Document 4GwrMMeZYQwNgKzYgKb6XKXV

1 iI AUDIT FORM DATE 5April 5. 1991 SYSTEM BEING AUDITED: Batch Water Strippers AUDIT MO. :______________________________________ AUDITORS I Lee Childers, Steve Wilkes, Debbie Johnson Go tslk to s&fsty to see wh&t ids&s thsy h&ve About the system and what things you should look for in your audit. Find existing documentation about the system: Found ( Not Not Found A Process Flow Diagram X (file 2.53.0) B P & I Diagrams Class "A" Design X (and PCD) ** PT- 3&S-^2'1 " D CMS - - (- bj X (file 2.53.0) D. Operating Procedures X E. Maintenance Procedures Mechanical Design & Construction Files X (drafting room) Plant Location Lists X Plot Plans X (file 2.53.0) EPA Rules X OSHA Rules X Vista Standards X (part of procedures) Previous Audits X VAB.0001128877 Interview three people separately who familiar with the system you're auditing. Learn from them how the system works and their concerns about the system. Interviewed Darnell Perry (O.M. Lead Operator), Rodger Collins (Vinyl Shift Supervisor), and Lee Childers (O.M. Lead Operator) There was general concensus that the system was operated In a safe manner, but there were a few concerns that dealt mainly with performance. These are listed In the Brainstorm section (#6). Is it operated as the operating procedures (design, etc.) say it is supposed to be operated? If no, what's different? No. Changes In operation are indicated on the attached operating procedures. Is it used per the appropriate OSHA, EPA, or Vista Standards? Yes/No YES VAB.0001128878 6. Brainstorm possible problems with the system. Attach the brainstorm list. 1. Insulate all hot lines for personnel protection 2. Leaky valves (steam and VCM-containing lines) 3. Wasting steam by feeding it to the stripper in two places during dump 4. Cannot dump in "DUMP" mode (which is automatic) - -have to dump in manual mode because pressure setpoint is not adjusted correctly. This is especially a problem on the south stripper. If the BWS is allowed to empty completely and VCM is fed to the hot stripper, the VCM may flash in the tank. In the "DUMP" mode, the stripper level is interlocked with the dump valve so that the dump valve closes at 10-12% liquid level, so to prevent flashing. 7. Do any of the problems identified in your brainstorming list make it unsafe? Yes. Uninsulated lines can cause burns. VCM can flash in a hot, empty stripper. VAB.0001128879 .8 What needs to be done as follow-up to this audit? What changes need to be made? 1. Hake sure that hot lines are insulated, particularly the sample lines - w.o. written. 2. Evaluate the following items to see if changes should be made: a. replacing leaky valves, especially steam valves, during shutdown; b. increasing hold time to 1 hour from 30 minutes; c. installing auto block valves on both sides of the 3-way inlet valve, to prevent VCM from going into a stripper while the other stripper is filling. Make necessary system changes so that strippers can be dumped in automatic (i.e. "DUMP" mode) instead of manual. The dump valve on the stripper is interlocked with the BWS pressure. The pressure setpoint is so low that the dump valve will close during the dump. In addition, if the operator forgets to stop the dump at 10% (of liquid level in the stripper), the BWS will empty completely. When he begins to fill the hot, empty stripper VCM may flash in the tank. 9. When should this be audited again? Why? In one year (after VCSM has been running for a while), to see if the safety items have been done. VAB.0001128880 PROPOSED 12/24/75 PROMULGATED 10/20/76 PLANT OPERATED UNDER A WAIVER OF COMPLIANCE UNTIL SYSTEMS COULD 8E INSTALLED TO MEET THE SITANOARD 9/1/78. - STRIP SLURRY T0^, 400 PiPM VCM - REACTOR OPENING LOSS 4 20 PPM VCM - NO MANUAL VENTING OF VCM - NO RELIEF VALVE DISCHARGES OF VCM - MINIMIZE FUGITIVE VCM EMISSIONS 0 RAILCAR UNLOADING LINES 0 DOUBLE MECHANICAL SEAL ON ROTATING PUMPS AND COMPRESSORS ANO AGITATORS 0 REDUCE VCM IN EQUIPMENT BEFORE OPENING TO ATMOSPHERE 0 SAMPLES 0 REQUIRED LEAK DETECTION ANO ELIMINATION PLAN CONTINUOUS MONITORS PORTABLE MONITORS 0 IN-PROCESS WASTEWATER STRIPPED TO LESS THAN 0 EXHAUST GASES REDUCED TO ^10 PPM VCM EMISSION TESTS VCM EMISSION MONITORING OF INCINERATOR OFFGAS REPORTING RECORDKEEPING VAB.0001128881 OPERATING MANUAL BATCH WATER STRIPPERS ABERDEEN CHEMICAL PLANT JUNE Vfr. 1981 Work By: D, C, D. Chris Wing ^ Process Engineer j Reviewed By: Veldon E. Messick Senior Process Engineer Approved By: \*cl R. A. Frohreich Chief Process Engineer # VAB.0001128882 OPERATING MANUAL BAWATER STRIPPERS ABERDEEN CH^icAL PLANT TABLE OF CONTENTS 1. 1NTRODUCT1 ON 11. PROCESS DESCRIPTION III. OPERATING PROCEDURES IV. INTERLOCKS AND ALARMS V. EQUIPMENT INDEX VI. INSTRUMENT INDEX VI 1. DRAWINGS A. INSTRUMENT LAYOUT B. ANNUNCIATOR LAYOUT C. PUSH BUTTON LAYOUT D. P6 I DIAGRAMS 1. BATCH WATER STRIPPING - OLD MODULE 2. BATCH WATER STRIPPING - NEW MODULE HHW mmmmm mm mup mm mm VAB. OOO1128883 MANUAL CAL PLANT A . INTRODUCTION The purpose of this system is to safely and practically treat the plant's process wastewater prior to draining it to the sewer The EPA standard requires that before any wastewater stream con vert) be released to the aooppb . Several wastewater streams throughout the plant are contain In^ted with VCM and require treatment reduces the VCM concentrat ion by jsteam is then rffumpSh to thefsewed and flows wastewater st he wastewater bducXftus W Pi Ifars Cooh\A p^r^ed. +1rxra&j^OK<L of C- La-5 Vrv ffc * VAB.0001128884 OPERATING MANUAL BAT shippers LANT II. PROCESS DESCRIPTION This system serves as a central collection point for all of the contaminated wastewater streams, which include water drains from the V-l l receivers, water from the emfssion recovery system, water from the CRD area, and water from the|contaminated drains. The streams from the V-lt area are routed|directly to one of two parallel stripping tanks, 1*5-801 or 45-302. The wastewater from the CRD area is collected In the existing blowdowtrdrum, 45-746, and pumped to 45-801 or 45-802 to be stripped. Each new tank is used as both a collector and a stripper. While one tank serves* as a collection vessej, the other is being stripped with steam. These vessels will alternate duties to provide continuous wastewater collecting. n The batch water strippers are controlled by a process computer (the Mod icon) which provides interlocks and valve sequencing. There are three modes of operation, (1) Fill (2) strip and (3) dump. When one tank is in the fill mode the other tank is either in the strip or dump mode. When one tank, say 45-801, is ready to be stripped, the panel operator routes thje process water to the other stripping tank, 45-802, by placing thalt tank in the fill mode. This is done from the control room by pressing the "mode adv" button until the "fill" light for 45-802 is on and pressing the "open button" for the inlet control valves for 45-802, CV-952 and CV-962. These inlet valves on 45-802 are interlocked with the inlet valves to 45-801 so that when CV-952 and CV-962 open, CV-951 and CV-96I close. 45-801 is now ready for stripping. The panel operator presses the "mode adv" button until 45-801 is in the "strip" mode. The 45-801 recovery valves, CV-953 and CV-965 and the stripping steam inlet valve, CV-959, automatically open while the VCM bleed valve, CV-955, automatically closes. Steam is then injected into 45--801 at 5,500 pounds per hour. Vapors from 45-801 are routed to the emission recovery system. The pressure in 45--801 and the suction of the emission recovery compressors soon equalize at 9 psia which corresponds to a stripping temperature of 190 F. When the temperature of 45-801 reaches tL90bFX a timer attached totthe temperature controller TR-95I is activated Thirty minutes later, the timer will activate an alarm on thb board, close vapor recovery valves, CV-953 and 965, and open CV-963, the pressurizing steam valve. Once the pressure of 45-801 reaches 6 psig, the operator will place 45-801 into the "dump" mode and open the water outlet valve, CV-957. VAB.0001128885 I OPERATING MANUAL At II. PROCESS DESCRIPTION (Cont.) CV-957 will close when the liquid level in 45-801 drops below LSL-951, the low level switch. This switch will also close the stripping and pressurizing steam valves, CV-959 apd CV-963, and open the pressure bleed and vapor outlet valves, CV-9*j5 and CV-965. Tank 45-801 will then automatically advance into the i"fII1" mode. This completes one cycle and 45-801 is now prepared to col 1act blowdown water. * During the collecting process, the stripping tank pressure is maintained at 2 psig. PIC-953 vents vapors from the stripping tank to the emission recovery system if the tank pressures exceeds 2 psig. In the new module the dxisting blowdpwn tank, 45-746 is used to store collected liquids. The water is reciirculated through 45-746 by the transfer pump, 72-974, or its spare 72-979. When the liquid level in 45-746 reaches the high level switchj, LSH-740, CV-968 on the recirculation line will close and CV-967 on the transfer line to the batch water strippers will open. At a ,1ow liquid level, C|f-967 will close and CV-968 will open allowing recirculation. The controls for the transfer pumps are located in the new module recovery section in the vinyl control room. * VAB.0001128886 OPERA! MANUAL OPERATING PROCEDURES Automatic Operation Determine If the batch water tank being filled is ready - to be stripped* A tank Is ready to^J^stripped if the level ^ in the tank is 6*-feet or higher, (worscairon the panel mounted level indicators). Thje level of the tank may be deter mined by checking the level indicators on the main control panel or looking at the liquid level sight glass mounted on each tank. A high level alarm (LAH-953 fojr 45-801 or LAH-954 for 45-802) sounds at a liquid level of 7-ifeet, 2-inches (80S of scale on panel mounted level Indicators!). B. If the tank being filled is ready to be stripped, the other batch water tank must be ready; to receive the water from the collecting headers. The tank jls ready to receive the water if it is in the "fill" mode (noted by the "fill" light being lighted). If the tank is in the "fill1* mode, the vapor outlet and pressure bleed valves (CV-965 and CV-955 for 45-801 or CV-966 and CV-956 for 45-802) will be open. C. Place the tank that is ready to be filled into the fill position by opening either CV-951 and CV-96I for 45-801 or CV-952 and CV-962 for 45-802. This will automatically close the corresponding set of valves on the ready to be stripped tank and 1ine up the three-way valves, CV-969, such that VCM from the double block and bleed on the VCM charge headers is draining to the tank being filled. NOTE: When both tanks are in the fill mode, the inlet valves to both strippers can be closed. The operator must be sure that this never happens by opening the valves on tbe tank to be filled instead of closing valves on the tank to be stripped. D. Place the ready to be stripped tank into the "strip** mode by pressing the mode advance button for that tank until the "strip" light is on. This will automatically: 1. Close the pressure bleed valve (either CV-955 for 45-801 or CV-956 for 45-802). ' 2. Open the vapor outlet valves (CV-953 and CV-965 for 45-801 or CV-954 and CV-966 for 45-802). 3. Open the stripping steam valve (either CV-959 for 45-801 or CV-96O for 45-802). VAB.0001128887 OPERATING MANUAL BATCH STRIPPERS PLANT III. OPERATING PROCEDURES (Cont.) Automatic Operation After the temperature of the tank reaches or exceedsu90oFJ a timer in the Mod Icon starts. When 30 minutes have elapsed: 1. The ready to dump alarm, TAH-951/952, is activated. 2. The recovery valves are closed. 3. The pressurizing steam valve (CV-963 for 45-801 or CV-964 for 45*802) is opened. E. When the tank pressure reaches 6 psig, as read on panel pressure indicators, PI*951 or PI*952, the mode advance button should be pressed to advance into the "dump11 mode and the water outlet valve (CV-957 for 45*801 or CV-958 for 45-802) should be opened. The level in the tank drops until the level reaches the set point for the low level switch (LSL-951 for 45-801 or LSL-952 for 45*802). This is approximate \2% on the level indicator. The low level switch on the tank does the following at low level. 1. Closes the water outlet valve. 2. Closes the stripping steam valve. 3. Closes the- pressurizing steam valve. 4. Opens the pressure bleed valve. t 5. Opens the vapor outlet valve. 6. Advances the tank into the "fill'1 mode. This completes a cycle for the batch water strippers. The operator will then wait until the other tank is ready to be stripped and start the sequence again. Manual Operation Ih automatic operation one of the indicators (fill, strip, dump) will be lighted. In manual operation the mode indicators will be off and the manual push button/light will be illuminated. Switching from automatic to manual mode will cause al1 valves to go to their fail safe positions and all interlocks and Mod icon control will be bypassed. The transfer of water from 45*746 ih the new reactor module to the batch water strippers is unaffected by a mode switch since there is a separate local manual take-over swtich for the new module. VAB.0001128888 mitrnmimmwim 4* MANUAL PPING III. OPERATING PROCEDURES (Cont.) Manual Operation To operate In the manual m._ode v# r - --ww ,,,,,, raw iriU f U mode . __ _ --^ indicator ^ jI lights will ---- go out and....t.h..e......'.'m...a..n..*w1 ill A11 of the go on The upcrator can tnen manua 11y operate the valves from the control boa Follow the sequence as described in the automatic operation secti the major---------------^------------ d- i.f.fe. wre. nce being i l%J that the panel operator must open and close each valve. When CV-969, will automat in the manual mode, line up to drain the three-way valve, to the south tank, 45*801. To fill the north tank this valve must 45-802 by operating the switch on the board. be I ined up with Power /raa1: |lure Mod power so' operation of the batch V,VCS 9no?'a De unaffec*ed by power failure. Upon 1s .P^ssure to the control valves, all will fail in the posit ion. ) 1 .................. .. VAB.0001128889 A IV. INTERLOCKS AND ALARMS The following interlocks are provided for on-off control valves to prevent discharging VCH contaminated water to the sewer. The interlocks are maintained by a process computer, the Hod icon 584. The interlocks are bypassed when the mode selection is off. Items in parenthesis correspond with 45*802 operations. 1. 45-801 (45*802) water inlet valves; CV-951 and CV-961 (CV-952 and CV-962) can be opened only in the "fill" mode. Both tanks may be in the "fill*1 mope simultaneously but only one set of inlet valves may be open as stated in item 2. 2. Opening the 45*801 (45*802) water inlet valves CV-951 and CV-961 (CV-952 and CV-962), automat leally; closes the 45*802 (45*801) water inlet valves, CV-952 and CV-962 (CV-951 and CV-961). 3. In the "dump" mode 45*801 (45*802), the water inlet valves, CV-951 and CV-961 (CV-952 and CV-9|62); the vapor outlet valves, CV-953 (tv-954) and CV-965 (CV-966); and the pressure bleed valve, CV-955 (CV-956) are all closed automatically and locked out of manual operation. 4. In the "strip" mode, advancement of mode cannot be made until the 30 minute timer in the Hod icon has timed out. See Operating Procedures, item D. Alarms Below are listed alarms and possible conditions that could cause these alarms. LAH-953/954 - High water level in batch water tank (7 feet, 2 inches) 45*801/802 1. Indicates that batch water tank is full and ready to be placed in "strip " mode. LAL-955/956 - Low water level in batch water tank ( i feet) 45-801/802 1. Indicates that batch water tank has low level. LAH-957 - High water level in new module collection tank, 45*746 1. Indicates that 45*746 is full. Possible malfunction in level switch of control valves. m mm* mmmrnmmmmmmmmmmmmmmmfmm# VAB.0001128890 mm mm ##*** t i INTERLOCKS AMD ALARMS (Cont.) Alarms (cont.) * pah-951/952 - High Pressure In batch water tanks (40 psig) 1. Bleed - back pressure controller (PIC-953) could be malfunctioning. 2. Steam blowdown pressure regulator failure (PIC-954). 3: Vapor outlet valves (CV-965/953 or CV-966/951*) closed durinq "stripping". 3 '** bleed valves (CV-965/955 or CV-966/956) closed during "fill". PAL-951/952 - Low pressure (below 2 psig) in batch water tanks. * 1. Water outlet valve (CV-957 or CV-958) open when tank is empty of liquid. r AA-951/952 - Control valves operated out of sequence. 1. Mod I con problems 2. Bad solenoid on a control valve. 1 VAB.0001128891 A EQUIPMENT INDEX A. Tanks 1. Blowdown drum - 45-801 - 45-802 a. Purpose Vessel to collect and recover various VCM containing vapor vents and waste waters. b. Description Horizontal - mounted, 26 foot 0 inch straight wall, 10 foot 0 inch I.D., carbon steel construction. c. Norma 1 ~ ~ .... Ambient temperature to 190^F and pressures from 10 inches Hg vacuum to 10 psig. d. ~ ' ------- 350F and full vacuum to 150 psig. B. Filters 1. Suction Strainers FD-951. FD-951S a. Purpose Strainer to remove PVC particles from the 45-746 liquid outlet to the transfer pump. b. Descript ion Four inch Andale type 105 simplex strainer with 3/8 inch perforated stainless steel basket and carbon steel body. c. Normal Operating Conditions i 0 psig and 130F at 75 GPM. d. Design Conditions 150 psig VAB.0001128892 OPERATING MANUAL BATCH PP1NG PLANT V. EQUIPMENT INDEX (Cont.) 6. EIters (cont.) 2. Flush Water Filters a. Purpose To remove dirt and scale from the seal flush filters b. Descript Ion Filterite high pressure filter, 3/** 3A HP, cartridge type, particle si with a polypropylene filter element core. inch, model LM010Sretention ten microns with a stainless steel Norma 1 rat Conditions 220 psig at 100F d Design Conditions 500 psig and ambient temp C. 1. Transfer Pump 72-97**, 72-979 a. Purpose lowdown water strippers, b. Description batch Centrifugal type, Gould's model 3196, 1 x 1 50-8 .0 HP, 3500 RPH. impel ler is 6.25 Inches c* Normal Operati Condit ions Rated for 75 GPM at 173 feet of differential head i VAB.0001128893 OPERATING MANUAL BATCH WATER ^TRIPPERS CAL PLANT VI. INSTRUMENT INDEX Flow Instruments Tag No. Service FIC-951 Stripping steam FI-956 Seal Flush FI-957 Seal Flush Pressure 1nstruments Tag No. Service PI-951 45-801 PI-952 45-802 PIC-953 PIC-954 45-801/802 Vapor Exit 45-801/802 Steam Level Instruments Li-951 45-801 Level LI-952 i 45-802 Level TYPe Setpoint Foxboro Spec-200 Indicating controller Brooks 3604c Rctameters Normal 0.25 GPM (Loca1) Brook 36o4C Rotameters (Loca1) Normal 0.25 GPh type Setpoint Foxboro Spec 200 Pressure Indicator Foxboro Spec 200 Pressure Indicator Foxboro 43AP-FA47C (Loca 1) 2 psig Foxboro Spec 200 Steam Control Foxboro Spec 200/dp Cell Foxboro Spec 200/dp cell VAB.0001128894 OPERATING ANUA L BATCH WATER TRIPPER ABERDEEN CHEMICAL PLANT VI. INSTRUMENT INDEX (Cont.) Temperature Instruments Tag No. Service TR-951 45-801 Temperature TR-952 45-802 Temperature Type Setpoint Foxboro Spec 200 Temperature 190F Foxboro Spec 200 Temperature Indicator With Alarm 190F TR-95I and TR-952 to be connected to a timer and a switch to control (on/off) stripper outlet control valve CV-953 (or CV-954). VAB.0001128895 OPERATING MANUAL BATCH WATER STRIPPERS ABERDEEN CHEMICAL PLANT VII. DRAWINGS A. INSTRUMENT LAYOUT B. ANNUNCIATOR LAYOUT C. PUSHBUTTON LAYOUT D. P I DIAGRAMS 1. Batch Water Stripping Old Module 2. Batch Water Stripping New Module * \ m Winl|rtJ*l|d*fc VAB.0001128896 4.+ 1* u,J s5 7 y/ $ f/ * * T J #i ^ 4 *\i/V* A^'* A A- 95/ SO W7V? 5 TRPRR '/ALVES OUT ORDEP A A - 952 /VO iV7T?.S73eW? VAI/S OUT OP OR OER LAH-955 SOUTH WATER STPtPPER HfGH L LAH - "5"*? SJORTh WATER S TR/PPER H/fiH L E\tl LAl'SSS SOUTH WATER STRIPPER. LOW LEVEL LAH - 9~6 ;JCR TH 7/A TER STR tPPER LtT PA H - 9S/ sour// yUAter STR l F PER HU}H FRESfcRE PAL- OS'/ /OSC W TR S TRl Fpen LC> \aj PPL - uR OuMP PA H - DS2L KiCRTH WATER 'TZ E/Z meprs.szuR. -AH-9S/ / OS'S. WT/? STRlFPEfZ R CAD'S D U A-} /=> C5? A 3 w V m wmtmmmmm HOXC loca rp (J AJ A')A /AJ C SAMEL MODULE /VTCi. OV/* V AFE sit |8i|,^ ISU DATC description ; Y CKD APO CONOCO CHEMICALS ABERDEEN MISSISSIPPI annunciator LAYOUT OPERATl NG MANUAL BATCH WATER STRIPPERS SCALE appo: oate: No 1128897 ISU DATE ________DCSCSIFTION Ss^A u| BY CKD ! APD VAB.0001128898 i_ OC AT 0 iM CLOUOEO A OH iKSTRU^eMT LAYOUT ORA>*JlW6, ^ C~& Y S&C.T/onJ t ! -^ ] . no vr*?./;r4 ; -jj* -'V' : P ^i ^ ! :1 !K ni \ .l';zi~ J -- mmm twmmmm ? The function of the batch water strippers is to remove VCM residu als from process wastewater before the water la released to the wastewater treatment ponds* This Is completed by Injecting steam through spargers located In the strippers, while pulling a vacuum on the tanks with the emission recovery system* A thirty minute timer is actIvatM^ when the {water in the stripper reaches the set temperature oi 215F. This {temperature has to be maintained during the 30 minute held period jor the batch will not be able to be An alam sounds when the batch has been held for thirty minutes above the set temperature. During this thirty minute interval pressure are critical* If vacuum la loet on the the performance of the strippers la A batch stripped when this occurs may or may not be tith level j of 10 ppm required by KM regulation. of tjha temperature/pressure recorder, the operator now what jthp pressure and temperature did during the It something unusual happens and vacuum Is loet on the the, operator can restrlp the batch and prevent a violation of EPA regulations. The normal temperature andj pressure operating ranges are listed below: Mode Fill Strip Dump T--r.ture 100o-150F 215 F Set Temp* 215F Pressure Slight Vacuum (0-51n Hg) Vacuum During Entire 30 min* Hold Period (0-10in Hg) Slight Pressure (0-5psi) VAB.0001128900 BATCH WATER STRIPPERS STRIPPING REPORT Batch No.: Date: 4 North or South S tripper: Shif t:__________________________ Comment* Time: Operator: VAB.0001128901 fMf rnmmmmm VAB. mo1128902 VAB.0001128903 BATCH WATER STRIPPING BATCH WATER STRIPPING