Document 4aaJVqMQ0V5RLwoEXVxJXbXLV

m SHMSL -COMPANY AND OFFICE CORRESPONDENCE All Concerned Minutes of Vinyl Chloride Safety Association Meeting October 20-21 7,/c? - v'^w* e,hiern\ ^ Farm SJt(4/73) DATt: FAOM: DtVJDtPT, Aboness: November 1, 1 983 J. E. Barton PVC Production Manager Illiopolis, II llLCAHONt: The following are minutes from the Vinyl Chloride Safety Association Meeting held on October 20-21, 1983 in New Orleans. The meeting opend by reviewing "Old Case Histories". Accidents which have happened in the past and have led to major changes in the VC and PVC industry. In 1964 the Thompson Chemical Explosion killed 7, injured 22 and destroyed the building. The cause of the explosion' and fire was a sight glass on a reactor which broke while being tightened under pressure. The sight glass had been replaced and was leaking, it was never hydrostated before recharging. In 1 968 a fire at the Hooker Burlington Bulk Process Plant caused major structural damage to the building, major piping and instrumentation damage. The fire was caused by a leaking flange on a transfer line between two reactors. Maintenance had replaced a control valve on the line and the line was never pressure checked before being put back in service. To add to their problems the line had no isolation valve and they had no plant fire protection group along with an inadequate water supply. In 1 972 a fire at the Goodyear Plaquemine Bulk Process Plant burned for 3 hours causing building, piping and instrumentation damage. The fire was caused by leaking gas igniting when the reactor dome blew off during the reaction. The dome was held in by a locking ring and how it became loose is not known. All the locking rings on reactors domes have been equipped with a wedge and proximity switch interlocked with the VC charge valve to prevent a reoccurrence. In 1977 an explosion in a scrubber at PPG in Plaquemine leveled their entire Oxichlorination facility. The cause of the explosion is not known, however, excess oxygen is suspected. Computerized interlocks and oxygen monitoring equipment are used now to prevent a repeat. At the BFG Plant in Altona 1.5 million pounds of liquid vinyl was dumped from a sphere when a maintenance man tried to close the bottom valve with a 2 X 4. He was working on the line downstream and the valve was leaking by. The 2X4 broke and the valve opened. There was no fire or explosion and the vinyl evaporated without incident. Sphere's today are being equipped with excess flow valves and remote operated fail safe valves to prevent similar incidents. BOR 000494 Page 2 Minutes of Vinyl Chloride Safety Association Meeting October 20-21 The meeting continued with the discussion of some "Current Case Histories". On 7/30/83 The Formosa Plastics Plant at Baton Rouge had a fire at the VC loading station. The fire was caused when a hose ruptured while being purged with nitrogen. The fire was fed from the tank car because the excess flow valve was installed wrong. The fire burned under control for 5 days; the car could not be unloaded. Excess flow valves have been replaced with check valves on all tank cars. At Occidental Chemical a man was killed while cleaning out a heat exchanger with an 18 foot flexible hose and a 2" rotating nozzle under 4200 pounds of pressure. It is not known why the hose bucked back out of the tube* but it struck the man in the throat and penetrated his chest before his helper could shut the equipment down. Predrilling tubes and using a lance instead of the flex line makes the job safer. A Bulk Resin Hopper Truck being unloaded in Mishawaka, Indiana on 6/28/82 split and spread resin over 300 feet of unloading area. The truck ruptured at 14 psig on the guage while 2-15 psig relief valves never opened. The truck was rolled over in 1977 and the welded repair was done poorly causing the hopper to fail. At Esso Chemical,in November 1982, a VCM line ruptured at a flange joint. The joint had corroided. A Monel flange was welded to a 304 stainless line with 308 welding rod. Piping standards were revised and job site inspections and Engineering approval were necessary before the job was accepted as compelte. I asked if anyone had experience with aluminum meters for VC service. No one uses aluminum meters because of possible corrosion, the same as copper. Stain less Steel is the one used. At the PPG Plant in Lake Charles, La, a tank car loading pump exploded. The pump failed at the frame adapter and split the case. It was estiamted that 4000 psig was necessary to split the housing. The cause of the explosion was hydraulic pressure build-up caused by thermo expansion. The pump was blocked in full of liquid and there was no equalization line or relief valve on the pump. In 1982, 5 Conoco VCM tank cars were involved in a derailment in Pittsburg, Texas. Three cars were in a creek and about 30% under water. The other two were on their sides but not in the creek. One of the cars was leaking into the water. There was no fire. The EPA and railroad officials were concerned about the contamination to the water in the creek which ran into a pasture some 300 yards away. Readings were taken at 300 yards and only 10 ppm was detected. The car that was leakino was supposed to be empty, but because of the angle it was hard to determine what the level was and because the leak was under water; impossible to plug. Four of the cars were full, three were pumped empty. The fourth could not be emptied because of damage and was vented under control until empty. Total loss was approximately 200,000 pounds of VCM and a frost bitten tree near where the car was vented. BOR 000495 Page 3 Minutes of Vinyl Chloride Safety Association Meeting 10/20-21 In Austria in April of 1982 a railroad tank car of VCM ruptured while setting on a siding track waiting for the proper papers for unloading. There was no fire. The car had been overfilled, sent through several check points on it's way to Italy. The excess weight was not caught until it reached Italy where they were refused to let it in the country. The car was returned after several weeks for unloading. Tank cars in Europe are not required to have safety relief valves. At lunch, Roy T. Gottesman introduced the VI (Vinyl Institute). He explained how the V.I. was formed to promote and protect the continued growth of the PVC/VCM industries. As a division of the Society of the Plastics Industry, the V.I. uses its resources to: A. "Serve as the representative for the PVC/VCM Industry" B. "Wage an affirmative public information campaign for the PVC/VCM Industry" C. "Address the issues facing the PVC/VCM Industry" D. "Conduct health and environmental research to promote the safe use of PVC products" The Vinyl Institute staff consists of an executive director who is responsible for the operation of the organization. The executive director reports to an executive board staffed by representatives from member companies who found the Institute. These companies are: 1. Air Products and Chemicals, Inc. 2. Borden,Inc. 3. Certain Teed Corporation 4. Conoco Chemical Company 5. The Dow Chemical Company 6. The B.F. Goodrich Company 7. Occidental Petroleum Corporation 8. PPG Industries, Inc. 9. Shell Chemical Company 10. Tenneco, Inc. After lunch the meeting continued with an update on Angio Sarconia by J.T. Barr of Air Products. The cases of Angio Saraconia peaked in the middle - late 70's and are now tapering off. The tapering off is believed to be due to changes in work practices, management changes, external changes like improved ventilation and inherent factors such as genetic makeup or delayed latency. There is 100 con firmed cases of Angio Sarconia throughout the world. Cases by countries are listed below: 1. United States 2. West Germany 3. France 4. Canada 5. United Kingdom 6. Sweeden 7. Yugoslavia 8. Italy 9. Czechoslovakia 0. Japan 1. No rway 30 21 14 10 8 5 4 3 2 2 1 BOR 000496 Page 4 Minutes of Vinyl Chloride Safety Association Meeting 10/20-21 J. T. Vaughan from ICI discussed a survey that was made by the Insitute of Occupational Mecidine on PVC Dust. The survey showed the breathable dust was not visible to the naked eye and high intensity lights were used to show how much dust was in an area. Paste and Emulsion resins created a much greater hazard than suspension. The effect of breathing PVC dust is like smoking cigarettes; damage to the lungs is similar. M. Nevill from Dow Chemical explained their area monitoring system consisted of a Beckman 6700 unit which had four, ten stream analyzers which pulled samples continuously. The cycle time is 50 minutes and all the readings are recorded and stored in the computer. Dow Chemical action level is 5 ppm. They use HNU Dectors to detect leaks. Personnel Monitoring is done by DuPont charcoal filter pumps. Physicals are given annually with twice per year over 10 years of service. The question was asked from the floor, "How many companies use badges for Personnel monitoring instead of pumps?" Eleven companies use badges while nineteen use pumps. Next on the agenda was the responce to the valve position indicator switch questionnaire by J.H. McCulley of Conoco. See attachment A for the valve Position Switch Survey Form and a summary of the results. In brief, the primary cause of damage to position switches are bumping or knocking out of alignment by personnel. The second major cause of damage was water. The problems could be solved by monitoring valve position and not actuator position. The last order of business for 10/20 was a presentation of B.F. Goodrich Chemical Plant evacuation procedure; how to make one up if you don't have one and then how to train your employees. A plant evacuation procedure should be designed to carry out a specific action, to be carried out by shift personnel and prevent or minimize damage to personnel and equipment. Training procedures must include defining terms, establishing communication through command centers and how the police and news media are to be handled. On 10/21 the meeting opened with the election of officers for next year. Dick Frohreich will assume the position of Chairman, Joe King was elected Vice Chair man, Dave Middleton, Program Chairman and J. Wallace, Secretary. The site for the 1984 meeting will be Pheonix, Arizonia The meeting continued with a presentation by J.T. Vaughan of ICI on Safety Per formance assessments. ICI selects a team consisting of a Senior Department Manager, an Engineer, an Area Supervisor, a Union Steward and an Operator all from one department. They then inspect another department making the tour with their counterposts. They do this once/year and it takes one full day. The team works from a check list and when the tour is finished they discusS their findings and recommend actions that could be taken. The question was raised on how to train and motivate employees. The concurrence of the group was that new employee training, regular supervisors safety training meetings, procedure update and retraining, safety counciling on the floor and internal inspections and audits were the bases for good safety performance. The group felt incentitive programs and other gimmicks should be changed every 6 months or they loose there effectiveness. BOR 000497 Page 5 Minutes of Vinyl Chloride Safety Association Meeting 10/20-21 J. Wallace from Esso Chemical and A. Peterson from Georgia Pacific discussed Process Safety and the results of a questioner on "Run-Away Reaction Control and Emergency Power" (attachment B). The survey showed the three main causes of run-away reactions were charge error, power failure and improper formulations. Action level on a run away reaction was 5F temperature rise on 10 pound pressure rise. The action taken started with manually putting the jacket on full cooling then bumping or completely killing the reaction with a short stop. If these two measures don't work then the reactor is vented to the recovery system or blown down to an empty vessel. Manual venting was a last resort. Most plants have some type of back-up power supply to disperse i.nhibitor by agitation during a power failure. Esco Chemical uses short, fast venting into their recovery system as a form of agitation to disperse their short stop. Next on the agenda was an update on EPA court action. 0. T. Barr reported that Air Products paid a civil suit in 1981 which amounted to $125,000 for 22 emiss ions. They had to agree to certain training for new employees, reviews with EPA on any releases, regardless of how minor once/year, and a review of all their records. If there were any violations they would be found $4500.00 per violation. This close control by EPA will be in effect for 2 years. Ethly Corporation had a civil suit of 2.54 million dollars for 98 releases dismissed by Judge Parker because they did not have to meet the EPA work practices standard;EPA is appealing. Bailey Barton reported that Borden civil suit at Leominster is pending court action after a move to dismiss was denied. Borden also has court action pending at Geismar on 34 releases between 1977 and 1983, along with 5 failure to report incidents within 10 days. B.F. Goodrich will go to court on 12/16 to answer for 18 releases at the combined locations of Calvert City and Louisville since 1978. Conoco is being sued for 6 releases at their Oklahoma City Plant since 1981 and 16 releases at the Lake Charles Plant. They have filed for dismissal. W. C. Holbrook from B. F. Goodrich discussed some new regulatory measures which may go into effect. They are numerical values put on releases: 50#/million pounds of PVC per year and 25#/million pounds of VC per year. Exception reporting is another item under consideration along with extending the time of reporting with out violation to more than 10 days. The meeting ended with a discussion on handling VCM waste from small pilot plant, reactors (attachment C). J. Wallace from Esso Chemical tabulated the survey results. 65% of all pilot plant reactors are vented to the atmosphere through a 40' stack. 21% are recovered by the plant recovery system and the remaining 14% are incinerated. JEB/der cc: W. F. Gabel, R. Jepsen, S. Moll, W. T. Gerson, L. Bird, M. Thoren T. Allen, R. Shah, R. Landon BOR 000498 ATTACHMENT "A VALVE POSITION SWITCH SURVEY FORM Note: Please fill out a separate survey fora for each type of indicator. Type of Indicator: ______ Electromagnetic Limit Switch _______ Inductive Proximity Switch (e.g. metal sensing) _____ Capacitance Proximity Switch (e.g. any material) _______ Hall Effect Proximity Switch (e.g. magnetic sensing) Photoelectric Position Switch (e.g. infrared) _______ Potentiometer Displacement Sensor _______ Optical Encode Displacement Sensor ______ Other (explain) : _____ Manufacturer (s): _____________________________________________________________ Model Number(s) (if known): ___ Number of switches of this type: 1-5 _______ 6-20 _______ 21+ Typical number of operating cycles of these switches: _____ per day _______ per week ______ per month _______ per year Reliability of Position Switch (mean time between failure): _______Months _______Years Cause of Failure (e.g. bent indicator arm, slipped magnet, water in switch, shifting of switch by vibration, mechanical damage by personnel, other). Please list by frequency of occurrence: ___ Maintenance Performed (e.g. alignment, replacement, wiring): Unusual Ambient Conditions (if applicable): _____ Vibration _______ High/Low Temperatures Other: ______________ Comments on Performance (e.g. good, poor): ______________ Please return completed questionnaire as soon as possible to: John H.-McCulley, Jr., Conoco, -Inc., Drawer-1267 Ponca City, OK 74603 Or bring response to the meeting in New Orleans. BOR 000499 1983 VSCA MEETING VALVE POSITION SWITCH SURVEY SUMMARY A. Survey Participation Total Number of Companies Responding Total Number of Plants Responding Total Number of Forms Returned 7 io+- 2fr B. Types of Switches Used Electromechanical - 15/26 Inductive Proximity - 6/26 Hall Effect Proximity - 5/26 58Z 23% 19% C. Mean Time Between Failures (Months) Type Switch Electromechanical Inductive Proximity Hall Effect Proximity Min 1 1 2 16 9 7 Max 60 24 10 D. Cause of Failure Electro mechanical Shifting 4 Mechanical Failure ' 2 Water Damage by Personnel 8 5 Vibration 2 Bent Indicator Arm 2 Electrical Failure Total 22 Inductive Proximity 1 5 1 1 8 Hall Effect Proximity 3 2 3 1 1 _2 12 E. Maintenance Performed Realign or Replace BOR 000500 19B3 VCSA MEETING VALVE POSITION SWITCH SURVEY ELECTROMECHANICAL LIHIT SWITCHES Manufacturer Pro*laity Hlcroswltch Model V3L-3-D8 V3L-139-08 RX21 and 3R021 No. of Switches 21 + 21+ 21 + 21+ Cyclea per Day 10 20 2 4 Betti* Fisher Control* Jam*aburg Hlcroswltch Hlcroswltch Hlcroswltch Bettis Switch 38 304 069-0071-00 EXAR and EXAR30 51HL1--7646 1CX42-77U 2CX3-7904 3R321AFC 3R02IAFC 21 + 21+ 21 + 21 + 21 + 21 + 21 + 6 8 4 4 8 8 8 YasatakeHoneyvell 1LX5001 VCX5001 21 + <20 Hlcroswltch Betti* Hlcroswltch LSXA -- 21 + 6-20 21 + 2 5 3-30 Mean Time Between Failures Cause of Failure Maintenance Performed 3 Tear* X Year* 2 Years Shifting of switch Shifting of switch Mechanical failure Cam indicator shifting and armature failure 3 Years 10 Months 1 Year 6 Month* 3 Months 10 Month* 6 Months Broken spring (rare) Water In switch Shifting of switch Hater In switch Mechanical damage by personnel Water In switch Bent Indicator in Water In switch Mechanical damage by personnel Bant Indicator an Water In switch Mechanical danage by personnel 5 Years Water In switch (2 or 3/Year) Mechanical damage (2 or 3/Year) by personnel 1 Month Water In switch Vibration 2 Months (v/o fallu re) 6 to 8 Water In switch Months Shifting due to vibration Alignment Alignment Replacement Cam alignment and replacement Armature repair occasionally Alignment Alignment Replace switch Alignment Replacement of switch Alignment Replacement Replacement of feedback arm Alignment of cams and Indicator arm Replacement of switches Alignment or replacement Replacement -- Repair (replace internals) Realign Unusual Ambient Conditions Vibration Vibration No No Comments on Performance Excellent Very Good Fair Fair No Good Ho Good Ho Cood Ho Good No Good Ho Cood No Good, moat problems cauaed by wstar and personnel No Good Deluge Fair Vibration Installed for only two sumtha Vibration Good. Soma In service High Humidity for sight years with no failure BOK 0 0 0 5 0 1 1983 VCSA MEETING VA1.VE POSITION SWITCH SURVEY HALL EFFECT PROXIMITY SWITCH (MAGNETIC SENSING) Manufacturer In house Wesco Wesco Uesco Model Number MS2A, MS2B MS2AAOO MS2-BB-00 No. of Switches 21* 21* Cycles per Day 2 16 21* 5,max 15/day 21* 12 In house 21* 12 Mean Time Between Failures Cause of Failure Maintenance Performed -- 6 Months 2 to 3 Months 10 Months 8 Months Slipped magnet Mechanical damage Water In Bwltch Slipped magnet or loss of magnet Slipped magnet Water In switch Vibration Mechanical damage 30X Electrical failure 70X Bent Indicator arm I0Z Mechanical damage fflj .ctrlcal failure 30Z Alignment or replacement Replacement of switch Alignment of magnet Alignment or replacement Replacement Alignment of magnet arms and magnets Unusual Ambient Conditions No No Comaente on Performance Good on automatic velvea Fair on manual valvee Good Vibration and deluge weter Fair. Performance improved with new magnet bracket design. Average Fair performance, requires excessive maintenance BOR 0 0 0 5 0 2 1983 VCSA MEETINC VALVE POSITION SWITCH SURVEY INDUCTIVE PROXIMITY SWITCH (HETAL SENSING) Manufacturer Pepperl and Fuchs (Germany) Model Humber Ho. of Swltchea H7-2-12-GK-H 21 + Cycles per Day 2 Cancral Equip 211117 ment and Manufacturing,- Co. Inc. (GOTM;1 Mlcrosvltch 6FR1-6 General Equip ment and Manufacturing Co. Inc. General Equip ment and Manufacturing Co. Inc. General Equip ment and Manufacturing Co. Inc. Serlea 20 and 40 237126 and 13929 211536 21 + 2 21 + 16 21 + 5t max of 15/day 6/year 21 + 12 Mean Time Between Failures Cause of Failure Maintenance Performed X Tears +6 Months tent indicator arm (2/Year) Mechanical damage by personnel (1/Yssr) Hons yet, installed 6 months ago Alignment Unusual Ambient Conditions Hone Hone Comments on Performance Satisfied Good 3 Months 1 Month Mechanical damage by personnel Vibration Mechanical damage Alignment or replacement Alignment or replacement Only in service a few months 2 Years Mechanical damage by personnel Physical damage 95t Shifting of switch 5X Alignment Replace due to excessive dead band Replacement Nona Good Vibration Fair and deluge water Dead band has bean a problam. Difficult to adjust position of the switches. Works wall and is the most reliable position switch used in the plant. BOR 0 0 0 5 0 3 ATTACHMENT "B VINYL CHLORIDE SAFETY ASSDCLATICN 1983 MEETING Ron-Away Reaction Control Questionaire 1. Guidelines for response: a) Please enter the point at which initial action is taken for each of the following occurrences during a run-away. (N/A implies that no action is taken for this occurence.) (i) (ii) (iii) Reaction readies#C above set temperature. Reaction readies psiq above set pressure. Others_______________________________________________________ b) Is the response to the above situations automatic? (Y/N) 2. Causes: a) Please identify the three major causes (in order) of run-away batches: Charge error ____ Mechanical failure ____ Instrument failure ____ Agitation loss ^ Loss of cooling ' ' Formulation ____ Others: 3. Control techniques: a) Please indicate the order in which the following techniques are applied during a run-away (assuming previous steps were unsuccessful): Increase reactor cooling Add liquid-phase inhibitor Add vapour-phase inhibitor Dump a portion of the batch Vent to recovery system Vent to atmosphere Others: ____ . ^ ____ _____ __ ____ .../2 BOR 000504 2- - \ 3. Control Techniques; (Continued) b) If an inhibitor is used: i) ii) iii) Does it control the reaction or Kill it? How many discrete inhibitor injection systems are available? How is the inhibitor injected? Gravity Pump N2 pressure Other (specify) c) Does the point at which the reaction runs away affect the control technique? If so, hew? d) Are you completely satisfied with your inhibitor system, or would you like to see improvement? e) What areas would you like to see improved? 1) Reliability 2) Operability 3) Toxicity 4) Product usability 5) Other reasons aixl comments ________ ________ ________ __________ 4. Power supply: a) How often is plant power interrupted, on average, per year resulting in loss of agitation? ________(times/yr) b) If an extended power failure is experienced, how is agitation restored in order to disperse an inhibitor? (If used): i) ii) iii) iv) Back-up power supply Short, fast venting (ie burping) Other: _________________________________ Reactor size ________ ________ ________ .../3 BOR 000505 4. Power supply; (Continued) c) If .a back-up power supply is available for agitation: ^ i) What type is it? (ie. steam, electrical, other) ii) What percentage of normal agitation speed does it supply? (%) d) Are you completely satisfied with your back-up agitation system, or would you like to see improvement? ________ What improvement would you like to see? 5. Frequency of use: a) How many batches per year result in run-aways where sane action is required? b) What percentage of the above number of batches result in environmental emissions of VCM? ________ ________(%) Please send response by October 14, 1983 to: Mr. M.J. Bate Esso Chemical Canada Technology Plastics Technology Centre 480 South Christina Street Sarnia,' Ontario Canada N7T 2P1 Or bring response to meeting in New Orleans. M.J. Bate/jcd 0063J/jrw BOR 000506 ATTACHMENT "C VINYL CHLORIDE SAFETY ASSOCIATION 1983 MELTING Small Pilot Reactor Environmental Questionaire This study is aimed to evaluating sound, safe practices far residual monaner disposal from small pilot reactors, i.e., those up to 50 U*S. gallons (0.19 cu.m) which are not covered by the U.S. EPA National Emission Standard. 1. Do you have pilot reactors less than 50 gallons? _______ 2. Are these coupled into the plant VCM recovery system? _______ 3. If not coupled to plant, is this because of A. Remote location B. Safety concerns C. Other reasons _______ _______ _______ 4. A. B. C. D. Do you vent to atmosphere. If so, how high a stack. Do you take any measures to disperse the monomer during venting. Have you any details of ground level concentrations during venting. 5. Do you treat the vented monomer by A. Liquification by compression. B. Liquification by cooling. C. Carbon absorption. D. Liquid absorption. E. Flaring. F. Incineration and scrutbing. G. Catalytic destruction. H. Any other method. 6. If absorbing do you A. Desorb and recover the monomer in situ. B. Move the absorbent to a treatment site. C. Treat the absorbent in another way. .../2 BOR 000507 2- - 7. Please comment can the safety, effectiveness and/or problems with your procedure. 8. Are there any local regulations covering this type of experimental equipment and/or emissions. 9. Plant location. Please return completed questianaires by October 14th to: Mr. J.R. Wallace Esso Chemical Canada Plastics Technology Centre 480 South Christina Street Sarnia, Ontario Canada N7T 2P1 Or bring response to meeting in New Orleans. J.R. Wallace/jcd 0063J/jrw BOR 000508