Document 5qg8mmrRD10n36oO0MqVLZBJ

Interoffice Communication To From R.T. Ferrell j. Friend Date February 26, 1975 Subject ENGINEERING AND WORK PRACTICE CONTROLS PLAN FOR OSHA The Oklahoma City PVC Plant's Engineering and Work Practice Controls Plan for compliance with the OSHA VCM standard is attached. Comments from those receiving copies of this letter will be apprec iated. This document will be discussed with Aberdeen personnel in mid-March. As you know, our Engineering and Work Practice Controls Plan must be on file by April 1 and can be reviewed by OSHA. Therefore, we want to be sure that everything listed in the plan can and will be accomplished. JF/kv CC: LNV, RDG, EMS, DVP , RAF, AWS, MS, ELK, LDJ, CHP 0000105*5 OCR engineering and work practxOe controls plan FOR COMPLIANCE WITH OSHA VCM EXPOSURE STANDARD CONOCO CHEMICALS OKLAHOMA CITY PVC PLANT APRIL, 1975 OSURE SOURCE WORK PRACTICE CONTROLS ENGINEERING CONTROLS /All rotary seals, flexible hoses, pipe unions and flanges, valve stems, swivel joints and seals on equipment enclosures which are |in low or high concentration VCM |service. 1.- a) At least once per month, measure VCM concentrations at all hoses, flanges, un ions, seals, valve stems and swivel joints in low or high concentration VCM ser vice. 'Repair or replace leakers on-the-spot, where necessary. List other leak ers for repair or replacement on a maintenance schedule. The fixed point monitor will detect the occurrence of rel atively large leaks which will be attended immediately. Initiate this program on 4-175. 1. Make an engineering study to determine which rotary equipment in VCM service can be improved by conver ting to other systems such as double mechanical seals, canned pumps, etc. Complete study by July 1,1975. b) Institute a regular lubrica tion schedule for swivel jo ints on April 1, 1975. Opening and working on equipment or piping which may contain VCM in low or high concentrations. o n o o o o h-* O 2. a) Before opening, remove VCM .2, a)Install electropolished from equipment or piping to internals in all reactors the lowest practical level by by January 1, 1976 in flushing, purging and/or order to reduce the fre evacuation, where possible. quency of reactor entries for cleaning. b) Wear personnel protection b) Study injection of poly equipment which meets OSHA merization inhibitor into standards when opening the VCM recovery system equipment or piping which may for reduction of fouling contain VCM. and plugging which would lead to reductions in c) Before commencing repair work, required maintenance measure the VCM concentration and cleaning. Complete in or near opened equipment or study by January 1, 1976. piping to determine what t OS U RE SOURCE Reactor sampling and handling of slurry samples Resin sampling and analysis VCM rail car unloading o n yo o o o o t--I o VI -V WORK PRACTICE CONTROLS ENGINEERING CONTROLS 2. continued personnel prote ction . equipment is required and if further VCM. re moval should be attemp ted. 3. a) Wear personnel protection 3 . a) Prepare an engineering equipment which meets OSHA design for a closed standards during reactor samp reactor sampling ling until enclosed sampling system by October 1, systems are installed. 1975 . b) Store, handle and analyze all reactor and slurry samples in a laboratory hood. b) Install a new laboratory hood by April 1, 1975. 4. a) Wear personnel protection equipment which meets OSHA standards when sampling and analyzing resin. 4 b) After pulling a resin sample, immediately seal the sample bag. Prepare an engineering design for an improved resin sampling system at the M-500 dryer. Complete design by August 1, 1975. 5. a) b) Wear personnel protection equipment which meets OSHA standards while at the un loading rack during hook-up, unloading and un-hooking. Use the new double mechanical seal unloading pump whenever possible. 5. a) Install a sight glass by July 1, 1975, in the unloading line at each rack for determining the liquid to vapor transition at the end of unloading. b) Prepare a design to rearrange valving at the unloading racks to min imize the volume of VCM that must be vented before unhooking a car. Complete design by June 1, 1975. 5T0000 ;POSURE SOURCE Slurry dump screener Screener at the reactors' wash system effluent Reactor rinse after dump Residual monomer in resin n o JO * co WORK PRACTICE CONTROLS ENGINEERING CONTROLS Perform an engineering study tp determine the feasibility of installing an enclosed culls elimination system* Tests must be conducted on any equipment proposed for this service. Complete study by December 1, 1975. 8. Transfer the effluent from the initial water rinse after reactor dump to the dump system and eliminate transfer to the sewer. Initiate before April 1, 1975. 7. a) Design and install an enclosure' on the wash screener similar to the existing enclosure on the dump screener. Complete by September lf 1975. b) Provide culls overflow enclosure subject to the study outlined in no. 6 above. 9. Perform a study to determine the feasibility of a residual monomer reduction process. Steam stripping the slurry and higher temperature processing are currently being investigated. Com plete study by October 1, 1975. frOSURE SOURCE 1. Water flow from the centrifuges ! to the open trenches in the \ dryer room I ! WORK PRACTICE CONTROLS .. Resin screeners at the dryers' effluents \2. M-500 dryer exhaust o o O O O O l--1 o -f0 ENGINEERING CONTROLS 10. Design a header to transfer all water effluent from the centrifuges to the process sewer via a closed pipe instead of open trenches. Design must avoid potential explosive concentrations of VCM in the sewer sys tem. If a residual monomer reduction process is installed (no. 9 above), VCM content of the water effluent will be sub stantially reduced. Complete design by Jan uary I# 1976, subject to no. 9 above. 11. Perform an engineering study of enclosing the culls overflow from the dryers' screeners. If a residual monomer reduction process is installed (no. 9 above) , exposures at the culls overflow will be sub stantially reduced. Complete design by April 1, 1976, subject to no. 9 above. 12. Design and install an elevated stack for the M-500 dryer exhaust by October 1, 1975. The elevated stack will reduce exposure in the resin loading area. |{POSURE SOURCE p| . Gaseous or liquid vents or purges which may contain VCM WORK PRACTICE CONTROLS ENGINEERING CONTROLS 13. Prepare a conceptual des ign and' feasibility study for a vent collection system with an assoc iated VCM recovery system. This system would allow containment and clean-up of VCMcontaining vent streams before discharge to the atmosphere. Corporate Process Engineering will complete conceptual design by January 1/ 1976. n o 000010550