Document 5bmGe1mLxnQ898kqdVZgonwqD
To: R. A. Conrad
CONFIDENTIAL
VISTA CHEMICAL CO.
Interoffice Communication
Subject:
Incident Investigation Team February 25, 1986
VCM Release - Caustic Dryer S-207B February 5, 1986
VIS1A
Summary
On February 5, 1986 at approximately 7:30 am, a Vinyl
Chloride release occurred in the Supersucker area at
the east end of Block II. (See Exhibit A. Plot Plan)
The release resulted when the Building Trades Leadman
involved in preparation work to recharge the "off-line"
Caustic Dryer,
S-207A, mistakenly unblinded
the
"on-line" Caustic Dryer, S-207B, and opened the valve
to the Supersucker Vacuum Units. The Control Room was
notified of the release immediately by Maintenance
Department employees. Shortly thereafter the Furnace
Deluge curtain automatically came on and sounded an
alarm in the Control Room.
Operations and staff
personnel immediately responded to control the source
of the Vinyl Chloride release at Caustic Dryer, S-207B.
All non-essential personnel in the operating unit were
evacuated.
The duration of the release was
approximately five (5) minutes. The quantity of the
release was estimated to be 3,982 lbs. The appropriate
regulatory agencies were notified.
Caustic Dryer Process Description (See Exhibit B. Proces's Flow Diagram Vinyl Purification)
The overhead product from the vinyl Column, C-203 is washed with 4 to 10% aqueous caustic solution in order to remove residual traces of HC1. This washing is accomplished in an in-line mixer and is followed by a phase separation step to settle the free caustic from the liquid VCM (VCM Caustic Decanter ,S-206). The wet, neutral VCM (200-600 ppm H-O) flows directly from the top of S-206 to two up-flow Flake Caustic Beds (S-207 A&B) which operate in series. The VCM moisture content is reduced below 100 ppm by absorbtion of water into the flake caustic. The dried vinyl product exits the top of the last dryer in line and flows to intermediate storage. The caustic melt which accumulates in the bottom of the dryer from water absorbtion is drawn off.
CUH 000005937
CONFiJiiiM r iMi_
VISTA CHEMICAL CD.
The S-207 Caustic Dryers contain 70% strength flake
caustic and due to water absorbtion, the beds must be
recharged on a routine basis to replenish the flake
caustic drying media. Each week a dryer (the first in
line) is taken off line, emptied of VCM, purged and
opened for recharge. Following completion of recharge,
the freshly charged dryer is placed last in line and
the on-line dryer then becomes the lead dryer.
This
cycle is repeated continuously each week as long as
full vinyl production is occurring in the plant.
Circumstances Leading Up to the Release
On Wednesday morning February 5, 1986 at 7:15 am
Freddie Guillory (Building Trades Leadman) obtained a
Hazardous Work Permit (See Exhibit C. Hazardous Work
Permit) in the control room from Dan Ross (Chief
Operator) to recharge Caustic Dryer, S-207A.
As
scheduled, the "A" Dryer had been cleared, purged, and
readied for maintenance work on the preceeding evening
shift (3pm-llpm) and graveyard shift (llpm-7am).
Upon
issuance of the permit, Ross contacted Paul Ceasar (2nd
Operator - Blk I), informed Ceasar the permit had been
issued, and instructed Ceasar to meet Guillory at the
Dryer. Guillory and Ceasar met at the Dryer and Ceasar
went to the top of "A" Dryer to block in the vent valve
to the Incinerator and shut off the nitrogen purge
valve. (See Exhibit D. Piping Diagram Caustic Dryers,
S-207 A&B and Exhibit E, Procedure for Clearing S-207
for Recharge.)
Ceasar advised Guillory the purge
valves had been shut off and Guillory could proceed.
Ceasar then left the area. As usual Guillory proceeded
to line up the Dryer to the Supersucker Vacuum Units.
He checked the pressure upstream of the spectacle line
blind, and finding no pressure he rotated the spectacle
line blind into the open position and opened the block
valve. Though the equipment was clearly labeled and
Guillory understood he was to prepare "A" Dryer he
mistakenly lined up the on-line "B" Dryer to the Vacuum
Units. The Vacuum Units are located approximately 85
ft. away in the Block II operating area. Guillory left
the area unaware he had made the error. (Refer to
Exhibit F. Process Area Photographs.)
Circumstances Following the Release
At approximately 0730 am Maintenance personnel noticed
a cloud at the east end of Block II and notified
Operations personnel in the Control Room.
Dan Ross
(Chief
Operator),
Carrol
Brown
(Acting
Shift
Supervisor) and Mike Ashby (Process Superintendent)
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CWH 000005938
CONFIDENTIAL
VISTA CHEMICAL CO.
left the Control Room upon notification of the cloud in
Block ii.
They proceeded between the blocks in an
easterly direction (See Exhibit G. Personnel Approach
Routes to Control Release).
Ross went to the dryers,
Brown to the monitors on the south side of Block II and
Mike Ashby to the east end of the Blocks.
At
approximately 0735 am Ross closed the vent valve at "B"
dryer which stopped the VCM release source and checked
"A" dryer valve.
Mike Ashby noted the source of the
cloud as the Supersuckers and proceeded to the fire
monitor at S-502. Brown was at the same time putting
both fire monitors on at the Furnaces and the Propylene
Refrigeration Area. Ross and Mike Ashby put the fire
monitor on to deluge the source of the release to
prevent the formation/ignition of the vapor cloud.
During the above
action, Dave Lonkowski,
(Board
Operator), announced the evacuation of the unit.
After the monitors were on, Ross and Mike Ashby
directed traffic to clear Vista's 4th Street.
Ronnie
Young (2nd Operator - Blk II), Paul Ceasar (2nd
Operator - Blk I) and Steve Ashby (Safety Director)
arrived at the east end of Block I. The above action
steps are felt to have been sufficient to correct the
immediate hazard to the plant and its personnel.
At 0745, Mike Ashby, with a portable gas detector calibrated to 10 ppm for Vinyl Chloride, surveyed the Block Area (See Exhibit H. Portable Detector Patrol Tour). No VCM concentrations were detected.
At 0750, nitrogen was injected into the vinyl dryer
vent line to clear it of any residual material.
A
fourth fire monitor (portable) was added during this
process.
At 0800, Mike Ashby again surveyed the Block Areas with a portable gas detector. Again, no VCM concentrations, were detected. (See Exhibit I. Portable Detector Patrol Tour.)
At 0815, steam was added to the outside of the dryer vent line to be sure residual material was vaporized. Fire monitors on the south side of the plant were discontinued.
At 0830, the all clear notice was given The last two monitors were blocked in. Unit was called to inform them that the controlled.
to the plant. The Ethylene
situation was
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000005939 CUH
Estimated Quantity of Vinyl Released
CONFIDENTIAL
VISTA CHE1VI1CAL CO.
Basis
1)
Calculate duration of release from S-206
Pressure
Recorder Strip Chart.
2) Calculate rate of release from FR-209 Vinyl Production Rate Strip Chart.
3) Note: At the time of the incident, the vinyl production
was lined up to T-401C.
The
pressure at S-206
and
T-401C were both at 54 psig.
When thevalve to the
Supersucker was opened, the pressure at S-206 dropped to
45 psig. Therefore, since the path of least resistance
was to the Supersucker (and the pressure actually
dropped in S-206), no production went to T-401C during
the time the valve was open. The amount of release is
based on the production rate and durationof release.
A. Duration of Release
Basis: PR-278 Strip Chart (S-206 Pressure Recorder) Using a 60 engineering scale.
From strip chart: 30 min. interval = 23 units release interval = 4 units
Duration of the release = 4/23 x 30 = 5.22 minutes
B. Rate of Release
Basis: FR-209 Strip Chart (Vinyl Production Rate)
m = 4.5 units x 22.6 gpm/unit = 101.7 gpm = 762.75 #/min. (07.5 #/gal.)
C. Quantity of Release
= 5.22 x 762.75 = 3,982 lbs.
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ooo*9 AO 00 C^VV
ISTA CHEMICAL CO.
Potential Employee Exposure to Vinyl Chloride
Nine (9) VCM Plant employees were potentially exposed to vinyl chloride vapors. These employees included:
1) Robert Shirley - Boilermaker, Mechanic "A" 2) Dan Ross - Chief Operator 3) Carrol Brown - Acting Shift Supervisor 4) Mike Ashby - Process Superintendent 5) Steve Ashby - Safety Director 6) Paul Ceasar - 2nd Operator - Block I 7) Dick Going - Instrument Technician, Mechanic "A" 8) Darryl Derouen - Instrument Technician, Mechanic "A" 9) Ronnie Young - 2nd Operator - Block II
Robert Shirley was working in Block II and initially went to
investigate the source and type of release. Upon recognizing
the product involved (Vinyl Chloride), Shirley immediately
left the area.
Six (6) employees were potentially exposed
while responding to the immediate emergency.
Dan Ross and
Mike Ashby responded to the release area immediately from the
Control Room. Dan Ross closed the valve at S-207B located
approximately 85 feet from the release area.
He then
directed a firewater monitor located adjacent to S-207B on
the release area. Carrol Brown opened a fire monitor east of
the Control Room and directed it east of the Furnace Area and
then proceeded south of Block II and directed a fire monitor
located south of the HCl Column, C-202 onto the release area.
Ronnie Young, Paul Ceasar and Steve Ashby connected a
portable monitor and moved it to a location approximately 50'
north east of the release area (Supersucker).
Following
these actions each employee left the exposure area to
evaluate further actions.
M. L. Ashby conducted area exposure surveys with a Threshold
Limit Value Portable Analyzer at 7:45 am and 8:00 am to
determine if there were areas of VCM concentrations above the
permissible exposure limits.
No VCM concentrations were
detected.
In addition to the seven employees mentioned above, two other Vista employees, Darryl Derouen and Dick Going, and six contractor employees were potentially exposed to vinyl vapors while they were evacuating the process area.
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CONFIDENTIAL
VISTA CHEMICAL CO.
Each employee potentially exposed was verbally notified and each reported no exposure symptoms. Each employee in this group will be notified of the potential exposure in writing within 10 days.
In addition to the nine (9) employees mentioned above, six (6) other contractor employees were potentially exposed to vinyl chloride while evacuating the unit. The contractor has been notified of the potential exposure of their employees, and the requirements of Part 1910.1017 of the OSHA Vinyl Chloride Standard.
Medical Surveillance
Dr. J. R. Drumwright - Manager of Vista Medical was
contacted to determine if medical surveillance was
needed in this instance.
Each employee has been
informed of
the potential
exposure and medical
surveillance examinations were made available to each
individual should they desire one. Based on the low
exposure potential and the length of exposure Dr.
Drumwright advised that immediate medical surveillance
would not be warranted.
Critique of Safety Emergency
Systems Utilized During
This
The following safety systems and/or equipment were utilized to analyze or control this emergency.
1) Fixed Point Gas Chromatographic Analyzer System CAR-401, CAR-171
Both fixed point monitoring systems were being calibrated at 7:30 am on 2/5/86.
The fixed point monitoring systems are span
checked daily and calibrated three times per week
by the VCM Plant Maintenance Department. At 7:30
am on 2/5/86,
an Instrument Technician was
performing a calibration on CAR-171 and CAR-401
and no data was recorded during the release
period. The monitors were placed back in service
as quickly as possible following the release and
were used to determine when the area was clear to
return to work.
2 Fixed J&W Combustible Gas Detector System
The system monitors combustible gas concentrations
primarily in Block
II for
the purpose
of
activating the water curtain in the Furnace and
Block II aisleway area.
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000005942 CUH
CONFIDENTIAL
VISTA CHEMICAL CO.
This system alarms at 25% of the LEL and activates the water curtain at 40% of the LEL. The water curtain was activated by the combustible gas detectors at approximately 7:30 am.
3) Furnace Firewater Curtain
The system was activated automatically by the Fixed Combustible Gas Monitoring System. system reportedly operated per design.
J&W The
4) Fixed and Portable Firewater Monitors
A total of four (4) fire monitors were utilized to
control the release situation.
All equipment
operated properly and with adequate water supply.
5) Portable Threshold Limit Value Analyzer
One portable TLV analyzer was used to survey the
release area at 7:45
am and 8:00 am.
No
concentrations were detected during the surveys.
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CUH 000005743
Regulatory Agency Notification
CONFIDENTIAL
VISTA CHEMICAL CO.
The following agencies were notified regarding the release of vinyl chloride on 2/5/86.
1) Agency:
National Response Center
Date/Time: 2/5/86, 8:25 am
Contact:
Mr. DeMarco
Tel. No:
1-800-424-8802
2) Agency:
La. Dept, of Environmental Quality
Date/Time: 2/5/86, 9:15 am
Contact:
Mildred Hebert, William Coltrin
Tel. No:
491-2082 Local
3) Agency:
U.S. Dept, of Labor
Occupational Safety & Health Admin.
Date/Time: 2/5/86, 3:30 pm
Contact:
Ms. Eva Mitchell, Jack M. Matthews
Tel. No:
504-389-0474
Conclusions
The basic cause of the release was a Maintenance
Leadman mistakenly unblinding and opening the vent
valve of the "on-line" Caustic Dryer to the Supersucker
Vacuum Unit. The employee involved understood that the
job scope was to recharge "A" Dryer as evidenced by the
work permit and interviews with the employee.
The
Dryers are clearly labeled and there was no confusion
on the employee's part on which line blind and valve
corresponded to each Dryer.
After the incident the
employee insisted he prepared "A" Dryer until he went
to the job site and upon seeing the "line up" realized
his error. The job was not new to the employee, by his
own account he has prepared "hundreds of dryers" for
recharge in the same manner. By the employee's own
admission he made a mistake and doesn't know how he
could have done this.
A contributing cause of the release was the isolated
practice of a Maintenance employee operating process
valves.
Maintenance mechanics
routinely operate
utility service valves
(i.e. water, air,
steam,
nitrogen) and valves associated with lubrication or
freon on refrigeration units. Instrument Technicians
routinely operate small valves to transmitters,
analyzers, etc. with close coordination with operating
personnel. However, maintenance personnel operating
process valves is generally an undesirable practice.
Had the line-up to the Supersucker involved two
persons, the Leadman unblinding the spectacle line
CWH 000005944
i ; ? J/-\L_
blind and the Operator opening the vent valve, it is likely the Leadman's error would have been detected and the incident prevented. This conclusion was supported by Paul Ceasar the 2nd Operator, Blk I.
Corrective Actions
In order to prevent recurrence of this incident the following measures will be instituted:
1) A revised clearing and preparation procedure will
be issued for recharging the Caustic Dryers, S-207
A&B. (See attached Exhibit J.)
The procedure
includes a detailed checklist (See Exhibit K) for
taking the Dryer off-line, as well as placing a
Dryer back in service, involving both Maintenance
and Operating personnel. The procedure will also
incorporate an Operations Department Lock and Key
Control on the vent valve to the Supersucker
Vacuum Units.
2)
Training
sessions
will
be
conducted with
Maintenance and Operations Department personnel
reviewing the incident, the new procedures and
checklist within two weeks after issuance of this
report.
3)
As an added precautionary measure
additional
spectacle line blinds will be installed to further
insure no vinyl chloride leakage occurs during
recharging operations. (See Exhibit L Recommended
Line Blinds.) Permanent spectacle blinds will be
installed as soon as possible. Slip blinds will
be used in the interim.
4) The
Plant
Superintendent
and
Process
Superintendent have completed a General Safety
Audit of the area.
The Survey addressed General
Work Area
improvements
including
obsolete
equipment removal, housekeeping, and equipment
storage.
5) A Process Engineering Safety Audit of the Caustic Dryer Area will be conducted to determine if any additional measures are required.
S.R.Ashby 7~ Safety Director
J. R. Holcomb Mech. Supt.
H. 0. Adkison Mech. Supvr.
Plant Supt. cc: RTF, (WLM-TGG)
Process Supt.
CUH 000005945
LIST OF EXHIBITS
EXHIBIT A EXHIBIT B EXHIBIT C EXHIBIT D EXHIBIT E EXHIBIT F EXHIBIT G EXHIBIT H EXHIBIT I EXHIBIT J
EXHIBIT K EXHIBIT L
PLOT PLAN VCM PLANT - PROCESS AREA PROCESS FLOW DIAGRAM - VINYL PURIFICATION HAZARDOUS WORK PERMIT PIPING DIAGRAM - CAUSTIC DRYERS, S-207 A/B PROCEDURE FOR CLEARING S-207 FOR RECHARGE PROCESS AREA PHOTOGRAPHS PERSONNEL APPROACH ROUTES TO CONTROL RELEASE PORTABLE DETECTOR PATROL TOUR 7:45 AM PORTABLE DETECTOR PATROL TOUR 8:00 AM REVISED PROCEDURE FOR CLEARING S-207 FOR RECHARGE S-207 DRYER RECHARGE CONTROL SHEET (CHECKLIST) RECOMMENDED LINE BLINDS
CWH 000005946
7s
4 TH
ST.
m
l, lU ^ Hi ^
CONFIDENTIAL
VISTA CHEMICAL CO.
process flow
DIAGRAM VINYL PURIFICATION
CUH 000005948
>1
CONFIDENTIAL
VISTA CHEMICAL CO.
fconoeo)
Stfeettye Date
Continental Oil Company VCM Plant
Hazardous Wcrk Permit I.
Time
o nt; t.>
*m pm
--------------------- -----------------------------
Expiree
am
f O 30 *m
Location
o - z-on h
Requested By
CyLj / ') 10/? <J
Description of Work
U/2 /cr- s7_ _
Permit mutt be displayed on job site and-returned to operations
Type of Work
Hot Work :*Burn-Waid-Other Ignition Source
Entry: Ve*ael>TaAk>Encloeara
Alterational Bapair-Openlnr Equipment
Q Driliinr-Chipping
Q Electrical-Instrumentation
fc/ ( -A"
<""7v- /-/^
i
\
Safety Equipment Required
'Goggles/Faaa Shield
G Life Lina
G Rubber Gloves/Boot*
O Safety Balt & Lanyard Q Slicker Suit/ChcmleaJ Sait Safety Line A Barn*** Fresh Air Mask
Safety Preparation*
s
Teet for Ol
--.
Teat for texiaity
D Electrical breakers looked out
Bliade installed
G Equipment tagged oot
G Equipment depresenred
G Sewers eovared
n
4.1.EL
L
_PPM VCM
n.......................................... Safety Precautions Water Spray G Firewatoh/lTre Ext. G Manhole Watch G Air Blower G Fire Blanket Q Low Voltage Light Q Caotion Signi/Barrlers
G
Special Precautions
Anrrali<AU PtmiU Maid Che kod br Shift fmui Cblaf Operator Moehanis la Chars* Permit Extended by
Job Status
Complete
Inooreplete
f
In charge Accepted Remark*
Shift Foremen oauit approve aS Hot Warfc PiraiU la Free. Area and Vtwd letiy Peralta.
From
am pm To
am pm
am ' aaa
EXHIBIT C.
HAZARDOUS WORK PERMIT
EXHIBIT E.
CONFIDENTIAL
VISTA CHEMICAL UJ.
PROCEDURE FOR CLEARING S-207 FOR RECHARGE
Line up (open valve) from S-206 to down-stream dryer.
Close valve from S-206 to up-stream dryer.
Open the valve on the bottom of the up-stream dryer. This will enable you to empty dryer into the line coming from S-206.
Close the outlet valve on the up-stream dryer. This isolates the up stream dryer with only the bottom valve open.
Open nitrogen to top of up-stream dryer. Open nitrogen slowly so as not to increase pressure on S-206 by more than 10-12 psig.
Watch for level to come down into the sight glass. When the level goes out of sight glass, wait about one minute (no more) then close the bottom valve.
Contact incinerator operator, then slowly depressure dryer to S-108. (leave nitrogen cracked in on top while depressuring).
Pressure dryer up with nitrogen to 50 psig and depressure three times. During this step, also open nitrogen to spargers, and depressure through sight glass to clear. Will have to keep in close contact with incinerator operator.
After No. 8 step, block in nitrogen going to the spargers, and with a positive pressure on the dryer sample for lab analysis. If analysis is less than 2% vinyl, depressure completely. If analysis is more than 2% vinyl, continue step 8 until an acceptable analysis is obtained.
After step 9 is complete, open the 2 valves going to the super sucker from the spargers, put the supersucker on and open the nitrogen wide open to the top of the dryer. After five minutes cut the nitrogen back to minimum and open the vent valve in the line to the supersucker.
Maintenance will open the dryer and then close the vent valve before recharging.
When recharge is complete, shut down supersucker and close the two valves from spargers to the supersucper. Pressure the dryer up to 75-100 psig with nitrogen, and leak check top manway. If there are no leaks, depressure, and pressure up to 50 psig two more times and depressure. Dryer is now ready to put in service.
CWH 000005951
COrihl jE.' i fi/AL
VISTA LriciVI *AL CO.
c 13) Open valve (barely crack open) from top of dryer in service, to spargers of the dryer you are putting i-n. service. Do not lower pressure on S-206 more than 10-12 psig during ..this step. 14) When pressure is equalized, open the valve to spargers wide open. Call incinerator operator, and slowly bleed nitrogen out of top of dryer to wet vent. When dryer is liquid full, put in service second in line, by opening top valve to the check tanks and closing the valve to the check tanks from the upstream dryer.
c
L
quH 000005952
EXHIBIT F. PROCESS AREA PHOTOGRAPHS
S-207 A&B Looking From North East (Caustic Melt Piping)
CONFIDENTIAL
VISTA CHEMICAL CO.
S-207B Roll Blind In Vent Line To Supersucker
Looking From North East
000005953 CUH
S-207B Block Valve In Vent Line to Supersucker Looking From the North
CONFIDENTIAL
VISTA CHEMICAL CO.
S-207B Pressure Gauge Between Roll Blind And Block Valve Or Vent Line to Supersucker Looking From North
CUH 000005954
Close Up of S-207B Supersucker Vent Line
Block, Blind and Gauge
CONFIDENTS
VISTA CHEMICAL CO.
STM Lif 30< ,s"p"s"k'"' tooklnI' CONFIDENTIAL
VISTA CHEMICAL CO.
BL-303 And 304 (Supersuckers) Looking From South East
^ 000003956
rrr
CONFIDENTIAL
VISTA CHtMiCAL CO.
CUH 000005957
V
.7- ?,* v
e^it j
CONFiDENTlAL
VISTA CHEMICAL CO.
REVISED PROCEDURE FOR CLEARING S-207 FOR RECHARGE
Earlv on Evening Shift
1. Line up (open valve) from VCM Caustic Decanter,S-206, to downstream dryer.
2. Close valve from S-206 to upstream dryer.
3. Let dryer sit for several hours, isolated with shakers on.
4. Draw off melt caustic to S-108 until all melt is gone.
5. Open the valve on the bottom of the upstream dryer. This will enable you to empty the dryer into the line coming from S-206.
6. Close the outlet valve on the upstream dryer. This isolates the upstream dryer with only the bottom valve open.
7. Open nitrogen to the top of the upstream dryer. (Blind in
nitrogen line has been removed)
Open nitrogen slowly so as
not to increase pressure on S-206 by more than 10-12 psig.
(Watch S-206 pressure closely while performing this step
relief valves set @ 113 psig and 115 psig.)
8. Watch for the level to come down into the sight glass on the dryer. When the level goes out of the sight glass, wait about one minute (no more) then close the bottom valve.
9. Contact the Incinerator Operator then slowly depressure the dryer to S-108. (Leave the nitrogen cracked open on top while depressuring.)
10.
Pressure the dryer up with nitrogen to 50 psig and depressure to S-108. Repeat this step 3 times. During this step, also open nitrogen to the spargers, and depressure through the sight glass to clear. Keep in close contact with the Incin erator Operator at all times during this operation.
11.
Block in the nitrogen going to the spargers, and with a positive pressure (no greater than wet vent header pressure) on the dryer, sample for lab analysis. If analysis is less than 1.3% vinyl, depressure completely. If analysis is more than 1.3% vinyl, repeat step #10 until an acceptable analysis is obtained. Need to have two (2) consecutive samples less than 1.3% by lab analysis.
Revised 2/14./86
CWH 000005961
CONFIDENTIAL
VISTA CHEMICAL CO.
12.
Write and issue permit to maintenance for dryer recharge.
Block in nitrogen and vent.
Fill out a "Dryer Recharge
Control sheet" for dryer to be charged.
13.
Check the pressure gauge on the sparger line and the vent line to be sure they are reading zero.
14.
Have maintenance blind the dryer to be recharged per the
control sheet.
The operator should then check for proper
blind installation.
15.
Have maintenance personnel check the bleeder at the blind for pressure and then remove the blind in the "Supersucker" line (only on the dryer to be recharged).
16.
An Operations Department employee must then remove the chain and lock on the vent valve to the "Supersucker" on the dryer to be recharged.
17.
The Operations employee will open the valves going to the "Supersucker" from the spargers. Put the "Supersucker" on and open the nitrogen wide open to the top of the dryer. After 5 minutes cut the nitrogen back to minimum flow and open the vent valve in the line to the "Supersucker".
18.
Maintenance will open the dryer and close the vent before recharging (Valve located at top of dryers).
valve
19.
When recharge is complete, maintenance will "Supersucker" and reinstall the blind in the line.
shutdown the "Supersucker"
20.
An Operations Department person will close the valve to the "Supersucker" and reinstall the chain and lock.
21. 22.
Secure the dryer valves and have maintenance pull blinds and set the dryer up for operation.
Pressure the dryer up to 75-100 psig with nitrogen and leak check all disturbed flanges and fittings. If there are no leaks, depressure, and pressure up to 50 psig and depressure 2 times to purge the dryer of oxygen. The dryer is now ready to be put in service. (Make sure blind is reinstalled in the nitrogen line).
23.
Open the valve (barely crack open) from the top of the dryer
ycu are putting in service.
Do not lower the pressure on
S-206 more than 10-12 psig during this step.
Revised 2/14/86
CWH 000005962
CONFIDENTIAL
VISTA CHEMICAL CO.
When the pressure is equalized, open the valve to the spar gers wide open. Call the Incinerator Operator and keep in close contact, then slowly bleed nitrogen out of the top of the dryer to the wet vent. When the dryer is liquid full, put it in service second in-line, by opening the top valve to the check tanks on the recharged dryer and closing the valve to the check tanks from the upstream dryer.
Revised 2/14/86
CWH 000005963
S-207
EXHIBIT K
lALwplr1 ",vi 1i
VISTA CHEMICAL CO.
DRYER RECHARGE CONTROL SHEET
Initials
A. Dryer Emptied and Purged
fi. Lab Samples 1) ppm 2) ppm
C. Pressure on Sparger line is zero, ready to blind.
D. Pressure on vent line is zero, supersucker valve can be unchained and opened.
E. Dryer recharge complete and manway on. F. Supersucker valve closed and chained. G. Dryer leak checked and purged.
h. Nitrogen blind reinstalled.
Issued 2/14/86
Cl-JH 00000b964