPULATED PENALTIES AGREEMENT
This Agreement between Conoco Inc. ("Conoco"), Vista
Chemical Company and Vista Polymers Inc. ("Vista") is entered
into for the purpose of delineating respective
responsibilities for the payment of any stipulated penalties
which may be assessed or become due and payable after entry of
Consent Decrees in the cases identified below.
1. Case No. 83-1916-E, filed in the District Court for the Western District of Oklahoma;
2. Cqdc No. 03-2010, filed in the District Court tor the Western District of Louisiana; and
3. Case No, EC-37-LS-P, filed in the District Court for the Northern District of Mississippi,
The Department of Justice has required, as a term of
the Consent Decree to be flld in
of these cases, for
payment of stipulated penalties as follows:
1. For failure to submit a compliance plan as described in, and in the time required by, Section III of each Decree, Conoco and Vista shall pay $1,000 per day of noncompliance.
2. For failure to take or complete the tasks according to the timetable outlined in the compliance plan submitted pursuant to Section III of each Decree,
Conoco and Vista shall pay $1,000 61? day ot noncom pliance .
The Department of Justice has further required, as a
term of each Consent Decree, that Conoco and Vista be jointly
and severally liable for, inter alia, payment of any
stipulated penalties 4 However, the Deuiwwu penult Conoco and
Vista to agree between themselves as to who shall undertake a
specific task. See Section II Bound Parties in each Decree. 0oO
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Accordingly, Conoco and Vista agree that payment of any stipulated penalties which may become due pursuant to the
terms of the Decrees entered in settlement of the cases
captioned
will ba paid AS followst
1. Liability for stipulated penalties for failure to submit o-eompliance plan as described in or in the time required by Section III of the respective Consent Decree will be borne equally by Conoco and Vista, Within twenty-five (25) days of the event causing stipulated penalties to be due, Conoco will mail to Vista a check for one-half of the amount of stipulated penalties due, made payable to Vista. Within thirty (30) days of the event causing stipu lated penalties to be due, Vista will mail to the appropriate ulllue of the united States Attorney, a check for the full amount of stipulated penalties due, together with a transmittal letter as required in Section XV of each Consent Decree. Such trans mittal letter is Lu bu unsigned by counsel tor
Conoco.
Provided, however, that each party to this Agreement reserves its right to seek recoupment, from the other party, its share'of any stipulated penalty paid if the delay or failure which caused a stipulated penalty to be due is primarily attributable to the other party.
2. Liability for stipulated penalties for failure to take or complete ta3ks according to the timetable outlined in the compliance plan described in Section in or the ruspuctlve uonsent Decrees will be borne solely by Vista. Within thirty (30) days of the event causing stipulated penalties to be due, Vista will mail a certified Check to the appropriate office of the United States Attorney made payable to the Treasurer of the United States, together with a transmittal letter as required in Section IV of each
Consent Decree, Provided, however, that Vista reserves its right to seek recoupment from Conoco any stipulated penalty paid to the extent the delay or failure which caused a stipulated penalty to be due relates primarily to Conoco's failure tn frdlAuj procedures enumerated below.
Fur any uf the tasks identified in any compliance
plan finhmi
pursuant to Section III of each Consent Duciwy
fur payment Of which Conoco is liable in accordance with the
CCR OOOOZIO^
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Du Pont-Conoco/Vista Asset Agreement dated July 20, 1984, Conoco and Vista agree to use the procedures enumerated below:
1. No later than thirty (30) days prior to submission of
the compliance plans. Conoco wj~i
from Vista
quality process design and._c.gs t-aitlmate for gao.h--project included j.n the" compliance planT The v
cost estimate will exclude contingencies. Any
disagreements between Vista and Conoco concerning the
design or associated coat estimates will be iwaulved
prior to joint submission of the compliance plans.
2. Onoc tho compliance plans are approved by EPA and
DOJ, Vista will prepare the definitive process design
and cost estimate according to the timetable in the
approved compliance plan. An Authorization for
FvnnHi +-ivro /ar'r'j
i i w*> p-Tjr nr 4 anA eppiroiud bj
Vista and transmitted to Conoco with copies of the
definitive process designs and cost estimates at-
, Each APS total will vcflecL the LuLai
capital projects identified in an individual plant
compliance plan. The cost estimate will include 24%
of direct cost for total Engineering plus 15% of
Engineering to cover overhead. The cost estimate
will exclude contingencies. Fifteen (15) days after
receipt of the AFE and support documents/ Conoco will
complete its review of the process design and cost
catimute provided, liuwever, that If additional infor
mation is necessary to evaluate an AFE or to resolve
differences between Conoco and Vista, Conoco will
have an additional 15 days in which to complete its
review of the AFE.
3. Vista will complete the capital project according to the time schedule included in the compliance plan,
4. Within thirty (30) days after Conoco has completed the review of the AFE, a progress payment invoice will be sent to Conoco from Vista and every thirty (30) days thereafter until the AFE total has been paid. Invoices are due upon receipt.
5. The amount of th^ ninthly progress paymont in baaed on the following formulas
AFE total or budget quality cost estimate total (plus 15% of the estimate total), whichever is less, per plant divided by the total number of months of the.longest term project identified in the AFE for each plant.
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CCR 000021041
Abnaaawii bisin woad
The progress payments will be in equal install ments invoiced on the thirty (30) day cycle until the total amount identified under the above paragraph is paid.
6, During the course of project implementation Vista will consult with Conoco in the event Vista identifies changes that could affect project cost in excess of the total budget quality estimate plus 15%,
Cujiuco and VISti recognise that after completion of
the last project addressed in an AFE, a review of expenditures
will be necessary. To that end, Vista will make available for
inspection sufficient documentation to permit Conoco to verify
the expenditures which have been or will be reimbursed by
Conoco.
Upon completion of the review, Conoco will determine whether the amounts expended by Vista were warranted under the AFE. If they were so warranted, Conoco or Vista will invoice the other for monies over or under the approved AFE amount respectively. Invoice payment will be due thirty (30) days after receipt of the invoice.
In the case of any disagreement with a request for
reimbursement Conoco and Vista will meet to determine the
split of responsibilities for these expenditures. Upon
resolve, the onmpnn-i
will follow the invoice px-ocedurau
described in the preceding paragraph.
CCR 000021042
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FOR CONOCO INC.
Batela 3. WauK.yibdrth
Donald D. Eoff Director,
Contract Coordination
FOR VISTA CHEMICAL COMPANY AND VISTA POLYMERS INC.
William L. McClain Counsel for Vista Chemical Co.
& Vista Polymers Inc.
WLM07/010
OCR 00002104-3
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CCR 0000210^
To: Distribution
tl)K
Interoffice Communication
From: Date:
S. C. Racca August 1, 1985
Subject: Consent Decree "Emission Control Plan Administrative Measures
VIS1A
As a result of the USA vs. Conoco Consent Decree recently entered into by Vista, several "Administra tive Measures" intended to reduce/eliminate the emissions of vinyl chloride due to relief valve releases and incinerator bypasses must be committed to by the VCM Plant. These measures include formal Operator Training programs, formal Operating proce dures, a formal Preventive Maintenance program, a formal Notification of Statds program, and Miscel laneous Inspection Programs. By formal it is meant an in-writing commitment concerning the scope of each program, the frequency for accomplishment of all identified action steps, and written documentation of completion of each action step.
As a result of discussions during the July 11 and previous meetings concerning identified "Administra tive Measures", the following division of duties/ responsibilities is established:
1) Operations Department (MLA) responsible for development and implementation of:
a) Operator Training Programs b) Operating Procedures c) Miscellaneous Inspection Programs
2) Mechanical Department (JRH) responsible for development and implementation of:
a) Preventive Maintenance Programs b) Miscellaneous Inspection Programs
3) Process Engineering Department (SCR) responsible for development and implementation of:
a) Notification of Status Program
Attached are specific measures which must be included in each of these programs. They are broken down into
CCR 000021045
TABLE I. ADMINISTRATIVE MEASURES TAKEN AND TO BE
TAKEN BY THE OPERATIONS DEPARTMENT
I. Measures Taken
A. Operator Training
1) Annual relief valve release avoidance training.
2) Special counseling of operators following any incident which did lead, or could have led, to a relief valve discharge
3) Specialized training program concerning the properties of liquid-full systems with specific emphasis on how those properties relate to overpressuring caused by failure to properly align block valves while putting a flake caustic dryer on line and while switching check tanks.
4) Each operator undergoes comprehensive training and testing while progressing from one position to another.
B. Operating Procedures
1) Modification of start-up sequence procedure for removing nitrogen from the HC1 column following an inventory control shutdown.
2) Development of furnace clearing procedure for venting nitrogen prior to start-up.
3) General procedure for removal of nitrogen in process equipment before, or during, start-up.
4) Establishment of specific procedures to limit impurities in the ethylene used as reactor feedstock by the ethylene feedstock supplier at the request of the VCM Plant.
CCR 000021047
c Miscellaneous Inspections
1) Routine monitoring of the pressure drop across the flake caustic dryers and appropriate corrective action when increased pressure drop is observed.
2) Addition of caustic decanter high pressure alarm switch to the "blind list" (used to ensure blinds are removed prior to start-up following turnarounds) in July, 1982.
3) Pre-startup inspections prior to putting new equipment in service.
4) Bi-weekly inspections of tell-tale pressure gauges on relief valve rupture disc assemblies.
D. Miscellaneous Measures
1) Institution of formal incinerator bypass investigations by operations supervisory personnel. These investi gations include a detailed report of each bypass incident and a written corrective action plan.
II. Measures to Be Taken
A. Operator Training
1) Training program related to prevention
of incinerator bypasses will be
formalized.
It will include
discussions of past bypasses, their
cause,
and
appropriate
preventive
measures.
B. Operating Procedure
1) Procedures for minimizing the potential for incinerator bypasses due to routine and emergency/non-routine vents will be reviewed and updated.
cc 0002104a
c Miscellaneous Measures
1) The chlorine supplier will be formally notified of the impact of off-specification chlorine on incinerator operation and advance warning by the supplier will be given to to Vista pursuant to the supply contract.
CCR 00Z1Q49
TABLE II. ADMINISTRATIVE MEASURES TAKEN AND TO BE
TAKEN BY THE MECHANICAL DEPARTMENT
I. Measures Taken
A. Preventive Maintenance
1) Conduct periodic check of relief valves during turnarounds by an outside contractor. This check is to ensure that all relief valves operate at their rated pressure and that they are in good mechanical condition.
2) Calibration of instrumentation to ensure that it is functioning properly and will alert of possible overpressure conditions.
B. Miscellaneous Inspections
1) All in-plant maintenance on relief valves is overseen by a certified relief valve inspector employed by the plant.
2) Following construction and installation
of new equipment and/or replacement of
existing equipment, the maintenance
department's
check-out
procedure
includes visual inspection along with
hydrotesting and/or weld X-rays.
C. Miscellaneous Measures
1) Pre-torqued rupture disc assemblies are used to prevent damage to the disc during installation
II. Measures to be Taken
A. Preventive Maintenance
1) The
existing
plant-wide
routine
maintenance program will be reviewed
and updated to specifically include
instrument and mechanical items related
to incinerator shutdown prevention.
CCR 000021050
TABLE III. ADMINISTRATIVE MEASURES TAKEN AND TO BE
TAKEN BY THE PROCESS ENGINEERING DEPT.
I. Measures Taken
A. Miscellaneous Measures
1) Warning signs have been installed near the start buttons of five pumps in vinyl chloride service. These signs warn operators to check valve line-up before starting the pump to prevent a possible VCM relief valve discharge.
II. Measures to be Taken
A. Notification of Status
1) Institute a formal Notification of
Status program to ensure that
administrative
measures
identified
herein are conducted in a timely
manner.
00002l51 CCR
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Cc 000021053
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CCR 000021054
Made By _______________________________ Date ___________________________________ Page of_________________________________
V3-20G-5
Job No. Title -- _______
CONOCO/VISTA VCM PLANT CONSENT DECREE MEETING
July 24, 1985
OBJECTIVE
DETERMINE MEASURES TO BE INCLUDED IN "EMISSION CONTROL PLAN"
AGENDA
REVIEW ATTACHMENT A MEASURES AND ESTABLISH STATUS OF EACH
I. MEASURES TAKEN
A. Administrative Measures
1. Formal Incinerator Bypass Investigations 2. Ethylene Feedstock Supplier Procedures
B Physical Measures
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Vinyl Flake Caustic Dryer (S-207A/B) Restric tion Orifice Dry and Wet Vent Header Pressure Control Modificatons Dry and Wet Vent Header Flow Indication Tank Farm Vent Blower Anti-surge Instrumen tation Combustion Air Blower Mechanical Stops Dry and Wet Vent Header High Pressure and Direct Chlorination Reactor High Flow Alarms in Main Control Room
7. Combustion Air Blower Steam Turbine Driver Lube
. Oil Filter Modifications
8 Incinerator Instrument Power Supply Low Voltage
Alarms
II. MEASURES TO BE TAKEN
A. Administrative Measures
1. Preventive Maintenance Program 2. Operating Procedures 3. Operator Training 4. Notification of Status Program 5. Chlorine Feedstock Supplier Advance Warning
CCR 000021055
B. Physical Measures
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.1.
2
3. 4.
.5.
6
.7.
8 9. 10.
.11.
12 13. 14.
In-situ Oxygen Analyzers Combustion Air Flow Control a. Vent Header Flow Feedforward (or Ratio) b. Firebox Oxygen Concentration Feedback c. Liquid Flow Feedforward (or Ratio) d. Natural Gas Flow Feedforward (or Ratio) Automatic Start-up of Standby Combustion Air Blower New or Modified Burner Assembly Flame Temperature Control Modifications Separate Natural Gas/Combustion Air (Premixed) Burner Direct Chlorination Reactor Vent Flow Control Flame Arrestor Level Control Revisions Tank Farm Vent Eductor Automatic Tie-Breaker HC1 Column Control Modifications Resize Vinyl Flake Caustic Dryer (S-207A/B) Restriction Orifice Light Ends Column Accumulator Flow Indication and Alarm Dry and Wet Vent Header High Flow Alarms
REVIEW INCINERATOR BYPASS RESPONSE.
INFORMATION REQUEST
("
114")
CCR 000021056
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DRAFT WLM05/017
TABLE I
Incinerator Bypass Nature and Cause Summary for the Period From
May 1, 1983 through March 13, 1985
Total Number of Bypasses Per Category
Automatic Shutdown
Nature and Cause Category
Partial Bypass
Flame Failure
Low Combustion
Air Flow
Other
I. Excessive Vent Flow from Main Plant
A. Routine Vents 1. Vinyl Product Caustic Dryer (1) 2. Vinyl Vent Recovery Unit (2) 3. Oxychlorination Purge Gas Dryer (3) 4. Flake Caustic Dryer (4) 5. Caustic Melt Blowdown Drum (5) 6. EDC-Caustic Decanter T-102 (6) 7. Direct Chlorination Reactor Startup (7) 8. Miscellaneous Equipment Clearing for Maintenance (8) 9. Main Plant Startup and Inventory (9)
1 3 1 1
1 1 2 2
1
41 1
1 1 1
3
CCR 0 0 0 0 2 1 0 5 7
B. Non-routine or Emergency Vents 1. Light Ends Storage Tank (10) 2. Vinyl Column (11) 3. Direct Chlorination Reactor a. Impurities in Reactor Feedstock (12) 1) Ethylene 2) Chlorine 4. HC1 Column (24)
1 53
43 5 1
2 2
C. Unknown Source
33
Nature and Cause Category II. Instrument Malfunction
A. Combustion Air Control (13) B. Instrument Panel Power Supply (14) C. Combustion Air Automatic Shutoff (15) D. Flame Arrestor Level Control (16) E. Flame Scanner (17) F. Valve Positioner (18) G. HC1 Absorber Quench Vapor Inlet Temperature (19) HI. Mechanical Malfunction A. Incinerator Burner B. Tank Farm Vent Blower C. Incinerator Firebox IV. Steam Outage V. Electrical Power Outage VI. Liquid Byproduct Feed Interruption VII. Operator Inattention
CCR 0 0 0 0 2 1 0 5 8
Total Number of Bypasses Per Category
Automatic Shutdown
Partial Bypass
Flame Failure
Low Combustion
Air Flow
Other
11 1
1 11
1 1
1
4
4 (20)
2 (21)
1
1
1
1
1 1 2
CCR 0 0 0 0 2 1 0 5 9
Nature and Cause Category___________ VIII. Miscellaneous
A. Tripout of Steam Turbine Driving Combustion Air Blower (22) B. Cause Unknown (23)
Total Number of Bypasses Per Category
Automatic Shutdown
Partial Bypass
Flame Failure
Low Combustion
Air Flow
Other
2 1
DRAFT WLMO 5/018
Notes for Table I
(1) The vinyl product caustic dryer is used to remove moisture from product being transferred from storage to railcars or ship.
(2) The vinyl vent recovery unit recovers vinyl product from railcar and ship vents by condensing vinyl vapors. Once condensed vinyl is recovered the remainder of the vent stream is incinerated.
(3) The oxychlorination purge gas dryer removes moisture from the oxychlorination purge stream before the stream enters the direct chlorination reactor.
(4) The flake caustic dryer is used to remove moisture from vinyl product being transferred from the processing unit to storage.
(5) Caustic melt from the flake caustic dryers is routinely transferred to the caustic melt blowdown drum where entrained and/or dissolved vinyl is weathered off to the incinerator.
(6) Crude ethylene dichloride is washed with caustic and then phase separated in EDC-caustic decanter T-102.
(7) Ethylene dichloride is produced by direct chlorination of ethylene in the direct chlorination reactor.
(8) During turnarounds and maintenance shutdowns equipment must be cleared with nitrogen prior to opening for entry.
(9) During main plant startup equipment must be purged of all oxygen and then inventoried.
(10)
Pressure in the Light Ends Storage Tank is normally automatically controlled by venting excess pressure to the incinerators. Failure of the automatic controller
and subsequent overpressure of the tank necessitated emergency venting.
(11) The bottoms of the HCl Column are fed to the Vinyl Column where vinyl chloride product and recycle ethy lene dichloride are separated. Occasionally the HCl column goes "sour" which results in HCl vapors in the top of the Vinyl Column, necessitating emergency venting of the Vinyl Column condensers.
1
(12) Impurities in the Direct Chlorination Reactor feedstock
and/or feedstock supplier operational upsets result in abnormally high vent rates.
(13) Incinerator combustion air control is used to maintain sufficient excess oxygen to ensure complete combustion.
(14) The incinerator instrument panel power supply provides regulated power to all control and indication instrumentation.
(15) When an automatic incinerator shutdown occurs a safety shutoff valve on the combustion air automatically closes preventing addition of air to firebox.
(16) Liquid seal flame arrestors are used to prevent flash back from the incinerator firebox into the exhaust gas headers.
(17) Incinerator firebox flame scanners are used to detect the firebox flame.
(18) Valve positioners are used on the exhaust gas header pressure control valves to ensure correct valve position for a given controller output signal.
(19) HCl absorber quench vapor inlet temperature is monitored and will initiate an automatic incinerator shutdown should safe operating temperature be exceeded.
(20) Mechanical malfunction of the tank farm vent blower results in bypassing of the tank farm vent only, not the direct chlorination and wet vent headers.
(21)
The incinerator did not shutdown because its power was not interrupted for more than 3 seconds, but power to the tank farm vent blower and to the main plant was interrupted on 2-7-84 and 6-1-84, respectively.
(22)
Incinerator combustion air is supplied by forced draft fans driven by either steam turbine or electric motor.
Turbine tripouts were caused by low lube oil pressure resulting from plugged filter elements.
(23)
The exact cause of the incinerator bypass that occurred on 12-31-84 at 0430 is unknown. Prior to its occur rence the vent header pressure decreased followed by a flame failure indication.
oooozi-061
CC*
2
(24)
A mixture of HC1, vinyl chloride, and ethylene dichloride is fed to the HCl Column where the HC1 separated from the vinyl chloride and ethylene
dichloride.
is
COR 000021062
3
iJRAFT WLM05/019
Table II
Incinerator Bypasses Reported During the Period from May 1, 1983 through March 13, 1985
Date
05-13-83 05-14-83 05-15-83 05-21-83 05-25-83 06-06-83 06-10-83 06-10-83 -06-18-83 36-21-83 06-22-83 07-08-83 08-01-83 08-04-83 08-10-83 08-24-83 08-28-83 09-02-83 10-13-83 11-01-83 11-05-83 11-14-83 11-15-83 11-30-83 12-15-83 12-21-83 12-23-83 12-23-83 12-25-83 01-12-84 01-26-84 01-27-84 01-30-84 02-05-84 02-05-84 02-06-84 02-07-84
02-09-84
Time(3)
0900-0945 2200-2204 0010-0015 1645-1650 0700-0730 1800-1820 1000-1005 1555-1600 1100 1400 (2) 2030-2200 0100-1000(2) 2045-2130 1015-1030 1700-1715 1400-1415 0430-0440 1530-1540 1715-1717(1) 2230-2235 1100-1105 1545-1625 0800-0805 0145-0215 0415-0425 0400-0410 0535-0550 0630-0730 1300-1530 2000-2005 1030-1032 1820-1830 1000-1002 0900-1115 20100100 1630-1705 (1,2) 1900-1905
Nature & Cause Category
I.A.8. I.B.3.a.2) I.B.3.a.2) I.C. I.A.8. I.B.3.a.2) I.B.3.a.2) I.A.8.
III.B. I.A.4. III.B, I.A.8. III.A. I.A.5. I.B.3.a.2) I.B.2. I.A.2. I.B,3.a.1) I.A.7. II.A. I. B. 3 ,a. 1) II.B. I.B.2. II.C. VIII.A. VIII.A. II.D. IV, I.B.2. I.C. I.C. I.A.l. V,
III.A. V.
I.A.9.
Parti Bypas
X X X X
X X X
X X
X X
X X
Automatic Shutdown_______
Low
Flame
Combustion
Failure
Air Flow
Other
Vent Header(s) _____ Bypassed
Wet
Dry
Tank Farm
X XXX XXX X XX
X XXX X
X XXX X XXX
X X XX X
X X XXX
XXX X XXX X XXX X XXX X XXX
X XXX X XXX X XXX X XXX X XXX X XX X X XXX X XX X X XXX X XXX XXX X XXX X XXX
X X XXX
X XXX
x
0000210&3 OCR
X
X
Date
02-10-84
02-11-84 02-13-84 02-13-84 02-14-84 02-14-84 02-17-84 02-19-84 02-22-84 03-08-84 03-09-84 03-30-84 04-02-84 04-05-84 04-06-84
04-07-84 04-11-84 -04-22-84 J4-25-84 05-07-84 05-11-84 05-11-84 05-28-84 05-30-84 05-31-84
06-01-84 06-01-84 06-20-84 06-27-84 06-28-84 06-28-84 06-28-84 07-06-84 07-19-84 07-19-84 07-20-84 07-22-84 09-04-84 09-05-84 09-10-i84
09-20-84 09-21-84
Time(3)
0815-0940 (5 mins.) 1251-1545 0225-0300 2315-2325 0740-1215 1747-1811 0040-0043 0030-0128 1730-1732 1830-1832 1600-1610 1110-1115 2200-2202 1030-1045 1430-2232 (23 mins.) 1410-1415 1905-1912 0300-0302 1430-1455 20001515(2) 0720-0745 0750-0754 0820-0821 0930-1053 (5 mins.) 1310-1311 1845-1925 1250-1300 1650-1700 1200-1215 1630-1650 1845-1925 1000-1058 1530-1622 1625-1630 0200-0205(1) 1350-1400(1) 0415-0730(2) 1210-1255 1100 (5 secs.) 1300-1301 1630-1645
Nature & Cause Category
I.C.
I.B.4. I.B.2. IV. III.C. I.B.3.a.1) I.A.8. I.B.2. I.A.2. I.C. I.A.8. I.B.2. I.B.1. I.A.9. III.A
III.A. I,A.8. I.B.3.a.2) I.B.3.a.2)
III.B. I.B.3.a.1) II.F. I.A.3. V.
V. I.B.2. I.C. II. E. I.B.2. I.B.2. I.B.2. I.A.2. I.A.8. I.A.8. I.A.8. I.A.9. III.B. VI. I.A.2.
I.A.4. III.A.
Parti, Bypas
X
X X
X X X X
X X X X X X X X X X
X X
X X X
X
X X X
Automatic Shutdown
Low
Flame Failure
Combustion Air Flow
Other
Vent Header(s) Bypassed
Wet
Dry
Tank Farm
X
XXX XXX X X XX X XXX XXX XX X XXX
X X X XXX X XXX XXX X XXX
XX X X X
X XXX X XXX
X X XXX
XXX XXX X XXX X XXX X XXX XXX XXX
X X XXX X XXX X XXX X XXX
X X XXX
XX
XX XXX
2
Date
09-28-84
10-08-84 10-25-84 12-03-84
12-12-84 12-13-84 12-14-84 12-24-84 12-31-84 01-21-85
Time (3)
1550 (2 secs.)(1) 1510-1520 1535-1546 1455 (5 secs.) (1) 0905-0912 0250-0340 0115-0135 0735-0736 0430-0440 1800-1802
Nature & Cause Category
Partial Bypass
Automatic Shutdown
Flame
Low Combustion
Failure
Air Flow
Other
VII.
X
I.A.2. II.A. I.A.6.
X X
X
II.G. I.B.3.a.1) I.B,3.a.1) II.D. VIII.B. I.B.3.a.1.)
X X
X
X X
X
Vent Header(s) Bypassed
Wet
Dry
Tank Farm
X
XXX XXX XX
XXX XX
X XXX XXX XXX
Notes:
(1) Three hour time-weighted average is estimated to be less than 10 ppm.
(2) Only the Tank Farm Vent bypassed the incinerator; therefore, the magnitude of the vent flow and vinyl chloride concentration were small. See Bypass Mechanism for the Tank Farm Vent attached.
(3) When the duration of the bypass spanned two or more consecutive days, two lines are used where the starting date and time are given on the first line and the ending date and time on the next. When the bypass was intermittent, the time period over which the bypass occurred is given followed by the total time during which the incinerator was bypassed in parenthesis, i.e., 1815-0940-(5 min.). When the duration of the bypass was less than 1 minute, the starting time is given followed by the duration in parenthesis, i.e., 1455 (5 secs.).
f CCR 000021065
3
DRAFT WLMO 7/300
Table III
Vent Header Affected Equipment Sources
I. Wet Vent Header
A. Continuous Sources
1. Light Ends Column Overhead Accumulator (S-102) - collects overhead product from the Light Ends Column
2. EDC-Caustic Decanter (T-102) - crude ethylene dichloride (EDC) and caustic are phase sepa rated in this vessel
3. EDC-Acid Decanter (T-1Q3A) - crude EDC and acid are phase separated in this vessel
4. Steam Stripper Aqueous Holding Tank (T-110) contains feed for the Steam Stripper
5. Tank Farm Vent System - collects vents from storage tanks
6. Light Ends Storage Tank (T-402) - stores overhead product from the Light Ends Column
7. Natural Gas Dryers (S-149 A/B) - remove moisture from natural gas entering the Direct Chlorination Reactor
8. CPS Collection Drum (T-512) - receives and phase separates (organic and aqueous phases) liquid from the CPS Underground Collection Drum (T-514)
9. CPS Underground Collection Drum (T-514) collects and adjusts the pH of drains from the Closed Process Sewer (CPS) system
B. Intermittent Sources
1, Flake Caustic Dryers (S-207 A/B) - remove moisture from product being transferred to storage
2. Vinyl Column Condensers (H-207 A/B) - condense overhead product from the Vinyl Column
CCR 000021066
3. Vinyl Product Caustic Dryer (S-401) - removes moisture from product being transferred from storage to railcar or ship
4. Oxychlorination Purge Gas Dryers (S-322 A/B) remove moisture from oxychlorination purge gas before the gas enters the Direct Chlorination Reactor
5. Caustic Melt Blowdown Drum (S-108) - collects caustic melt from the Flake Caustic Dryers
II. Dry (or Direct Chlorination) Vent Header
A. Continuous Sources
1. Direct Chlorination Reactor Crude EDC Tank (T--101) - receives crude EDC product from the Direct Chlorination Reactor
2. Heavy Ends Column Overhead Accumulator (S-103) - collects overhead product from the Heavy Ends Column
3. EDC Tar Still Column (C-104) - distillation column for removing EDC from heavy ends byproduct
4. VCM Tar Still Column (C-204) - distillation column for removing EDC from heavy ends byproduct
5. MeCl Unit CO2 Stripper (W-112) - Removes CO,, and other noncondensables from MeCl product^
6. MeCl Chiller (X-7) - Recovers MeCl product from the desuperheater vent
B. Intermittent Source
1. Vinyl Vent Recovery Unit - recovers vinyl from railcar and ship vents during loading
III. Tank Farm Vent Header
A. Continuous Sources
1. Tars Storage Tanks (T-405 & T-452) - store heavy ends byproduct
2 OCR 000021067
2. Slops Tank (T-460) - stores off-specification intermediate products
3. Pure EDC Storage Tank (T-451) - stores pure ethylene dichloride product
4. Dry Crude EDC Storage Tank (T-450) - stores crude EDC from the Direct Chlorination Reactor Crude EDC Tank and/or recycle EDC from the bottom of the Vinyl Column
5. Wet EDC Storage Tank (T-453) - stores wet EDC from the Wash System
CCR 000021068
3