Document 2j702E2R9NbOjM0EJ8Q6pRb4g

Conoco Chemicals f ontirj^Qtal Oil Company 30x New Highway 25 rterdeen. Mississippi 39730 April 23, 1979 Mr. James T. Wilburn Chief, Air Enforcement Branch United States Environmental Protection Agency 345 Court land Street, N.E. Atlanta, GA 30308 Dear Mr. Wilburn: Pursuant to our conversation of April 11, 1979, we are submitting the attached list of measures currently being taken or in the process of implementation to reduce the potential for relief valve discharges at our Aberdeen Plant. If you have any questions please call me at 601-369-8111, Ext. 23!jjj C.- Curry L. Miller Plant Manager cjt Attachment ATTACHMENT 1. Additional high level alarms have been ordered and will be installed in the two fresh vinyl chloride receivers. 2. The process leads to the existing level instruments on the fresh VCM receivers will be heat traced and insulated. 3. Revisions to the standard operating procedure have been made to require termina tion of polymerization with the emergency kill system if the reactor pressure reaches 145 PSIG during production of 5385 grade resin. 4. Operating personnel are now required to wear self-contained breathing apparatus before starting the addition qf nitric oxide to the reactor. 5. The emergency nitric oxide kill system has been pressure checked alternative kill system will continue to be pressure checked every six to assure the integrity and readiness of these systems. The standard operating procedure has been changed so that after batch, the reactor condenser will be inspected to determine if If it is found to be plugged, it will be cleaned prior to chi batch in that reactor. 7. The standard operating procedure has been changed to require a initiator loading for any batch following a coarse hatcft la the reaction rate. .. A new relief valve has been ordered and will be installed to which relieved prematurely. Operator training sessions covering the stardard operating pr< conducted on a formal basis once per year and for new emp. initial orientation period. 10. A new rupture disct installation has 1)4 on B-3g| which can be asaenbled ed and will he totalled "-- nature " - --* : '