Document 6BQ8kg7ZXQyZg2OrovzY9qE1d

ENVIRONMENTAL INFORMATION MANUAL CONOCO, INC. VCM PLANT WESTLAKE, LOUISIANA Revised1 MINE, 1982 DTH 000120195 CONOCO VCM PLANT ENVIRONMENTAL INFORMATION MANUAL TABLE OF CONTENTS SECTION I. GENERAL POLICIES AND GUIDELINES COMPANY POLICY PLANT POLICY POSSIBLE SOURCES OF POLLUTANTS GUIDELINES FOR DAILY POLLUTION CONTROL GOVERNMENT REQUIRED ROUTINE POLLUTION SAMPLING EMERGENCY POLLUTION GUIDELINES EMERGENCY TELEPHONE NUMBERS ENTRY RECORD SECTION II. VCM EMISSION REGULATIONS AND PLANS NATIONAL EMISSION STANDARD FOR VINYL CHLORIDE LEAK DETECTION AND ELIMINATION PLAN VCM NON-COMPLIANCE REPORTING PROCEDURES STANDARD OPERATING PROCEDURES - MAIN PLANT STANDARD OPERATING PROCEDURES - LOADING RACK STANDARD OPERATING PROCEDURES - LOADING DOCK VCM PLANT CURRENT EIQ VCM PLANT PAST EIQ SECTION III. WASTE WATER REGULATIONS AND GUIDELINES NPDES PERMIT SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN SECONDARY WASTE WATER TREATMENT OPERATING MANUAL (. SECTIOfi IV. HAZARDOUS WASTE REGULATIONS AND GUIDELINES RCRA GUIDELINES FACILITY INSPECTION PLAN CONTINGENCY PLAN EMERGENCY AND DISASTER PLAN MANIFEST SYSTEM SUPERFUND REPORTING ASBESTOS HANDLING PROCEDURE I)TH 00120197 SECTION I GENERAL POLICIES AND GUIDELINES dth 000120199 SECTION I COMPANY POLICY The worldwide activities of CONOCO, Inc. involve extensive uses of natural resources. CONOCO accepts wholeheartedly its corporate responsibi1ity for maintaining and improving the quality of the environment. Specifically, it is the policy of CONOCO to conduct all its activities in such a way as to effect prudent and responsible use of air, water, land and other natural resources. Moreover, CONOCO recognizes that because the beauty of the environment and the protection of wildlife are of prime importance to man's well-being, these also are among its essential concerns. In making decisions on the use of natural resources, the resultant benefits to society will be weighed against the costs of maintaining and improving the environment. CONOCO, Inc. adopts these goals: 1. To recognize the need for environmental improvement and to work vigorously toward carrying out the necessary programs of developing, installing, operating and maintaining effective control equipment. 2. To continue the search for new products and new processes compatible with the environment. 3. To anticipate possible emergencies threatening environmental quality and to prepare plans for the prompt handling of these emergencies. 4. To accumulate and disseminate scientific and technical information on environmental matters to the end that abatement implementation will be by the best available methods and at the lowest possible cost. 5. To use aggressively scientific and technical knowledge and skill in anti-pollution and conservation activities throughout all of CONOCO's operations. 6. To continue to cooperate with those governmental agencies charged with promulgating, administering and enforcing laws and regulations pertaining to natural resources. 7. To maintain an awareness of and sensitivity to environmental responsibi1ity among all CONOCO employees through a strong program of information and education. 8. To communicate to the public CONOCO's commitment to environmental conservation. DTH 000120200 SECTION I PLANT POLICY At the VCM Plant, each individual is responsible for minimizing pollution and for seeing that a good sound pollution abatement program is practiced. Should a large spill or large gas emission occur, the Plant Manager will be notified immediately. Large spills or large gas emissions which do not endanger life or property, but which may violate federal or state pollution regulations will be handled by the guidelines set forth in this manual. Major spills or major gas emissions which endanger life or property and violate federal or state regulations will be handled by the Emergency and Disaster Plan in section IV of this manual. Because of familiarity with most possible plant pollutants, Operations will be responsible for cleanup of a pollution problem. In addition, the Chief Process Engineer will be available to act as technical advisor. It is plant policy that only the Plant Manager or his specific designee will issue any statements to local, state or federal agencies, news media or company management. DTH 000120201 SECTION I POSSIBLE SOURCES OF POLLUTANTS / A. Water The plant process effluent is composed of several streams which leave the plant and flow into the secondary waste treatment system, and then into Bayou Verdine. The rainwater effluent exhausts into two areas. The battery limits and 75% of the offsites drain to the secondary waste treatment system. The other 25% drains into the pond south of the Vinyl Chloride Plant. Major Water Effluent Sources Possible Pol1utants 1. EDC Purification Water Wash System Ethyl Chloride Ethylene Dichloride Hydrochloric Acid Sodium Chloride Sodium Formate Sodium Hydroxide Ethylene Glycol Ethylene Chlorohydrin Vinyl Chloride 2. Process Sewers, Block I Anti-foulants Ethyl Chloride Ethylene Dichloride Heavy Tars Sodium Hydroxide -Steam Condensate (Temperature) 3. Process Sewers, Block II Cu Catalyst During Oxy Reactor Washing Ethylene Dichloride Furnace Decoking Organics Heavy Tars Hydrochloric Acid Steam Condensate (Temperature) 4. C-500 Bottoms Chlorine Ethylene Dichloride Hydrochloric Acid Iron Sulfuric Acid Cooling Tower Biocides Cooling Tower Dispersents DTH 00012020 5. Offsites, NE Section 6. Offsites, SE Section 7. Offsites, W Section (Rainwater runoff to pond due south of VCM Plant) Cooling Tower Makeup Chemicals Suspended Solids Chlorine Ethylene Dichloride Oils Other Organic Chlorides Sodium Hydroxide Suspended Solids Calcium Chloride Oils Suspended Sol ids B. Ai r The plant air emissions presently come from six major sources. (See the Plant EIQ in Appendix.) Source Possible Emission 1. R-201 A & B Carbon Monoxide Sulfur Dioxide Hydrocarbons Nitrogen Dioxide Particulate Matter 2. C-500 Particulate Matter Sulfur Dioxide Nitrogen Dioxide Carbon Monoxide Hydrogen Chloride Chlorine VCM Ethylene Ethane Methane Hydrogen Ethylene Dichloride Ethyl Chloride 1 ,1,2 Trichloroethane 3. Dock EDC Tank (T-415) Ethylene Di chloride Other chlorinated hydrocarbons Hydrogen Chloride 4. Dock VCM Vent Recovery VCM * DTH 000120203 5.Vent Incinerator Particulate Matter Sulfur Dioxide Nitrogen Dioxide Carbon Monoxide VCM Chlorine Hydrogen Chloride Solid and Liquid Wastes The solid and liquid wastes that are generated in the plant are classified into two major categories, hazardous and non-hazardous, according to the Resources Conservation and Recovery Act (RCRA). Wastes at the VCM Plant are defined as hazardous if they contain or are contaminated by VCM or EDC. Wastes are also hazardous if they fail any one of the following tests: 1) Ignitability, 2) Corrosivity, 3) Toxicity, and 4) Reactivity. Hazardous wastes as defined by RCRA regulations must be handled, stored, and disposed of according to the requirements set forth in this manual. The following wastes have been classified as hazardous: 1) Heavy ends from the distillation of ethylene dichloride in ethylene dischloride production (EDC tars). 2) Heavy ends from the distillation of vinyl chloride in vinyl chloride production (VCM tars.). 3) Asbestos insulation. 4) Vinyl Chloirde (VCM) contaminated material. 5) Ethylene Dischloride (EDC) contaminated material. 6) Copper Pit Sludge. 7) T-l Pit Sludge. 8) T-2 Pit Sludge. 9) VCM Plant Wastewater. 10) Incinerator Wastewater. 11) Laboratory Hood Charcoal Beds. 12) EDC and VCM Filter Cartridges. 13) T-500 Pit Limestone. 14) Spent Calcium Chloride. 15) Laboratory Sample Bottles. 16) Laboratory Chemical Reagent Bottles. DTH 000120204 17) Copper Chloride Catalyst. 18) Raschig Rings. 19) T-500 Pit Sludge. 20) Secondary West Equalization Basin Sludge. 21) Secondary South Equalization Basin Sludge. 22) Secondary Activated Sludge Unit (A.S.U.) Material. 23) T-981 Pit Sludge. 24) T-982 Pit Sludge. 25) Incinerator Overflow Box Sludge. 26) Quench Column Coke. DTH 000120205 SECTION I GUIDELINES FOR DAILY POLLUTION CONTROL C-500 During upsets in the system which cause a heavy load on the C-509 vent scrubber, the large water dumps should be used to minimize possible air pollution. C-500 Venturi Scrubber The venturi scrubber-pump will be run continuously. The T-509(T-1) pit should be acidic when this pump is running. Pumping caustic will cause severe corrosion to C-500 tower. Cleaning Contractors Maintenance will have the responsibility of instructing cleaning contractors on safety and pollution hazards. No organic solvents can be dumped into the effluent water system under any conditions. Cooling Tower Blowdown An excessive number of blowdown points can cause relatively low cycles of concentration in the cooling tower operation. This results in high chemical treating costs. Unnecessary blowdown points should be minimized whenever possible. Drainage Ditches Plant storm and process sewers should be cleaned frequently. Residue considered hazardous under RCRA regulations should be disposed into appropriate hazardous waste containers. FiIter Servicing Spills from filter servicing should be minimized whenever possible. All spills should be water washed to the process sewers immediately. Housekeeping Practices When spills do occur, it is the person's responsibility who is causing the spill to clean the area promptly. Spills should be prevented when possible. Outdoor Burning No open burning is permitted in this plant unless prior approval is obtained from the Plant Manager. DTH 000120206 t 9. Pump Priming and Servicing Corrective action should be taken immediately to repair leaks or other mechanical problems to insure minimum effluent contamination. Priming or servicing spills should be hosed down immediately with water into the process sewers. 10. Sampling Special VCM sampling systems must be used at all times. Special EDC sampling systems will be available and should be used at that time. Samples other than VCM should be flushed to the process sewers for the minimum period required to insure an accurate sample. All spills should be hosed down with water when they occur. 11. T-510(T-2) Pit The T-510 pit west of the C-500 vent scrubber should be checked periodically to insure that the EDC level is low enough to prevent free EDC from reaching.the secondary water waste treatment system. EDC should be pumped to thewash system forrecovery. 12. T-500 Neutralization Pit/Feed to Secondary pH Control The T-500 neutralization pit acts to neutralize hydrochloric acid by passage through clam shell or limestone rock. It is the Shift Supervisor's responsibility to have this pit checked at least once per shift and to order clam shell as needed. The pit should be checked each shift to insure that channeling through the bed does not occur. The feed to the secondary pH should be maintained at 5.0 to 6.0 by adjustment of the trim neutralization system. 13. Venting of Gases The venting of gases to the atmosphere should be minimized whenever practical. 14. Steam Stripper One of the two plant steam strippers must be kept in operation at all times. The column must never handle and liquid over 7.0 oH. 15. Secondary Waste Treatment System The pumper/loader will be responsible for control of the secondary system except for the in-plant pH control system which will be opera ted by a boardman. Secondary operating and maintenance guidelines are included in Section III. DTH 000120207 16. Closed Process Sewer Pump casing, vessel contents, column washes, etc. shall be drained to the closed process sewer for the processing through the steam stripper for removal of vinyl chloride and ethylene dichloride. / DTH 000120208 SECTION I GOVERNMENT REQUIRED ROUTINE POLLUTION SAMPLING Wa ter EPA NPDES Permit Compliance samples (see appendix) are the only required routine water samples. Air The following emission points will be monitored to demonstrate compli ance with EPA vinyl chloride regulations. A. Incinerator - The exit gases will be continuously monitored for VCM content. For compliance this stream must contain less than lOppm Vinyl. Continuous vinyl chloride vent concentrations will be fed to the Interdata Computer for tabulation. B. Oxy Vent - Vinyl Chloride emissions must be limited to 0.2 grams per kilogram of ethylene dichloride produced from the oxychlorination process. Continuous vinyl chloride vent concentrations will be fed to the Interdata Computer for calculation of emission quan tities. C. Carbon Beds at Docks - Vent gases from these carbon beds will be monitored by the dock area fixed point monitor. Vinyl chloride content is limited to less than 10 ppm as established in the vinyl standard. Solid and Liquid Waste All wastes which were suspected of possibly being hazardous were sampled and tested for purposes of compliance with the November 19, 1980, date for submittal of the RCRA Phase I permit application and in accordance with DNR Analytical Operations Procedure Manual. These wastes were sampled and analyzed in accordance with the EPA procedures to deter mine whether each waste would qualify as hazardous based on the cri teria as given in RCRA 261 Subpart C, if the waste stream did not al ready qualify under SubDart D. All wastes were samnled with these determinations as priority, a secondary considerationbeing the proper handling of the waste, based on the analytical information generated, to supplement historical handling information already a part of nor mal operating procedures. The results of the analysis of each waste will be considered to be representative of that waste until such time as information is received or generated which indicates analysis of the specific waste has changed. This indicator could be results of an analysis performed by an offsite disposal facility, a change in the waste generation process, an indi cation in the storage or treatment process, or simply a suspicion by the specific facility ooerator that certain characteristics of the waste have changed. DTH 000120209 At such time that changes in the waste generation process occur that may change the characteristics of the waste, the specific stream will be sampled and analyzed in accordance with EPA procedures (or an equi valent method), to determine the extent of the change in analysis and the hazardous/non-hazardous waste status. Handling and disposal of the wastes will, at that time, be based upon the degree and type of hazard the analysis indicates. v. i DTH 000.120210 SECTION I v EMERGENCY POLLUTION GUIDELINES The possibility of an emergency pollution problem is minimized by proper operation and maintenance of all process equipment- In the event of such an emergency, the .following procedure should be followed. 1. -The Plant Manager will be notified of a large spill or gas emission immediately after precautions are taken for the safety of personnel in the area of the spill or emission. 2. Only the Plant Manager or his designee will report, to the proper authorities, a pollution problem which has spread beyond the plant boundary limits. 3. Operations will be responsible for coordination and control of all efforts necessary to minimize the pollution hazard. The Chief Process Engineer will act as technical -advisor. 4. The following steps shall be taken immediately to minimize a pollution hazard. a. Water Pollution Hazard Should a large liquid spill occur, first efforts should be directed toward f preventing further spillage. The spill should be trapped in an existing pit (T-500, T-509(T-1)y T-510(T-2), or secondary system pits)-to prevent it -- getting into the plant effluent outfall. Vacuum trucks should be ordered as necessary to recover any liquid spill (such as ethylene dichloride) which cannot be neutralized into an inorganic salt compound. In the event of an acid spill, clam shell or caustic should be added to the trapping pit to provide neutralization. Should a spill occur in an area which does not drain into an existing effluent pit, efforts should be made to contain the spill within the plant boundary limits. A possible method is the damming of a drainage ditch; and then, using vacuum trucks or neutralization as required to minimize the problem. If a hazardous chemical spill reaches Bayou Verdine then action should be taken to report the spill to state and federal authorities. b. Air Pollution Hazard Should a large gas emission occur, first efforts should be directed toward preventing further gas emission. Since most gases in the VCM Plant are toxic, flammable, or both, extreme care should be taken when attempts are made to stop a gas emission. Water sprays should be used when required to prevent a -fire or an explosion hazard. The proper safety equipment must be used at all times. If the released gas is vinyl chloride, refer to the Operational Emerqency,, Plan in the VCM Compliance Plan for specific information on how to handle and report the gas-emission. DTB 000120211 If the gas emission creates an actual or potential disaster situation, refer to the plant's Emergency and Disaster Plan in Section III. The Department of Natural Resources has set up a procedure designed to minimize the danger of air pollution emergencies due to stagnant atmospheric conditions. Each industry in the state has submitted an action plan to the state showing how that industry will reduce an emission whenever air stagnation conditions develop. The action plan for the VCM Plant is appended to this section. If the state Department of Natural Resources (DNR) determines that dangerous atmospheric conditions exist, they will contact each industry and request that one of the three classifications (alert, warning, emergency) of the air emergency episode plan be implemented. Upon notification, the Plant Manager should be immediately notified and he will order any required changes. No action should be taken until the Plant Manager has been contacted. Plant production rates will be reduced only under the most severe condition (the "emergency") and the Plant Manager's approval must be obtained before any rate reductions are started. DTH 000120212 EMERGENCY EPISODE PLAN FOR DNR CONOCO VCM PLANT Alert Level 1) Minimize all vehicle traffic. 2) Defer all possible truck or rail loading. 3) In winter, cut off cooling tower fans and steam turbine if cooling load wi11 permit. 4) Notify all employees of alert and request that they curtail all vehicle use. 5) Defer any cooling tower chlorination. 6) Defer liquid chlorine car unloading. 7) Cease any spray painting work or sandblasting work. 8) Cease any solvent cleaning operations by maintenance. 9) Cease all fire training school operations. Warning Level 1) Stop all loading operations of VCM, EDC, and light ends. 2) Shutdown all non-essential motors in plant. Cut night time lighting load to minimum allowable by safety. 3) Defer cleanouts of bauxite and flake caustic beds, unless critical. 4) Cut off or curtail any non-essential production. Eliminate any material "reworking". 5) Notify employees of warning and of requirement for use of car pools. Emergency Level 1) Cease all non-emergency vehicle use. Release all non-essential people from reporting to work. 2) Cut back plant to 80% of design (1.6 MM Ibs/day VCM) and minimize oxy vent gas hydrocarbons. 3) Cut back cracking furnaces to maximum possible degree. 4) Cut off spare pumps wherever possible. Minimize steam supply to all reboilers. DTH 000120213 SECTION I EMERGENCY TELEPHONE NUMBERS State and Local Agencies Agencies to contact in case of 1. Water Pollution Incident a. Division of Water Pollution Control Office of Environmental Affairs Department of Natural Resources Baton Rouge Office (504) 342-6364 (504) 342-6363 Holidays, Nights or for Hazardous Wastes (504) 342-5595 b. Alternative to above call: La. Office of Conservation (504) 342-5540 c. U.S. Coast Guard Duty Officer, New Orleans Duty Officer, Port Arthur (504) 589-6275 (713) 971-2261 d. Calcasieu Sheriff's Office 491-3702 Agencies to contact in case of -- 2. An Air Pollution Incident a. Calcasieu Lake Charles Health Unit Dr. Russell R. Coniey(Director) b. Alternate to above call: Dept, of Natural Resources Mr. Gus Von Bodungen 491-2040 478-6020 491-2040 (504) 568-5122 (504) 568-5123 (504) 342-1206 3. Other Area Industry (if affected) a. PPG Industries, Inc. Contact guard and request guard to contact Shift Supervisor 491-4242 b. 01 in Corporation, guard After 4:00 PM 491-3310 491-3000 c. Cities Service Oil Co., guard 491-6230 DTH 000120214 SECTION I EMERGENCY TELEPHONE NUMBERS (Con't) B. Federal Agencies 1. National Response Center (Superfund Incidents) (24 hours) 1-800-424-8802 v t ! 000120216 SECTION I ENTRY RECORD Visits to the VCM Plant by air/water/solids waste pollution authorities must be noted on the "Entry Record" which follows. Visitors to the VCM Plant for pollution control surveys may make inspections only under the supervision of the Chief Process Engineer or his designee. In his absence the Plant Manager-shall be responsible. This entry record will provide a complete report of a pollution control visit. DTH 000120216 REQUEST FOR ENTRY TO A CONOCO, INC. FACILITY 1. My name is. I represent (agency or bureau) _______________ __________________ , which is established by the laws of the (United States) (State of _____________ ). My official title or position is. My business address is 2. In my official capacity, I am requesting admission to (piant or faci1ity) ________________________ , for the purpose of: ( ) a. gathering scientific research information and/or studying technology development, under ; (statute or popular name of act) ( ) b. making a regularly scheduled inspection of the facilities, under ( ) c. ( ) d. (statute or popular name of act) taking samples of water, air, or (circle) type of air monitoring equipment __________ _________________________ water chemical analyses (tests and methods) location(s) for sampling _____________________________________________ making a special inspection of the facilities for the following purposes: ( ) e. ( ) f. under |__________________________________ __________________________ (statute or popular name of act) gathering evidence for pending or potential criminal or civil proceedings, under __________________________________ ___________ (statute or popular name of act) other; specifically______________________________________________ under __________________________________ _________________ (statute or popular name of act) 3. I specifically wish to see the following units or activities: 4. I will split samples and furnish you the analytical results of the tests. 5. I understand that I will be furnished a guide and such other assistance as I may require for information or safety. I will comply with all safety regulations and instructions, whether written or oral, while on the premises. (date) ______ (time]' Visit authorized by: ' (Visitor) Title: ____________________ Plant Manager 000 i202l<7 SECTION II VCii EMISSION REGULATIONS AND PLANS DTH 000120218 SECTION II NATIONAL EMISSION STANDARD 'A ) FOR t v (VINYL CHLORIDE < \ ooo^0219 HAZARDOUS EMISSIONS S-19! 121:0473 Subpjrt F--National Emission Standard (,;> "Inaroccss wastewater" moans any fir Vinyl Chloride water which, during manufacturing or |4[ |-K 46559, October 21. 1 976j processing, comes into direct contact (>1.60 A pp! ic.ibiiiI r. with vinyl chloride or polyvinyl chloride or results from the production or use of (a' This subpart applies to plants any raw material, intermediate product, which produce: finished product, by-product, or waste 11) Ethylene dichloride by reaction of oxygen and hydrogen chloride with ethylene, 12) Vinyl chloride by any process, and/or product containing vinyl chloride or polyvinyl chloride but which has not been discharged to a wastewater treat ment process or discharged untreated as wastewater. (3) One or more polymers containing any fraction of polymerized vinyl chlo ride. (b) This subpart does not apply to equipment used in research and develop ment if the reactor used to polymerize the vinyl chloride processed in the equip ment has a capacity of no more than 0.19 m' (50 gal) ic) Sections of this subpart other than ^61.81; 61.64 (an 1), fbi. (cl. and Id). 61.67; SI 68: 61.69; 61.70; and 61.71 do not apply to equipment used in research and development if the reactor used to po lymerize the vinyl chloride processed in the equipment has a capacity of greater lhan 0.19 m* (50 cal) and no more than 4.07 m` (1100 gal). M2 FR 29005. June 7. 1977] 61.61 Definitions. ik) "Wastewater treatment process" includes any process which modifies characteristics such as BOD. COD. TSS, and pH. usually for the purpose of meet ing effluent guidelines and standards: it does not include any process the purpose of which is to remove vinyl chloride from water to meet requirements of this subpart. (li "In vinyl chloride service means that a piece ot equipment contains or contacts either a liquid that is at least 10 percent by weight vinyl chloride or a gas that is at least 10 percent by volume VTfiyiclTTdficle"" ---------------------------------------- im > `Standard operating procedure" means a formal written procedure offi cially adopted by the plant owner or operator and available on a routine basis to those persons responsible for carrying out the procedure. Terms used in this subpart are defined (n) "Run" means the net period of in the Act, In subpart A of this part, or time during which an emission sample Is in this section as follows: collected. (a) "Ethylene dichloride plant" In cludes any plant which produces ethyl ene dichloride by reaction of oxygen and hydrogen chloride with ethylene. (b> "Vinyl chloride plant" includes any plant which produces vinyl chloride by any process. (ci "Polyvinyl chloride plant" includes any plant where vinyl chloride alone or in combination with other materials is polymerized. id) "Slip gauge" means a gauge which has a probe that moves through the gas/ liquid interface in a storage or transfer vessel and indicates the level of vinyl (0) "Ethylene dichloride purification" includes any part of the process of ethyl ene dichloride production which follows ethylene dichloride formation and in which finished ethylene dichloride Is produced. (pi "Vinyl chloride purification" In cludes any part of the process of vinyl chloride production which follows vinyl chloride formation and in which finished vinyl chloride is produced. (q) "Reactor" includes any vessel in which vinyl chloride is partially or totally polymerized Into polyvinyl chloride. chloride in the vessel by the physical (r> "Reactor opening loss" means the state of the material the gauge dis emissions of vinyl chloride occurring charges. when a reactor is vented to the atmos (e> "Type of resin" means the broad phere for any purpose other than an classification of resin referring to the emergency relief discharge as defined in basic manufacturing process for produc ? 61.65(a>. ing that resin, including, but not limited (s) "Stripper" includes any vessel in to. the suspension, dispersion, latex, bulk, which residual vinyl chloride is removed and solution processes. from polyvinyl chloride resin, except (f) "Grade of resin" means the-sub bulk resin, in the slurry form by the use division of resin classification which de of heat and/or vacuum. In the case of scribes it as a unique resin, l.e.. the most bulk resin, stripper includes any vessel exact description of a resin with no fur which is used to remove residual vinyl ther subdivision. chloride from polyvinyl chloride resin <g> "Dispersion resin" means a resin immediately following the polymeriza manufactured in such away as to form tion step in tile plant process flow. fluid dispersions when dispersed in a 11) "Standard temperature" means a plasticizer or plasticizer/diluent mix temperature of 20 C '69" F). tures. <hi "Latex resin" means a resin which is produced by a polymerization process which initiates from free radical catalyst sil.'s ar.d is sold untiried. ii> "Bulk resin' 'means a resin which is produced by a polymerization process (u) "Standard pressure" means a pressure of 760 mm of Hg (29.92 in. of Hg). [42 FR 29005. June 7. 1977] 61.62 Friiis'ion dami.ird for ctliylciv ilirliloriiiv plants. in which no water is used. (42 FR 29005, June 7, 1977' (a) Ethylene dichloride purification: The concentration of vinyl chloride in ail exhaust gases discharged to the at mosphere from any equipment used In ethylene dichloride purification is not to exceed 10 ppm, except as provided in ol.libla). 'fills requirement does not apply to equipment that has been opened. Is out of operation, and met the require ment In $ 81.65 (b) (6) (1) before being opened. (b) Oxychlorin&tlon reactor: Except as provided in 81.65(a), emissions of vinyl chloride to the atmosphere from each oxychlorlnatlon reactor are not to exceed 0.2 g/kg (00002 Ib/lb) of the 100~ percent etnylene dichloride product from tne oxychlorlnatlon process. 61.63 Emission standard' for vinyl chloride plant*. An owner or operator of a vinyl chlo ride plant shall comply with the require ments of this section and 61.65. (a) Vinyl chloride formation and puri fication: The concentration of vinyl chloride in all exhaust gases discharged to the atmosphere from any equipment used in vinyl chloride formation and/or purification is not to exceed 10 ppm, ex cept as provided in S 61.65(a). This re quirement does not apply to equipment that lias been opened, is out of operation, and met the requirement in 161.65(b) (6) li) before being opened. 61.6 4 Emission itnmlnril for polyvinyl rliioridr plant*. An owner or operator of a polyvinyl chloride plant shall comply with the re quirements of this section and 1 61.65. (a) Reactor: The following require ments apply to reactors: 11 > The concentration of vinyl chlo ride in all exhaust gases discharged to the atmosphere from each reactor is not to exceed 10 ppm. except as provided In paragraph (a)(2> of this section and $ 61.65(a). (2) The reactor opening loss from each reactor is not to exceed 0.02 g vinyl chloride/Kg (0.00002 lb vinyl chloride/ ibi of polyvinyl chloride product, with the product determined on a dry solids basis. This requirement applies to any vessel which is used as a reactor or as both a reactor and a stripper. In the bulk process, the product means the gross product of prepolymerization and postpolym eriza tlon. (31 Manual vent valve discharge: Ex cept for an emergency manual vent valve discharge, there is to be no discharge to the atmosphere from any manual vent valve on a polyvinyl chloride reactor in vinyl chloride service. An emergency manual vent valve discharge means a discharge to the atmosphere which could not have been avoided by taking meas ures to prevent the discharge. Within 10 days of any discharge to the atmosphere from any manual vent valve, the owner or operator of the source from which the discharge occurs shall submit to the Ad ministrator a report in writing contain ing information on the source, nature 3 24-7,4 (See. 61.64UH31] 1`a-.l :> i 111 !il HI Al 16 \A MON \L AITAlKo. IM'.. it ASIIIVITON. D.C. 201)37 31 DTH 000120220 HAZARDOUS EMISSIONS S-39! 121:0475 lated vessel: bv ducting any vinyl chlo ride between the two seals through a control system from which the concen tration of vinyl chloride in the exhaust gases docs not exceed 10 ppm: or equiva lent as provided in 5 G1.66. * 4) Leakage from relief valves: Vinyl chloride emissions due to leakage from each relief valve on equipment m vinyl chloride i.ervice are to he minimized liv inril.iiIIin;; a rupture disk hctwcen llic equinmeni and the relief valve, by con nect in g the relief valve discharge to a process line or recovery system, or equiv alent as i .ovided in 5 61.66. <5> Manual venting of gases: Except as provided in e 61.64fa> (3 >. all gases which are manually vented from equmment m vinyl chloride service are to' be ducted through a control system from which tiie concentration of vinyl chloride in the exhaust gases does not exceed 10 ppm: or equivalent as provided in 5 61.66. 16> Opening of equipment: Vinyl chloride emissions from opening of equipment (including loading or unload ing lines that are not opened to the at mosphere after each loading or unload ing operation) arc to be minimized as follows: <ii Before opening any equipment for any reason,- the quantity of vinyl chlo ride is to be reduced so that the equip ment contains no more than 2.0 percent by volume vinTTchlonde or U.Wbu m' (25 gal' of vinyl chloride, whichever is larger, at standard temperature and pressure: and it > Any vinyl chloride removed from the equipment m accordance with para graph (b>(6i(i> of this section is to be ducted through a control system from which the concentration of vinyl chlo ride in the exnaust gases does not exceed 10 ppm. or equivalent as provided in > 61 GO. < 7 Samples: Unused portions of sam pler, containing at least 10 percent by weight vinyl chloride are to be returned to the process, and sampling techniques iic to be such that sample containers in . i.iyl chloride service arc purged into a c'o-ed process system. Leak detection and elimination: Vinyl chloride emissions due to leaks from equipment in vinyl chloride service arc to be minimized by instituting and implementing a formal leak detection .uv.I cumulation program. The owner or operator shall submit a description of tiie program to the Administrator lor approval. TSc program is to be sub mitted within 45 days of the clfective date of these regulations, unless a waiver of compliance is granted under 5 61.11. If .. waive** of compliance is granted, the Program is lo he .submitted on a dale scheduled by the Administrator. Ap proval of a program will he granted by me Administrator provided he finds: 111 It includes a reliable and accurate u'.vl chloride monitoring system for dot Jt i viol I o: maior leaks and identification ui lie? general area oi the plant whoroTt i.. located. A vinyl chloride momtorI.- : system means a device which obtains r.ir samples from one or more points on '\-p It contains a definition of leak a continuous sequential basis anti ana which is acceptable when compared with lyzes the samples with gas chromatog the background concentrations of vinyl raphy or. ; the owner or operator as chloride in the areas of the plant to be sumes that all hydrocarbons measured monitored by the vinyl chloride monitor are vinyl chloride, with infrared spectro ing system. Measurements of background photometry flame ion detection, or an concentrations of vinyl chloride in the equivalent or alternative method. areas of the plant to be monitored by the in It includes a reliable and accurate vinyl chloride monitoring system are to _p:n initio hydrocarbon detector to be used be included with the description of the routinely to find .-11111111 InikM und lo pin program. The definition of leak for a point the major leaks indicated by the given plant may vary among llic differ vinyl chloride monitoring system. A ent areas within the plant and Is also to portable hydrocarbon detector means a change over time as background con device which measures hydrocarbons centrations in the plant are reduced.. with a sensitivity of at least 10 ppm and is cf such design 2nd size that it can be used to measure emissions from local (9' Inprocess wastewater: Vinyl chlo ride emissions to the atmosphere from inprocess wastewater are to be reduced ized points. as follows: i iii > It provides for an acceptable cali (i) The concentration of vinyl chlo bration and maintenance schedule for ride in each inprocess wastewater stream the vinyl chloride monitoring system and containing greater than 10 ppm vL.yl portable hydrocarbon detector. For the chloride measured immediately as it vinyl chior-.de monitoring system, a daily span check is to be conducted with a concentration of vinyl chloride equal to tiie concentration defined as a leak ac leaves a piece of equipment and before oeing mixed with any other inprocess wastewater stream is to be reduced to no roore than 10 ppm bv weight before being mixed with any other inprocess wastewa cording to paragraph (b)(8) <vi> of this ter stream which contains less than 10 section. The calibration is to be done ppm vinyl chloride: before being exposed with either' , to the atmosphere, before being dis (A) A calibration gas mixture pre charged to a wastewater treatment proc pared from the gases specified in sections ess: or before being discharged untreated 5.2.1 and 5.2.2 of Test Method 106 and as a wastewater. This paragraph does in accordance with section 7.1 of Test apply to water which is used to displace Method 106. or vinyl chloride from equipment before it (B) A calibration gas cylinder stand is opened to the atmosphere in accord ard containing the appropriate concen ance with 1 61.64(a) (2) or paragraph tration of vinyl chloride. The gas com (b> (6> of this section, but does not apply position of the calibration gas cylinder to water which is used to wash out equip standard is to have been certified by the ment after the equipment has already manufacturer. The manufacturer must been opened to the atmosphere in ac have recommended a maximum shelf life cordance with 161.64(a)(2) or para for each cylinder so that the concentra graph (b> (6) of this section. tion does not change greater than p:5 i ii' Any vinyl chloride removed from percent from the certified value. The date tiie inprocess wastewater in accordance of gas cylinder preparation, certified with paragraph (b> (9) (i) of this section vinyl chloride concentration and recom is to be ducted through a control system mended maximum shelf life must have from which the concentration of vinyl been affixed to the cylinder before ship chloride in the exhaust gases does not ment from the manufacturer to the exceed 10 ppm. or equivalent as provided buyer. If a gas chromatograph is used a3 in 5 61.66. the vinyl chloride monitoring system, these gas mixtures may be directly used to prepare a chromatograph calibration curve as described in section 7.3 of Test Method 106. The requirements in sec (c> The requirements in paragraphs <b>(1>, (b)(2), (b)(5). (b)(6), (b)(7) and (b> (8) of this section are to be in corporated into a standard operating procedure, anr made available upon re quest for inspection by the Administra tion 5.2.3.1 and 5.2.3.2 of Test Method tor. The standard operating procedure is 106 for certification of cylinder stand to include provisions for measuring the ards and for establishment and verifica vinyl chloride in equipment --4.75 m* tion of calibration standards are to be 1.250 gal In volume for which an emis followed. (41 I R 29005, June 7. 1977| sion limit is prescribed in 61.85(b) (6) (!) prior to opening the equipment and using Test Method 106. a portable hydro (iv i The location and number of points (o be monitored and the frequency of monitoring provided for in the program are acceptable when they are compared with the number of pieces of equipment in vinyl chloride service and the size and physical layout of the plant. >vi It contains an acceptable plan of action to be taken when a leak is de tected carbon detector, or an equivalent or al ternative method. The prethod of meas urement is to meet the requirements in 5 61 67(g> (5> ti) (A) or (g) ((5) (i) (B). 141 FR 53017, December 3. 1976) 61.Equivalent equipment and pro- miurn, Upon written application from an own er or operator, the Administrator may 3.24.;a I'uMislic.i [Sac. 61.661 I 111 III Rl Ai OI NAIIONU. AI I AIKS. INC. VV A.SI II NC.roN. DC. 20037 33 I)YH 000120221 HAZARDOUS EMISSIONS S-391 121:0477 j i The reactor opening loss for which iin emission limit is prescribed m 4 61.64 ia'< 21 is to be determined. The number of reactors for which the determination is to be made is to be specified by the Administrator lor each individual 'plant at the time of the determination uased on the plants operation. For a reactor that is also user! iw a stripper, the deter mination may be made immediately fol lowing the stripping operation. <i) Except as provided in paragraph ib>i5mu) of this section, the reactor cpenir.g loss is to be determined using the folic.ving equation: IT (2.G01 (10-) (('!>) 17 f - Wi viuvl ciU,nsl* ^mvsjtionr.'k^ ptotluv i. M'--- h y il i Ji* r<*>-ior in in1. I #. nH y of vi MV l I'hlQl 111'- at iinr ill liu '| >11- ; ! it i< | .'i f * hi hg'nt1. ;* * ( ..iiv<tsimi fiH'iur Tiit |if1111. < '* n>t ,i i*y vMum*' vms i tihlm uU* ;i* il> "uiii"l *\* T.-'t Mni* ii infl or .i |>ont>k' Imlnc.jIkiii <h-i r whit'll mi'iiHi rv* J>\ <i roc.i rl'on*. null a '.oiiMtiviry of nr l*usi lJ ppm. ) Niiuii- f >f l:.ih In's 'mre lhe ivu-ioi w .is I.-ai ( p-rt< 'I i n t V i nmsphi-ri'. / !*:: ki! >l J'olvsmyl c ll>1 lli* p....hiri`<l pr; i ;iii'h in *!:. vimti l'*r of but r lire sine- in*'* or u lufft wpMKM U tlU* dlQlOSpIlCie. A' II Method 106 is used to deter mine il'.e concentration of vinyl chloride <C:h. the sample is to be withdrawn at a con: taut rate with a probe of sufficient length lo reach the vessel bottom from the manhole. Samples are to be taken for 5 minutes within 6 inches of the ves sel bottom. 5 minutes near the vessel center, and 5 minutes near the vessel top. iEi If a portable hydrocarbon detec tor is used to determine the concentra tion of vinyl chloride (Cb). a probe of sufficient length to reach the vessel bot tom noin the manhole is to be used to make the measurements. One measure ment will be mace within 6 inches of the vessel bottom, one near the vessel center and one near the vessel top. Measure ments are to be made at each location until the reading is stabilized. All hydro carbons measured are to be assumed to be vinyl chloride. iCi The production rate of polyvinyl chloride iZ) is to be determined by a method submitted to and approved by the Administrator. i ii i A calculation based on the number of evacuations, the vacuum involved, and the volume of gas in the reactor is hereby approved by the Administrator as an al ternative method for determining reac tor opening loss for postpolymenzation reactors in the manufacture of bulk resins. iil.ftH f'mi.i'nn mutliIlM'illg. ' a i A '. myl chloride monitoring .-.vs- ti'in is lo he used to monitor on a enn- jTfntm.1. HIM1, IIP.' etm.g.ticn.1! fnlinTile sources for which emission limits are pre- .cribeu in iji.ijjr.ii .iiifj'iTi. TP 1 (13 a>. .nut I 0-1 C4> a i 111. < b>. ic>. and and for any control system to which reactor c.'..i>sit-ns i re rcqui.wil lo he dueled in 12) or lo which fugitive einivuonv .ire wqsi.ee to ce dueled .a ehi.o.i (M lii tin. -mu mi i2). ibj (5). tb) (6) id), ami (bl v9l tui. [4 1 FR 5 301 7, December 3. 1976| b 1 Tito vinyl chloride monitoring sys tem vs used to meet the requirement in paragraph iat of this section is to be a device which obtains air sampels from one or more points on a continuous sequential basis and analyzes the samples w ::h t as Cuemotograohy or. if the owner or operator assumes that all hydrocar bons mcn-ured are vinyl chloride, with ir.fr:.re : spectrophotometry, flame ion detection, or an equivalent or alterna tive method. The vinyl chloride monitor ing system used to meet the requirements ;n 5 61 65(b) <8> <i) may be used to meet the requirements of this section. ei A daily span check Is to be con ducted lor each vinvle chloride monitor ing system used. For all of the emission sources listed in paragraph tai of this section except tr.o cne for which an emis sion limit is prescribed in 61.62<b>, the daily span checlt is to be conducted with a concentration of vinyl chloride equal to 10 ppm. For the emission source for which an em.ssion limit is prescribed m 01.62 'ui. the daily span check is tosbe cjnuticted with a concentration of vinyl chloride which is determined to be equivalent to die emission limit for that fqurce based on die emission test required by >61.6". The calibration is to be done with either: [41 FR 55017, December 3. 19761 (1> A calibration gas mixture pre pared from the gases specified in sections 5.2.1 and 5.2.2 of Test Method 106 and in accordance with section 7.1 of Test Method 106, or |42 FR 29005. June 7. 19771 '2> A calibration, gas cylinder stand ard containing the appropriate concen tration of vinyl chloride. The gas com position of the calibration gas cylinder standard is to have been certified by the manufacturer. The manufacturer must have recommended a maximum sheif life for each cylinder so that the concen tration does r.ot change greater than --5 percent from the certified value. The date of gas cylinder preparation, certified vinyl chloride concentration and recom mended maximum shell' life must have been arfixed to the cylinder before ship ment from .the manufacturer to the buyer. If a gas chromatograph is used as the vir.yl chloride monitoring system, these gas mixtures may be directly used to prepare a chromatograph calibration curve as described in section 7.3 of Test Method 106. The requirements In sec tions 5.2.3.1 amt 5 2.3.2 of Test Method 106 for certification of cylinder stand ards and for establishment nr.d verifica tion of calibration' standards are to be followed. , 42 Fii 25005. June 7. 19771 A 1.1.0 1 .ti. Ail report. a' A.i owner or operator of any .-ou. ee to winch this subpart applies shall submit a statement in writing notifying tlie Administrator that the equipment, and procedural .specifications in 55 61.65 'bi'il. ib)(2), (b)(3i, (bi(4>, tb)*5). 'bi'di, (bi(7), and ib)(8> are being implemented. ib)(l) In the case of an existing source or a new source which has an initial startup date preceding the effec tive date, the statement is to be submit ted within 90 days of the effective date, unless a waiver of compliance is granted under 5 61.11, along with the informa tion required under 61.10. If a waiver of compliance is granted, the statement is to be submitted on a date scheduled by the Administrator. (2) In the case of a new source which did not have an initial startup date pre ceding the effective date, the statement is to be submitted within 90 days of Ihu initial startup date. <c> The statement is to contain the following information: d) A list of the equipment installed for compliance. 12 ` A description of the physical and functional characteristics of each piece of equipment. (3i A description of the methods which have been incorporated into the standard operating procedures for meas uring or calculating the emissions for which emission limits are prescribed in 55 61.65 (b) (li (i) and (b) (6> <i), (4) A statement that each piece of equipment is installed and that each piece of equipment and each procedure is being used. 01.70 Srniicnnuel i* 3 (a) The owner or operator of any source to which this subpart applies shall submit to the Administrator on Septem ber 15 and March 15 of each year a report In writing containing the information required by this section. The first semi annual report is to be submitted follow ing the first full 6 month reporting period after the initial report is submitted. (41 FR 53017. December 3. 1975) (b)(1) In the case of an existing source or a new source which has an initial startup date preceding the effective date, the first report is to be submitted within 180 days of the effective date, unless a waiver of compliance is granted under 3 61.IE If a waiver of compliance is granted, the first report is to be sub mitted on a date scheduled by the Ad ministrator. (2) In the case of a new source which did not have an initial startup date pre ceding the effective date, the first report is to be submitted within. 180 days of the initial startup date. (c) Unless otherwise specified, the owner or operator shall use the Test Methods in Appendix 3 to this part to conduct emission tests ns required by paragraphs (c)(2) and (c)(3) of this section, unless an equivalent or an alter native method has. been approved by the Administrator. If the Administrator finds reasonable grounds to dispute the 3-2T/S I'.iidivlu la i ill lit Kl it 0 \ \ . R.S \t ill MRS :\C . W \Mi; .i.l [Sec. 01.70(c)! DC 200'' DTH 000120222 SECTION II NATIONAL EMISSION STANDARD FOR VINYL CHLORIDE DTH 000120223  ' 3 1 p-'; i Ct LEAK DETECTION AND ELIMINATION The CONOCO VCM Plant Leak Detection and Elimination Plan is designed to provide a formalized procedure for controlling leaks from equipment in vinyl chloride service. The plan is organized following the requirements of the leak detection and elimination section of the national emission standard for vinyl chloride. This plan will be reviewed semi-annually to determine if the plan meets the original purpose. Continuous Monitoring System A. Purpose A continuous monitoring system provides a permanent, dependable means to monitor the vinyl chloride concentration at representative points throughou the plant under all wind conditions and directions. B. Description Three multipoint area monitors, Honeywell Model 1000 gas chromatographs (CAR) will be used for detection of major leaks and identification of the general area of the plant where a leak is located. The monitors will sample the air at each sample point on a continuous sequential basis, with each point being sampled once every 10 minutes. These chromatographs are CAR-171 for the plant process area, CAR-401 for the offsites area, and CAR-678 for the dock area. The CAR's are presently being utilized for the VCM monitoring plan and have proven to be reliable area monitors. Honeywell has stated that their accuracy is + 5:;> at VCM concentrations over 1.0 ppm. The output from each of the monitoring points of CAR-171 and CAR-401 is printed on a recording chart. The number corresponding to each sampling location is indicated as well as the vinyl chloride concentration in ppm. An analog output from CAR-171 and CAR-401 is also transmitted to a PerkinElmer Computer located in the main control room. The computer is programed to average the individual analyses for each monitor point and print the hourly ("eraces for each point at the end of a 24 hour period. Current averages for any point can also be obtained at any rime by operator command. Since CAR-673 is used only during ship or barge loading and is located at the dock, it is not tied into the computer system. C. Location and Number of Monitor Points The vinyl chloride monitors will utilize the ten monitoring points located in the plant process, offsites and dock areas as shown in Figures 1,2, and 3, respectively. j Each point is monitored once every ten minutes. However, CAR-678 located at the dock is only operated during ship loading since the dock is staffed and all equipment in vinyl chloride service is in operation only during ship leading. DTH 000120224 D. Calibration and Maintenance The vinyl chloride monitoring system will be maintained, calibrated, and span checked on a weekly schedule. CAR-171 and 401 will have an elution check three times a week to ensure that they are reading the correct chromatograph peaks. CAR-678 will have an elution check before each ship loading. In using the CAR's for OSHA monitoring, it has been the plant's experience that the span changes very little with time and that a weekly span check is sufficient to ensure reliable and accurate readings. E. Defini tion of a Leak . A leak shall be defined as any hourly average concentration of VCM over 15 ppm in the process and offsites areas and six consecutive readings of over 5 ppm in the dock area. An audio and a visual alarm will be given whenever a leak occurs in the process and offsites areas. An audio and visual alarm will be given with each analysis of 5 ppm or greater in the dock area. Weekly Leak Patrol A. Purpose The weekly leak patrol will be used as a check on the plant continuous monitoring system. This leak patrol will determine if any area in the plant is not adequately covered by the monitoring system and will also indicate any unnoticed monitoring equipment failure. B. Description A Bacharach Instrument "TLV Sniffer" will be used to detect leaks on a weekly leak patrol. This weekly patrol will follow the route shown in Figures 4 and 5. This portable analyzer will also be used to pinpoint major leaks indicated by the viny. chloride monitoring system. A log book will be user to record the date, start1, nc time, and end. u of eacn patrol. Persons conducting the patrol will sign each log entry, record each leak found, and record the action taken. C. Calibration and Maintenance The portable detector will be maintained, calibrated, and span-checked on a weekly schedule. D. Definition of a Leak A leak shall be defined as a background concentration of VCM over 15 ppm in the process and offsites areas. Ar. audio alarm is given by the "TLV Sniffer whenever a concentration of combustible gases exceeding 15 ppm is detected. DTH 000120225 The operators involved in the leak patrol must then determine the origin of the high concentration of gases. The Action Flan should then be implemented even if the gases are not from a vessel in vinyl service. The type of gas escaping should be noted on the Leak Detection Form. Action Plan The action plan upon detection of a leak will be as follows: 1) The person finding the leak will attempt to control the leak. 2) If that person is unable to control the leak, the Operations Shift Supervisor will be notified. The Shift Supervisor will take one of the following actions. a) Repair the leak, or b) Notify the Maintenance Department to take corrective action to control the leak. 3) The Leak Detection Form (Figure 6) will be initiated by the person finding the leak and given to the Operations Shift Supervisor. If the person finding the leak cannot correct the leak, the Shift Supervisor will either take action to correct the leak or notify the Maintenance Department to correct the leak. The Shift Supervisor will then record the action taken to control the leak. 000120226 DTH rv O ^ J ii "'i il ii r\ \L (- ,, ; ; .* -.! fj -i 13, k i i J \ *- n /; * CAR-6 78 MONITORINGifelH'"T5'' ": DOCK ARlA uir-.ijQF R A/'/ov.a t-0f:O CARBON BED L. A-C/d [ f--. 5i;:xCj^'~i'l-; n V // A L.C i`0 />/ T /.';?, i O/J u-vr !M SERVlG /-1 "*T J 2`V-Y- II 0229 I)'XH 0()0^ 1 ( WEEKLY LEAK PATROL ROUTE S7 >! t r 5 `U> l- i 'vi 1 FIGURE 6 CONOCO VCM PLANT LEAK DETECTION FORM Name of person finding the leak: Date: T ime: I. To be completed by person finding the leak. 1) Location of Leak: 2) Cause of Leak: 3) Action Taken to Eliminate Leak: 1) Action Taken? 2) Leak Controlled? 3) Leak Not Controlled? 4) Other II. To be completed by Shift Supervisor if leak has not been controlled. 1) Action taken to control leak. a) Maintenance Department notified to correct leak? b) Other? flame of Shift Supervisor: Nhat time 'was the leak reported to the Shift Supervisor? NOTE: Give this form to J. W. Ware, who in turn, will give it to Engineering for inclusion in our environmental file. DTH 000120232 SECTION II VCM NON-COMPLIANCE REPORTING PROCEDURES DTH 000120233 EPA VCM COMPLIANCE RECORDS The EPA Standards for vinyl chloride emissions require that all vents from equipment in vinyl chloride service, except oxychlorination, contain less than 10 ppm VCM. The vent from the oxychlorination unit must contain less than 0.2 grams of VCM per kilogram of EDC produced. In addition to reducing the VCM emissions to these levels, the EPA Standards also require that the plant continuously monitor the vents and maintain records providing proof of com pliance. In the case of the incinerator and oxychlorination vents, the standards require the plant to keep records of the average emissions for each hour. In order to help reduce the labor required to maintain these records, the Inter data computer in the main control room has been programmed to collect the data and calculate and print out the hourly average emissions. The procedures listed below have been formulated to assure that the emissions data compiled by the computer are properly forwarded to the EPA file maintained by the Process Enoineering Department. Included also are procedures to assure that the neces sary data are collected when the computer is down or when there is a noncompliance. During normal operation, collection of the computer summary table and used chromatograph charts is all that is required. If there is a non-compliance (i.e., the oxy vent hourly average exceeds 0.2 grams VCM/kilogram EDC produced, the hourly average for the incinerator's stack gas exceeds 10 ppm VCM, or the incinerator or steam stripper are by-passed), a report of EPA VCM vent noncompliance must be completed and forwarded to the Process Superintendent who will forward it to the front office Secretary for filing. A. Normal Computer Operation The computer has been programmed to collect and calculate the hourly average VCM emissions from the incinerators and the oxychlorination unit. The computer also compiles and averages the fixed point monitor data for each hour. These averages are printed out at the end of each hour. At midnight the computer prints out a summary table of all the hourly average emissions for that day. When the computer is operating normally, the Operators need only perform the tasks listed below. 1. Detach the summary table of the hourly average emissions from the computer printout at the end of each day. The summary table should be forwarded to the Process Superintendent who will in turn forward to the front office Secretary for filing.2 2. Collect the used charts from CAR-171, CAR-401, CAR-305, and AR-904 and forward them to the Process Superintendont who will in turn forward to the Chief Chemist for filing. Be sure that the beginning and ending date and time are marked on the charts. DTH 000120234 Page 2 B. Computer Failure In the event of a computer problem or failure, the first action step is to consult the computer guide book and attempt to bring the computer back on line. If the first few attempts to bring it on line are unsuccessful and it appears that the computer will be down for an hour or longer, then procede as follows: 1. Complete a "Report of Computer Failure" sheet (see attachment) and complete the compliance checklist which includes: a) Mark the date and time of the computer shutdown/startup on the fixed point monitors CAR-171 and CAR-401. b) Mark the date and time of the computer shutdown/startup on the oxy vent analyzer CAR-305. c) Call the incinerator control room and inform the Operator to mark the date and time of the computer shutdown/startup on the incinerator analyzer AR-904 d) Attach the computer printout of any hourly averages of the day recorded prior to the shutdown to the computer failure report. e) Manually record the fixed point monitor data during the computer shutdown and attach the log sheet to the computer failure report (see attachment). 2. At the end of the day, attach the summary table of any of the hourly average emissions which might have been recorded to the computer failure report and forward the materials to the Process Superintendent who will in turn forward to the front office Secretary for filing. 3. In the event that the computer remains down for longer than a day or through midnight, then complete a computer failure report for each day and continue manually recording the fixed point monitor data until the computer is back on line. Either a total summary table or a completed computer failure report with appropriate attachments must be forwarded to the front office for filing each day. During prolonged computer shutdowns, the later computer failure reports may simply state that the computer is still down and the fixed point monitor log is attached. Mote: If a tota 1 summary table is not printed out at the end of the day, even though no ccmouter problems were indicated during the day, complete a computer failure resort making note of the fact and attach the entire computer printout for the day to the report. Also, mark the date and time on any analyzer charts affected. DTH 000120235 Page 3 C. Relief Valve Discharge A "Report of Relief Valve Discharge in VCM Service" (see attachment) must be completed anytime that a relief valve or rupture disk in vinyl service discharges to the atmosphere. According to the EPA VCM Emission Standards, "In Vinyl Service" means any vent that comes into contact with a vapor stream containing 10 mole % VCM or a liquid stream contaning 10 wt. % VCM. If you are not sure whether a certain relief valve is in vinyl service or not, fill out the report anyway. Any reports of relief valve discharges in VCM service should be forwarded to the Process Superintendent. The EPA Standard requires that all relief valve discharges to the atmosphere be reported within 10 days. Therefore, the VCM Plant Shift Supervisor should be notified by phone immediately. D. Steam Stripper By-Pass/Shutdown A "Report of Steam Stripper By-pass/Shutdown" (see attachment) must be completed anytime the wash water by-passes the steam stripper or the stripper is taken out of service. The water by-passing the stripper must be sampled every two hours using the following procedure. a) Fill a four ounce sample bottle completely full. b) Indicate on the tag the following information: Steam Stripper Non-Compliance Sample Date: Time: VCM: The Laboratory should refrigerate the samples and analyze for VCM. Any reports of steam stripper by-pass/shutdown should be forwarded to the Process Superintendent who will forward to Process Engineering for filing. E. VCM Loading Dock Proper recordkeeping at the VCM loading dock under normal conditions requires only that the used charts from the dock analyzer and the log sheets be forwarded to the appropriate Refinery personnel. Dock personnel should also be supplied with the forms and instructions to report a relief valve discharge in vinyl service. 1 000120236 T)TH Date: _______ S/S Signature: REPORT OF COMPUTER FAILURE (See Note 1) 1. Time of Fai1ure: 2. Time of Startup: ___________ 3. Reason for Computer Failure:4 * * * * 4. Compliance Checklist: a) Mark the date and time of the computer shutdown/startup on the fixed point monitors CAR-171 and CAR-401. b) Mark the date and time of the computer shutdown/startup on the oxy vent analyzer CAR-305. c) Call the incinerator control room and inform the Operator to mark the date and time of the computer shutdown/startup on the incinerator analyzer AR-904. d) Attach to this report the computer printout of any hourly averages of the day recorded prior to the shutdown. e) Manually record the fixed point monitor data during the computer shut down and attach the log sheet to this report. Motes: 1) This report must be completed anytime that the Interdata computer shuts down for longer than an hour. 2) Describe any circumstances that may be relevant to the computer failure. DTH 000120237 Date: S/S Signature: REPORT OF VCM RELIEF VALVE DISCHARGE 1. Date of Relief: __________________________________ 2. Time of Relief: __________________________________ 3. Source of Relief (i.e.; Equipment No. & RV No.): 4. Duration of Relief (Estimate as Accurately as possible): 5. Reason for Relief Valve Discharge: 6. Corrective Action Taken: 7. Direction of Wind: 8. Was Anyone Exposed? If so, who?9 9. Witnesses: Notes: 1) This report must be completed anytime that a relief valve or rupture disk in vinyl service discharges to the atmosphere. Also, the report must be completed if a valve in vinyl service is manually vented for any reason. i 2) Record and describe any conditions or circumstances related to the discharge including suen items as temperature and pressure readings before or after. 000120238 DATE: S/S SIGNATURE: REPORT OF STEAM STRIPPER BY-PASS/SHUTDOWN (See Note 1) I. Reason for By-Pass or Shutdown: 2. Tine of By-pass/Shutdown: _______________________ 3. Time of End of By-pass/Startup: _________________ 4. Analytical Results of Samples Taken (See Note 2) Date: ppm VCM ppm VCM ppm VCM ppm VCM ppm VCM ppm VCM ppm VCM 0600 0700 0300 0900 1000 1100 1200 1300 1400 1500 1600 1700 1800 1900 2000 2100 2200 2300 2400 0100 0200 0300 0400 0500 Notes: 1. This report must be completed anytime the wash water by-passes the steam stripper (i.e.; by-pass T-110, overflow of T-110, etc.) or the stripper is taken out of service while the wash system is in service.2 * * * * 2. The water by-passing the stripper must be sampled every two hours using the following procedure: t a) Fill a four ounce sample bottle completely full. Note: V.'hen the can is put on, there must not be any vapor space in the bottle. b) Indicate on the tag the following info: Stou;a Stripper Non-Comnl i a rice Sample Date: Time: VC": DTH OOOl^O9^^ The La bora to j 1 d re:ri: ?rato the r ales and analyze for VC'*. EOJ vt W> _* owc oc c `o CL -oa x i cCO a. E CoJ a ~c rco cs: '5fs0 CJ> O ffs ite s -- C ar 401 U n it S tatus LJO Cl 00 to tn rr CO CM o o> CO r-* to in ro CN - P ro ce ssin g A re a -- C a r 1 7 1 T im e 0100 0200 0300 0400 0700 0000 0900 1000 1 100 1200 2000 2100 2200 2300 10090 O O 'J O j I | | i 1 Ii i! o; coj oi 5! S Cl cl o u->! tci Is- Ol o o> o - C5 o C<Ts\1 DTH 000120240 EPA VCM NON-COMPLIANCE FORMS The following form and instructions have been included in this write-up as a means to report the times that the vents are in non-compliance. These noncompliance reports are extremely important since the plant will have to account for any non-compliance in our semi-annual reports to the EPA. More importantly, the information included in the reports may provide insight into problem areas which can be improved to reduce the incidence of non-compliance in the future. The VCM Plant is technically in non-compliance and violates the emission standards anytime an hourly average emission from either the incinerator or carbon beds exceeds 10 ppm VCM, or an hourly average emission from the oxy unit exceeds 0.2 grams of VCM per kilogram of EDC produced. A "Report of EPA VCM Non-Compliance" (see attachment) must be completed anytime that the computer or GC charts indicate that the plant is exceeding the emission limits. Special care should be taken to relate and describe the reasons for the violation and corrective action taken since these facts must be included in the semi-annual report. Any completed reports of EPA VCM non-compliance should be forwarded to Process Engineering for filing. DTH 000120241 DATE: S/S SIGNATURE: REPORT OF EPA VCM VENT NON-COMPLIANCE (See Note 1) 1) Area of Violation: 2) Time of Violation: _______________ 3) Duration of Non-Compliance: _____ 4) Reason for Violation (See Mote 2): 5) Corrective Action Taken:_ Notes: 1) This report must be completed anytime that an hourly average emission from the incinerator or carbon beds exceeds 10 ppm VCM or the emission from the oxy unit exceeds 0.2 grams VCM per kilogram of EDC produced or a vent by-passes the incinerator. 2) Explain any circumstances which relate to the incident of non-compliance (i.e.; the incinerator was down so many hours because....) DTH 000120242 SECTION II STANDARD OPERATING PROCEDURES FOR OPENING EQUIPMENT IN VINYL SERVICE TO THE ATMOSPHERE DTH 000120243 TABLE OF CONTENTS Introduction A. EDC Purge Procedure for Vinyl Unit B. C-201, Quench Column C. C-202, HCl Column D. C-203, Vinyl Chloride Column E. F-401 and F-402, Vinyl Product Filters F. F-625, Vinyl Loading Filter G. H-202 A & B, Quench Column Condenser H. H-203, Quench Reflux Cooler I. H-206 A & B, Vinyl Column Reboiler J. H-207 A & B, Vinyl Column Condenser K. H-211, HC1 Interchanger L. H-213, Quench Column Interchanger M. Refrigerated Vent Recovery System (H-490, H-495, T-491, and H-494) N. H-435, Vinyl Vent Recovery Condenser, H-486, Bron Fintube Rail Car Vent Condenser, and H-491, Refrigerated Vent Condenser O. R-201 A & B, EDC Reactor Heater Cracker P. S-108, Caustic Blowdown Drum Q. S-206, Decanter R. S-216, RV-210 and 211 K.O. Drum S. S-207 A & B, Caustic Dryer T. S-401, VCM Caustic Dryer U. S-490, Tank Car Vent K.O. Pot V. S-625, Dock Vinyl K.O. Pot W. S-626, Suction K.O. Pot X. T-202, HC1 Column Bottom Drum Y. T-401 A, B, & C; Vinyl Check Tanks and T-411 A, B, C, & D; Vinyl Storage Tanks Z. T-490, Vinyl Vent Recovery Storage Tank AA. T-626, Dock Vent Receiver Tank and H-625, Dock Vinyl Vent Recovery Condenser I)TH 000120244 APPENDIX SECTION XI Standard Operating Procedures for Opening Equipment to Atmosphere 'The attached operating procedures have been developed in compliance with Section 61.65 (c) of the National Standard for Vinyl Chloride Emissions. These procedures have been established and are used by the Conoco VCM Plant to assure that the vinyl content is reduced to less than 2% before opening any equipment to the atmosphere. In almost all cases however, the attached procedures actually provide for a reduction in vinyl content to less than 25 ppm before opening equipment. Procedure A presents the details for shutting down the entire vinyl train in preparation for an extensive plant turnaround. The shutdown for turnaround in volves an EDC purge of the system to flush out the vinyl chloride. The procedures which follow present details for shutting down and opening individual items during a non-turnaround situation. All items in vinyl service which can be opened indi vidually without a major shutdown have been included. These procedures will be extended to include the expanded Plant. DTH 000120245 U \'i4-- PREPARATION FOR OPENING EQUIPMENT IN VINYL SERVICE A. EDC Purge Procedure for Vinyl Unit (Refer to Figure I) 1. Switch VCM rundown tank and reduce furnaces to 4.0 units of vapor feed. 2. Block in HCL valve to MeCl unit. 3. Kill all furnace fires. 4. Hold vapor feed to furnacesoat 3.0 units and cool down until the outlet temperature reaches 190-200 C. 5. Block in all quench; natural and emergency. 6. Keep Oxy on line as long as possible by lowering C-202 pressure. Shut down Oxy when HC1 production required. Do not vent from PRC-216-A. 7. Block in the two drain valves at the bottom of the HCL K.0. pot as EDC will accumulate while EDC flushing. Close 1" equalizing valve at K. 0. pot. Block in HCL to Oxy at PRC-216-B. (After H-309) 8. Switch VC Tar Still make to T-102. 9. Isolate C-202 from T-204 by blocking in the isolation valves next to column to prevent EDC entering the HCL lines. See attached drawing. 10. Put C-203 bottoms to dry crude. 11. Block in the vapor feed valve to C-202, but continue liquid feed for VCM flushing, lower front end pressure to 10 to 20 PSIG via 2" vent at H-211. (Caution: DEPRESSURING IS LIMITED BY WHAT INCINERATOR CAN TAKE) 12. It may become necessary at this point to add three to four fires on each side of each furnace to maintain 190C on the furnace outlets. 13. Start N2 purge to the top of the quench accumulator to sweep out HCL and vCM vapors and to maintain suction head pressure for the P-202 pumps. 14. Start N2 purge to LRC-201 bleed valve. Block in the upstream block valve to LRC-201 and have board operator open valve wide open. This will flush HCL and VCM out of C-201 as well as S-202 and H-211. .15. While maintaining approximately 3.5 to 4.5 units of steam flow to the HCL column reboiler, take off refrigeration to H-204. Start depressuring C-202 to 5 PSIG slowly via the new depressuring line after H-309 to the dry vent. (CAUTION: DEPRESSURING IS LIMITED TO WHAT INCINERATOR CAN TAKE) DTU 000120246 W \w ; ! :i - 16. Start hot- gassing BL-501. 17. As VCM production falls off, reduce C-203 pressure to CO psig with tray 5 temp, at 70C. When EDO shows on local G.C., reduce steam to the re-boiler slightly and pump 5-EOS contents pump looses suction. VCM check tank until reflux 13. Block in VCM to S-206 and iU pressure VCM out of product Tine to S-206. 19. Start venting K-207 ASB to dry vent header. Watch white elephant level closely to prevent overfilling. 20. Maintain steam flew to C-203 reboilcr at approximately 2.5 to 3 units to hold 130 to 140C on tray 5. 21. Pump accumulated EDC in S-205 to Dry Crude until Reflux Pump loses suction. Put some of this material to the column as reflux to flush that line. Do not try to hold reflux on the column. 22. Start sampling for VCM-content at the following points. a) C-201 overhead at M-211 (Vapor Sample) b) C-202 overhead at PRC-216A (Vapor Sample) c) C-203 overhead at sample line to on-stream G.C. [Vapor Sample) Sample at one of the three following points each hour for VCM content: 1) C-201 Reflux' 2) C-202 Bottoms 3) C-203 Reflux 23. Continue flushing operation for six to eight hours or until VCM content is less than 25 ppm, then empty all equipment and nitrogen purge. Pressure EDC out of all connected lines while emptying. DOTES:1 2 3 1) Watch levels closely in white elephant and Haveg Drum. Pump to slops. 2) It will be necessary to have N2 hoses secured to'the following equipment prior to stopping the EDC Flushing Procedure to prevent vent header gases backing into equipment as it cools and to prevent a vacuum being pulled on columns and vessels. a) H-201 ASB b) R-201 ASB c) C-201 d) S-202 e) C-202 f) T-202 g) C-202 3) Be sure that overflew line on Haveg Drum is open from side and not bottom. 24. When EDC purge procedure is complete, cleat the attached procedure. CL \.Q. Pot of ECC using DTH 000120247 ......\ t A\ fV '. ^ = : V4 I S \ "l -1 \U a) H-201 A & B b) R-201 A & B c) C-201 d) S-202 e) C-202 f) T-202 g) C-203 4) Be sure that a drain is set up on T-501 during EDC purge. 24. When EDC purge procedure is complete clear HCL K. 0. Pot of EDC using the attached procedure. DTH 000120248 U >\ \I'i1 'Cs! A o a! v- a-.1 -Z b C^l UJ i/> o; UI CL _J P -30/ A J o3 VINYL TRAIN DTH 000120249 m vvv* \\j5j j ,X , 'V V\ V* B. C-201, Quench Column 1) Prior to shutdown get a minimum level in S-202. 2) When the feed from the furnaces has been shut off, pump the contents of the quench accumulator to the HC1 column. 3) Block in the vapor equalizing line between the quench accumulator and the HC1 column. Block in furnace vapor lines and vaporizer drawoff lines. 4) Line up the quench accumulator to T-102. 5) Pump any additional EDC from the quench accumulator to T-102. Purge the liquid feed line to HC1 column into C-202. Purge the liquid reflux line empty. 6) Operate the tar stills at full rate with the product lined up to T-102 (the pH on T-102 will have to be watched closely to prevent its going acidic). 7) When feed to tar stills stops, drain heel from bottom of the quench column to the quench column blowdown drum. Make sure the vent valve on the quench column blowdown drum is open to the wet vent header. Note: N^ purge blowdown drum before using. 8) Begin venting the quench accumulator via H-211. 9) Complete depressuring the quench column to C-500. 10) Nitrogen flush the quench column from the tar still reflux line to C-500 through H-211 vent and P-202 suction line. Close H-211 vent when through N2 purging. 11) Pump out both tar stills to tars tank. 12) Empty the liquid leg between H-202s and S-202 to grade. 13) Drain and depressure the P-201 and P-202A & B pumps andpiping. 14) After it is determined that there are no liquid levels in C-201, S-202, and the transfer line between H-202 and S-202, start nitrogen into the Tar Still make line. Sample at H-211 just above the vent valve for vinyl, EDC, and HC1. Vinyl content must be reduced to less than 25 ppm before opening. 15) Turn over to maintenance for blinding. DTH 000120250 C. C-202, HC1 Column (Refer to Figure II) 1) After EDC purge is complete. 2) Shut steam to H-205, be sure to hold 5 to 10# on C-202 with N2, 3) Block in equalizing line between C-202 and T-202 with vent open on T-202, put as much EDC rundown from trays as possible into T-202, then pump T-202 to C-203. 4) Isolate C-202 from T-202 complete with vent on T-202 closed. 5) Dump H-205 to blowdown drain or sewer, when complete depressure C-202. 6) Ng purge column from sight glass to S/S header and drain line until Maintenance ready to blind. 7) Empty S-214 and other low points of EDC while purging C-202. Use S/D procedures to empty. DTH 000120251 - -** ' .i. \ . \ ' e H FIGURE II C-202, HC1 Column (C-202 ISOLATION FROM T-204) DT.H 000120252 r\ WP.t i >\,\ kjKJ j ;1 .) _ i ';ji 3 t ji D. C-203, Vinyl Chloride Column (Refer to Figure III) 1) After EDC purge is complete and steam is off H-206;s, start a N? flow from the bleed at FRC-205. Flow through interchanger long^ enough to clear it of most of the liquid. Block in interchanger, (feed side) open bypass and continue purge. 2) Start a purge from the bleed on FRC-206 (reflux) and clear reflux line of liquid back to column. Build 50-60 psig in column. 3) Clear the column of all EDC. Blow through the interchanger and H-209 and out the loop at P-112, until all the liquid is clear at P-112. Block in interchanger. 4) Open drains on H-206's and drain EDC to vinyl column blowdown drum. Drain P-204 cases. Purge (press and depress) through H-207's, $-205 and out at P-204 cases to vent. 5) Sample at P-204 case, bleeds for vinyl concentration. DTH 000120253 on SS )\J i 3 v^ i V~ 0, \ 4 * I i <1 i< \i- FIGURE III C-203, VINYL CHLORIDE COLUMN T.? f / 6/ a/ ,-2- J," c1 V- C'JC T.\Cq*/ r c :-.> A'- 'J rC c~ -rfit -- o /2'/A/1-?-f ^hok:. >,-' _1 jr,i' Cf-T'- :><..('i r-^y-- r-3 V'ZfU 7~ DTH 000120254 X" t-. E. F-401 and F-402, Vinyl Product Filters This procedure involves clearing the VCM filter vessels by repeating a nitrogen pressurization/ejector evacuation cycle. The new lines facilitate circulating the nitrogen through the filter. The procedure is as follows: The letters in parentheses refer to specified valves on Figures IV and V. 1) Close all valves (A) through (S)-. 2) Connect two flexible hoses to connections on nitrogen lines and close bleed valves. These hoses eliminate the possibility of VCM bach flowing into the nitrogen header when the filter is on stream. 3) Open (A), (B), (C), and (D) to pressure vessel. h) Alternating, crack open/close (li) to pressure liquid vinyl out of the filter vessel. . 5) Close (li); open (It), O'), (N)> and (P) to ready E-l/2 for purging. ' 6) Open (J), close (I), and pressure vessel' until the pressure gauge registers a constant pressure. Note: Opening either pressure gauge valve (I) or (J) allows recording the filter pressure on the inlet or discharge side, respectively.7 8 9 10 11 7) Open (E) to start: steam flow to H-401/402. Valve (E) is a glove valve and should be used to control the steam rate to H-401/402. TG-1/2 registers the exiting nitrogen temperature which should be maintained between 45 to G0C. 8) Close (D), open (L) to begin evacuation. 9) Close (J), open (I), and evacuate the vessel until the pressure gauge registers a constant pressure. 10) Close (L), open (D) to reprossuro the vessel. 11) Repeat steps 0, C, 9, and 10 lour or five times to properly purge live vessel. DTH 000120255 12) Close (F) and (D); open (L) and depressure the filter to near atmospheric pressure. 13) Close (!.) - The filter is now ready for opening and changing elements. M) Close vessel and repeat steps G and P> through 12. 15) Close all purging valves, open two bleed valves on nitrogen lines and remove tv/o flexible hoses. 1G) Open (C), (11), and (I) to bring filter on stream. DTH 000120256 i\V'T 3 I *2 \'LJ> il 'si a F-401, VINYL PRODUCT FILTER ............ `i * pfN\V\TV^^* i. n" l V. 9 * " ? .,*% . o IT h ul TH 000120257 >1 F-402, VINYL PRODUCT FILTER F. F-625, Vinyl Loading Filter 1) Pressure any liquid vinyl in the loading filter to the 10" loading line from the VCM Plant.Be sure that all the lines downstream of F-625 are purged to the loading line, also. 2) Block in F-625 at the upstream side. 3) Line up the Filter to the dock vent stack. 4) Start nitrogen into F-625 and purge through the carbon bed adsorption system to the dock vent stack. 5) Continue the nitrogen purge until the vinyl content in a sample taken upstream of the carbon beds contains less than 25 ppm vinyl. 6) Turn over to maintenance for filter changing. CL. __ H-202 A & B, Quench Column Condenser (Refer to Figure VI) 1) After C-201 has been drained and blinded (see Part A for proper procedure), block in the cooling water and drain the exchangers of water. 2) Blind the 20" inlet nozzle. 3) Hook up a steam hose at the 3" inlet nozzle. 4) Blind H-202 from the S-202 transfer line at the inlet to S-202. 5) Start steam to H-202 with the drain open to the closed process sewer. 6) After the condensers are hot, steam for at least 2 hours more. 7) Shutthe steam off and block in the sewer line. Pull the plug on the inlet nozzle and sample for vinyl content. If vinyl concentration is greater than 25 ppm, steam purge again until the concentration drops below 25 ppm. DTH 000120259 - rr^'* * * \ ^-. .1 . * ,*1VA* H \ r,.*\",.Mi?T\i ! 5 (.* \* i FIGURE VI H-202 A & B, QUENCH COLUMN CONDENSER 2-Q1' r.u.c T // 6' Z 2 '2" r rvrva a- / C-iT J. ( A '-v r* ---------------- ! //" 5 c , /"] ; A DTH 000120260 \ -.. H-203, Quench Reflux Cooler 1) Bypass the cooler by blocking in the inlet and outlet valves. 2) Open the drain to the closed process sewer. 3) Start a nitrogen purge at the top of the cooler pushing liquid to the sewer 4) Continue nitrogen purging for at least 4 hours, and then pull a sample for vinyl content. 5) When the vinyl concentration is less than 25 ppm, discontinue the nitrogen purge, block in the drain, and turn over to maintenance. H-206 A & B, Vinyl Column Reboiler (Refer to Figure VII) 1) After the steam is out of H-206, close the 14" outlet valve. 2) Hook up a nitrogen hose by the pressure indicator (PI) and pressure the liquid contents back into C-203 until the level instrument indicates empty. 3) Block in the inlet valve, and open the drain to the closed process sewer. 4) If the drain valve is plugged, block in the nitrogen by the PI and hook up - nitrogen hose to S-220. Then depressure H-206 to about 20 psig. 5) With the process sewer line and line to S-220 closed, open the nitrogen 1 inf at the bottom of H-206 and blow the plugged- drain line back into H-206. 6) When the drain valve is unplugged, open it to the closed process sewer and drain the liquid. 7) When H-206 is empty of liquid, open the valve to S-220 which vents to the wet vent header. 8) Hook up a nitrogen hose to the PI and purge H-2G5 through S-220'to the wet vent header.9 9) Continue purging until the sample at the S-220 inlet has a vinyl content of less than 25 ppm. DTH 000120261 FIGURE VII H-206 A & By VINYL COLUMN REBOILER I)TH 000120262 f n ' ii ?A3 iHJ ^r J. H-207 A & B, Vinyl Column Condenser (Refer to Figure VIII) 1) Block in the inlet valve to the exchangers . 2) Hook up a nitrogen hose to the inlet nozzle and pressure the liquid vinyl to S-205. 3) When the sight glass shows empty, purge at least 5 minutes more and then block in the outlet valve to S-205. 4) Open the valve to the wet vent header to depressure. 5) Hook a chemical hose from the outlet nozzle to the wet vent header. 6) Nitrogen purge from the inlet nozzle through the wet vent header. 7) Continue nitrogen purging until the vinyl content at the sample point on the vent line is less than 25 ppm. 1. ,,,-"7 V / DTH 000120263 \i r\ 1 * : , w' i1 i 1 s ' ' i FIGURE VIII H-207 A & B, VINYL COLUMN CONDENSER uk\V :> 0 01 4 \yIi J 0 '1 k t 000120264 dth i n;.\ '; Uv1V ^ j , r~ <r- , 1 4 ' " V, : O 5H *r 4?Z-e-* ;'*, M^ K. H-211, HC1 Interchanqer 1) After C-201 and C-202 have been drained and blinded (See Part A for the proper procedure), start a nitrogen purge from S-214 to the bottom of H-211. H-211 is purged through H-309 into the oxychlorination reactors for at least 4 hours. 2) Sample for vinyl content at PRC-216B. When the vinyl concentration is less than 25 ppm, block in the valves at the inlet of H-211 and H-309. 3) Depressure H-211 through the HCl-to-MeCl valve, and then turnover the system to maintenance for blinding. L. H-213, Quench Column Interchanqer (Refer to Figure IX) 1) After R-201 A&B are shutdown and MC-205 A&B are blocked in hook N2 hose upstream of MC-205BV. 2) AT P-451 A&B block in suction valves. 3) Open valve to dry rerun header. 4} At P-453 line up header to T-453 through circulation line. Make sure line to T-415 is blocked in. 5) Start N2 at Mc-205B pushing EDC backwards through H-213 to P-451's and then to T-453.6 7 8 9 10 6) When N2 will come out on bleed on top of Dischg line at P-451B, H-213 is empty. 7) Block in lines at P-451's and P-452's and N2 at MC-205BV. 8) Block in inlet and outlet line to H-213. 9) Hook M2 hose at upper bleed valve and chemical hose at lower bleed valve going into vent header. 10) N2 purge H-213 until sweet. The reason for starting M2 at MC-205 is so H-213 outlet line will not be liq. full EDC during T/A. DTH 000120265 FIGURE IX H-213, QUENCH COLUMN INTERCHANGER <\Z a ti ll) DTH 000120266 0 2-01- M. Refrigerated Vent Recovery System, (H-490, H-495, T-491, and H-494) 1) Pump all the vinyl out of T-491 to T-490 . 2) Leave the suction of P-491 open and the discharge closed. 3) Block in the process inlet to H-495. 4) Start nitrogen into the inlet of H-495 and depressure through the back pressure control valve. 5) Hook up a chemical hose to the outlet spool of H-494 and to the vent at the sight gage of T-491. Depressure system to the vent header. 6) Pressure purge this system to 40-50 psig at least 4 times. 7) Continue pressure purging until the sample at the back pressure control valve contains less than 25 ppm vinyl. N. H-485, Vinyl Vent Recovery Condenser, H-486, Brown Fintube Rail Car Vent Condenser, and H-491, Refrigerated Vent Condenser. 1) After clearing T-491 to T-490, make sure that any remaining liquid vinyl in H-485, H-486, and H-491 is drained into T-490. 2) Start nitrogen into the inlet of H-485 and purge through H-491, T-491, and H-486. Vent the nitrogen to the incinerator line. DTH 000120267 Ji iOna-t !' ' ii 'j j ?' i iiL T3 .n s * lli iL 3) Continue purging the system until a sample of the vent stream going to the incinerator line contains less than 25 ppm vinyl. 4) Turn over to maintenance for blinding. 0. R-201 A & B, EDC Reactor Heater Cracker 1) Gradually lower the feed to the furnaces and the outlet temperature until four units feed and 450C outlet temperature is established. 2) When the conditions set out in Step 2 are established, kill all fires in the furnaces. 3} Continue feeding the furnace at 3-4 units feed until a furnace outlet temperature of 300C is reached. 4) At an outlet temperature of 300C, shut down the feed to the furnace and block in the quench flow when the outlet temperature reaches 175C. Close the chain valve at H-211. 5) Block in the feed to the vaporizers; blow out the preheat coils and block in steam to the vaporizers and blow the condensate to grade. Isolate vaporizers from furnaces so liquid level in furnaces can be cleared faster. Block in vaporizer drawoff. 6) Flush nitrogen through the furnace at a low rate. 7) Empty furnaces to slops storage. When liquid is out switch to vent header. 8) Block in the quench return line at the column and open the quench valves at the furnace so that the quench line can be drained down. Block in the emergency quench. Do not block in both ends of the furnace feed line. Block in both vapor valves to C-201 so purging of HC1 from furnaces can be speeded up. p, S-IQ8, Caustic Blowdown Drum 1) Block in the NaOII Blowdown line from S-207 A & B at S-103. 2) Put steam to the jacketed vessel to drive any residual vinyl to the wet ven header. Continue the steam purge until a sample taken at the vent line contains less than 25 ppm vinyl. DTli 00120268 pm as UUi'<ii si-.'L.i i i sAL 3) Drain all the NaOH to T-251 or T-423. 4) Hook a steam hose to the nozzle by the sight glass and steam for at least 3 hours, draining condensate to T-251 or T-423 intermittently. 5) Discontinue steaming, block in the valve to the vent, and open the bleed valve. 6) Have Maintenance blind the system and open the bottom nozzle. 7) tlnhead and wash out the NaOH completely before entering. Q. S-206, Decanter, (Refer to Figure X ) 1) After C-203 has been shutdown, raise the caustic level in S-206 to float th vinyl out. This muse be done slowly and carefully. Sample for caustic in the overflow. Watch caustic level in btm of S-207. When it starts up fast discontinue caustic feed to the vessel. 2) Block in S-206. 3) Connect a nitrogen hose and force the caustic out of S-206. Maintain pres sure in the vessel so as it is vented it will contain primarily nitrogen. Watch effluent pit for excessive venting. 4) When the vessel is empty of liquid, depressure via the wet vent line 1. 5) Connect steam hose from fifty psi supply to point #4. 6) Line up to sewer via drain valve #2. 7) Start steam purging. 8) Continue steam purging until sample at top of S-206 is <25 ppm VCM. 9) Shut off steam at point #4. 10) Close valves at point =2. 11) Disconnect hose at point >4 and leave valve open to prevent pulling a vacuum as vessel cools down. 12) Turn over to Maintenance for blinding. 13) When blinding is complete start an air purge to sweep out any VCM that coul. be left after steaming. DTH 000120269 rV ? ", A \ f' LAJ ' '^ rl \\ i - i-i i1j1 i\ J*, " FIGURE X S-206, DECANTER !- 1 i f. ' Tv r m\ 3 v v-< j L i s k - R. S-216, RV-210 and 211 K. 0. Drum This vessel serves as a K. 0. Pot downstream of the relief valves on S-206 and S-207. 1) Check to be sure that there is no leakage from the relief valves to the vessel. 2) Start nitrogen into S-216 and purge the vessel to the wet vent header. 3) Continue purging until the vinyl content is reduced to less than 25 ppm. 4) Turn over to Maintenance for blinding. S. S-207 A & B, Caustic Dryer (Refer to Figure XI) The Vinyl Dryers are operated in series with either one first in line. Either can be bypassed, but not both atthe same time. - As a guide we will assume A is first in line and that it will be bypassed and taken out of service for entry. 1) Open Valve A and close Valve B. 2) Drain the NaOH in S-207A to S-108 while watching the sight gage. 3) Close Valve C and Open Valve D. 4) Open the nitrogen at the top of S-207A and push the vinyl out S-207A to the inlet of S-207B. 5) Open the nitrogen line atValve E slightly to empty the bypass line of viny 6) When the liquid vinyl is out of S-207A according to the sight gage, close Valve D and open the drain valves on S-207A to S-108. 7) Pressure purge S-207A at least 4 times and then sample at the inlet spargers for vinyl content. 8) When the vinyl concentration is less than 2%, start the super sucker. With Valve D closed, open the 4" valves on S-207A to the super sucker.9 9) With the nitrogen still going in on the top of S-207A, pinch the butterfly valve until a slight vacuum is noted on the pressure indicator. Leave this set up until Maintenance pulls the manway, then close the ' butterfly valve and nitrogen to S-207A. DTH 000120271 A* C:}S\ i ?\ 4 rM' t > '>1 U\L 10) Pull air through S-207A at least 30 minutes. 11) Open the butterfly valve and close the 4" valves to the super sucker. Shut down the super sucker. 12) Shut the drain valves to S-108 and open the drain valves to the sewer. 13) Wash out S-207A to the sewer. 14) When washing is complete, close the drain valve and blind vessel. 15) When removing the blinds, starts the super sucker to pull air through the dryer while recharging. This keeps NaOH dust off the rechargers. *\ 7 000120272 dtb f\\ 'K\ \\W w W! ujl SIS $i$! ) T. VCM Caustic Dryer S-401 Cleanout Procedure Prior to starting a dryer cleanout, the slop caustic tank must contain 16 to 25 feet of 30 percent caustic. Tf less level is available a great er temperature rise will result. Evacuate the vinyl (vapor and liquid) from the caustic bed using the Corken compressor system. Then purge with nitrogen and vent to the incinerator. Purge to less than 2% VCM. Blind the 10" bed inlet and outlet and the 2" vapor and liquid purge lines. Install the 4" spoolpieces on the inlet and overhead lines to the bed. Line up from the pump, upflow through the caustic bed, back through the strainers and into the slops caustic tank. Pump through the bed for at least six hours or until the temperature of the return caustic starts falling. If the pressure drop across the strainer reaches 20 psi, switch strainers and follow the strainer cleanout procedure. i At the conclusion of pumping block in the pump and the line to the bed. Blow the return line back to the slop caustic tank with nitrogen. Then block in the return line inlet line and the circulation line. Blow teh caustic in the bed and inlet line back to the slop caustic tank. Drain the rest of the caustic to the sewer. Remove the top manway, flush out the caustic, and recharge the bed with flake caustic as usual. DTH 000120274 T-423 Slops Caustic Dilution Procedure The tank contents should be less than 100F (38C) at the start. Block in the 4" caustic lines to and from the VCM Plake Caustic Bed and the 2" caustic line from the unit. Circulate the tank through the strainers. After one hour of circulation sample the caustic. Have the lab determine the percent caustic. Using the percent caustic and the tank level go to the dilution table and determine the amount of water to be added. If there is no number in the square corresponding to the proper percent caustic and level the tank will overflow if diluted to 30 percent. Use the dilution amount for the same level and a 1 ower percent caustic. Set the proper amount of water on the water meter. While still circulating, open the valve on the water meter. The proper amount of water will be added and the valve will shut off automatically. Circulate for one hour after the water meter shuts off and then analyze the caustic again. The caustic should be 30 percent. DTH 000120275 ' ! A-s /, L-VJU_. 1 3\ 3 7-. WATC-i- At) D- O OoA ^ -v.J PG-P.C.t;h t~ 7w 37 C.A., JST'I COV f 37 s') 3 ^ I 7 7 .: i 2.. > V .9 .Co 7. 8i 7 /o 11 ITIt) /*/ y ./> /A 77 .....71 .. /?._ ;c 2) 2. 2.9. 2 } 27 2 t;' --1 / o'^ . . ISW 30 / 3 o-? Vi* L? I -/ A10 Oj -4- 1 1ZS /i ? 1 033 9z.i ron l o 1'-! 21'-/ S? 1 US 1 \Zc 1 | 1 5 3 S' 1 (c i |<1ji 23 20/7-:.. \ ?* -> ~s'i. ~ 1 ?7 / ^S r,'* ;--' - 3 |A Z 7/ 7 7 Z'A'Z- --V*" '/ l'/SG" vq 1 1 ?.4,0 7 -27 1 s 27 <71 7 27 ( A 3 o 'S? -5 3 ; 1 / ,4 Jr r. "aa. 377 7 4.I./V 7 l''- . --J 3 5 30 * 37V 2 3-327 3-70 7.1 "71s ' ^. 771 3 "7 7 ; r' 774'1 _' 0 ------ - C v ~) __ , -- _. ; 7 63O 7<3 13'7 3 ; s33 2z79 27 52 1 -w 1V CO7-' '5 <71 '2 7/37 3 577 C*c* / SS< 7 6 .7 70 O 3 6? &? 7 ? 7 3 sT 77 10 2zis 7/97 7 00 7 /o// </ /'C 57 2 ,7oi: 7V7 3 / / 9 5" 2 2- 0 7is [ 2 so 1 s -/ 3 l?79 2oqq 2'37-/ tr ( 0 *~ 3:27 37 77 737 V ! 3 31 O -OVA 5Vi;3 973 *SS-S ZSlZ. 377 / 77/3 0S1 7 .7377 7> Al-.- 2 2o 2 777 7 C l 2.3 7 7 03 7 ?. l?Ojr. c'l 3- I q/ -> 0< ^/ / C>'->"- A 7 57 / S4fV 7727 2C-7- // 3/''/2 2 <7o' 2 T-il -7 3'12. 793 7 107?. 1 //Z70 / 0 co 7 S 1/ ^1 3 iz.'2qV IZiOS \ -7 7 / 3197 1 17a / ^33 !3 ez 9 [/ n / /2<V3Cr /3(2 / /iPV-^ 17370 !-''/ 1 S m <'t i5.L/3 2 . I V? 3 3 J31A1 / 7 7 y | y O'- 1 2- 7 1 / i ; r Zl^ZI /A 73 70 0 -- - i _-- i-- 1 057 / 2.7 / / 007 . r 19 25 A 3 Z's S 3 319 i 5 S-17 /w sj O' -J \3 s^/' 7 . G3S7 <15* /_ 7' O 2; 9 7(el2\ %..f/ 0 0 V2fc O ' . ^57o 'o .7.5 3 3. 8S !co. .991 7' 'Z-llS O; t >-!/ -.>'-r /C--V 29 / O \ 1 2//Otv 3 121 1.5" //7i 3. . /2337 ,/7ZO^ . 1 C. 0 4-- / 3 7 -T'O /'i ; '0? /7 Z 57 / 0 2. <7 /S7 29 1 SO-j 3 ' 1711 S' !VS7wr rS3s^ /7 90 / /47S3 /9.01 z. 1 /1 35 0 2oq, </t/ -(9 7 7 -55 i` ^5 O5 C\ 2Z i'Zc- /A 077 z; 0 > s' 7A/2 S Z- / 9 7 0 7 Z 2.2 71 z <^0 / 7.1 "VS' 2.3 0^ iT 2V/9? P L. ;' O ^v_ >v'- n* ts''' 1I 20^7 7 2*7 7/ I, o, >-~*--- ^ <_ ' - -- 7.795-? 2V:zi .2.7 70 25Z7-S- __ 1... . .. .-- -- ----- 7277.. -- --- .. -- .t-:------- : _ __ _ __ ------ .. . tt i 1 -- -- .----- ' ------ -_ __ !__ ^ . 4--... ... * i __ ' -'- ` ' -' ~~\ AvAA-ET ' '' DTH 000120276 9 ' \ Ai-: U L-r-z ur A ii A/o W/\ \ l_i R._ A. o o G \j> CY Allo rG S. 3 X7 PfcLfVLc.U-.rG-T xa <-',3/ 0/\LJOT \C_ c'- s' <xx S-,,C-/v - ; L' 1 2- ...3 iun 3 zz3 >/ ; " c / 71?-/ T> _*? - .0." ; t V 0/3' A VG-S'cV- ,1 ,) -* (o 9yA2 / ^ ' .. 7 s / / 07 9 / -' 7 '' ' " /IT?,': * / - c'% <? . /o /J /Vo' / '.-// Z rr/y-n /73 V 7 /73V 7 ... 12 13 K/ :i? v Zl.C 'J 7/ / v o v" / L .1.6 . ___/0r> L. n V-`/ / A v 9S7 F /. v.;y iv.G 7,A:.;G77 *-- J-- o-. '> Cr~ > ;. - ;- .' ......ir.. z^qcc-.-- */ "/ 'a- _.J9 *. J /.O 337 37 3/.' 2 9* V \/* "/ --. * J2'l __ J7<2' -2-3. Lll/ -------- ... - __ __,, -.... -- --- ; _ . ----- -- _ _ 93 on --- -- ---- 3-7 --- 3. . _____ 1... '. ............. /9o'/ G V'o C> 0 ' o '*/ % :.' ! ; '/ / r' /.;/o 7 /3 33'/V V /'/3'uo I 77 / .7 / ' ' 7 Vv' N*_ 3'/ n *_ . .' " \* 3V2 17 w ; 3-7 3 -s12 - -- ----- -- -- -- -- -- .-- U / O o G- V 0 G_. 7. V 'Cc<D 73ST3 33/ 9 v J7o07 i-'/ 3 '/7D =-/ 3-/0 U '3 (./ 2- 7_ - / J 0 /o U/'O / / 0 c ' / 3 ili-o _ i1 ?J 3I- 1 /' 17 7 S' ;U:<3 ~/9 -'70 533 7 2-77 -/ C1. O.v' (n / t`- 0 ; 1 z z -i 7. i/nco ,'G // 311 ^- 0' 9->' '-vo c. *._ /7 2-/ 9 SG3 7 V VS 7 /f2 Jr Of 2V i'cSi 79.733 2: Cjco~7 /1- i 0 / VC' 1 7 303 / . C2 0 2.107 3. '3--' IS-;-) ?: i ov i V . 1 77 ?.-;UU:'7 2 zncz D 73 ' 3 c 13- r \ 1V.> 7..-,* r--, U'1, '-'7 -1 ... / 3 > / 3V/^ .'7g73_ --'77 . '/ -: V - > V' 7C; L ** . r 7 :: ; V 2 03 rv 0 r. _-j 3 2-/3 / 3' ' -7 ' 9/97 7 ?/: - - 3y -'CW f /* v *> `3 ~' . 3 V* * f/ T- / / C / l/<'S'!n . y / ^ :> ... _ .. .. ` --'*' ' ...... 213.2.1 o- --iv O -^ - V> 3 s'.' ^7 ; f 2*, : f * / -X,' ---* . .* I*s'. r 7 73`'/ 2^2 i/'c/ v. -//Scr// --------- rz.519 ,1: i/p'9'7 . ^ --* T^' < /; _2"/ 07 7'3/ 9G C~3 0.2 j ' 71 >-'' 3 : 7> 0 3u'- O 7-.Z-. Si-fcV;? : V 3' 9 3.. ^ ^/ . - P:;c n-/ C/7 0 V 2* 97 0 3 L/k/p' --. - .. .77": . -/302 V' ........... ... ------ ....... - ... - . ------ ..........----* .----.--... ;. _ . -- . - -- "r---- " ------- ----- ---1- ------ _-- .- _ .. -- '' -- ---- ------- -;.......-- . .:----:... . ................. -- ------- -----: --- ---7 -- -- -- ---:. ---- . ------- ----- : ..-rr:.. _ _____ . ____ , - -- --.--. ...--.--... *** -------- ---- ; * ____1 - '` -----~ ----- --- ------- . . . --- . . -- - - - - - -------- c . c .;t. \ T'i c : <* ' \J9 \ __c jri 7 >, r. - i. \ 0.7 DTH 0001202V7 * L_e= IT oGLL- V 9 ! ' <5~9 Watr_ . Adog-p . . C66 al_v_om s 3 ; pi<Ld.Gl.M'T .^au^tic. . , 69.6. \6i..6 -.; 7.6. a: / A v~7 9/ AT 0 vS"(S' CoO . Co "2_" ... .. 3 (S'Co 337.0? . 3559 37 v 9. ... ...2, . .637 f 07 C 2 7 119 7977 3 9o'o 7 /A Z.2 /O 47? //zyo V A*.. /Z7A2/.0 91. S' 13^o^ HZ.ZS- 79966 /o2 ?p / 7 7 7 ? ./677V _ _ .6 ... 7- - 'S /9//3 2 2799 zo/sy l.oztTC- 2/. 3 A?. .2 2 79 9 23031- 27/7/6 762 c.// 2 7oO' Z? V76 29799 9 13470 30319 32o3 5' 33937 :...... /o . 7/ 796 33740. 35576 37US7 :____..iJ........ 7 2 a / 37/3.0 39769 9/23.6 '...LIZ ... 13 ... 1 /V / \/<5 . ____i --11- L hr... --J9-- :A.21A <05/?- 92 7/3 .9992.6 9529? 9617 6 .96733 99677 L/'?2iS V.9Sl\ 66921 ^SCO'7/ SZ^>C)S. ................- 9 o9 fc?9 - ................... ------; - -- ;----- :-- _ .. ... ------------ . --:------*-- 'l ----------- .. 6m. .ATT-TT-.. ----------- . t * _. '* ... ;--------- _ -----`.2_ l -- i i : J7<2- l . . ___. ________. .7 - --- ' ------- .4. ___----------- '-------r --------------- 6-9--- 1 ; ;------r- L_iV._ |___ .24 Q7 i -2? L^.._ .jf....... i < ...-- --- -- -------: f; -- ------- . ------: ' ---- j----- : :----- 1 i--r . __ ------L------ 11 ------- 1 ,-n:L.. . .'T7T. . * I ___ _______ _ _ I--- -- 1t '..__L__ _ _ _ L. . . .1__* (RjAjC ------------------------------------ ` continct;-: CALCLi'-.-VTiO _ TV'IA . .Q.I.LU AJ-A 1 r---w ,,. i \ CON'INENTAL OIL COMPANY TANK NUMOEH: WESTLAKE, LOUISIANA U 1 3Ut'!' ` 1 T' | 3] 4'vr*' I 2 pop -1 1 3 :,i cs 0 4 :,4 i i i.p: ^ s 11 2.0? = ci .. . _i . > i ",t'i' 1 9.1 f. 1 19, 67 19.77 3 20,079 2 0,3? _3_ 4 5 A _ ,. ' 37.2 0-*. 37.5 0 9 37.6 1 5 35,1 ? 1 3?,?7 3C. 7 3 3 -> 3 : 4 5 t) c.-A. ur.c --i ,r 1 .,iir--;--- 3 l-'- -- V---'i'v'M ) i v:/9 7 (.y \UCE I'-G" IN *> _____ 91,9 8.9 Fftnm *?;Hn ! *) 13 1 10.367 j j. 5 .1 > 55.603 1i 2 74,22 9 1 92.2 9 5 92,60? NSNSSiSSSN'N J2~ 5 6,1 69 3 74,535 3 92.90 2 3 56,4 7 5 4 1 74.8 4 1 4 93.214 4 56.7 81 5 i 7 5.14 6 b 93,520 57,0 8 7 r. 1 75.4 54 r. 93,827 a -LI *1 ?-i3l 2.C37 :fl 20.6 90 20,996 7 8 39,0 3 e 39,3 7 a 57,393 57,6 9 9 1 ft 75,760 76,06 6 ~ ft 94,133 94,4 39 ~7~ 8 9i 9 I 21,301 9 39,6 5 0 9 58,006. 9 76N372 0 94,74 6 9 10 i .JL'.i \2 3 7,5 * a 10 1l 21,607 21,91 3 10 11 39,9 5* 0.26? 10 n 5, 31 2 58.61 0 10, u 7 6,6 7 8 7 6.9 8 4 in l\ 95,0 52 95,356 in tt 11 2 __3 4 )1 6 * * P C Q .1 6 5 .4 7 1 .777 5.0 a 2 c 7 a ;3 5.6 9 4 5.0 -* <.305 '6 f 7 3 2 2.2 1 9 2?.,_'? 22.0 30 23.1 36 23. 1 2 3.7 7 2.03 3 2 4,35 8 2,6 6 n 1 2 3 4 3 G .H 4 0,5 6 8 0,8 7 1,180 1,4 P6 1,7 9? 2.0 7 7 2. C 3 2.709 3,01 5 i_ 2 3 4 5 G 5 8,9 2 59.2 30 59.5 3 6 59,8 4? 6 0,1 8 60,35 4 60,7 6 1 61,067 61.373 21 1 3 4 a~c 77,280 77.596 77,902 73,209 78,515 73,821 7 9,1 2 7 79,4 33 __1 2 3 4 ft K 9 5.6 6 4 95.97 1 95,277 96,583 96,890 97,196 97,502 97,eC9 98,115 U 1 2 3 4 5 0 7 8 9 0.6:: 9 2 .970 9 \3? 1 9 6 1,6 7 9 9 8 0,0 4 5 9 98,4 21 9 10 :i 12 5. v: s 7,2? r 7c 10 ]1 7 25.27 6 2 5.5 P l pc O up 10 11 \6?7 3,933 .?3 <7 - --1--0 11 61,9 8 5 62.291 6 2.997 10 1:2 CO 351 00,6 57 C C-, ->- 11T 11 27 98,727 99.034 99.34 0 10 11 22 i 7.8 3 3 _i 2 6.1 9 3 1 4,54 6 1 6 2.00 3 1 8 1,2 7 0 l 99,646 k 3 -*i4-l. 5 P, 5? o,7f,9 9,C{2 5 2 4 6 2 6, 9 0 2''.eo 27.H0 27, 1 6 3 4 _S 4 4,8 5 1 4 5,1 8 6 5. 6 2 5.7 6e 2 3 4 6 8,2 O'? 6 3,5 1 5 61,6? 2 6,1 2 6 3 4 81,576. 81,882 8 2,1 3 6 82.494 3 4 _S_ 9 9.9 6 3 100,259 100,565 100,8 71 2 3 T ~T 9.37 3 a 27.721 f 5.6 0 7 23.027 ` 7 * 9.9 8 20,333 8 9 10," 2 5 9 2*638 9 10 10,575 10 28,94 10 n 10,9 9^- 11 29.250 11 6,07 4 4 30 4 ^6 2 6 6,99? 7,298 7,604 a a 9 10 11 6 . 3 4 6 4,7 4 0 6 5,0 6 65.35? 65.6 58 65.964 6 7 3 9 10 TT 82.800 83,106 S3,13 83.719 8 ,02 5 84,332 G 8 9 in 11 101.176 101,4e 101,790 102,097 102,403 102.709 a 7 8 10 11 11,203 C 29,556 13 47,910 13 66.270 23 84.63S 2Z 103.016 33 t l 11, fO 9 1 29.861 1 8,21 5 1 66.577 1 64,944 \ 103.322 2 i:,ei * 2 30,167 2 8,52 1 2 66.883 2 85,251 2 103,6-26 _3 1 2.1 2 3 3 30,4 7 3 3 8,827 _3 67,189 3 85,557 3 103,934 4 5 1 2. 30 12737 4 5 37.779 31,OP 5 4 _4 9,1 33 <7. 39 4 5 67,4 9 5 67,001 4 5 85,863 8 6.1 6 9 4 a 104,24 1 104,547 6 1 ,. A 31,371 A 9,7 5 A 6". 1 0 7 A 8 6.4 7 6 a 10 4,653 FRACTION'.. 7 A- l'.3c 1 i "*,6 9 7 7 a 31,697- 7 32.003 0 50,0 51 50,357 7 a 6-:, 4 I 3 68.71 9 7 ,4 86.7 8? 87,088 7 a lOSatoTT 105,466 1 19 36 9 1 *.9 6 9 32.309 0 50,663 9 69,0<- 5 9 87,395 9 105,772 57 10 l 1 .27 0 1 4.5 7 6 10 n 32.61 5 32.920 10 11 50,9 6 9 51,275 10 11 69,331 69.6 3 e. 10 n 87,701 8 8,0C 7 10 11 105,076 10 5,385 K Si 77 96 I 1 .9 3 : Oi 3'*.??* Hu 51,5 0 10 6 9,9 4 21 1 '1 3 Lc 32 1 , 5 1,8 "6 1 } L, J - 0 l 89,313 68,620 r:j 1 106,691 106,9 97 115 134 2 ft4 ' i 1 5. 3 1 *.7 ^ Q 1 *. 1 C 1 6,4 1 0 3 4 & A 3a, l A A 34,450 34.7 5 6 35.06? 3_ 3 4 3 8 5 2.1 9 2 52.4 9 8 52.804 53.110 5"\ 1 ^ __2_ 3 ft4 b 70,5 5 6 70,8 6 2 71,168 71,47 4 7 1,7 c* 0 2 3 ft4 3 83,926 89.23? 8 9,5 3 9 8 9,8 4 5 92,1 5 1 2 3 4 a a 107,304 107,610 107,91 5 1 03,223 1 0 3,5 ? 9 M. 'li Ki 1 53 17? 191 210 2 30 7| 1 7.C 1 7 11 1 7. 3 ? 7 8 35.368 35,67 7 ft '53.v; 2 5 4,0 2 6 7 H 7 Z,, f, h 0 7?.393 9'.',4 5 0 90,7 p 4 7 1 0 H, 8 3 5 1 011 li 24 9 268 91 17.633 e 35.97 9 9 5 , 3 9 7 2.6 9 9 9 9 1,070 9 1 0 9,4 4 0 % 207 10 i 17,9 3 9 :o 36,2 5 10 54.6 39 10 7 3,00 5 10 91,37 a 10 109,7 5 4 1 306 "1"1 1 ' 1...?............. fir 3*.c9i 1! 5 4.9 4 5 11 - 7 ^ : 3 . 1I 1~ 1` _____ ^ -_^ r ' - I1I1 11 1* 9.060 _____ CAPACI If IN U. 3. GALLONJ S TRAPPED 3EPTEMBER 23, 197 1 . E: T^f.< BOTTOM C0N3I0ERE0 FLAT ' AT TIME OF CAL I ERA TlON. NOTE; CAcACiriE3 REEL EC 7 EXPANSION OF TANK OBELI FCR LIQUID hE-U. *-*C TC- O* FVT*Ol/Ui Maoia if r vos r0(xo ucn^mI DTH 000120279 i ViSi s i ! u 1M 1 iT^ i- u. S-490, Tank Car Vent K. 0. Pot 1) Pressure purge any liquid vinyl in S-490 into T-491. 2) Block in S-490 from T-491 at the valve nearest to S-490. 3) Start a nitrogen purge to the inlet of S-490. Open the vent line to the incinerator. 4) Continue nitrogen purging until the sample at the sight gage contains less than 25 ppm vinyl. 5) Turn over to Maintenance for blinding. V. S-625, Dock Vinyl K. 0. Pot 1) Line up S-625 through the carbon beds to the dock vent stack. 2) Put steam to the vessel to drive off any liquid vinyl. 3} Start nitrogen into S-625 and continue purging until a sample upstream of the carbon beds contains less than 25 ppm vinyl. 4) Turn over to Maintenance for blinding. W. S-626, Suction K. 0. Drum 1) Pump any liquid in S-626 to the 10" loading line from the VCM Plant. 2) Line up the vessel to the carbon bed adsorption system. 3) Start nitrogen into S-626 and purge through the carbon beds to the vent stack. 4) Continue purging with nitrogen until a sample taken upstream of the carbon beds contains less than 25 ppm vinyl.5 5) Turn over to Maintenance for blinding. DTH 000120280 i~\ i. l n Vi 'va* \i X. T-202, HC1 Column Bottom Drum (Refer to Figure XI$ 1) After C-202 is shutdown, pump all the vinyl and EDC from T-202 to C-203. 2) Block in T-202. 3) Open the 2" drain to the process sewer and drain any remaining liquid from T-202. 4) After closing the drain valve, open the 1" bleed valve and depressure the vessel to the dry vent header. 5) Close the 1" bleed and the 3" valve under the relief valve. 6) Pull the blind to the wet vent header. 7} Hook a steam hose to the 1" line on the bottom of T-202. 8) Open the vessel to the wet vent header and the closed process sewer. 9) Start steaming the vessel. 10) After the vessel is hot, pull a sample from the LR-206 top balance line and analyzer for vinyl. 11) When the vinyl concentration in the sample is less than 25 ppm, block in the steam, sewer line, and wet vent header line. 12) Open the bleed line so vessel won't pull a vacuum. DTH 000120281 A fV-u ^ `u^ FIGURE XII T-202, HCl COLUMN BOTTOM DRUM -- KJI *->/: ocs S j j[)TH 000120282 ry I ",*J, iJ * r--- n ? **7" *A \^^ **i y i^. i ,m Y. T-401 A, B & C; Vinyl Check Tanks and T-411 A, B, C, & D; Vinyl Storage Tanks. 1) If vessel is not completely empty of liquid, either pump out or pressure out with nitrogen the liquid to another vinyl tank. 2) When the vessel is empty, block in the bottom gate valve. Also, block in the circulation and transfer valves on the dike. 3) Open up to the Corken Compressor and draw a vacuum on the tank. 4) Start nitrogen into the tank and raise the pressure to about 40-50 psig. 5) Open the block valve allowing the vessel to depressure to the vent header. 6) After pressure purging 4 or 5 times, sample the overhead vapor for vinyl content. 7) Continue pressure purging until the vinyl content of the overhead vapor is less than 25 ppm. Z. T-490, Vinyl Vent Recovery Storage Tank 1) Pump out all the liquid vinyl to another vinyl tank. 2) Block in all valves. 3) Open the pressure relief valve to the dry vent header. 4) Start nitrogen into the tank and pressure purge until the sample caught by the pressure gage contains less than 25 ppm. 5) Blind the tank 6) Hook up a steam hose and purge before entering. DTH 000120283 r.^Un(VV\ . - i*^' s, 4 fM '%111 1 AA. T-626, Dock Vent Receiver Tank and H-625, Dock Vinyl Vent Recovery Condenser 1) Pressure purge any remaining liquid vinyl in H-625 into T-626. 2) Pump the liquid from T-626 to the 10" loading line from the VCM Plant. 3) Line up the outlet of T-626 through the low pressure header to the carbon beds. 4) Start nitrogen into the inlet of H-625, purging through the exchanger and T-626. 5) Continue purging the system until a sample upstream of the carbon beds contains less than 25 ppm vinyl. 6) Turn over to Maintenance for blinding. \;ri i DTH 000120284 SECTION III STANDARD OPERATING PROCEDURES LOADING RACK VCM SERVICE DTH 000120285 VCM TANK CAR PURGING PROCEDURE A. Dedicated VCM Cars with 0? Content Greater than 1,000 ppm 1. Depressure car directly to the Incinerator line. Do not go through vent recovery unit because high levels of O2 in this unit could be a safety problem. 2. Pressure car with nitrogen to 40 psig and depressure to Incinerator. 3. Check 03. If not 1,000 ppm or below, repeat Step #2. B. Clearing Dedicated VCM Cars for Dome Removal 1. Pull VCM vapor out with the Corken compressor. 2. Pressure car to 40 psig with nitrogen and depressure to Incinerator. Do not go through the vent recovery unit. 3. Do Step 2 until car is below 1 ppm vinyl. 4. When car is 1 ppm vinyl or below, start plant air to the car and depressure to the atmosphere until at least 20" Og. Air purging is not required if the car is not to be entered. Clearing Undedicated VCM Cars of 0 (Cars that contain Air Onlyl 1. Pressure car to 90 psi with nitrogen and leak check. 2. Check around dome, valves, packing, dipstick, and R/V with snoop or water for leaks. 3. If any leaks found, report to Shift Supervisor for repair. 4. Depressure to atmosphere and keep pressure purginq to 40 psig until 1,000 ppm O2 or less is obtained. DTH 000120286 VCM CAR LOADING I. Respiratory Protection Requirements 1. Cannister Masks a. Use this type of mask when opening loading or vent valves at start of loading a tank car. b. Use this kind of mask (unless blue light is on) during the loading operation. 2. Fresh Air Mask a. When disconnecting or sampling a loaded vinyl car, always use a fresh air mask. b. Whenever the circulating blue light is on, it means that a high concentration of vinyl, 5 ppm, is in the area and a Fresh Air Mask must be worn. II. Spot up of Car and Preloadina A. Loading sphere and related equipment 1. Line up sphere and equipment in this order of flow unless other wise noted: a. sphere b. P-411's c. S-401 d. S-402 e. F-402 2. Circulate sphere and sample if not already done. B. Spot up of cars 1. Apot up all cars that are to be loaded. 2. Put up blue flags and derails. 3. Chock and ground all cars. DTH 000120287 C. Pre-Loading Checkout List - Figure I 1. O2 must be 1000 pom or below before loading. 2. Check platform guard rails around the dome for defects. Notify Shift Supervisor if defects are found. 3. Make a walkaround inspection of the car. If any noticeable problem is detected with the trucks or underframe, contact Shift Supervisor before loading. 4. Check tanks for dents and leaking valves, packings and flanges. 5. Check VCM lettering on the side of the car. It must be 4" high lettering. 6. Check DOT number on side of the car. If anything other than 112A or 105A, do not load. 7. Check safety valve test date. If more than 5 years since tested, do not load. 8. Check tank test date, if more than 10 years since tested do not load. Car Hookup 1. Install Rail car blower hoses and start up - rail car blower. 2. Install laoding nipples and hook up to loading hoses. NOTE: Loading nipple threads must be Teflon taped. 3. If the car has been in vinyl service, it probably will not need to be hooked up to the vent line. 4. Make sure all bleeds and pressure-vacuum clearing system are blocked in on loading and vent arms. 5. If car has old dip tube, hook up to level pot and set dip tube about 6" to 8" below required outage (i.e. add 6" to 8" to outage figure and set dipstick at that level). (See Figure II) 6. If car has magnetic dipstick, check stick to be sure it slides freely and works properly. DTH 000120288 IV. Loadino 1. When all cars are inspected, put on a cannister type mask and proceed to hook up loading hose. 2. If old dip tube is used,open all valves from dip tube to stack line. 3. Pressure each hose and camlock connection to full ^ pressure. 4. Leak check connections and hoses. 5. If no leaks, shut off N2 and educt hose. 6. Open loading valves to cars. 7. Check for leaks on loading arms, nipples, and dip tubes. If any are found, shut valves off, clear lines and repair leaks before going on to next car. 8. Proceed to next car and start loading the same way. 9. Keep cannister type gas mask on during all loading unless the blue light is on. Then it is necessary to put.fresh air masks on. 10. If blue light is on, locate leaks and repair. 11. If a car is loading slow, it may be a pressure build-up in the car from inerts. Hook up vent line checking for leaks and vent to fin fan and refrigerated vent recovery unit. 12. If a car with an old dip stick seems to be taking a long time to fill, check sight glass on level pot to see if level alarm is working. If liquid is entering the sight glass, the level is up to outage. 13. When car with magnetic dip stick reaches outage, shut loading valves. V. looping off (old din tube cars only) 1. When car reaches set outage .on dip tube and shuts down, raise-dip tube to correct outage.. Let level pot, sight glass and tubing clear of liquid vinyl. (See Figure II) DTH 000120289 2. When rest of cars have loaded or it is possible to stay with the car, start loading car again with dip tube on correct outage. When needle on the pressure gauge on dip tube line shakes and falls off, stop loading car. It should be on correct outage. VI. Samp!ing 1. Put fresh air masks, tvvek coveralls, and impermeable gloves on. These are requirements to sample vinyl cars. 2. Pull samples on cars (do not vent bombs to atmosphere). Vent the bomb via the small dip tube hose to the incinerator. See Fiaure II. 3. You may sample cars before all loading is done. Be sure proper pro tective respiratory equipment and clothing are worn. VII. Disconnect and Sealing 1. With loading valve on the rack closed, start II2 to loading arm pushing vinyl into car. Open and close eduction valve on the car to push liquid VCH into the car. See Figure III. Valve A 2. Close eduction valve on car block in h'2 to loading arm, and start eductor to pull vacuum on loading arm; also educt vapor in vent arm if used. Pressure purge and evacuate 4 or 5 times. See Figure III. 3. With fresh air respirator, tyvek coveralls, and impermeable gloves on, disconnect piping from car. 4. Finish making our loading report. Figure I. 5. Hake sure all valves and valve packings are leak-free and that safety valve is not leaking. 6. Install pulgs with chains on all valves. Install diD tube covers and thermowell covers. 7. Notify Shift Supervisor or Chief Operator for leak check. DTH 000120290 8. When everything in dome is complete, shut dome cover and seal with a dome placard and car seal. 9. Disconnect rail car blower hoses and shutdown blower. 10. Make sure all loading arms, dip tube lines, and thermocouples are free and out of way from the car with loading ramp in the raised position. 11. Change all 4 placards on the car. 12. Unhook grounds, unchock, and remove blue flags for switching. 13. If there is any problems with equipment on car, report to Shift Super visor so he can arrange to have it repaired. DTH 000120291 T /A VG! PLANT TANK CAR LOADING REPORT Car No. . Product >n -.Initials Date o^r-iri*'^ir*n rvi^r'n:i^ 1 i<\f Incoming L'eicht j-t ;f : //a 57 77 Incor.ino Tern.. ~i $ Inccninc Pressure 6 Inccning C? (1) Hue!: Ro1fs I'issinn LSafety Railing Ladders Ok ' (1) Trucks ?< I'ndarfrar'e OK Tan!: Defects Dees Car have Head Shield? Nann^tic Ci"stick StencileJ VC.". If No-Nhat i: Stenciled COT !12A or 10uA SV Test Less Than 5 Years Tank Test Less Than 10 Years ?jO& Yes No C3 /.j-'" Yes <jD O''" a Yes -No B "' 0- Yes No V' 0(2 )cn Yes.- N'o G" a Yes J-.o a rz- Y^n (Z a rr'n(Yes - iio i) .... Yes^Nocr an -- - Yes^-No j *G -- -O---JTs -l'' 1 . *------------ Post-Loadin': Checkout List Loaded Lai chi Loaded Out tea Loaded Terser?tore Loaded Fron Tan!: or Sohern _i2- i.,,.___, <0?l-.* . k. /J./r-s -- P^r'S o AJ S# *4 I J Cdr- S 6 aw /J //w^AA 0? After Leading All Liquid Valve Plans Ticks Chaired All Vacor Valve Plans Ticht V Chained liieri: oreter :.e!l Can Tirf.t ?. Chninod Di;> fate La ten in ('lire PI C\ *z i r'iz (Cotil i.nds) z ( 1- 1 ' < n t - 1 r i f' ') Test Tate S: ulo Valve 1 ' 1 n 7i V Chain'''! Seal (U (2) Nn. vj :.vr 7.. .5 J?'J) / cl:,:/.:: slnl.t.'ilct r'*v-:r n:s: <*?y- Yes ni''" Yes . K ' -: J Yes j. Hfk .................... Yes " ..... O' V J. f) i " Yes | n '' -!................... * l; '""F .- . r- . - - -- DTH 000120292 dTH 000120293 .4 " | "ij.................. i: I I'sI i' Nil'T.rj.CI ) as. S'NM3i n r- ~ VA vvcy ; 2iX } 3" -rue.c vCt-rr Kl t" W t*J F\UL V/\LVC i v:. .j I u\ ^i:.C !"(' i DTH 000120294 nr,o.ve i na'.v^oi___ T C oJl->! !. v. i a i: - ' c ' : . . >* POKIN ', Z'\'Z Z'.y. V. ' t- \*. / \ 1*. f'' ^ UO f \ t * or/.iai Ho, Continental Oil Coir,puny CO S VCM Plant Tank Car Loading Report Cur No. _____ Product Pre-Loading Checkout ListInitials Date Incoming '.`/eight Incoming Temp. Incoming Pressure Incoming 02 Hunk Bolts Missing (1) Safety Railing & Ladders OK Trucks & Undcrframe OK (1) Tank Cefects Does Car Have Head Shield? Magnetic Dipstick Stenciled VCM If No--What is Stenciled DOT 1 1 2A or 105A SV Test Less Than 5 Years Tank Test Less Than 10 Years Yes No Yes No Yes No Yes O No Yes D No Yes No Yes No Yes No Yes No Yes No (2) (1) 0) (1) Post-Loading Checkout List Loaded Weight Loaded Outage Loaded Temperature Loaded From Tank or Sphere 02 After Loading All Liquid Valve Plugs Tight (i Chained All Vanor Valve Plugs Tight & Chained Thermometer Well Cap Tight Chained Dip Tube Lorch m Plactj Placards in Place (Goth tndsi (Goth Sides) Test Tube Sample Valve Plug Tight ?. Chained Yes I ! Q Yes Yes Yes Yes Yes SPrtl No (1) Do Net Load Yes (2) Contact Supervisor Comments E b -.'.j O ' 1 1 -7 7 DTH 000120295 Cl. os~ cx ou . n m rj rj r Li XJ r> [; rj O O y> o j.-' j u r.j O *s\ I* Continental Oil Company (conoco) VCM Plant Pumper/Loader Track Situation L notion C.ir T lark 2 2 2 3 3 4 4 4 Soot t *M*r* 3 2 1 Off Spot Off Spot 3 2 ii Off Spot Off Soot 2 > Off Spot Off Spot 2 1 Off Soot 4 Off Soot Off Snot \V*st 5 6 i r i S s Lo idinq No. Contents St JtuS 0.voen llrforc i ___________1_________________ 1 ! i 1 1 1 . i ' After V*.' ' * Sew} m?ts' lull Sejicd Samofcd Loaded 1 ________1_______________ i| !| Car Sailed 1 1 ________ I_______________ 1|i ______________i____ L___ i_________ i 11 i l i ______________ i________ ii 1i ____________________________ i 1 ri 11 1i 1 i l1 1 i ii i ti i !I i1 i 1 i' 1 i i 1 1 l i i i 1 1 l 11 ! [1 ii !i l1 i i ! i i i i i ii !1 11 1i ii !i 1l |1 !i ii 'i 1 l i i || 1i Pl> cards | Spec C*. i ! __ 1 ! I PIcjio Be Accurate f.Mifc LCvefl r 40ta T-401 11 T 401 C r 4n a T 411 Jt r 4ii c T A 11 D T 4',? Grffk. M.ih# 3 iuo'M No 1 Shift. ? copies o H'i * and No. 3 smlt. Da:*Status uf SO j Cjw(ic Car Cars Neeomn Rei.imnhi**] Time Operator- IP-401 d.o ICjuMc tied c! o i 1 i 1 F 402 ct D. SjuYite Hed d D: C Pj- *! 1 v pr Fully LvV't-.l r.r-f to OnCO Cjr NO. V iten.il ------------ 1 Out To S'jft Finish g.$4R fR. o n ... ! ri 0TH 000120297 (conoco) Interoffice Communication To J. W. Ware From pi. G. Jake! dj"? March 23, 1981 Sublet Startup and Operation of the Rail Car Blower System The Rail Car Blower, BL-420, will be used to reduce employee exposure to vinyl chloride emissions from leaking rail car domes during rail car load ing operations. The blower system will pull air into the dome and out the side port hole through a 6" hose into a common header. Air collected in the common header will be exhausted through a stack at an elevation of 60 feet above grade. Prior to opening the domes of the vinyl rail cars after they arrive in the plant the 6" black and orange hose will need to be fitted snuggly to a port hole by hooking both of the attached straps to two other side port holes in the dome (see attached drawing). After the hoses have been attached to the domes, the blower, BL-420, can be started from either guard shack. All domes must have hoses hooked.up before they can be opened; however not all hoses need to be hooked up before .the blower is started. Once the blower has started, the domes can be opened up. The blower will be shut off and the 6" hoses disconnected only after the loading operation is complete and the domes closed. A low amperage alarm is provided for the blower to alert operators when there is low air flow through the system. A vacuum bleed valve is included to ad mit air to the blower suction when low amps (low flow) occurs, to protect the compressor from surging. Bleeders in the common header should be opened on a weekly basis to drain any liquid which may have entered the system. If there are any questions please call me at extension 5049. Mark G. Jakel Process Engineer kf CC: JAD-GLF-JWW(15)-CWT-JRH(4)-DLD-PLF-PE DTH 000120298 \ } o -( "t ///' A o '-y I C5i * vb N "* <53 ^ >k t> 5^5 a5* -j <X3.r Ce: dth 0120299 (conoco) Interoffice Communication To Distribution from J. W. Ware oate August 22, 1980 subject Railcar Loading/BL-410 Meetings The subject meetings have been completed with the appropriate personnel from all shifts. The attachments reflect information collected during the meetings which will hopefully clear up some misunderstanding with respect to breathing air use on the rack and lead to the improved operation of BL-410. Please let me know of any further problems or questions which come up. J. W. Ware is CC: c. Landon c. Kroske K. Cash C. Buller C. Brown E. Gould J. Vickers D. Ross R. Fox C. Turner M. Powers R. Young P. Ceasar B. Wilburn M. Fontenot F. Broxton L. Barron B. Bauer A. C. Hughes DTH 000120300 VINYL LOADING BREATHING AIR REQUIREMENTS Task Breathinq Air Breathing Air nat'Req-'d Req'd Remove plugs X __Break thermowell cover Remove sample tap plug ------ ------- --------- X X Remove dipstick cover ...... .............. ............ X Put nipples in (install new teflon tape if needed) X Hook up loading hoses (good 0-rings) X __Pressure up fPr check X Check O2 at sample tap X Start loading X Car nears correct outage-sample it X _Car_reaches correct outage ` _ __________ X _S/D_ loading ____ ________ __________ X Take final 02 on vent arm _______ X Push liquid into car w/ N2 X Purge liquid line into car _________ X Vacuum/pressure PJJcgeJU^es ___ __________ Block off loading hoses________ ________ ________ X X Depressure loading lines X Disconnect hoses __Remove nipples X X Install plugs w/ new teflon tape X Shut off breathing air X DTH 0120301 CONOCO STANDARD BREATHING AIR REQUIREMENTS VINYL CHLORIDE Whenever equipment is opened which does contain vinyl chloride, has ever contained vinyl chloride or could possibly contain vinyl chloride, breathing air use is required. DTH 000120302 Process Flow Diagram BL-410 C Operating Notes i T'Vre.Ci.c.Cj o uS.14, (1) Turn the start switch off before pressing reset buttons. (2) An appropriate level in the intercooler is important because: (A) It cools the gas feed to the second stage (B) It cools the liquid going to the overhead condenser (C) It prevents liquid from entering the suction of the second stage (D) It provides a feed to the oil recovery pot A level controller attached to the side of the intercooler controls the intercooler level. Monitor this level on a routine basis. The appropriate level should be stable in the intercooler even when the unit is shut down. (3) The oil level in the crankcases ofthe low and the high stage compressors is important. You should be able to see a level in the sightglasses at all times, even when the unit is shut down. (4) The oil recovery pot located on the skid immediately southwest of the intercooler has a level indicator on it. It normally runs V4 to V2 full. If an oil oroblem develops it may be traced to a low or high level in this pot. DTH 000120303 BL-410 Operating Notes (.continued) (5) The fin-fan cooler is critical. Be sure it comes on when you start the unit. If it doesn't you will blow a relief valve on the receiver. It only takes a few minutes to loose a lot of Freon through a relief valve. (6) The relief valves (2) on the receiver, once blown, sometimes will not re-seat on their own. Stroke the valve under the relief valves all the way in or all the way out to switch relief valves to stop one from blowing. (7) The level of Freon in the overhead condenser is critical to stable unit operation (rule-of-thumb setpoint on the controller is 1.5). Too high a level with a heavy vent rate will overload the low stage compressor and increase the high stage discharge pressure. Too low a level will give you no cooling in the condenser. DTH 000120304 SECTION II STANDARD OPERATING PROCEDURES LOADING DOCK VINYL SERVICE DtH 00^0305 -* TABLE OF CONTENTS I. General Requirements of the EPA Standard for Vinyl Chloride II. Carbon Adsorption System A. Discussion B. Regeneration Procedure C. Schematic showing arrangement of carbon beds at Dock III. Operating and Clearing Procedures A. Connection of Vent and Loading Hoses B. Blind removal from vent hose spool piece on Dock. C. Blind removal from loading hose spool piece on Dock. D. Hydroquinone addition procedure. E. Disconnection of vent hose from ship. F. Disconnection of loading hose from ship. G. Blind installation in vent hose spool pieces on dock. H. Blind installation in'loading hose spool pieces on dock. I. Sampling Procedures: 1. Collection of samples at the discharge of ship's pump. 2. Collection of samples at a sample tap. IV. Drawings A. Drawing No. 119-3: Procedures for loading VCM at Dock No. 3 - Details B. Drawing No. 119-Z: Hydroquinone Addition System C. Drawing No. 140-Z: Pump-Around System for Ship Sampling i 000120 306 I)Ttt I. GENERAL REQUIREMENTS The EPA's National Emission Standard for Vinyl Chloride sets guidelines for the regulation of vinyl chloride emissions to the atmosphere. The regulations that apply to operations activities at the No. 3 Loading dock and.the procedures used by CONOCO to comply with the regulations are summarized below. A. Vents to the Atmosphere The EPA standard specifies that all vents to the atmosphere must contain less than 10 ppm VCM. Compliance with this regulation is achieved by routing all vents to either the vent recovery system or the carbon adsorption system. B. Vents from Relief Val.ves The EPA standard specifies that preventable relief valve discharges will not be permitted. . Rupture discs have been installed under all relief valves and, where possible, the discharge piping has been routed to either the vent recovery system or the carbon beds. C. Clearing of Equipment and Lines Several guidelines are presented- in the EPA Standard for the clearing of equipment and lines. By following the operating procedures presented in this manual and by controlling all vents to less than 10 ppm vinyl, it is possible to comply with the EPA Standard. D. Seals on Pumps and Compressors The EPA Standard specifies that emissions from seals on all rotating equipment are to be minimized by installing double mechanical seals or by an approved method. The vent from the nitrogen purge on the vent recovery system com pressor is -outed to the carbon adsorption system. ". Leak Detection and Elimination Plan The EPA standard specifies that emissions due to leaks are to be minimized by implementing and following a leak detection and elimination plan. Such a plan for the No. 3 Loading Dock is included in this manual. DTH OOO1' ?.Q307 CARBON ADSORPTION SYSTEM The EPA Standard mandates that all emissions to the atmosphere must have a VCM concentration of less than 10 ppm. The majority of the vapors generated during the loading operations pass through a vapor recovery unit at the dock for recovery of VCM and are returned to the main plant area by a pipeline. Additional vinyl is recovered in the main plant and residual vapors are piped to the thermal incineration system. Several loading operations vents, however, cannot be processed through the vent recovery unit because of their low pressure or because of oxygen content. Therefore, a carbon adsorption system was installed to control the VCM content in these emissions. When the streams are routed through the beds of activated carbon, the VCM is trapped in the carbon granules by physical adsorption. The carbon adsorption system currently consists of two 220 gallon drums arranged in series. Each drum contains 725 lbs. of Calgon BPL type 4x10 mesh activated carbon. The drums are protected by a relief valve which discharges directly to the vent stack. If the valve relieves, then the discharge must be reported. See Section II of this manual for an explanation of the reporting procedure. The adsorption capacity of the system is extremely sensitive to inlet conditions. The adsorption capacity decreases with stream humidity and the beds cannot reduce the VCM concentration in the vents to less than 10 ppm if streams having high VCM'concentrations are routed to the beds. Therefore, the only vents that are routed through the beds are those that are generated during the hose connection, ship hold sampling, hydroquinone injection, and hose disconnection operations. The procedures for these operations were re vised in early 1979 and copies of the revised procedures are included in this manual. The concentration of the VCM in the vents being routed through the beds is continuously monitored at two points by the fixed point monitor system. The first point is located between the two drums and must be connected prior to each loading operation. The second point is located downstream of the carbon beds and is permanently attached on the line that routes the vents to the vent stack. If a vinyl concentration of greater than 10 ppm is indicated between the two drums, then the loading operation must be stopped and the VCM Plant Shift Supervisor must be contacted so that arrangements can be made to regenerate the first drum. If a vinyl concentration of greater than 5 ppm is indicated downstream of the carbon beds then the loading operation must be stopped and evaluated. It is imperative that the VCM concentration in the vents never be allowed to exceed 10 ppm. 000120308 DTH v Zi r \ ;\VT; A \ ij'i l * i U - 11 _iR^J^DsjRP2I2N SYSTEM (CONTINUED) ' Upon saturation (which is indicated by VCM in the vent downstream of the beds) or upon completion of the loading operation, whichever occurs first, the carbon beds must be returned to the VCM Plant for regeneration. The VCM Plant Super visor will write a work order for maintenance to bring the beds back to the plant. The urgency of the work order depends on when the next ship loading is scheduled. The beds are regenerated by stripping the VCM from the carbon with hot nitrogen A general discussion of the procedure for regenerating the beds is attached. A schematic showing how the beds should be arranged at the loading dock is also attached. I y -i DTH 000120309 REGENERATION OF CARBON BEDS The following are general instructions for the regeneration of the carbon beds using hot nitrogen. I. Purging the Two Pressure Vessels on the Trailer 1) Purge the two vessels in series. The hot nitrogen must enter the top of the two vessels and exit out of the bottom. 2) Notify and coordinate all purging operations with the incinerator. 3) Keep the inlet pressure low enough that the high nitrogen flowrate does not cause a by-pass at the incinerator. The inlet temperature must be limited to 275F. 4) Purge the vessels until the hot nitrogen exiting them contains less than 10 ppm VCM. A < :\ T DTH 000120310 -l 1 0 r *7 o i J -J f T I)TH 000120311 VCM- *XV V III. OPERATING AND CLEARING PROCEDURES: A. Connection of vent and loading hoses B. Blind removal from vent hose spool piece on Dock C. Blind removal from loading hose spool piece on DockD. Hydroquinone addition procedure E. Disconnection of vent hose from ship F. Disconnection of loading hose from ship G. Blind installation in vent hose spool pieces on Dock H. Blind installation in loading hose spool pieces on Dock I. Sampling Procedures 1. Collection of samples at the discharge of ship's pump 2. Collection of samples at a sample tap. DTH 00012a n2 OPERATING PROCEDURES CONNECTION OF VENT AND LOADING HOSES Discussion The new clearing procedure given below can be broken down into three basic steps. 1) .The first step is to flush the VCM out of the spool pieces with N2 to the vent recovery system. All of the liquid should be flushed out during this step. 2) The second step is to "pressure purge" the spool piece. This is accomplished by blocking in the spool piece, building the pressure with N2, and then bleeding the pressure off to the vent recovery system. The VCM vapors are diluted by the N2 each time the pressure is allowed to build. This"step is performed ten times so that the vapors are diluted to a low concentration and the dock personnel will not be exposed when they break the flanges. 3) The third step is to activate the eductor while breaking the flanges. In the past, the eductor was used to clear the spool piece of VCM but it is now used only to prevent any VCM that may remain in the spool piece from escaping into the atmosphere. The new procedure was developed to reduce employee exposure to VCM while also reducing the adsorption load on the carbon adsorption system. More time is required to clear the hoses and spool pieces but the procedures should not be rushed for any reason. If the procedures are not followed, then the dock personnel carrying out the procedures could be exposed to VCM. Procedure (Refer to Drawing 119-3 of this design) 1) Lift hose onto ship with valves F and G in the vertical plane. The spool piece should be connected onto the vessel so that valve F is on the bottom. This is important for liquid drainage during hose disconnection. 2) Connect the chemical hose that is on the reel to valve G-. Connect chemical hose fi 01.1 valve F to valve H. 3) If tine vc-nt recovery system is nut al'ieaoy on, net if; plant control room (sc that they can start their vent recovery system a.,a preparations can be made at the incinerator) and then start the dock vent recovery system. 4) Purge the spool piece with nitrogen to the vent recovery system as follows: a) Open valves I,'H, G, F and C. Then purge spool piece with nitrogen for five minutes by opening valve A. All of the liquid should be flushed out during this step. If, after five minutes, there is still evidence ofliquid (sucli as frost on the line) then continue to purge the line until the line is empty. b) Close valves F and G. DTH 000120313 A v s \ V sa A* CONNECTION OF VENT AND LOADING'HOSES 5) Pressure purge the spool piece as follows: ' a) Open valve F, allow spool piece to depressure to vent recovery system and then close valve F. b) Open valve G, allow pressure to build in spool piece and then close valve G. c) Repeat steps(a )and(b )10 times. Pressure purging in this manner will dilute any VCI1 that remains in the spool piece. 6) Open valves G and F and purge through spool piece for one minute. This is done to flush out any VCM that may remain in the chemical hoses so that the dock personnel will not be exposed to VCM when they disconnect the chemical hoses. - 7) Close valves H and A in th-at order. Then open valve B. This is done to depressure the chemical hoses. After the hoses have been depressured, close valve F and disconnect the chemical hose that is connected to valve F. 8) Connect hose to ship as follows: a) Pull a vacuum on spool piece by opening valve A (valves B, C and G should already be open). b) Remove the blind flange from the end of the spool piece and connect the spool piece to ship flange. Continue to pull a vacuum until the flange bolts have all been tightened. This will reduce exposure of dock personnel to VCM because the eductor sucks air into the spool piece and entrains the residual vinyl in the spoof piece. c) Close valve A and after the pressure on the chemical hose returns to atmospheric pressure, close valves B, C and G. d) Disconnect chemical hose from valve G. Revised 3/16/79 VCM Design No. 1 19-700-379-C'JT 000X20314 A o, \ifX OPFRATIHG PROCEDURES yv** BITHD REMOVAL FROM VENT HOSE SPOOL PIECE OH DOCK Discussion The new clearing procedure given below can be broken down into three basic steps. 1) The first step is to flush the VCM out of the spool pieces with M2 to the vent recovery system. All of the liquid should be flushed out during this step. 2) The second step is to "pressure purge" the spool piece. This is accomplished by blocking in the spool piece, building the pressure with , and then bleeding the pressure off to the vent recovery system. The VCM vapors are diluted by tire 2 each time the pressure is allowed to build. This step is performed ten times so that the vapors are diluted to a low concentration and the dock personnel will not be exposed when they break the flanges. 3) The third step is to activate the eductor while breaking the flanges. In the past, the ecuctor was used to clear the spool piece of VCM but it is now used only tG prevent any VCM that may remain in the spool piece from escaping into the atmosphere. .( '` i .The new procedure was developed to reduce employee exposure to VCM while also reducing the adsorption load on the carbon adsorption system. More time is required to clear the hoses and spool pieces but the procedures should not be rushed for any reason. If the procedures are not followed, then the dock personnel carrying out the procedures could be exposed to VCM. Procedure (jlefer to Drawing 11S-3 of this design) 1) This line should not have any liquid VCM in it but it is cleared in the same manner as the other spool pieces in order to limit exposure to VCM. 2) If the vent recovery system is not already on, notify the VCM plant control room (so that they can start their vent recovery system ai.d preparations can be made atthe incinerator) and then start the dock ventrecovery system. 3) Purge the line between the blind and valve M_as follows: a) Open valves T, L. J and I. (Valve T is a 2 inch valve and should be k open. If it is opened all of the way then too much nitrogen will be used and two things may happen: 1) The suction pressure on the vent recovery system will go up because it cannot handle the additional M2 - -i 2) The increased flew could upset the VCM Incineration Unit and all clearing operations on the dock will have to cease and cannot be resumed until the unit lias stabilized. b) After five minutes close val as T and L. DTH 00012.0315 BLIND REMOVAL FROM VENT HOSE-SPt)OL PIECE ON DOCK 4) Pressure purge the spool piece as follows: a) Open valve T, allow pressure to build in spool piece and then close valve T. b) Open valve L, allow spool piece to depressure to vent recovery system and then close valve F. c) Repeat steps (a) and (b) ten times. Pressure purging in this manner, will dilute any VCM that remains in the spool piece. d) Close valves T, L, J and I. 5) Remove blind as follows: a) Pull a vacuum on spool-piece by opening valves S, R, B and A. b) Brea!: the flange and remove the blind. Continue to pull a vacuum until the flanges are secured back together. c) After securing the flanges close valves S, R, A and B. 1 Revised 3/16/79 VCM Design No.: 119-7C0-379-CWT DTH 000120316 OPCRATI.'.'G PROCEDURES BLIND R OVAL .FROM LOADING HOSE SPOOL PIECES Oil DOCK Discussion The new clearing procedure given below can be broken down into three basic steps. 1) The first step is to flush the VCM out of the spool pieces with h'2 to the vent recovery system. All of the liquid should be flushed out during this step. 2) The second ,step is to "pressure purge" the spool piece. This is accomplished by blocking in the spool piece, building the pressure with N2, and,then bleeding the pressure off to the vent recovery system. The VCM vapors are diluted by the ii'2 each time the pressure is allowed to^build. This step is performed ten times so that the vapors are diluted to a low concentration and the dock personnel will not be exposed when they break the flanges. 3) The third step is to activate the eductor while breaking the flanges. In the past, the eductor was used to clear the spool piece of VCM but it is now used only to prevent any VCM that may remain in the spool piece from escaping into the atmosphere. The new procedure was developed to reduce employee exposure to VCM while also reducing the adsorption load on the carbon adsorption system. More time is required to clear the hoses and spool pieces but the procedures should not be rushed for any reason'. If the procedures are not followed, then the dock personnel carrying out the procedures could be exposed to VCM. Procedure 1) If the vent recovery system is not already'on, notify the VCM Plant control room (so that they can start their vent recovery system and preparations can be made at the incinerator) and then start the dock vent recovery system. ?) Purge the line between the blind and control valve as follows: a) Open valves P, D, K, J, I and purge the spool piece with for five minutes. Valve P is a 2 inch valve and shc-uld be only U open. If it is opened all of the way, then too much nitrogen will be used and two things may happen: 1) The suction pressure on the vent recovery system will go up because it cannot handle the additional nitrogen. 2) The increased flow could upset the VCM Incinerator Unit and all clearing operations on the dock will have to cease and cannot be resumed until the unit has stabilized. If, after five minutes, there is still evidence of liquid (such as frost on the line) then conti ue to purge the line until trie line is empty. b) Close valves P and D. DTH 000120317 BLIND REMOVAL FROM LOADING HOSE SPOOL PIECES ON DOCK 3) Pressure purge the line ( on both sides of the blind) as follows: a) Close valve K and open valves D and E. Valves J and I should be open. b) Open valve P and allow pressure to build, then close valve P. c) Open valve K and allow pressure in spool piece to bleed off to vent recovery system then close valve K. d) Repeat steps (b) and (c) ten times. Pressure purging as described above will dilute any VCM that is in the spool piece. 4) Close valves E, D, K, J and I. 5) Remove blind as follows: ' a) Pull vacuum on spool piece by opening valves N, 0, B and A. b) Break the flange and remove the blind. Continue to pull a vacuum until the flanges are secured back together. c) After securing the flanges, close valves N, 0, B and A. Revised 3/16/79 VC.*! Design No.: 1 19-700-379-CWT DTH 000120318 HYDROQUirJONE ADDITION PROCEDURE Safety This procedure must be followed exactly. Any shortcuts or changes could result in exposure to high concentrations of VCK vapor. Hydrcquinone is very irritating to the skin and should be washed off immediately. Always stand up-wind when adding hydroquinone to the injection pot. If you should get hydroquinone in your eyes, go to an eye wash immediately and flush your eyes for at least fifteen minutes. Then get medical attention promptly. Hydroquinone Addition (Refer to Drawing 119-2 of this Design) 1) Establish flow to the injection tank as follows: a) Open valves (5), (14), (13) b) Close valves (3), (1) 2} Purge vinyl out of injection tank as follows: a) Open valve (15, (16), (17) b) Open valve (2). This is the nitrogen line. It is possible to tell when the tank is clear of.liquid VCM by listening to the flow in the drain line. 1 c) When the tank is clear of liquid VCM, close valves (2), (15), (16), (17) 3) Purge the injection pot as fellows: a) Open valves (8) and (9) and allow the pressure to build up in the injection pot. b) Pull suc;ion on injection pot by opening valve (10). c) After 1 '2 minutes, close valve (10) and allow the pressure to build buck up in the injection pot and then pull suction on injection pot by opening valve (10). d) Repeat the procedure of allowing the pressure to build in the in jection pot and then pulling suction five times. e) When valve (10) is opened for the last time, also crack (7) momentarily to eliminate any pressure trapped in the ball valve. Close valves ' (10), (9), (3) in that order. .4) Add hydrcquinone to the injection pot by onening valve (7) and pouring the powder into tiie pot. Be sure all of the powder drops into the pot, then close valve (7). DTH 000120319 J U i li j i UL.i -i f hydrcqui,-;o,-;e addition procedure 5) Put nitrogen pressure on the injection pot by opening valves (8).and (9). Ce sure that valve (10) remains closed. If .it is opened the hydroquinone will be sucked into the line to the vent stack. 6) Drop the hydroquinone into the injection tank by opening valve (6). After 30 seconds, close valves (6), (8), (9) in that order 7) Open valves (11) and (12) and allow VCM to flush through the injection tank for at least 10 minutes. -~ 8) Steps 2-7 must be repeated for each ship hold. When hydroquinone has been added to all holds, line up VCM flow back through filters by closing valves (5), (14), (13) and opening valves (3), (1). Revised: 3-16-79 VCM Dcsicn Ho. : 119-7C0-379-CVJT DTH 000120320 OPERATING PROCEDURE DISCONNECTION OF VENT HOSE FROM SHIP Di scussion The new clearing procedure given below can be broken down into three basic steps. 1) The first step is to flush the VCM out of the spool pieces with N2 to the vent recovery system. All of the liquid should be flushed out during this step. 2) The second step is to "pressure purge" the spool piece. This is accomplished by blocking in the spool piece, building the pressure with N2, and then bleeding the pressure off to the vent recovery system. The VCM vapors are diluted by the M2 each time the pressure is allowed to build. This step is performed ten times so that the vapors are diluted to a low concentration and the dock personnel will not be exposed wherf they break the flanges. 3) The third step is to activate the eductor while breaking the flanges. In the past, the eductor was used to clear the snool piece of VCM but it is now used only to prevent any VCM that may remain in the spool piece from escaping into the atmosphere. The new procedure was developed to reduce employee exposure to VCM while also reducing the adsorption load on the carbon adsorption system. More time is re quired to clear the hoses and spcdi pieces but the procedures should not be rushed for any reason. If it is, then the dock personnel carrying out the pro cedure could be exposed to VCM. Procedure (Refer to Dwg. 119-3 of this Design) Note: Breathing air must be worn during the hose disconnection procedures. This action is necessary to protect personnel from leaking valves on the ships and barges. 1) Close the ship's valves on the end of the hose. 2) ` If the vent recovery sysi-en is not already on, notify the VCM Plant control room (so that they can start their vent recovery system . and preparations can be made at the incinerator) and then start the dock vent recovery system. 3) Purge the vent hose with as follows: DTH 000120321 a) Connect the chemical hose that is on the reel to valve G. b) Open valves A, C, and G. Valves Y, W, and M should already be open. \_y DISCONNECTION OF VENT HOSE FROM SHIP 4) Pressure purge the spool piece as follows: a) Connect a chemical hose from valve F to valve H. -Open valves H, A, and I. b) Open valve G, (valve C should already be open) allow pressure to build in spool piece and then close valve G. c) Open valve F, allow spool piece to depressure to vent recovery system and then close valve F. d) Repeat steps (b) and (c) ten times. Pressure purging in this manner will dilute any VCM that remains in the spool piece. 5) Open valves G and F and purge through spool piece for one minute. This is done to flush out any VCM that may remain in the chemical 1 hoses so that dock personnel will not be exposed to VCM when they disconnect the chemical hoses. 6) Close valve H and A in that order. Then open valve B. This is done to depressure the chemical hoses. After the hoses have been depressured, close valve F and disconnect the chemical hose that is connected to valve F. 7) Disconnect the hose as follows: a) Pull a vacuum on the spool piece by opening valve A. b) Disconnect the vent hose from the ship and install the blind flange on the end of the spqpl piece. Continue to pull a vacuum until the blind flange is secured. c) Close valve A and then close valves B, C, and G. d) Disconnect chemical hose fron valve G. Revised: 2-16-79 VCM Design No.: 119-700-379-CWT DTH 000120322 i j? i i 'Ij,i ijj!`j^$L s]j \ \1j Js /, ^ ; . an OPERATING PROCEDURE DISCONNECTION OF LOADING HOSE FROM SHIP Di scussion The new clearing procedure given below can be broken down into three basic steps. 1) The first step is to flush the VCM out of the spool pieces with No to the vent recovery systein. All of the liquid should be flushed out during this step. 2) The second step is to "pressure purge" the spool piece. This~is accomplished by blocking in the spool piece, building the pressure with N, and then bleeding the pressure off to the vent recovery system. The VCM vapors are diluted by the Ng each time the pressure is allowed to build. This step is performed ten times so that the vapors are diluted to a low concentration and the dock personnel will not be exposed when they break the flanges. 3) The third step is to activate the eductor while breaking the flanges. In the past, the eductor was used to clear the spool piece of VCM but it is now used only to prevent any VCM that may remain in the spool piece from escaping into the atmosphere. The new procedure wn,s developed to reduce employee exposure to VCM while also reducing the adsorption load on the carbon adsorption system. More time is required to clear the hoses and spool pieces but the procedures should not be rushed for any reason. If it is, then the dock personnel carrying out the pro cedure could be exposed to VCM, Procedure (Refer to Dwg. 119-3 cf this Design) Note: Breathing air must be worn during the hose disconnection p-ocedures. This action is necessary to protect personnel from leaking --. Ives on the ship. 1) .Close the control valve on the loading line. Using h'2 from dock, blow liquid VCM in line to ship. Then close the ship's valve and valve Z. 2) If the vent recovery system is not already on, notify the VCM Plant control room (so that they can start their vent recovery system and preparations can be made at the incinerator) and then start the doc!; vent recovery system. 3) Connect the chemical hose that is on the reel to valve G. Connect a chemical hose from valve F to valve H. 4) Purge the spool piece as follows: 00l20323 a) Open valves I, H, G, F, and C. Then start nitrogen flow by opening valve A. The spool piece should be purged for five minutes. disconnection of loading hose from ship b) After five minutes, close valves F and G. 5) Pressure purge the spool piece as follows: a) Open valve G and allow pressure to build, then close valve G. b) Open valve F and allow spool piece to depressure to vent recovery system, then close valve F. c) Repeat steps (a) and (b) ten times. Pressure purging in this manner will dilute any VCM that remains in the spool piece. 6) Open valves G and F and purge through the spool piece for one minute. This is done to flush out any VCM that may remain in the chemical hoses. 7) Close valves H and A in that order. Then open valve B. This is dene to depressure the chemical hoses. After this has been done, close valve F and disconnect the chemical hose attached to valve F. 0) Disconnect the hose from the ship as follows: a) Pull a vacuum on the spool piece by open-ing valves G, C, B, and A. ' Pull a vacuum on the snool piece for five minutes before, proceeding to the next step. This will ensure that all of the VCM in the spool piece and ship valve has been vaporized. b) Disconnect the spool piece from the ship flange and install the blind flange. Continue to pull a vacuum on the spool piece until the blind is secured. c) After securing the blind close valves A and B. \ 9) Purge the loading hose of liquid as follows: a) Oper valves A, Z, D, K,'and L. Valves X and M should alrerd'' ,,e oocn. This will start-ni irogen flowing through the hose to che vent recovery system. b) The liquid will try to settle in the loading hose so it will be necessary to lift the loading hose with the boom to allow the liquid to gravity flow into the spool piece on the dock end of the loading hose. Lift the hose in increments of five feet, pausing eacli time long enough to purge the liquid to the vent recovery system. Continue to lift the hose until all of the hose Ins been lifted above the level of ttie dock and the hose is empty. Then lower the hose onto the dock end close valves Z, X, ard D. OTH 0001203 24 DISCONNECTION OF LOADING HOSE FROM SHIP 10) Disconnect the chemical hose from the spool piece as follows: a) Deorcssure the spool piece on the ship end of the loading hose by closing valve A and then opening valve B. b) Close valve G and disconnect the chemical hose. 11) Depressure the loading hose to the carbon beds by partially opening valve N. (Valve B should be open and valve A should be closed.) The line must be depressured slowly to ensure that the carbon beds are not overloaded. Revised: 3-1C-79 VCM Design No.: 1 19-700-373-C',,!T DTH 00012032 OPERATING PROCEDURE Discussion The new clearing procedure given below can be broken down into three basic steps. 1) The first step is to flush the VCM out of the spool pieces with h'2 to the vent recovery system. All of the liquid should be flushed out during this step. 2) The second step is to "pressure purge" the spool piece. This is accomplished by blocking in the spool piece, building the pressure with and then bleeding the pressure off to the vent recovery system. The VCM vapors are diluted by the M2 each time the pressure is allowed to build. This step is performed ten times so that tlie vapors are diluted to a low concentration and the dock personnel will not be exposed when they break the flanges. 3) The third step is to activate the eductor while breaking the flanges. In the past, the eductor was used to clear the spool piece of VCM but it is now used only to prevent any VCM that may remain in the spool piece from escaping into the atmosphere. The new procedure was developed to reduce employee exposure to VCM while also reducing the adsorption load on the carbon adsorption system. More time is required to clear the hoses and spool pieces but the procedures should not be rushed for any reason. If it is, then the dock personnel carrying out the procedure could be exposed to VCM. _ Procedure (Refer to D;g. 119-3 of this Design) 11 The line between valve W and M has already been purged with nitrogen during the hose disconnoction procedure. Therefore, it is only necessary to pressure 'purge the line before pulling a vacuum and installing the blind. 2) If the vent recovery system is not already on, notify the VCM Plant control room (so that they can start their vent recovery system and preparations can be made at the incinerator) and then start the dock vent recovery system. 3) Pressure purge the line as follows: 'a) Open valves L, J, and I. b) Open valve T and allow pressure to build then close valve T. c) Open valve L and all pressestu: re in line to bleed to vent recovery system, then close valve L. DTH 000120326 1 w J A 1i BLIND INSTALLATION IN VENT HOSE SPOOL PIECES ON COCK d) Repeat steps (b) and (c) ten times. Pressure purging as described above will dilute any VCI-1 that is in the spool piece. e) Close valves L, J, I, and T. 4) Install blind as follows: a) Pull vacuum on spool piece by opening valves S* R, B, and A. b) Break the flange and install the blind. Continue to pull a vacuum until the flanges are secured back together. c) After securing the flanges close valves S, R, B, and A. Revised: 3-1G-79 I)TH 000120327 ~t OPERATING PROCEDURE BLIND INSTALLATION Hi LOADING HOSE SPOOL PIECES ON DOCK Di scussion The new clearing procedure given belov; can be broken down into three basic steps. 1) The first step is to flush the VCM out of the spool pieces with I>2 to the vent recovery systen. All of the liquid should be flushed out during this step. 2) The second step is to "pressure purge" the spool piece. This is accowplished by blocking in the spool piece,'bui Iding the pressure with N2 end tIson bleeding the pressure off to the vent recovery system7 The VCM vapors are diluted by the N2 each tine the pressure is allowed to build. This step is performed ten times so that the vapors are diluted to a low concentration and the dock personnel will not be exposed when they break the flanges. l 3) The third step is to activate the eductor while breaking the flanges. In the past, the eductor was used to clear the spool piece of VCM but it is nov/ used.only to prevent any VCM that may remain in the spool piece from escaping into the atmosphere. The new procedure was developed to reduce employee exposure to VCM while also reducing the adsorption load on the carbon adsorption system. More time is required to clear the hoses and spool pieces but the procedures should not be rushed for any reason. If it is,_ti:e-n the dock personnel carrying out the procedure could be exposed to VCM. Procedure (Refer to Dwg. 119-3 of this Design) 1) If the vent recovery system is not already on,.notify the VCM Plant control room (so., that they car start their vent recovery system and preparations can be made at the incinerator.) and then start the dock vent recovery system. 2) Purge the line between the control valve and valve X as follows: a) Open valves P, E, K, J, and I. Valve P is a 2-inch valve and should be only 1/4 open. If it is opened all of the way thorn too much nitrogen will be used and two things may happen: 0N0 1) The suction pressure cn the vent recovery system will go up because it cannot bar,die the additional nitrogen. 2) o M. r fi at the VCM Incineration Unit oaring ope reckons w: the deck will have to cease be resumed until the unit .Mas stabilized. DTH 0 0 0 1 2 0 3 f -A ~1 .BLIND INSTALLATION IN LOADING HOSE SPOOL PIECES ON DOCK If, after five minutes, there is still evidence of liquid (such as frost on the line) then continue to purge the line until the line is empty. b) Close valves P and E. 3) Pressure purge the line as follows: a) Open valve P and allow pressure to build in the line and then close valve P. b) Open valve E and allow pressure to bleed to the vent recovery system, then close valve E. c) Repeat steps (a) and (b) ten times. Pressure purging in this manner will dilute any VCM that is in the spool piece. 4) Install blind as follows: a) Pull a vacuum on the line by opening valves N, 0, B, and A. b) Break the flange and install the blind. Continue to pull a vacuum until the flanges are secured back together. c) After securing the flanges close valves N, 0, B, and A. 5) After installing the blind, the pressure on the loading hose can be weathered to the carbon beds by opening valves X, N, and B. If the pressure is not weathered off and liquid does remain in the hose, then pressure could build in the loading hose due to thermal expansion. Revised: 3-16-79 VCM Design No.: 119-7C0-379-C:;T PTH 000120329 SAhrDihi procih';jp. 7, ! i f/\s J - S/U COLLECT1G OF Shhl'LFS AT Tile DISCHARGE OF SUIT'S PUT IP Discussion :cr. dev.:n into th roe basic step > r VC * *, usi nq the shi p's \Aimp, throueh the ! tS nl; throng h 0 no o f the c :',**** 1c taps. . cl car, 1 ino up the f lov.' thro ay h the sairnle bomb and collect the samnle mol 0 T, pparat US of 1 '.quid VCi! by blowing e;i. T he man Oil the dock MUSt Oiserace tiic.* valves to supply the nitrogen. 3) The t!il rd step is to remove the remaining VC!', by act.ivav.iiio mho c ductor Again, the man on the cioql; will nave.to operate the valves. After the sample apparatus is clear of vinyl, rc-r.icve the bomb. From the* standpoint of minimizing the load on the carbon beds, this is the preferred sampling procedure because the eductor is used only to clear the sample apparatus after the sample has beer: collected. * Procedure (Refer to 0;.cj: 1AQ--1 of this resign) . 1) Ilal-.e connections between valves A and B, valves i: and H, a:id connect the sample bomb to the sample apparatus. Connect the eductor hose at valve (:. ?.) Line up the flow through the rotameter by opening valves A, B C, F, M, and J. 3) Start the ship's pump. A) Ater sufficient time has been oil'.vied for the sample line to !::: flushed and the vinyl in the i ova meter is clear, line up the flow t!r. oegh the sample bomb by opening wives D and E and closing valve C.S) S) After filling the bomb, stop the ship's pclose valves D end !-. an: open valve C. C) Open valve Vr*1 ^c,i.*j_ blew vinyl out of sampl ing system a: into the .ship vent using ui trngen. on ties!: will have io cuerate L.he valves to supply . nitrogen.) 7) After all of the liquid VCi 1 has boon Mrv..vi bad; into the hold, close valves A and !!. Iron tell the men on the dock t v.; wiui t the eductor. !) n ). . 1 \ . v. L Mu . .4 ,, - -i t>; tt r' D <ii:d C. DTH 000120330 VC:* resign ho. 1 '.0-7C::-A79-w.:;' j , 1 ' Ts sait'U?.?u raocEmiKK coLirci 10;; or samples at a sa?;-5i.it tap j \1 * 3-- Hi scnsr.ion 'v The new sampl ing procedure can be broken down into four basic steps. 1) The first step is to prime the gear pump with t!ie eductor. After the pump lies been primed and started, isolate the sample apparatus from the eductor. 2) The second step is to circulate the VCM, using the gear pump, through the sample apparatus and bach into the tank through one of the other sample taps on the tank being sampled. When the vinyl in the rotameter is clear, line up the flow through the sample bcm.b and collect the sample. 3) The third step is to clear the sample apparatus of liquid VCM by Mowing it back into the tank using nitrogen. The man on the dock must operate the valves to supply the nitrogen. 4) The fourth step is to remove the remaining VCii by activating the edoctcr. Again, the man cr. the cock will have to operate the valves. After the sample apparatus is clear of vinyl, remove the bomb. The load on the carbon beds v:ill be greater when collecting the samples in this manner because the eductor must 'be used to prime the gear pump.. A portable pump could net be found that could pull enough suction to sample the tanks wi Li-out being primed. Once wet, the gear pump will lift up to 26" J In; ho./o'-cr, it will not dry lift over G" 1^0. Dry running is harmful to the gear pump, although it can pump mi .red phase .(air/liquiri) with no ill effects. Procedure (Refer to Dreeing 140-1 of this Design) 1) Make connections batwe bomb to the strap! ip-il a] a) 1. i I'.'.' up the fi ov; throu G. lU.U 3) Prim. the gear pemp by the dock wil l ha.v o to , 4) When vinyl appears in start the gear pu ...p by 1 a no H, a u a a 1 i Ilia i 5) After sufficient time 1 and the vinyl in the n sample bomb by op on i ug 6) After f i 1 1 iir; the Um!: |*uwp by clasir-j v nlv-e DTH 000120331 I 7) 0|)'jm valve C and the pii:"p by-pass (valve >1).' Then blow the vinyl out of the sarpl i ::<j eppnm tus and into the ship's tank usihq nitrogen. The man on the <oci; will have to operate the valves to supply the nitrogen.- d) After all of the liquid VC!i has been blown bad; into the hold, close valves A and II. Then tell the man on the dock to activate tire eductor. 9) Disconnect the bomb at valves D and E. VCI'i Design Do. 1 o0-700-479-CVJT ( 'I DTH 000120332 VCM- ll<r- 7oo -2 7 ( - DTH 000120334 CONTINENTAL OIL COMPANY LAKE CHARLES VCM PLANT LAKE CHARLES. LA. ' A t0 : - x.' Vr A. % A CsyNc\v/ ^ xAs\j> x a ua >- 2L 1.Si <za. O h~ '* i Sz Q ri <r ? =21iii a SJ5W--^5tnf3l^2^OC*<uJAi _J=JI 3cf" Es" 3s-5-5 o: <. tM 22 CO & o T | : o CC ' 3 O A? 2- X X>~\ ' u<** aG 3i DTH 000120335 SECTION II STANDARD OPERATING PROCEDURE LOADING DOCK EDC SERVICE DTH 000120336 STANDARD OPERATING PROCEDURE - LOADING DOCK - EDC SERVICE This section will be added at a later date When the equipment pieces have been installed and operating procedures revised. DTH 000120337 SECTION II VCM PLANT CURRENT EIQ DTH 000120338 Qt-Q FRANK A. ASHBY, JR. SECRETARY DEPARTMENT OF NATURAL RESOURCES OFFICE OF ENVIRONMENTAL AFFAIRS AIR QUALITY DIVISION August 6, 19S1 B. JIM PORTER ASSISTANT SECRETARY Mr. J.A. DeBemardi Conoco Chemicals Company P. 0. Box 605 Westlake, Louisiana 70669 ATTN: Mr. Gary Foshee Re: Conoco Chemicals Company Westlake, Calcasieu VCM Plant Modifications 1. Heat duty for VOI Furnace from 51.3 mm BTUH to 62.5 mm BTUH. / 2. Change in heater and in cinerator emissions as follows in T/Y, Part (-) 3.56, SO? (+) 1.9, NO? (-) 24.5, HC" (+) 0.04, CO (+) 0.29 Dear Mr. DeBemardi: This is to confirm that the permit request for the above referenced project in Calcasieu Parish, has been approved by the Assistant Secretary, Office of Environmental Affairs, Department of Natural Resources, under Air Quality Regulation 6.1.1. The submittal was approved on the basis of the emissions reported and the approval in no ray guarantees the design scheme presented will be capable of controlling the emissions to the types and quantities stated. A new application must be submitted if the reported emissions are exceeded after operation begins. The permit number cited below should be referenced in future corres pondence regarding this subject: Date: August 6, 19S1 Permit No. 1605 T Approved by: BT . ______ Assistant Secretary PMR/lbc dTH 000120339 P.O. PC .v o 32C L.OYC S M s Cali* Charles VCM Plant CERTIFIED MAIL 28094935 RETURN RECEIPT REQUESTED Conoco Chemicals Company A Oivision ol Conoco Inc P O Bo, 605 Westlake. Louisiana 70669 (3181 491-521 1 June 1, 1981 Mr. Gus VonBodungen Technical Secretary Department of Natural Resources Air Compliance Division P 0 Box 60630 New Orleans, LA 70160 Dear Mr. VonBodungen: Conoco Chemicals Co., VCM Plant in Westlake,- Louisiana is proposing to modify the Emissions Inventory Questionnaire (EI01 for the proposed VCf^ Plant Expansion (Permit No. 1424T, approved October 15, 1980, originally submitted Feb. 5, 1980). This revision will update the New Cracking Furnace (Point Source IIC) and the Vent Gas Incinerator (Point Source V-A) for the latest more definitive design data for the expansion. The previous submittals (2/5/80 and 8/21/80) were based on preliminary design data. The revised submittal reflects an increased heat duty for the New Cracking Furnace, from 51.3 MM BTU/Hr. to 62.5 MM BTU/Hr, and a decrease in the particulate matter and nitrogen dioxide emissions from the Vent Gas Incinerator. The net changes in total emissions for Furnace and Incinerator combined are minimal as shown in Table I. Also included with this EIQ submittal are updated emissions for existing Cracking Furnaces IIA and IIB. The revisions are merely a correction in the heat duty from 51.3 to 59.4 MM BTU/Hr. to reflect actual maximum firing rates and the use of the corrected AP-42 emission factors (revised 4/77) in the computation of emissions. The emissions to be reported now show a decrease for all pollutants with the exception of S0? which increases as shown in Table I. It should be noted that no revisions nave been made to these point sources, but the increased duty is only a more accurate reflection of maximum historical operating capabilities. Please find enclosed a check for $270.00 permitting fees. Also if there are any questions concerning these revisions please contact Gary Foshee at (318) 491-5062. Sincerely J. A. DeBernardi Plant Manager DTH 000120340 uj O CJ?. *--* < rr uj <-- < o zc h-- O OO LxJ O o< o ^S s: i-- 33 < CO uZ3 MM 0X0 LU 33 h-' LU 03 X zz o o Li- < G C_> zr CO LU o rr co --o <: CO 1-- J-- LU IT CO LU C <C02U Q- -- 2Z x s: ^ LU UJ CO o o rr cn in in o CM o co 1 + r CM o + o + 1 VO o O VO CM in cn in o ro o ro r-- *3" o O i + CM 1 1 1 CM VO oo r"-" vo oOo o oo + +" Q C 2= O < 1-- -J < < 2 uj c; h UUUA o z< zp M rr *-- uj ujc; uZ O LU = t-- => Ll_ Z ~ >S-3 oo o cn rs* VO r-- oo CO o LO S CM in N wEClrtO cn p-_ r_ > O Z < <-J CTY in r-M OO p LU Li. -- CO OS iS <_> y-- <2 OS LU o> UJ OS LU y O 32 H* --11-- *5 < t OS f-- OS LU C OU. z Q MU. 1-- UJ o o z CO CTY X cn CO mazz o ry VO o CM o z lu i-- --i SB CM in VO LO LaUs M i-- i< uj Ur t-- c cn cn in p* oo o os --> c z r^. DSTCSLU ucsu> r- LU CL 3 O LU z z< TABU SUMMARY OF EMISSIONS CHANGES CONOCO CHEMICALS CO. VCM PLANT EXPANSION ANNUAL EM ISSIO NS, TONS/YR. Q UJ 1-- UJ 1-- Q LU UJ o MM X O UJ MM o aUJ Ml X O CO X o MM 03 H* O o 2Z o 1-- < MM CO c 2T --1 Q 23 03 rz I-- 33 O a: LU CO < C_J rr LU 33 __1 __1 -- 33 u. __j oos >-- CO o MM CsL U >T~ o a. Ou ZD OO -- 33 >31 C o MM >  Wn<*'r5* '.< DTH 000120342 SN LOUISIANA AIR CONTROL COMMISSION ?. 0. 3cx 60630, New Orleans, La. 70160 Telephone: (504) 527-57J9 EMISSION INVENTORY QUESTIONNAIRE (Revision of 11/74)P.ioe 1 of 9 CHECK ONE 0? THE BLOCKS BELOW: CONOCO CHEMICALS COMPANY This inventory includes only presently existing emissions. (name of company) (21 This inventory includes both CONOCO INC.________________________ _________________________those old emissions ("expected to be still existing)and those pro (parent company; if above is a division) posed additional emissions in Submitted by company on _________ MAY 28. 1981 (date) cluded in our permit request for ___________ VCM PLANT EXPANSION (type of new facility/modification Please file a separate report for each of your plants physically located in Louisiana. This which was submitted to the com mission on 7/S/P0 (date) and which new emissions are to be inventory covers the following plant location: existing by 11/1/Q? (date). _________ CONOCO VCM PLANT (plant's name, if any) ____________WESTLAKE (nearest town) ____________ CALCASIEU (parish of plant site) INSTRUCTIONS: Keep ihz original of this form; retvJin a photocopy to this agency. Vo not write information in ihz top on left side margins of this form, cs file foldza. binding* may cove* thz information. We have tried to ask only fok thz Information z nzzd, please do youJi best to answer each, question. Qua. authority to ask for this information is contained in R.S. 40:2201 zt sec. Copies of this law arz available upon request. Air pollutant emission data provided on this form shall be available to thz general public, without exception. All ether data and information provided on this form and attachments shall also be available to the public, except that upon a showing satisfactory to the Technical Secretary that suck other data and in formation, if made public, ivould divulge methods or processes entitled to protection as trade secrets, the data will be kept from all persons other than employees, or other agents, of the Louisiana and federal air pollution agencies. (1 Confidentiality of all information, except the air pollutant emission rates, is requested, and our justification for this request is attached to the back of this form. (Check the b'iocx if tnis is the case.) If certain questions are not applicable, indicate "none" or "not applicable" (M.A.J. Terms such as "not significant", "nil", "trace", "negligible", etc. are not accept able. Please attach additional sheets if more space is needed. An updated report should be submitted in the future when the annual emission rate of any pollutant from any stack changes more than 1071 from reported values._________________________________________________________________ ITEM 1 . . . ORGANIZATION ACTIVITIES A. Circle any days of the week normally not operating: M Tu W Th F Sat B. This facility, as a whole, typically operates ^ 341 __days per year. The peak production season is w. The facility normally operates 1 Q 2 0 3 eight hour shifts per specify the hours normally worked per day.___ 2. Approximate number of employees at this location is_ 10 Sun day, or DTH 000120343 s> EMISSION INVENTORY QUESTIONS IRE /Revi r-ed 11 / 7^% __________________ Page 2 of 9 F. If the facility, as a whole, operates intermittently, give details on the lines below:_______________________________________ ___ G. Ownership of facility. Please check one of the following: corporation, partnership, or sole proprietorship D city government state government other, specify regulated utility federal government H. Please check off, or write below, the descriptive operation: lumber industry chemical industry pulp paper D natural gas industry cement industry petroleum industry lj p3x*ticIcooard sugar cane industry plywood other, specify name which applies to your asphaltic concrete fertilizer metals industry fish meal brick making I. Please give possible sources a very brief description of your opera of air pollution. Sier to attached Cprioocness, s woitehscermipptihoansis(,Spnecafinovn TT II and Section III). 4 ITEM 2 . . . FUEL USE BY FACILITY AS A SKCLS Check one of tha blocks below, and supply information as requested: l thi* invznt&Ly i* fax "pxe*ently existing" condition* {cus checked fa ox page. 1], piaue g-cve ike infajumtion xequested below Hie latest 12 month pexiod fax ukiah you have data.. 'Data fax the 12 months ending Mo nth t Veax: (&ill in} ha* been given. fatux e use i* c'pzcted to be matexiatiy al^exent [athen! than a* outlined in a cunxent pzjuait xequezi) give detail* on a sepxxcte sheet. 09 7 this Inventoxy i* being submitted in conjunction with a veAjr.it xeoue*t la* checked on page 1}, please give the annual consumption note* expected fax ike total plant fax the 12 month* failotoinn the date the new Qudlity cx modefalcation become* operational. Thi* date Is UStea on page 1. Type of fuel Natural zes Process gas o. 1 to 4 fuel oil ^o. 5 or 6 fuel oil Bark/ wood chips Coal (specify ash 7. & anthracite/bituminous) Ocher Annual Consumption Sulfur 7. Heating value (ii = thousands') (bvveicriti 57 mil lien cubic feat M ora i n/:-`5Cf) MM BTU/ MM ftJ P10 :c 111 i o n c u b i c feet rlH0 ar?.i n/MSCF 1 MM 3TU/ MM ftJ 3173 M caller.? .. . rail?-? r "- .... 0.75 * MM BTU/ M nal MM BTU/ M gal MM BTU/ ton zor.s MM BTU/ ton ; MM BTU/ ww tTU` DTH 000120344 f:*otr EMISSION INVENTORY OUESTIONNAIP.E /Revised 11/74) Page 3 of 9 ITEM 3 . MATERIALS USED, PRODUCED. STORED, OR TRANSPORTED 5Y TOTAL PLANT A, Raw materials or materials being trans ported Name of material _ Plhvlene ... Chlorine Oxvaen Ounntitv used or transported How stored How moved Annual Hourly Hourly (Be specific - (Pipeline, average average maximum floating roof tanktruck, (give tank, fixed etc.) units) lb/hr lb/hr roof, etc.) 492 MM Lb 59.767 62,682 INot Stored Pineline 750 MM Lb 91 .108 95,552 iPressure Tank ci nel i ne/Rai 1 c. 13.125 MM 1 .709 1 ,792 Not Stored Pineline Lb 1 B. Products or bvoroducts Tntermpdiate Products: _ 1 -.1. Hvdroaen Chloride . 528 MM Lb 64,140 i 67.269 -2. .1.2 Dichloroethane . 1.663 MM 202,038 1211.894 Lb 1 1 1 'Pressure Tank | Pioeline INitroaen Padded 1 SniD and iFixed Roof Tanks! Railcar. Final Product 1. Vinvl Chloride Ill i 1,000 MM 1121.477 i127,403 !Pressure Soneres Snip, rail- 1 Lb j ! 1 car, or Dine! ITEM 4 . . . EMISSION INFORMATION ON THE ENTIRE PLANT AS A WHOLE The nates given should cjonne&pond, In mo6t cases, ta the sum o<$ the Individual avenage nates o the point sounces listed In the. Item 5 page* &on each type o ala pollutant. A. PARTICULATE SOLIDS OR LIOUIDS soot from combustion mineral dust other, specify: other, specify: other, soecifv: Material name Emission rate (if must specify) lbs/hr 1 19.13 ! i i i Emission rate tons/vr P,3 97 B. ORGANIC GASES OR VAPORS alkanes/ paraffins Methane and Ethane alkenes/ olefins, specify: aikynes/ acetylenes aromatics, specify: alcohols, specify: other, specify: Haloaenated other, specify: Haloaenated 1,2 Dichloroethane Vinvl Chloride other, specifv.Other Haloaenated Ma terials i 1 1 I 1 | 1 C, INORGANIC GASES OR VAPORS sulfur dioxide hvdrogen sulfide carbon monoxide nitrogen oxides mmonia haloeens, specify: organic sulfides (except H-S) other , spec!fv: -____________ SO- _________ _______________ 1 CO 1 NO- i i HC1 and Cli" 1 ' 1 i~ I 1.15 1.61 2.5b 0.05 17.1b 4.3p 51.83 99.19 03 /.Ub ms 0.28 /U.J3 T02 220.47 434.69 DTH 000120345 EMISSION' INVENTORY QUESTIONNAIRE (Revised 11/74') Page 4 of 9 OTES TO ITEM 5 Please read all notes before attempting to fill out pagc(s) 6. 1. Use any number you wish, but please be consistent in identifying this point by the same number on calculations, maps, future correspondence, computer printouts, etc. 2. If the emission point Is not a vertically discharging stack, or if there is no clear-cut point of emission (e.g., dust from moving equipment, multiple leaking valves, evaporation from storage tanks, etc.), put a zero in this column. 3. Give the inside diameter at the top. For non-round exits, use the equivalent di ameter, equal to 1.128 tines the square root of the cross-sectional area at the point of discharge. Diameter, volume flov rata, and exit velocity must be consistent! 4. A "boiler", for purposes of this form, is to be understood to be any combustion device which heats a fluid and is separated from such fluid by a partition. Thexefaoxe oil heatZKA, VowtheXm heate/iA, etc.. CLXe included. Internal combustion engines and incinerators are not included. Direct fired kilns are not included. 5. Enter the proper code number, taken from the list below: 000 No control equipment 010 Electrostatic Precip. 040 Alkalized aluminia 001 Wet scrubber, above 95% efficiency 041 Dry limestone injection above 957. efficiency 011 Electrostatic Precip. 042 Wet limestone injection 002 Wet scrubber, 80% - 95% efficient 043 Sulfuric acid plant, 80% - 957. efficient 012 Electrostatic Precip. contact process 003 Wet scrubber, below 80% efficient 044 Sulfuric acid plant, double below 80% efficiency 013 Gas scrubber, general contact process uQ4 Gravity collector, 014 Mist eliminator 045 Sulfur recovery plant use * above 95% efficiency 017 Fabric filter 046 Reduced emissions by 005 Gravity collector, 019 Catalytic afterburner changing process 80% - 95% efficient 020 Catalytic afterburner, 047 Vapor recovery system 006 Gravity collector, with heat exchanger 048 Activated carbon adsorp below 80% efficiency 021 Direct flame after tion 007 Centrifugal collector burner 050 Gas absorption column, above 95% efficiency 022 Direct flame after packed. 008 Centrifugal collector burner with exchanger 052 Spray tower for gases 80% - 95% efficient 023 Flaring 053 Venturi scrubber for gases 009 Centrifugal collector 039 Catalytic oxidation - 049 Liquid filtration system below 80% efficiency flue gas desulfuriza 051 Gas absorption column, tion tray-type 6. Give the percent by weight of uncontrolled emission removed. If unknown, leave blank; if there is no effective removal, enter a zero in the column.7 7. Enter the number of the method used, as follows: (1) By actual stack test (2) By material balance. provided that this method is applicable. (i. c. , ikiA method, obvlouAly cannot be uAed whexz the inaccuxacleA in mecAuxenent axe equal to ok gxeatzx than the absolute magnitude the lo66e&. Art excr.cie c& pxopex uaz would be uhexe solvent e/niA&iorA axe not dlxectly neaAuxed, but all solvent puxchaied Ia eventually to&t to the atmo&pkexe, and tkcxe&bxe matexlal bought divided by opex- :ng houxA equalA lo&A xate. ) (3) By the use of E.P.A. emission factors. (See the "Compilation or Air Pollution Emission Factors", E.P.A. publication AP-42) (4) By making a conservative estimate. (5) By the use of emission factors other than those supplied by the E.P.A. DTH 000120346 EMISSION INVENTORY CUE ST TONNATES f R r> y { <; d 1 ] / 7 i I Pace 5 of 9 NOTES TO ITEM 5, CONTINUED (-continuing with note 7:) (6) Use this number if and only if you are submitting this form in connection with a permit request, and the emissions referred to have no present existence, but are simply the result of design calculations. (7) Sources ceasing emissions must be reported on one inventory document after they cease operation (see note 8). Emissions will be zero, and a number 7 should be placed in the "emission estimation method" column. 8. If this particular pollutant, from this particular stack (point source), was not included in the stack or point source information submitted on your last Emissions Inventory Questionnaire, or if this is the first Emissions Inventory Questionnaire you are submitting, WTite "add" in this column. If this particular pollutant, from this particular point, was Included on the last Emissions Inventory Questionnaire (EIQ) submitted, but the amount has been in creased or decreased (to other than zero), write "change" in this column. If a point source has ceased operation since your last EIQ, the pollutants from that point should be reported as having zero emission rates on next submitted EIQ, and you should write "delete" in this column. AFTER A VELETTOH HAS BEEN ONCE RE PORTED, VO HOT REPORT THE P01HT AT ALL OH ANY FUTURE ElQ_'S AMD VO HOT USE~THAT POINT'S 1HVEHTIFICAT70H (IV) HUMBER IN THE FUTURE FOR AHY OTHER POINT. 9. Report the concentration of particulate matter only for incinerator flue gases, in grains per standard cubic foot of dry flue gas. (See Regulation 20.6.1). If this point is not an incinerator flue, write "N.A." in the column. Report SO2 concentra tions for any stack in which it is found, in PPM by volume at standard conditions. Stack exit concentrations need not be reported for other pollutants. 10. If the hydrocarbons being emitted are of unknown type or have been obtained~froa emission factors which do not indicate the hydrocarbon type, simply report the data requested on the line marked "hydrocarbons". If, however, you know more about the specific hydrocarbons being emitted (for example - that they are non-methane hydro carbons , or that they are paraffinic hydrocarbons, or that they are, say, 20 weight 2 alkenes with remainder paraffins, or if you know the specific name of the hydro-.-, carbon being emitted, say, benzene or methanol or methylechvlketone or whatever) please leave the line marked hydrocarbons blank, write in the name or partial iden tification of your specific hydrocarbons in one of the blank lines below, and give the data requested on that line. 11. Report the fuel charging rate, if any, in units of KM ft^ (million cubic feet) for gases, M gal for fuel oil, and tons for coal, bagasse, sawdust, etc. Report the process materials charging rate, if any, in units such as M Bbl. (thousand barrels), tons (of material processed or produced), tons (air dried unbleached pulp), M gal (storage capacity of tanks; breathing losses), etc. Please telephone us and ask if unsure of what units to use. Do not list air or water as "process materials". In determining rates, do not include any recycle amount unless asked to do so, in general the rates should be determined on a "fresh feed" basis. For storage tanks, list separately under "Name of fuel/ process material" the two catagories of breaching losses and working losses. The "rate" of the breathing loss determinant is M gal (storage capacity) and, of the working loss, is also M gal (throughput). If any one pollutant type (i.e., SCb, particulate matter, ecc.) is emitted from more than one stack (or other emission point) serving the same piece of equip- ent, please explain briefly on the reverse side of the page 6 subsheet, and write See reverse side" prominently ac the bottom of toe form side. 000120347 DTH ITEM Nv.. 5EMISSION INVENTORY QUESTIONNAIRE ( R e v v ed 1 1 /7 4 )f a ge 6 o 9 (SUBPACE NO. 1 OF 8 ) T h is page is to be used to re co rd the d a ta from one s ta c k (o r o th e r em ission p o in t) o n ly . Photocopy th is page as many tim e s as th e re a re in d iv id u a l e m is s io n p o in t s , and U3e one page f o r each p o in t . N ote t h a t th e s u b s c r ip te d numbers In d ic a te e x p la n a to ry notes on pages 4 and 5. X C*4 O 4) o u CaO u3 CO Z<0 o-- y a aS c4oJ 4aJ u a M<0 *o X4oC-1O OLO ^ CO U iM a *cJo aCM CM CO ^ u C^O LcrTi -C 41 cMo O>2 CJ ^ =a T3 Cl >L 0(A1 c Cl C6L M 3O* O o <: u LtJ s i " o= a> M<o 4W-1 A CML (MA o<sJ M 2c_2> 01 >> a .a UCLl *-4 O3 LOi -9 <r oa (Q <A| L* *** jtf] L 4) cOl o CSl -Ao3hJfit| >2...i|. :s -yx M 3.1 Cl Cl <go * ca. l-- ^...... w co | cal >\ o c -= li a _ z >H u -i-=S CIA CL > | iwO oH /> Cl so ^ -- CM* 4J *UMS O G3.-43-1 f0-H Xc3.'oCOvr-! 03 0 nc3 <u3 XLi UO uO 4- 1 X Li v-/ <30 ACJA 4-1 MI >s C 3 Cc -oM iI co l Cl! 3 I cm 8-t CL CQ }0 Cirf CM 01 0>) LI a3i p-H i-4 <0 i <y CO Cl 3> 3CM >C> a C3L iU I "L 4J 01 t-4 "3 CO cm 30 xj x-s a CW 3 M r0a - jQ a 3 (/) -M 3 o w iM cm -OO 3 CO CA a> U o CO X XoOJ <3 -3 CCAl 3 o< 3 L-4 iM o x(-As -3 x MCJ 3 V4 _^j 2 ^ Cl CL 4J *3 >w : CM UL ocnc <r o HCO o CHQ sO O a; o o "O CLTl, 3 01 .a KTi CtDo CA Cl *(H0 C>%L ^ c? CM JCCl - cc CM n (a >\ CO L4 M ^a C<3l 4J C u x Cl W Cl > Cl Cl <A Li LTT CX c &0 O3 XCl CA O(A <3 CO w L | kn co ea> -- >s >s MC O *3 -mC c uO f-4 5 3 <u m --< cr 4J -M o ci o LUbc Cl CC<3O 40-1 .3 01 U a CO Cl <*3 oS-i Oo c o 3 i-i O 4J O3 CAgO MM3 UL2 DCCAl iCcll m CM (CO T m 3 O Li (A >i c Li c Li CM LO m d :: aCA X3 ZC cn 5 Cl 4cJi O L^i -^-I! CH=J o o CM yo 4J 73* a" 2 =1=1 4J 3 C3i o uu o Ccl CL M3 O' HCl CL1OM44 o 01 CJ 2 4J Mo M MM3 o uu c 3 ri CM3BL o Q cr Cm o o ooo CD O ZD BSE " o CA u vs C CJ 3 CJ (0 oU3. CCA* MC3 Q jux<3: M CO M 3 McC3; u --o MM -3 xcJs t3s C w M uw nc 'i-e*. L4-JI o __ ur~ O 4J 3 C^l ^M <3 OCL M c do c w! X Mo i3 C *31 C ft U= CU-*l C- Mi Cj c Ml Li "dJ *-*! C!.r u ul u Li U| V.J o 4C.ll ^ *j 4&-1 M e3 *Me X P3 Ln_i C_) Sf>-MO u nL MCcO Zu 3fV. ^CTi CO Wa Xo Li > Li > u > L L> L Mtn 1LO-4i MCl 3es <CC Cl *-<(_U-5 Urn ^3 O s H-* in O CO fM CA ^ UOCJ LCPJ3l Li CO 1H U 4CJl Q. Li *CMA n e O r-4 J43J CC3Ml ja>> CCAA OLOC.l u<<t/xi t3 Cl O --Li U> *--o^Z*1 aw 4J -coj n3c Cl >H -o3 au CL_ CJ 3CJ L3U >> cm cm rC~J o L-- os c CCCJ 2 --------------- -- U 4-1 >--*i cj a23 Li o lm 3 cm *h5. i O 3cr* >> C 01 Li Cl 4oCJO (A r-^ iMC3l 3 J0=1 4oJ aM C*MM o u 3 a UH -3 a r40-11 h0M1 O>\ *cH 4-1 4J c rQl UM4 CL y-i. LOi -c0o1 M 4-1 C 40J) c CJ r-soH Cl oL 5 Li TC(3AJ >j a o juz go o CaL CA i-4 0M1 C3 CJ H t4l CL 01 U H 3 - 01 u 0 u C3 3 3cr U 3 CJ pCD- CO to LVaii 3 L-i cr CJ r-i 5 4-1 Co>M-i <o_i MCA -4CC-1l X 'Ll u<uCA o ^4 Ma Cl X4-1 Li --< *0 M*CcMO Li x4a-:1 1-4 CJ ooa LO * TZ (a3A 4wcM-11 <c i-CDi a i*4 mLi C9 Cl 4-1 4 o ou LCi i-l Q M 3 ^W3S M CJ C3M 3 eO Li cm U 01 XJ CM o 0c1 o3 U 3 "O MC3l a CJ -* 6 o u to c uM a pH o -3 -3 M C>l MO m <h ^ >i cc j CccCCAlLI dCJ. 4o-1 oc 3 -3 CA iA o Cl L O 4aJ X01 0oC19 3aCO. ,,__ c DTH 000120348 DTH 000120349 DTH 000120350 DTH 000120351 o DTH 000120352 1 / 7 A ) P a g ev i st'L'EM n o . 5EMISSION INVENTORY QUESTIONNAIRE (Re ed 1 6 o f 9 (SUBPAGE NO. 7 OF 8 ) d DTH 000120354 T ills page Is to be used to re c o rd the data from one sta ck (o r o th e r e m issio n p o in t) o n ly . Photocopy th is png ns many tim es as th e re a rc in d iv id u a l e m is s io n p o in ts , and use one page f o r each p o in t. Note th a t tiie s u b s c rip te d numbers in d ic a te e x p la n a to ry notes on pages U and 5. ITEM N\. 5EMISSION INVENTORY QUESTIONNAIRE (R e v is e d 1 1 /7 4 )Pago 6 o f 9 (SUBPACE NO. 8 OF 8 ) T h is page Is to be used to re co rd the data from one s ta c k (o r o th e r e m issio n p o in t) o n ly . Photocopy th is page as many tim es as th e re are In d iv id u a l e m is s io n p o in ts , and use one page fo r each p o in t. Note th a t the s u b s c rip te d numbers In d ic u te e x p la n a to ry notes on pages 4 and 5. DTH 000120355 EMISSION INVENTORY QUESTifiNNAIRF. (Revised 11/74) TEM 6 . . . PLAi^T LOCATION FOR AIR POLLUTION DISTHRSION MODELI NT, Pare 7 of 9 Give below the Universal Transverse Mercator rone number and Universal Transverse Mercator (UTM) coordinates, to the nearest one-tenth kilometer, of your facility. We must have this information since we are required to report it to the U. S. Environ mental Protection Agency for vide area dispersion modeling purposes. The coordinates can be obtained from most U. S. Geological Survey maps, scale 1:24,000 or 1:62,000 for your particular area. These maps, if not already in your possession, may be found in your local library, or can be purchased from the U. S. Geological Survey (USGS) at the address shown below for 75C each (1974 price). An index of all the maps available for Louisiana, together with prices and detailed instructions' for ordering, may be obtained free by addressing a request to: U. S. Geological Survey, Distribution -Cent-er, Denver Federal Center, Bldg. 41 Denver, Colorado 80225 If the map has the Universal Transverse Mercator (UTM) coordinates listed, it will have the UTM cone number mentioned among the writing along the bottom of the map. This zone number will be either 15 or 16 for Louisiana. Please note, that latitude, and longitude axe. not^ what we need, and that the USGS maps do not show UTM grid lines as they do latitude and longitude; however, tick marks along the edges of the maps do indicate the UTM grid locations. A straight edge must be used to connect tick marks at the opposite sides of USGS maps when interpolating between UTM tick marks because the map grid is drawn on the latitudelongitude system and, therefore, the UTM grid may appear quite skewed. For the scales :ntioned, tick marks appear for every 1000 meters (1 kilometer), with every fifth tick mark and the tick marks nearest the southeast and northwest corners of the map 'giving the value in meters. The 1:24,000 scale is preferred to accurately locate the facility, but the 1:62,000 scale may be used if the 1:24,000 scale map is un available for your area. For example: The state capitol building in Baton Rouge would be: UTM zone No. JL J5 horizontal coordinate: 6 1_ 4._1 Km. E vertical coordinate: 2 2 2 2*2 Km. N Your facility: UTM zone No. 1___5 horizontal coordinate: A 2 2.'3. Km. E ITEM 7 . . . COMPLIANCE STATUS vertical coordinate: 4 _._5 Km. N Cheek one of, the blocka below, regarding ycu/i facility' 4 " Ccr.cZlance Schedule": fp(Such a d ocument has not been requested of us, so far as we know. Such a document was requested, or submitted, but we haven't yet received noti fication that it was accepted at a public hearing by the Commission. O We were notified that the document was accepted at a public hearing; no schedule of actions to achieve compliance was necessary. Q We were notified that the document was accepted at a public hearing; our sched ule of actions to achieve compliance by ____ (month), 197 _ (year) was approved. The jst recent "increment of progress" date in our schedule of actions was achieved (mor.th)____ (day) 7 _ (year). QyOU MUST FILL IN THE DATE BLANKS IF YOU HAVE CHECKED THIS PARAGRAPH^] OTtt 000123B EMISSION INVENTORY QI.'EST I ON" .'A IRS 'R-> ;:-< r \\'7Z) Pa?B of 9 :em p . . . refuse collection .-.md dcepc'S.-l f A. Amount of combus C in le refuse disposed of per yzzr:_________5_9_1_5___T__o_n_s___________________ (give cne applicable units) B. Description of refuse; check off applicable categories: _ P_a_p__e_r s_c__ra__p -- -Ru.b.ber temp Co Wood scraps L sawdust G Wee Marbase or animal wastes dS Other, specify:. Rubbish c. Method of refuse disposal; check off applicable cacagories: Q City pickup O On-site dump On-site incineration dS Contractor pickup Cn-sitc outdoor burning On-sita landfill Other, specify:_____________________________________________________________________________________ D. If disposal is by contractor pickup, rive chr? nape., and ad.dr.es.a of .the contractor: Browning-terns Industries of Louisiana' Inc. Solid VJaste Division-cities oervice Highway - Maplewood, LA 70563 E. The on-sice incinsra S No on-site incir.er Single chamber Multiple oh srr.b *r if any. ras cha following design features: G Arce.rbu ears G Water scrubber installed Primary secondary Waste material disposed of G burners 1 ns t el lad- by burning in a boiler F. Incinerator equipment data (if applicable): Manufacturer:NA_____________________________ ________________ Model: Capacity:Installation date: . Auxiliary fuel used: \tyce, how used, rata of use)________________ ITEM 9 SUPPLIESXTAET INEC?.MAT TON A. Plecuz zupplij a uizlt pcot plan on mao iVfUc.ii zhosz the locullonz oj ztackz foh. othzn. zctin.ce*s) , tcgzthzn. tcito. t:\z zoiui.cz Idzvv'zL^lizatLon num'oejiz {.'ton Item 5, the. plant bou.ndcui.Lzz, a dJUtjxn.cz zaULz, cod t.:z riuuzcxlon tionil1. Plzcjz cJLzo zhoiv, on a. zzpcuiatz dlcugnam l{, nzczzzcA.;;. tiu1 -Loccz.Lo.-i c j thz plant 1st stelation to nza/izz-t hlghuxxyz, n.zzJjdzntlal cuiqjxz , and Lounz. f-xt-zch the mapz to thz back o tfuz {onm. B. Approximately how much money have you spent on air oollution control equipment and operation in the past 10 years? Equipment $15,500,000Qpera[-On $ 2,930 ,U00 ITEM 10 TOXIC SASH3 A HAZAnnO'JC MATERIALS A. Are there any substances used or p rocuced in your facility which could cause itnmediate injury to life or property, i_f thev were emitted .to the atmosphere, which are not already listed in this form as one which is presently being emitted to the atmosphere? (e.g., chlorine for water treatment, toxic gases, gases used as catalyses, etc., which ordinarily do not e scape) Please list such substances below. If none, please so state. __________ __________ B Does your facility use or produce asbestos mercury (other chan laboratory use), beryllium in any amcur.C whatsoever If ins or is vos, give decaf it bnlev r on v. parate sheet. If answer is r.o, please write ho" below: _____ mo DTH 000120357 ryusiPN I'.vtnto.-.y citittr-o.itit r^d -- r* O *" 0 ii . . . ttfspnnti. a cbf.ttficatton A. The nnnnc.pr of the facility, on 1 oca: i or.- at the pl;i.it /-.(tc, is os follows: Name : Title: Name of Company: Business street address/ F. 0. Box: City or town, parish, Zip code: Business area code/ telephone No.: J 2.^5 5 A. 00 if C ^ ri ardi . PI er.c !`iSnaccr - VC" Plant LOhOCO ur.emica i s Lorn,canv . A Division of r ^ ^r> inr. P. 0. box 6 05 Wes:iake. LA 70669 31c ''W-Pi-SOt-A 9. Person to concoct at the site o the facility about air pollution control, if different from the above: Sa~.c: Title: Business telephone No./ extension: Garv [_. Feshet Chief Process Enemoer a i a r r: C. If the company's air pollution control correspondence and documents are prepared at a headquarters office, at a different site, give the information on the person to be contacted below: hacc=: _Mike Haves Title: Director of Environmental Control Conoco Cnm cels Company B iness street address/ P. 0. Box: .y, state, Tip code: P. 0. Box 727 west i a.-: 2, LA 70 559 .'sir.ess area code; telephone No.: 31c/Ar2-5 ^36 D. Person who prepared this report: Name: Title: Firm: (if prepared by a consultant) Company: (if prepared in-house) Street address/ ?. 0. Bex: City, state, Zip code: Area code, telephone , extension: do Or.Z Co' the above. jiLSi check appropriate black:) O A. 3. C. Virgil M. Fisher Process E nci r.eer Coreco un 2 ~icals L. * 1 M ar.v * U Zj 0 X sj Wesci a.-:e. LM 3lb/-ri-a u J / 70 o5 ^ ' -` - CERTIFICATION, x czrJtiiu, tti'd.V'- -the previhionj, in Louisiana and United S-tatCA lav loiizh provide cririvsJ. pcncitid, jOA. iaiic i-taier,znti, that this E~iizion PTH 000120358 A 'i SECTION II VCM PLANT PAST EIQ .7 * iv - DTH 000120359 LOUISIANA A72 CONTROL COMMISSION P. 0. Box 6063V, New Q.rlexns, La. 70160 t Telephone: (504) 527-57T9 EMISSION' INVENTORY QUESTIONNAIRE (Revision -of CONOCO CHEMICALS COMPANY (name of company) CONOCO INC. (parent company; if above is a division) Submitted by company on February 5> 1980 (date) Please file a separate report for each of your plants physically located in Louisiana. This inventory covers the following plant location: 11/74) p,,,,P i of Q CHECK ONE Or^KE BLOCKS BELOW: Drhis inventory includes only presently existing emissions. SI This inventory includes both those old emissions ("expected to be still existing)and those pro posed additional emissions in cluded in our permit request for VCM PLANT EXPANSION (type of new facility/modification' which was submitted to the com mission on 2/5/80 (date) and which new emissions are to be existing by 11/1/82 (date). CONOCO VCM PLANT____________ WESTLAKE______________ CALCASIEU______________ (plant's name, if any) . (nearest town) (parish of gl_anc sitej_ INSTRUCTIONS: Keep the. oniginal of this fotm; return a. photocopy to this cjgeney. Vo not wrote information in the top on. left side trarg.ins of t'ois form, as file fold-t bindings may coven the information. We have tried to ask only fan. the Infafixation e need, please do youn. beat to answer each question, Our authority to atk fan. this 'hfonmation is contained in R.S. 40:2201 et sec. Copies of this law one available upon request. Ain. pollutant emission data pnovided on this, fa/on shall be available to the genenal public, without exception, til othvi data and in.fanxati.on provided on this fafun and cticchraei'its 6 hall alto be available to the public, except that upon a. showing satisfactory to the Technical Secretary that tuck other data and in formation, if made public, would divulge methods on. processes entitled to protection a6 trade secrets, the data will be kept from all persons othen. than employees, on. othen. agents, of the Louisiana and federal air pollution agencies. fxl Confidentiality of all information, except the air pollutant emission rates, is requested, and our justification for this request is attached to the back of this form. (Check the block if this is the case.) 11 certain questions are not applicable, indicate "none" on. "not applicable" (N.A.). Term*, such as "not significant", "nil", "trace", "negligible", etc. are not accept able, Please attach additional sheets if more space is needed. An updated report should be submitted in the future when the annual emission rate of any pollutant from any stack changes more than 10Z from reported, values .________________________________________________ ____________________ ITEM 1 . . . ORGANIZATION ACTIVITIES A. Circle any days of the week normally not operating: M Tu W Th F Sat ". This facility, as a whole, typically operates 341 days oer year. . The peak production season is N - A . ___________________________ _ ,0. The facility normally operates Dl 0 2 El 3 eight hour shifts per specify the hours normally worked per day. E. Approximate number of employees at this location is________ 7IQ Sun day, or .-- DTH 000120360 EMISSION INVENTORY 0 iJESTIONNAIRS /Revised 11/71.) Page 2 of 9 F. If the facility, os a whole, operates intermittently, give details on the lines below: G. Ownership of facility. Please check one of the following: 2 corporation, partnership, or sole proprietorship deity government statu government ocher, specify.~ * Qregulated utility federal government H. Please check off, or write op eration: (2 chemical industry P natural gas industry petroleum industry sugar cane industry other, specify _______ below, the descriptive lumber industry pulp & paper cement industry particleboard plywood name vThich spplicc to your asphaltic concrete fertiliser metals industry fish meal brick making I. Please give a very brief description of your operations, with emphasis on any possible sources of sir pollution. Refer to attached process description (Section H and__ Section. .U.1L_____________________________________________ . . ________ ______ 1 i ITEM 2 . . . FUEL USE 3Y FACILITY AS A K-IOLE Check one of the blocks below, and supply information as requested: I thiA J-iVjerJt&uj Za ion "pneAzntZy exZAtZng" corditZorA icu chcckzd ion. p.igc 1], pteoAz give the Znionr.icU.Lon nzqu.zjiZ.zd bcZcw ion. thz ZrzZz&t 12 north pznZjod ion ukick you luzvz dctc. ViUs. ion the 12 rr.orthA ending Month:Vzxn:1{ZZZ in) hiu been gZvzn. Ii {xtunc vaz Za expected to bz mzze/ixrUty cU{{cncrt (other than oa outlined Zjz a cunnext pc/if.iZt nzqczot) g-Lvz actaZdA on a ucpoxxtz uhzzt. Ii thxA Znvzntony .La bz.Lng mbrrZttzd Zn conjunction uxitk a pcnrr.it nzqueAt [oa checked on page 1), pizoAC give the anstuot corAiuoption notes exceeded {.on ihz tctaJL ptsjrt {on the 12 r,onilA {oZZoviJjxq the detz the new {cjcZZZty cn rr.oct^ZctUlon bzcaneA opcnotZoniZ. T'uZa aetz 7jT~ZZazSZ on page 1. Type of fuel Natural cas Process gas '?o. 1 to 4 fuel i. 5 or 6 fuel oil oil Sark/ wood Chios Coal (specify ash 7. ct onthracite/bitutcinous) Other Other Annual Consumption (M = thousands^ 52 million cubic 668 million cubic 3237.8 K eallor.s M rollons tons Sulfur % Heating value feet !/1 drain / (MSCM feet nnn orain/ IMSCH ` 0.25 1 MM RTU/ MM f + J >01 BTU/ MM ft^ MM BTO/ 4* <>'1 MM r.TL'/ * cal *'>; ETl;/ ton tons Mill 5TU/ con M_M I'.T'J/ ! MM NTl'i DTH 000120361 I * emission questionnaire /Revised ii'7i) Pang 3 of Q .S U5 PRODUCED, STORED, OR TRANSPORTED SY TOTAL PLANT V fcTtuCCiTl.fli'S or Ousntiev used or transported Hov stored hov coved materials being trnns- Annual Hourly Hourly (Ee specific - (Pipeline, ported average average naxirr.ua floating roof tanktruck, (give tank, fixed etc.) Name of material units) lb/hr lb/hr 192 MM ID. 59.76/ 62 ,Dd2 roof, etc.) Not storeo ripe i me 750 MM Lb. 91.103 95,552 Pressure Tank Pioeline/P.ailci 0 v '/ran 13.125 MM 1.709 1,792 Not stored Pioeline 1 ID.I 1 ________ :_________________!_________ !___________ I. 1 1 I 1 3* rleduces or bvoroduc zs T - -a a.-ii a + Q DrCdUCtS1 III! 1 1 Uv^v^nnan ' fh] ? 10 Hi r^'lfirnsf r|ans 523 MM Lb. 64.140 67.269 1 .653 MM 202.033. 211.894 Pressure Tank Pi Deline Nitrocen Paaaedl SniD and Lb. Fixed P.oof Tanks Railcar. " - a t ^T-d'JCt f !| | i i \'in'/I eh i oride 1.000 MM 121.-7 7 i 127.403 Pressure Soneres Snip , rail- Lb. car, or oioeln MISSION' INPOP-MATION ON' THE ENTIRE PLANT AS A WHOLE Thz >idtZZ given zhculd zcv.zApsnd, In r.czt aizzz, to thz zun thz Individual av&iagz fidzz o& thz cclrl zouizzz LLztzd In thz Iter, 5 pagzz $oa. zc.zk tupz oj( alt poltutant. Material nans Emission rate Emission race f*/. PARTICULATE SOLIDS O?. LIQUIDS soot free, eembus cion mineral dust 1 (if must soecifv) I lbs/hr 20.33 tons/vr .36.83_________ 1 ether, soecifv: 1 11 other, soecifv: i 1| other, soecifv: 1 (| 3. ORGANIC GASES C?. VAPORS* - - * .. r> oarnffins 1 , St'Cifv: 1 Mathano and Fthane 1 1 IQ 1 4.88. | aikvnes/ see cvier.es ! I! aromatics, soecifv: i a icc.coi s , soecifv: 1' OZ r.**T . 5 ~ i T V ; 1.2 Dicnloroethans o z r. r. s z-** c i f v t a | r r. n r n d Vinvi Chloride O h a, r . 5 Z ? C I f V r ^fchor U /. ] <n n n a rj [* = teri a 1 s 1.61 R. 55 0.06 1 i /.uo ms uTTa C. INORGANIC CASES C?,, VAPORS kulfur dioxide r. v c r c'0 - sulfide Ini ~ ~ 7* n nx' cn 5 larr-e-in ; . c n -* C i f t n* < c ,. t i r- a ^ ^ v ,ner. ~ r-ec i: : - s^ SO' n 1 u.'i fi. > 1 /. 01 6.52 5 3.05 1 1 99.19 1 68.45 17.73 244.97 1 434.69 1 DTH 000120362 EMISSION INVENTORY QUESTIONNAIRE (Revised 11/74) Page 4 of 9 NOTES TO ITEM 5 Please read all notes before attempting to fill out page(s) 6. 1. Use any number you wish, but please be consistent in identifying this point by the same number on calculations, maps, future correspondence, computer printouts, etc 2. If the emission point Is not a vertically discharging stack, or if there is no clear-cut point of emission (e.g., dust from moving equipment, multiple leaking valves, evaporation from storage tanks, etc.), put a zero in this column. 3. ' Give the inside diameter at the top. For non-round exits, use the equivalent di ameter, equal to 1.128 times the square root of the cross-sectional area at the point of discharge. Diameter, volume flow rate, and exit velocity must be consistent! 4. A "boiler", for purposes of this form, is to be understood to be any combustion device which heats a fluid and is separated from such fluid by a partition. Tht/lZ&0\t oXZ ktaXtAA, VovXh.CAm hZJXX<UUif tXt. OAZ XntZu.dtd. Internal combustion engines and incinerators are not included. Direct fired kilns are not included. 5. Enter the proper code 000 No control equipment 001 Wet scrubber, above 95% efficiency 002 Wet scrubber, 807. - 957. efficient 03 Wet scrubber, below 807. efficiency - *004 Gravity collector, above 95% efficiency 005 Gravity collector, 807. - 95% efficient 006 Gravity collector, below 80% efficiency 007 Centrifugal collector above 95% efficiency 008 Centrifugal collector 80% - 957. efficient 009 Centrifugal collector below 80% efficiency7 number, taken from the list below: 010 Electrostatic Precip. 040 Alkalized aluminia above 95% efficiency 041 Dry limestone injection 011 Electrostatic Precip. 042 Wet limestone injection 80% - 95% efficient 043 Sulfuric acid plant, 012 Electrostatic Precip. contact process below 80% efficient 044 Sulfuric acid plant, double 013 Gas scrubber, general contact process 014 Mist eliminator 045 Sulfur recovery plant use 017 Fabric filter 046 Reduced emissions by 019 Catalytic afterburner changing process 020 Catalytic afterburner, 047 Vapor recovery system with heat exchanger 048 Activated carbon adsorp 021 Direct flame after tion burner 050 Gas absorption column, 022 Direct flame after packed. burner with exchanger 052 Spray tower for gases 023 Flaring 053 Venturi scrubber for gases 039 Catalytic oxidation - 049 Liquid filtration system flue gas desulfuriza 051 Gas absorption column, tion tray-type 6. Give the percent by weight of uncontrolled emission removed, If unknown, leave blank; if there is no effective removal, enter a zero in the column. 7. Enter the number of the method used, as follows: (1) By actual stack test (2) By material balance. provided that this method is applicable. [X. C. , XlUs. mzthcd oevXouAty can.noX be uued utkznz the. Zna.cc.jJia.cZzA Xn mzcuuAZjnznX ajie tqmzL Xo oa. gtizaXzA Xhan Xkz abioZuXz mag nXXudz o{ the. Xo&4Z&. An zxasnpiz o jj propcn. tue uxjuXd be uihzfiz 4oZvznX mX6iXon& cxz not duitcXJLij meaJ>uA.cd, buX aJLZ AoZvzrX punckauzd '*> zvznXuaZly tost Xo Xht aXmo&phzAZ, and Xhzn.z&oA.z maXtxXaZ bonghX dXvXdzd by opet- Xng hotvu zquati Zo44 AaXz. J ` (3) By the use of E.P.A. emission factors. (See the "Compilation of Air Pollution Emission Factors", E.P.A. publication AP-42) (4) Ey making a conservative estimate. (5) By the use of emission factors other than thos.e supplied by the E.P.A. DTH 000120363 EMISSION INVENTORY QUESTIONNAIRE (Revised 11/74) Page 5 of 9 NOTES TO ITEM 5. CONTINUED (-continuing with note 7:) (6) Use this number if and only if you are submitting this form in connection with a permit request, and the emissions referred to have no present existence, but are simply the result of design calculations. (7) Sources ceasing emissions must be reported on one inventory document after they cease operation (see note 8). Emissions will be zero, and a number 7 should be placed in the "emission estimation method" column. 8. If this particular pollutant, from this particular stack (point source), was not included in the stack or point source information submitted on your last Emissions Inventory Questionnaire, or if this is the first Emissions Inventory Questionnaire you are submitting, write "add" in this column. If this particular pollutant, from this particular point, was included on the last Emissions Inventory Questionnaire (EIQ) submitted, but the amount has been in creased or decreased (to ocher than zero), write "change" in this column. If a point source has ceased operation since your last EIQ, the pollutants from that point should be reported as having zero emission rates on next submitted EIQ, and you should write "delete" in this_column. AFTER A DELETION HAS BEEN ONCE RE PORTED, DO NOT REPORT THE POINT AT ALL ON ANY FUTURE Eld'S AND DO NOT USE~THAT POINT'S INDENTIFICATION [ID] NUMBER IN THE FUTURE FOR ANY OTHER POINT. 9. Pxeport the concentration of particulate matter only for Incinerator flue gases, in grains per standard cubic foot of dry flue gas. (See Regulation 20.6.1). If this point is not an incinerator flue, write "N.A." in the column. Report SO2 concentra tions for any stack in which it is'found, in PPM by volume at standard conditions. Stack exit concentrations need not be reported for other pollutants. 10. If the hydrocarbons being emitted are of unknown type or have been obtained from emission factors which do not indicate the hydrocarbon type, simply report the data requested on the line marked "hydrocarbons". If, however, you know more about the specific hydrocarbons being emitted (for example - that they are non-methane hydro carbons , or that they are paraffinic hydrocarbons, or that they are, say, 20 weight % alkenes with remainder paraffins, or if you know the specific name of the hydro-.' carbon being emitted, say, benzene or methanol or methvlethvlketone or whatever) please leave the line marked hydrocarbons blank, write in the name or partial iden tification of your specific hydrocarbons in one of the blank lines below, and give the data requested on that line. 11. Report the fuel charging rate, if any, in units of MM ft-* (million cubic feet) for gases, M gal for fuel oil, and tons for coal, bagasse, sawdust, etc. Report the process materials charging rate, if any, in units such as M Bbl. (thousand barrels), tons (of material processed or produced), tons (air dried unbleached pulp), M gal (storage capacity of tanks; breathing losses), etc. Please telephone us and ask if unsure of what units to use. Do not list air or water as "process materials". In determining rates, do not include any recycle amount unless asked to do so, in general the rates should be determined on a "fresh feed" basis. For storage tanks, list separately under*"Name of fuel/ process material" the two catagories of breathing losses and working losses. The "rate" of the breathing loss determinant Is M gal (storage capacity) and,of the working loss, is also M gal (throughput). If any one pollutant type (i.e., SO2, particulate matter, etc.) is emitted from more than one stack (or other emission point) serving the same piece of equipent, please explain briefly on the reverse side of the page 6 subsheet, and write "See reverse side" prominently at the bottom of the form side. DTH 000120364 05 to to c 05 CO c. AJ a. in *4 *--4 W JC VI 44 (A X >s 3 a. (0 0 u o 2 aj aj O a. r- AJ CO pM C3 r- C/5 AJ >i C5 u co O 2= aj vO c u --4 C ccO o *4 Cu o c o. c o f* o 93 C3 93 C5 H c 14 5O 4-f Vi O 05 CO u C3 0 C- Vt 0) cc o Xa o <n cz 3 Ci u tn u <0 **r3* > fj 5 s; cc c c 10 cm Vi 44 O *3 Q. C o 03 UC z OO o M CO CO toH 05 03 01 -C -^4 co w 4- S s 05 o M - <3 cv c >* o n O C O 3 OC-l fc Cl tJ CO v# -w 05 > 4-> w o -4 O > u *o z >S 05 U co a 0 3 U 4J 3 a Cl c jo a Q u *-4 o o a. 4-5 -3 X 4-5 o Is s 05 C3 4J 05 CO 00 CO u C3 CJ -*4 vn c- a *3 4 c CO 4J --4 --4 o JZ > 93 '--4 C. 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OF f t ) T h is page is to be used to re co rd the data from one s ta ck (o r o th e r em ission p o in t) o n ly . Photocopy th is page as many tim e s as th e re are in d iv id u a l e m is s io n p o in ts , and use one page f o r eacli p o in t. Note th a t the s u b s c rip te d numbers in d ic a te e x p la n a to ry notes on pages 4 and 5. or hi Xo o oCl4 tft m3 CM CO <9 m_ ^OGC.JLTO> Q B ir> Mo C/3 M cn m CJ *rC43 *3 u IX <9 ^3* O Uh C9 M 03 O 3 UH (Q O M_ jj CO ^cn X CJ 60 > H O 2c* jxO ' ^ 3 ci > Mci CO u c o e rGH. 0c* o CJ <3 TS LO UoH ci E* cC3 x o C>wJ Mto3 m Cu (A MX 0 (J tl con >% ox oo U fH o3 Ma (0 X 3C on 03 M u- 1 s.s| CJ O G. O CE H r4 <9 6 M C O i>n c> c co X CD | aH i> om CO --4 cn >> 1 Z CX Mc -3 ^ CSJ* I1 9) M J CM CJ O a. > I Cl o to z bCNGJJ 03 N* M r4 O 3X0 Q. m -h t X cOM3.' 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Note th a t th e s u b s c rip te d numbers in d ic a te e x p la n a to ry notes on pages 4 and 5. N orm al o p e ra t in g tim e o f th is p o in t [d o y s ] 52 X Lu CJ CJ Q u A 3 P3 14 CO ura x cj )> uoo cl ^ <6j CO 14 uoCP CO iH o X a<o C1O4 UOf3 Ml CN CD TC3J ml eg OH CO Cl CJ CO co > 2 4 o 2 ax ^ S3 CO -O uC>J CJ ca u C CJ CHL 3 cr ci cj n CJ > CJ a ' oo a Oft o c= -X 4-i 2 * <u -H W 14 y ft. W Q L ^ M U L^ O QCJ >> po oCJ iu rH 3U O71 14 X3eCJ 3C | *h >* po* a*- M 1 5, 3C CJ H Cl 11 1 (0 Li H CL > 1 Ml O E CJ CJ cn 4-1 o z | tn| CVJ* VI H 3 JC. O Q. 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Joh 00 CJ Oo c o Co iH u 4 a *o wEO (A fl X iH 44 44 E <0 a w cj E c o >4 ^H iH > CO CA 3 tn a ca c iH u s sE ao < CJ V4 AJ c Eo 3 H u W x iH V) CJ X H 4J CA <0 5 ca x z o Vl *H c CJ o to -H a CA CA PJ H >E < Cl CJ 14 (A ax |L rH 14 O cc rH c? CJ o H u CL o 14 iL c 3 ML o cr <aa u QJ CJ \ c 14 oc iH rH 14 O w 3 r4 a. rH 44 H Cl -H c 3 -0 o o cr o P-i o CJ o vl o n 14 c Ml QJ O 14 3 CJ rH ct L CO o za V4 Cl u CJ 14 *3 c aH E 3 X iH o 1C4l X hH o *3 cl CJ *L :-o L cn X c c oc o cH rH "3 3 o Li H 2 X C Li o re u oc c c C3 c o > 14 Ui M u X U rH !. c Li P2 5 H > C a tn = x a L* r* L p Li Vl - Lri II * Cl ^ o 1. AJ E <c 3L CJ E 14 ca y r-- N U C z Lft 60 C CX iL 60 M CO o rH L> u U u |4 w >- > wc rH 3 CJ CO c 1. *H c CO n < Li CJ u E r-t rH U3 CO JC <D o U rj OU Li 10 CL m U iH ox u CJ >% 3 ja Ml 3 CJ CJ s. > 44 U ^w o H 44 CJ iH As 3 CJ > CJ H X U AJ rH c: H CJ 14 C s 0) CO CJ u o IL a CJ 3 ML Ml eC o ZZ. CJ F. <0 z ... 14 14 -c u jt: CJ --< aj o A u rH CJ CJ 6 Ml <0 Cl X 3 a- Cl 14 3 Ml iL #k r 0) 44 o 3 >, -H 14 cn cr rH CD ttt C O 44 Vj U iH r* iH -o CJ s 3 cj a 14 Li o o X X Lr 14 O c rH 14 iL c Ml a CJ x *o <0 M * 14 a o >% c rH 44 c iH X *H CL r C iL o CJ u S 3 U CJ 6 a CA CJ o o C o CL iH N 44 13 14 o iH C 3 >, u 3 14 CO O *H 14 C* CO Shu <0 C3 CJ a u au u X. CJ -H 3 CJ s to 14 3 Ml U tO -H c o c fj* iL c iH X CJ CJ -U H u c u Q ^L iL Vl 1 E aj Vi o CO 3 ML O O CJ o Xo Li 44 X ML 14 o _0r^1 H CJ o u O -H Li 14 CJ c W X Cl O 3oa iL U ^L VM e o c X Ml T3 c: o C3 14 H U O CJ c CJ 3 n (A H E X M AJ f< 3 14 Li o hH VO C O Lt -o 0 CJ CO CJ Ml a CO X iH x 14 c rH -L 14 CO U U O iT . r~ CJ o o 3 o LI CJ O u r~. s x) o > -H CO VM iL x o. O w <0 M i-< to a M u -L o 2 44 a CJ j= CJ o a a. ftCD - DTH 000120370 I \jjfj f EMISSION INVENTORY QUESTIONNAIRE (Revised 11/7&> TTEM ft . . . PLANT LOCATION FOR AIR POLLUTION DISTHRSION MODEL INC Pare 7 of 9 Give below the Universal Transverse Mercator zone number and Universal Transverse Mercator (UTM) coordinates, to the nearest one-tenth kilometer, of your facility. We must have this information since we are required to report it to the U. S. Environ mental Protection Agency for wide area dispersion modeling purposes. The coordinates can be obtained from most U. S. Geological Survey maps, scale 1:24,000 or 1:62,000 for your particular area. These maps, if not already in your possession, may be found in your local library, or can be purchased from the U. S. Geological Survey (USGS) at the address shown below for 75C each (1974 price). An index of all the maps available for Louisiana, together with prices and detailed instructions for ordering, may be obtained free by addressing a request to: U. S. Geological Survey, Distribution->Cent-e*r, Denver Federal Center, Bldg. 41 Denver, Colorado 80225 If the map has the Universal Transverse Mercator (UTM) coordinates listed, it will have the UTM zone number mentioned among the writing along the bottom of the map. This zone number will be either 15 or 16 for Louisiana. Plea.&z note that latitude and longitude one not what we need, and that the USGS maps do not show UTM grid lines as they do latitude and longitude; however, tick marks along the edges of the maps do indicate the UTM grid locations. A straight edge must be used to connect tick marks at the opposite sides of USGS maps when interpolating between UTM tick marks because the map grid is drawn on the latitudelongitude system and, therefore, the UTM grid may appear quite skewed. For the scales -entioned, tick marks appear for every 1000 meters (1 kilometer), with every fifth tick mark and the tick marks nearest the southeast and northwest corners of the map giving the value in meters. The 1:24,000 scale is preferred to accurately locate the facility, but the 1:62,000 scale may be used if the 1:24,000 scale map is un available for your area. For example: The state capitol building in Baton Rouge would be: UTM zone No. JL 5 horizontal coordinate: 6 7 4.1 Km. E vertical coordinate: 3 3 7 0.6 Km. N Your facility: UTM zone No. i. 5. ITEM 7 . . . COMPLIANCE STATUS horizontal coordinate: Km. E vertical coordinate: 3 3 4 6 5 Km. N Check ontoi the blocka below, KegaAding you*. facility* & "Compliance Schedule ESuch a document has not been requested of us, so far as we know. Such a document was requested, or submitted, but we haven't yet received noti fication that it was accepted at a public hearing by the Commission. We were notified that the document was accepted at a public hearing; no schedule of actions to achieve compliance was necessary. D We were notified that the document was accepted at a public hearing; our sched ule of actions to achieve compliance by ____ (month), 197 _ (year) was approved. The ost recent "increment of progress" date in our schedule or actions was achieved r- (rnonth)____ (day) 7 _ (year). [jfOU MUST FILL IN THE DATE BLANKS IF YOU HAVE CHECKED THIS PARAGRAPH^) DTH 000120373 EMISSION INVENTORY ONES IONaAIRE (Revi i 1 `74) Paeo R of 9 ITEM S REFUSE COLLECTION AIT1 DISPOSAL A. Amount ox' combustible refuse disposed of per year: 5915 Tons ______________ (give the applicable units) 3. Description of refuse; check off applicable catagories: IS Paper scrap Rubber scrap CP Wood scraps : sawdust Wet garbage or animal wastes DO Other, specify:__ Rubbish, C. ' Method of refuse disposal; cheek off applicable catagories: O City pickup CO Contractor pickup D On-site dump On-sitc cutdccr burning On-site incineration On-site landfill Other, specify:_______________________________________________________ D. If disposal is by contractor pickup, give the name and address of the contractor: Browning-Ferns Industries of Louisiana Inc. Solid Waste Division-Cities Service Highway - Maplewood, LA 70o5~3 E. The on-site incinerator, if any. has the following design features: 0 No on-site incinerator G Afterburners D Water scrubber installed Single chamber Primary secondary U Waste material disposed of Multiple chamber burners installed by burning in a boiler F. Incinerator equipment data (if applicable): Manufacturer:N .A .Model: Capacity:Ins cal la!: ion date: Auxiliary fuel used: (type, hot/ used, race of use)________________ ITEM 9 SUPPLEMENTAL INFORMATION A. Pleaue supply a unit plot plan on. map which 6how* die. location* o iic.du (on. oihes. 6ouncesi, together laitk the t.oiuice identUiozltcn numbenu fcom Hem 5. die plant boundas,ie*, a cLLlZojicc Lc/~ie, and the dinecticn Month, Please alio ihotv, on a iepanate dlagnam i{, nece**a>iy, the location o3 die plant In natation to~neaxat highvmyi, neiideiiial os. ecu, and iowru, httc.ch ike map* to ike back 0& tiilu ionm. See Figures I and II. B. Approximately how much money have you spent on air pollution control equipment and operation in the past 10 years? Equipment $15,500,000 Operation $2,935,000 ITEM 10 TOXIC GASES & HAZARDOUS MATERIALS A. Are there any substances used or produced in your facility whi :h could cause im mediate injury to life or property, jlf they were emitted to the atmosphere, which are not already listed in this form as one which is presently being emitted to the atmosphere? (e.g., chlorine for vxater treatment, toxic gases, gases used as cata lysts, etc., which ordinarily do not escape) Please list such substances below. If none, please so state. , No- B. Does your facility use or produce asbestos, mercury (ocher than laboratory use), * beryllium in any amount whatsoever? If answer is v,;. give detail': br'1 r: r~ : ~ separate sheet. If answer is r.o, please write 'r.c1' oelow: No 1 ------------------------------------------ 0001203^ 4 EMISSION INVENTORY ONESTIONNATEE (Revised 11/78) pi^n Q 0 f Q / itzm !i . . . rrscov:::. & certification /, A. The nnnnj'.rr of the facility, on location- at the plant site, is as follows: Name : Title: Name of Company: Business street address/ P. 0. Box: City or town, parish, Zip code: Business area code/ telephone No.: James A. DeBernardi . Plant Manager - VCM Plant Conoco Chemicals Company, A Division of Conoco. Inc.; P. U. Box 605 Westlake. LA 70569 318/491-5064 B. Person to contact at the site' of the facility about a'ir pollution control, if different from the above: -* Name: Title: Business telephone No./ extension: Garv L. Foshes Chief Process Er.cmeer 313/491-5062 C. If the company's air pollution control correspondence and documents are prepared at a headquarters office, at a different site, give the information on the person to be contacted below: Name: H. J. Neeld _ Title: Name of company; or parent company: Director of Environmencal Control Conoco Chemicals Comoanv ~ 'sir.ess street address/ P. 0. Box: . rty, state, Zip code: dustnass area code; telephone No.: P. 0. Sox 727 Westiaxe, La /Cool) 318/491-5436 D. Person who prepared this report: Name: Title: Firm: (if prepared by a consultant) Company: (if prepared in-house) Street address/ ?. 0. Box: City, state, Zip code: Area code, telephone 5?, extension: one -the. above., jll.St die.ck appropriate btoeki) O A. 8. O C. Jonathan G. Cole___ Process Enaineer Conoco Chemicals Comoanv P. 0. Box 605 Nestlane, LA70669 318/^91-000/ E. CERTIFICATION, j ctfjti&y, under the provisians >6: Louisiana and United States Loj>: ickick provide criminal penaULii.es or ^cLsc statements, that this Emission Inventory Qjcsiicnrjcire, including all attachments thereto, contains information tcki.cn is teaiz and correct to tiiz best o/ mu knatciedoe aid bcLiet . --------------------------<________ _____ ^X&^gnature of "'manager, or other company agent) J. A. DeBerry.rdi . Plant Kanacgr - VCM Plant (printed or typed name f* title of person above) 8/ 2-1/%-Q I (cate a:gnca) 000120376 LOUISIANA AIR CONTROL COMMISSION P. 0. 3ox 60650, Mew Orleans, La. 70160 Telephone: (504) 527-57 7 9 EMISSION INVENTORY QUESTIONNAIRE (Revision of Conoco Chemicals Company (name of company) Conoco Inc. (parent company; if above is a division) Submitted by company on 8-23-79 (date) Please file a separate report for each of your plants physically located in Louisiana. This inventory covers the following plant location: 11/7A)Page 1 of 9 CHECK ONE OF THE BLOCKS BELOW: DThis inventory includes only presently existing emissions. KfThis inventory includes both those old emissions(expected .to be still existing)and those pro posed additional emissions in cluded in our permit request for Alternate Fuel Gas Svstem (type of new facility/modification] which was submitted to the com mission on _pq_7Q (date) and which new emissions are to be existing by 12-1-79 (date). (plant's name, if any) . (nearest town) (parish of plant site) ____ ________ INSTRUCTIONS: Keep the original of, this farm; return a photocopy to this aaencu. W not ictite info-motion ln thz top or Left side mrgins of this form, 06 file foldzn. bindings troy covet thz information. We have &u.zd to ask only for thz information oz nzzd, please do your best to answer each question. Goa. authority to ask for this information is contained in R.S. 40:2201 zt see. Copies of this taw are available upon request. Ait pollutant emission data provided on this fosim shall bz available to the general public, without exception. All othe/i data and information provided on this fern and attachments shall also bz availoblz to thz public, except that upon a showing satisfactory to thz Technical Secretary that each other data, and in formation, if made public, would divulge methods on processes entitled to protection as trade secrets, thz data will bz kept from all persons other than employed, or othex agvvts, of thz Louisiana and federal aix pollution agencies. I | Confidant laIIty of all information, except the air pollutant emission rates, is requested, and our justification for this request ia attached to the back of thi3 form. (Check the block if this is the case.) If czrtabx questions ate not applicable, indicate "none" or "not applicable" (N.A.). Tears suck as "not significant", "nil", "trace", "negligible", etc. are not accept able. Please attach additional sheets if more space is needed. An updated report should be submitted in the future when the annual .. emission rate of any pollutant from any stack changes more than 10% fr^m reported values, ____ ITEM 1 . . . CHC-AN7ZATION ACTIVITIES A. Circle any days of the week normally not operating: M Tu W Th F Sat Sun B. This facility, as a whole, typically operates rn 1. The peak production season is Yoar Round days per year. 2. The facility normally operates 1 D 2 0 3 eight hour shifts per day, specify the hour3 normally worked per day,________________________ E. Approximate number of employees at this location Is 100 or - DTH 000120376 EMISSION* INVENTORY QUESTIONNAIRE (Revised 11/7M Paee 2 of 9 F. If the facility, as a whole, operates intermittently, give details on the lines below: _______________ ___ G. Ownership of facility. Please check one of the following: E-corporation, partnership, or sole proprietorship Qregulated utility city government state government Cj federal government other, specify_________________________________________________________ _____________________ H". Please check off, or write be low, the descriptive operation: lumber industry B chemical industry pulp & paper P natural gas industry cement industry petroleum industry P particleboard sugar cane industry P plywood other, specify ___________ name which applies to your asphaltic concrete fertilizer metals industry fish meal brick making I. Please give a very brief description of your operations, with emphasis on any possible sources of air pollution. ITEM 2 . . . FUEL USE 3Y FACILITY AS A UKQLE Check one of the blocks below, and supply information as requested: this itvjzntosiy is ion. " fn.zszn.tty existing" coizditcons \as che.ck.cd ion. page 1), pizosz givz tiiz juxionxeation nzouzstzd bzio'.o ic<% the latest 12 month pzniod ion. vdvich you. have data. Data. ion. the 12 n:onths ending Month: Vzc/i: (iiil <n) has bzen given. tptunz use is expeetzd-.to be maxetaUly diiiznznt {other than aa outlined in a cjjlhjlzxZ pejw.ut request) give details on a azpasictz sheet. 0 li this inventory is be.Lng submitted in conjunction taiik a. pznsr.it request {as checked on page 1), pizazz give the annual consumption suites expected ion. the total plant iosi the 12 months ioitoMsaiq the date the new ituzHity cn niociCtjZcation becomes opznatiarai. This date is listzu on page 1. Type of fuel h-icur.i L m3 Prnce33 ms No. 1 to 4 f uo i oil No. 5 or (> fuel oil *inrk/ wood coins Coai. (specif/ asn V. & anrhrjcifc/bituminous) Other Cthr l 1 Annual Consumption (M = thousand 9,0 million cub'c h h million o u h r. M im 1 , n a M o alion o to 03 ton i foot f r> t Sulfur 7. Heating value < !?v "e (chrJ n nnin/'.KfiF MM BT'uV MM frJ 10 nriin/mf IcrF MM BTL7 MM ft-3 ' M^l BT'J/ M MM 8TU / M csl MM RTU/ ton MM BTU/ con i mm ETU/ ! ________v__u__r_-_^_r*__/ ______ _ DTH 000120377 r P5ir.:;i t : x f. ? Tver; y oi r. st I o: :n'A tt. k (Rr.vfr.oH 11/74) Pm-n3 of 0 ~1 tt:: i !-{/.T':nT.\i.r. vs~.n. ptodkcsd. stobki). oh TKANr.roHTCi) total plant A. Hr.:; t.::iccrin 1:; or nnccrir.ln being cranuporccd o c nv i cr-i" Ch'lorinr; Ou.ini:i tv used or cranr.nor Cod Annual average Hourly Hourly average mor.iniuiTi (give units) 1 332 1 431 lb/hr 40.567 55,107 lb/lir 50.092 72,875 i i He;.' Cored (Be specific floating roof tank, fixed roof, etc.) NOT STORED PRESSURE TANK How moved (Pipeline, tnnktruck, etc.) PIPELINE PTPFI IME ?i RAIL 3. Product.1; or h V P'"C'd'.lC U T. i-iTEi:-:-E'JfATE PRODUCTS 1. jw.ii'rvrr-.rt Chiorv;o) 2. 1.2 Oicnioro-.?u;>.>.nr: rmai f r'OGucz vin'.'i Cm 1 once 1 j 403 i 1.115 i 1 690 | 1 1 49.2^2 1135.241 I i 84.31 1 1 55.335 1159.040 1 91.535 1 1 1 1 PRESSURE TANK PIPELINE_______ 1 niTROCEN PAnnPO j SMTP AMO f FIXED ROOF TANKS! RAT! CAR ! PRESSURE SPHERES! SHIP OR RAILCAR 1 :i 11 ..JTZM L . . . EMISSION information on TI'2 KMT IRE PLANT AS A WHOLE fhzJUltQA gtvZA z'JjL cr-A/tciccit'i, jj\ aoiCi, to tJiz ina 0& the. Jj\dLvidaaL fiu&uyc uiu t.jotr.i boioicte LL-ttvA ln /;s. 5 p^gcss ^c-t accli -Cij'pe oo <u/t pctiiLtant. -thd A.. PATTIC!L7_\TE SOLIDS 01 LIOUIDS Soot ire r. c c 6 o r. z 1 o r. -.r-.imro V Hurt other. r'ricifv; rxcivv i D*' "' r *)%/+** *t Material name Emission rate (if must soecifv) lbs/hr 19.7 Emission rate tens/vr Pin. 9 * B. OT.OM.'IC CASHS C?. VAF01S *n'-r/ nor nr f inr. Msthnno/EtlvinG 43/5 a 1>:n/ n1 fv; Ethvl vm/Pronvl on* 117/14.0 nIk"no / .'.c'.<;*/ lcn.:n r.rc~- tier.. nee i; v : 1 /I ) C. C.;; ! 'Z t rnnr * * 1 ui i rc/j tthyl Chloride 489 1.2 Rich loroot'h.uu? 4i 7 V i n v 1 (ill or me 14.0 (as 1,2 L) 7 cn loroei.':':.')' ) 46 c. i:;c:'.c.\:;rc cap or; on vapohs l ! * \ ` T* f 1 J f! ? Y13 iiV'l :i - i: i : ; r1 ^ * f* f 1 > i Oiv | f ^ r 1.0 ;o1 1 47A K?. 8 | ' i: 1 i. . * r . . *. ">' r i | v : 1;C 1 /' 1 -> (-0. m/9.6 *_2.'_T'_'J. !'': ' '' <>-yr iM'r -:.) I I [IP--, ' c '. : ~: _____________j~~7 173/20 47Q/59.7 2,001 1,701 60.2 188 9.126 ... 1 .7P.4 224 248/39./ DTH 000120378 ( [:>: crintc::y nnr.jrrrr-WAirvH (n,-vt r..-ri 11/74) P.tr-e A of 9 TO ITEM 5 Please read all dotes before attempting to fill out pngc(s) 6. 1. Use any number you wish, but please be consistent in identifying this point by the oar.-; number on calculations, maps, futurecorrespondence, computer printouts, etc. 2. If the emission point is not a vertically discharging stack, or if there is no clear-cut point ot emission (e.g., dust from moving equipment, multiple leaking valves, evaporation frera storage tanks, etc.), put a zero in this column. 3. Give the inside diameter at the top. For non-round exits, use the equivalent di ameter, equal to 1.123 times the square root of the cross-sectional area at the point of discharge. Piateter, volume flew rate, and exit velocity must be consistent! A. /. "boiler", for purposes cf this form, is to be understood to be any combustion device which heats a fluid end is separated from such fluid by a partition. ThcJlZ- &c'iC. C-LZ hzzte>LS, Vc:zhci;n hazXzu, etc. <Vie dneZilded. Internal combustion engines end incinerators are not included. Direct fired kilns are not included. s: Enter the proper code number, taken from the list below: cco l'o control equipment 010 Electrostatic Precip. 040 Alkalized aluminia 00L I.'at scrubber, above 957, efficiency 041 Dry limestone injection above 95% efficiency Oil Electrostatic Precip. 042 Wet limestone injection 002 Met. scrubber, 80% - 95% efficient 043 Sulfuric acid plant. -- SO-'. - 957. efficient r Met ccrubbcr, 012 Electrostatic Precip. contact process below 80% efficient 044 Sulfuric acid pLant, double bclc;; 807. efficiency # 013 Gas scrubber, general contact process -v04 Gravity collector. . 014 Mist eliminator 045 Sulfur recovery plant use above 95% efficiency 017 Fabric filter 046 Reduced emissions by 005 Gravity collector, 019 Catalytic afterburner changing process .. . 80% - 957. efficient obo Gravity collector, 020 Catalytic afterburner, 047 Vapor recovery system with heat exchanger 048 Activated carbon adsorp bclc:.* 807L efficiency 021 Direct flame after- . tion 007 Centrifugal collector burner 050 Gas absorption column. above 95% efficiency 022 Direct flame after packed. 003 Centrifugal collector burner with exchanger 052 Spray tower for gases 807. - 957. efficient 023 Flaring 053 Venturi scrubber for gases 009 Centrifugal collector 039 Catalytic oxidation - 049 Liquid filtration system below 807. efficiency flue gas desulfuriza 051 Gas absorption column. tion tray-type 6. Give the percent by eight of uncontrolled emission removed. tf unknown, leave blar if there is no off active removal, enter a zero in the column. 7. Enter the number of t'ho. method used, ao follows*. (1) r.y actual stack test method is applicable. [Z. <L. , -t/ucA ncthod cLv.LcillZu eznrsi be. uezd tony:a the hjzzzzuzzeiee tn rjc.zeuto.icnt (Vic equaZ -to o-'i. qyrs-f'll tlzir. tie zt:.ciutc r.zn.uiC:::ie o{ the tos>zv\. An cxrjr.i;t.l cf, pxopvi il&C kviUl1. he idiczc -`.cOjoiC eucizicr.z c.xe r.ot dLiccCtu mzevicd. hut izZJL ioivzixt pa/Lchaicd L '.'rr.CzzCC:/ Loot iz the w.nzvhexe, cj\d t'nexz^cxe rmCt'L-Uii bought iLivuicd by opex- tj1->U Z.O<j j J ' (3) V.y che u ;c of H.P.A. emission factors. (See the "Compilation of Air Pel 1esian Emission Factors", E.P.A. publication AP-42) (A) by making a conservative escimace. DTH 000120379 (j) !'y the u.'e of emission factors other than these suppl led -by the E.P.A. ( F.Minsio:.' t:.,vv:?.tc:,v pi':-:stio:"'aike (Hoy f no d 1 1 / 7 A *> Parr 5 of 9 '.T'7 TO ITEM ri, CON i'T:.'II.~n (-continuing with note 7:) (0) t'sc this number if and only if you are submitting this form in connection with a permit requeue, ami eke emissions referred to have no present existence, but arc simply the result of design calculations. (7) Sources ceasing emissions must be reported on one inventory document after they cease operation (nee note 8). Emissions will be zero, and a number 7 should be placed in the "emission estimation method" column. 8. If this particular pollutant, from this particular stack (point source) , was not included in the stack or point source information submitted on your last Emissions Inventory Questionnaire, or if this is the first Emissions Inventory Questionnaire you are submitting, write "add" in this column. If this particular pollutant, from this particular point, was included on the last Emissions Inventory Questionnaire (EIQ) submitted, but the amount has been in creased or decreased (to other than zero), write "change" in this column. If a point source has ceased operation since your last EIQ, the pollutants from that point should be reported as having zero emission rates on next submitted EIQ, and you should write "delete" in this_column. AFTER A VELcflON HAS SEEN ONCE RE POTTED, VOT/OT RETORT THE POINT AT ALL ON ANY FUTURE ctQ'S AND VO NOT USE THAT POINT'S 1/IDENTIFICATION (II?! NUNSER IN THE FUTURE FOR ANY OTHER POINT. 9. Report the concentration of particulate matter only for incinerator flue gases, in grains per standard cubic fcot of dry flue gas. (See Regulation 20.6.1). If this point is not an incinerator flue, write "N.A." in the column. Report SO2 concentra tions for any stack in which it is found, in PPM by volume at standard conditions, sek exit concentrations need not be reported for other pollutants. jlO. . If the hydrocarbons being emitted are of unknown type or have been obtained from emission factors which do not indicate the hydrocarbon type, simply report the data requested cn the line marked "hydrocarbons". If, however, you know core about the specific hydrocarbons being emitted (for example - that they arc non-nechanc hydro carbons , or chat they are paraffinic hydrocarbons, or that they arc, say, 20 wai-shc 71 ftlkcr.es with remainder oar.-;: ft. nr:. or iz you know the specific name of the hydro--, carbon being emitted, say, benzene cr methanol or methv1ethvIketonc or whatever) please leave the line narked hydrocarbons blank, write in the name or partial iden tification of your specific hydrocarbons in one of the blank lines below, and give -the data requested on that line. 11. Report the fue 1 charging rate, if any, in units of MM ft-* (million cubic feet) for gases, !1 gal for fuel oil, and tons for coal, bagasse, sawdust, etc. Report the process materia1.:; charging rate, if any, in units such no M Dbl. (thousand barrels), tons (0: material processed or produced), tons (air dried unbleached pulp), M gal (storage capacity of tanks; breathing losses) , etc. Please telephone us and ask if unsure of v/hac units to use. Do not list air or water as "process materials'1.' In determining rates, do not include any recycle amount unless asked to do so, in general the rates should be determined on n "fresh feed" basis. For storage tanks, list separately under "Fame of fuel/ process material" the two catagorics of breath; loss.;-, and working losses. is M gal (storage capacity) and,of 1 If any one polluc.inc type (l.e The "rate" of the breathing work 4 ,> r loss, is .also M so:, part iculato m utter, 5 :l 1 G:l po i nc) s erv 1 ng the loss determinant vo r re aid e of the page 6 'Sec reverse aide" prominently at the b 01 l c :i of th.e f era side. DTH 000120380 EMISSION INVENTORY - CRACKING FURNACE STACK^^ AVERAGE EMISSIONS IN TONS/YEAR Name of Pollutant r Particulate Matter Sulfur Dioxide Nitrogen Dioxide Hydrocarbons Carbon Monoxide Emissions for Natural Gas Firing 3.81 0.123 48.7 0.634 3.6 Emissions for Refinery Fuel Gas Firinq . 3.81 4.48 48.7 0.634 3.6 (1) The VCM Plant has tv/o cracking furnaces. In the EIQ they are identified by point source ID numbers IIA and IIB. The data presented here are the emissions for each individual stack. DTH 000120381 o cq yp* 6fl T3 CC c p 3 XJ C. u. q *4 o *4 u u XJ q JC >> 3 O. q o o CJ CjlJ o u XJ XJ <o Ch .n C2 Pm q =3 CO XJ >H V pH) XJ o =o Oj mh o XJ vO p XJ pH C CJ o pH CCF Cm o q o. cu C o p o qq qO pH u oo ViH u o CJ CO XJ o a. /p. u CJ r-N o c s-/ o pH pH a Cl q "3 c 3 3 XJ q q *3 H > CJ q oc <*y c k q C XJ o C VO t u UH O T pH C. C <q q XJ p 2 q O <} O -3 p4 PH q q H CJ q a to -H co u: XJ a =0 <y Q. "3 u pH C >* o O O p/ o 3 o Cl 3 q &H u p^ CJ > XJ LJ o > XJ "3 e Z PH rz pH >s CJ 2 q ao c 3 U XJ P-4 q q to O c to JP cj q pH U pH o .cj cu U -c >: XJ CJ q p q cj q xj CJ q co q u Q rj -p* C.- "3 vn q XJ -p n >4 q U q CJ S -2 H q3 PH q C XJ pH X Cm cj o o u q3 q xj to q u jc a c OB.LT a S lt xj cj to xj <o U CJ XJ V s q -rH *3 -M O q xj to xj Uh c: LT c XJ O Mh q xj cm qO *3 uh q ou eo xj cr X <u 60 > *4 O ao zz q O'! pH pj o CJ > u a XJ c CJ a C, -pH 3 cr CJ o t_ JS < jj H cr UH O u. U- CJ < eg q cd C ^ -J O Lt CJ q > xj cr pH q ZC XJ --< C. in HH W oO u < cr qO 3 >s QX 3 O U pH 3U o CJ q jd u 3 C p4 OQ -- < -- II d X t XJ q V)\ 1 U uj u oj o o 3| > H O- c O H CJ a .H --1 o C. el Hi >1 3 3 f'J1 q xj -o| a H 60 I >4 1 OCX q 2 u x| -o c\J 1 q pH 6 OH CJ XJ N CL > 1 3 to o 2 LpJ cj O <~s tn fJ 3 C JZ CO oc pH -pH XJ XJ q -pH uX XJ o OS c 3w Uou cqq o <3 O CO q m q co p* >> >s JC pH J3 XJ C o -o c a pH c U c\ B *pH pH 3 3 03 pH pH a* XJ P-Hx. o3 U3 oC 3X0 Or. J -- 3 a' C 3 MH 3 O3 q U O XJ suo XJ x XJ XJ w pH q w xj u 3 Ml C q cc u nj O quo. 3 - pH C O pH o u O hH 3 *> CO 3 ID < CSJ ss q vn CVJ r< X 3 to CSJl <PN 33 >03 pH >. c rH q pH 3 CO 3 q 3 X > Mh p q Uh H <r 3 to tXH = xco * U xj 3 H-O *w c pl XJ ys 3 q 3 o SH VXJ 3 3 UH OCX X 3 qw3 3 C XJ >> q XJ pH T3 CM 3 JJ qq ah u i- Vi XX '- >3 H 3 --I 3 Uh 3 q3 UH MH 33 VH H tz CQ CQ ts sO SO xo o oo a pH pH q yN xj q 3 Lx qw 3 pH -a o.'-' H >S XI XJ xJ 3 CJ Cl UH C HUH > u aX c r-J r^U-J * OJ r-- C lt; cv q q> eo xj pH jh u a xj o <3 M H Ml X CJ W CJ > a 3 q "v. XJ M4 in co p--* CO c o c^ O XJ pH q -Q qgO W *H pH XJ XJ E3 u a5 CSJ A. 3c M- o U pH -pH Cl q q CO 3 3 q3q 1 * < Ov p c U O eo m j3 c 0c1 C XoJ jr o)to 3 i-l o Hpro S w U j: 3V) Q)V *3 X* ~*poH x0)j q SouOJ a3 g -O<30 <o -O U O 3 < Oc O CJ o o JP CO -H o XJ to <Uo>q *t(e3Ho0 40J) fC O' cr XJ oZD -----------------FT r-- c c 3 pH W 3 3 u0 aS. "Ho XJ XJ -pH -pH A3 2 O o 30*0M-1h oa CSJ ^ XJ c 3 B Cm pH a 3 -0 cr o oo CO CO O'! 3 O pH <j-i q a CO CJ q xj tn q xj vi o CJ c O O TJ uqu Cl G3 o o XJ -H c q xj q hH XJ 3 "3 q xj C q a XJ u <j P3 c pH rn XJ MH fN O VO opH-3a c vm Q O xJ qo ' --f=l, * I5 C>l cCJ W| u| u cJ ~! r: ! jz ao M XJ uuuuuu n u u_ o q uu o 3 CSJ CO c JC ^ qCO u q uuu uuu s o q 3 C c u< CJ XJ q 6 pH pH (qA .X 3 CJ U C3 O XJ U V) a. q u -U O J3 o <-> xj t>0 q s: UZ q* co CO pH q pH u 3 XJ q e q q O 3 J3 Mh O 3 o o to u <T3 0.0 3a _3 > XJ U 3 5w O pH XJ a *h 3 C 3 a> a -H J- O XJ ,-- pH CJ 33 3 LM Lh > Uh So CJ c 3 P" B 4- q CJ 2 Cil .... XJ V< o O - o pH 3 Uh a 3 X 3 Cl CJ XJ 3 X q UH o >. -H XJ pH W a UH T3 3 xj q C3 36 t-H CL c> pH 3 3 Mh O* CJ pH q xj OO U xj MH O q .c XJ pH oX 3 XJ U XJ xH C UH a a M C pH pH CL s Vi CJ a OX O XJ o >% U pH XJ xj q q 3 3 /-N c #H tO *pH pH -O -pH Vi pH pH V. o q 3O *c o 3 XJ X pH U XJ 3O \-/ pH o o tr o 3 u q *ph 3 xj u pH *3 3 u -o oc 3 XJ XJ c c pH 3 aq CL -pH -pH 3 XJ cr q 33 : 60 c3 -H XJ U 3 uh 3 o pH 3 3C 3o uh c a XJ 3 E JO o pH 01 -o ou 3 N q q3 pH -- o u Uh 3 XJ C a XJ u j 3 3 0 3 ou c JO pH q p to Ma &c- o qqU -- --4 0 Hf) q CJ 4= CJ 0 q 01 q O C DTH 000120382 000120383 dth ITEM NO. 5 EMISSION INVENTORY QUESTIONNAIRE (R e v is e d 1 1 /7 4 ) j DTH 000120384 CJ <cCtDi a 00.CT <U O -- CO nj -sQ a) "C7 "O u. -CJ 1- o o <-C o CJ o, zUJ o < cu CD ZD UD <o c o C r- o *- r-- rj T3 c/i H O -C r- -U> M f3 ^ tU UJ UJ Oc C- I-a^C-----m--I--.- 4(-U> >- ICfl C S rj o <LUKI" c: f1=3 o-- fc </) 5~ > ui cj r nX. -- 4<-u .^O U;>J o 1IT) CJ >> 4-> O C T r-- rj a OE S- Q. o 4-J *r- kO C o cr *+U U UJ cr *-> oc r- *---- CJ o to Dla r-- U-J r-- 0) -- C T3 "U o o cr o a. u lj u Average Emission Rate lb s /H r O O w C3 C3 OLlJ UJ UJ UJ UJ LcJ UJ < <<S<2 G GG G GG G 'sr*3-,:r-3-'3-'?-Tr*T3- I owoicaciMMO . <-- I-- CO CM IN. N Cl CO <S- r- CJ -- CMl j-" Cf> - -m* - O' CO lO m*=r <7 ryiinin-irrm *T rNc lo cm 'T i-- rv'.c.cnj . r-- *a in <tonr'.r)N('jcj CO \ <\J 1C r-- VS- *5" CT> i-- -- cr\ in *>cn o CO V ro n r*> n nn >*o r oocooooooc oooooooc:< < V-- UJ TO CJ >-- <! +J CT 4* nj o *J ;j 1 <i r> OS UJ J-- UJ 1-- /*~`; UJ r^1 UJ >-- a X --^ ox u r x* ---- o u* O c: T *" < -- O CmI Tj UJ cj C ' '/ 7^7 N--. r ? u-- u. 1 'V. _ j *- y .-- r T > -- T .* c. *_ * H. _J < O h-- CO 7 *" c5 LD C< < '^ o rr r : r rr - --- **- U) *' t T! "** *t: i j-- ; c ii j t- . U 1' UJ - .T , 1-- wi J ' DTH 000120385 J  I ) DTH 000120386 DTH 000120387 DTH 000120388 --1 dth 0120391 n co[ j. o o. o u l-J O o 4J -r: G c>. .*CM m >w >. r--1 i" *o U-i C --N U yo c ao c< Cu i-j CU C o M VI *^4 r: 5 j-i a T3 o <u r-* o *--< 2xi V Ti rz l C) J \ Vt v; p* i' > rj CJ C Cu c V ft 6 Ww cl Vw .--4 *rt 3 7. iJ 0 - C o "G M HO O'1! '"3 >- O OC-S U l> C3J '-*1 Zi mm Vj ! CCJl <J u*v t : :! r.i V ) 0f )1 -o r; rj cl u Cl C) <r.0i --w4 .r u *j <o .n l L VI oo cj o .c U CJ o .C u ^4 n -C <u 4J o U-J O JJ vO C CJ --< c oo cr. CL O c CL -* Oc JC H O w r co cj fc: U CJ O vu< W C U Coa-0 O Cl L< CJ oc 'w/ O CJ ow O C 3 C iJ aV) -a cj O a c: Crf o n aV-) o cm C.-J c o *o CL a cj c n O o^ O -i H uon: | jC lj <c//ll rJ e wCJ to o O'* -o j-i > O U3 oL i O -c U -r-l > o lJ "O /-- C o CO CJ CJ o c -o >> CJ u O CJ o o 3 W CJ PJ a 00 CJ c f/0 J3 CJ a M o* a c. cj -C x LJ o mVI cn < Q4 CCJO CO << ) r* s cl. Ii *\ rv , * i (.) p. ' 4 j o t;. 1 V) CJ I DTH 000120395 DTH 000120396 o tO n tr. to Cur^* o .a r- ctni o e* AOM o CJ C'. c c* I> Cj "I a HC/3 j: rJ U! j W S'! "3 i J< > Or< 0C/03 *.) >J o C` DTH 000120397 ) DTH 000120398 ci CO O; (U A .arr.t vTuwcC-O4xl uwi "*v O 0 o .3o i/% 1 Cl 1,1 e. o'. 6 u O M.Ck4 ujc: u -uCPI -->4-f It Cl ioJ o|i: O \D Ql c-i r: ccor: o --4aJ oo. -oaC V) o Co XVo-Ji u*a* u O CCoCOlu suo Cl oc C up: oCl 3 OC-<A I -Oc i > o er: rcj: o C3 ctsJ on <A iJ *C*- U.| oc. Cl LrJj -orc-l CPJ* Ct*o4A U 13 { ag C<aOx fO< oMo ou rj Tn3O-4 > o LJ TcO c o (A o LJ o c a -r-1 o'33 -OA) cXal wa uo a c oO jiaZ LJ lA CJ4 iA rj r.---j1 lA *l>V 'TcO 1A iJ o .c OCtjn a IUA J DTH 000120399 ( emission i::y;:!:To:;Y quest in boat iw-. (P>fV I r, f < I 11/ 7 'i ) ( Pare 7 of 0 it;-:;; a h.location for Air. pollution oj ship, stop modeling { Give he low die Universal Tr an.; verse Merentor zone number and Universal Transverse nercator (UTM) coordinates, Co die nearest one-tnntli kilometer, of your facility. We tnur.c have chic Informntlon since we arc required Co report it Co the U. S. Environ mental Protection Agency for wide area dispersion mode ling purposes. Th.e coordinates can be obtained from most U. S. Geological Survey maps, scale 1:24,000 or 1:02,000 for your particular area. These maps, if not already in your possession, may be found in your local library, or can be purchased from the U. S. Geological Survey (b'SGS) at the address shown below for 75C each (1974 price). An index of all the naps available fer Louisiana, together with prices and detailed instructions" for ordering,'may be'obtained free by addressing a request to: U. S. ecological Survey, Distribution-sCenter, Denver Federal Center, Bldg. 41 Denver, Colorado 80225 ' If the nap has the Universal Transverse Mercator (UTM) coordinates listed, it will have the UTM cone number condoned among the writing along the bottom of the nap. This rone number will be either 15 or 16 for Louisiana. VLeznote. thsX Zaditiidz and ZonQZt'idz aA.z nnZ_ idiot we. need, and that the USGS naps do not show UTM grid lines as they do latitude end longitude; however, tick narks along the edges of the maps do indicate the UTM grid locations. A straight edge must be used to connect tick narks at the opposite aides of USGS naps when interpolating between UTM tick marks because the map grid is drawn on the latitude- longitude system and, therefore, the UTM grid nay appear quite skewed. For the scales mentioned, tick narks appear for every 1G00 meters (1 kilometer), with every fifth ,r\. k mark 2nd the tick marks nearest the southeast and northwest corners of the map Lf'ti.ving the value in meters. The 1:24,000 scale is preferred to accurately locate the facility, but the 1:62,000 scale may be used if the 1:24,000 scale map is un available for your area. ' - - For example: The state capitol building in Baton Rouge would be: UTlt acneHo. JL _5 horizontal coordinate: .6 J. ii*l. Km. E _ vertical coordinate: 3 _3 _7 0.J5 Km. N Your facility: UTM zone No.J _5 horizontal coordinate:- 4_ 1_ 2_.9_ Km. E ITEM 7 COMPLIANCE STATUS vertical'coordinate: 3 3 4 6 5 Km. N Chcdi one o -the bCodn bcXci'J, AegoJicUng ijcua ^aaiLU.d 6 "Ccxiptiancc. SdizduZc" OSuch a document has not been requested of us, so far ns we know. D Such n document was requested, or submitted, but we haven't yet received noti fication that It was accepted ac a public hearing by the Commission. t J'i.'e were notified that the document was accepted at a public hearing; no schedule of actions to achieve compliance was necessary. ... D he were notified that the document vos accepted ac a public hearing; our sched ule actions to achieve comp 11; by ]_2_ (month), 197 5_ (year) was approved. The ' st recent "Increment of prcy.rcs date in our schedule of actions was achieved r:. ?_ (''onch.) n J_ (day) 1 5 (year). [YOU MUST KILL 1.*! TIill DAVE BLANKS IF YOU HAVE L!iLC-:::u this pauauilu-Q .. . >TH 000120400 KKir.r.K':.' iK'.'!:;,'Tn:'.v n;:i nil;:NAT KE (He V I - oil 11 / //, ) P.ien 8 of 9 > ; a . . . Kiirnr-: collecttom and iKcror.Ai. A. Amount of combustible refuse disposed of per ye nr: 4,140 Tons (give th.c applicable unit:;) B. Description of refuse; check off applicable catngories: C3 Taper scrap D Rubber scrap Cl Wood scraps & sawdust I':t garbage or animal v?astcs 'POthcr, specify: SPENT CATALYST AND RUBS ISH C. Method of refuse disposal; cheek off applicable categories: City pickup O On-site dump On-site incincraticn Contractor pickup On-site outdoor burning Q On-site landfill Other, specify:.;________________________________ __ D. If disposal is by contractor pickup, give the name and address of the contractor: EROWHIS-FEaRIS INDUSTRIES OF LOUISIANA INC. SOUQ WASTE niVISIOM-UTV StRVTCF HibhvMY - MAI'LE'.-iOOO, LA 70563 ______________ _________ E. The on-site incinerator, if any, has the following design features: No on-site incinerator Afterburners Water scrubber installed Single chamber O Primary & secondary Waste material disposed of Multiple chamber burners installed by burning in a boiler F. incinerator equipment data (if applicable): . - .... Manufacturer:'-Model:.............................................................................................................. .............................. ( ' Capacity:______________________ ______________________Installation date:__- I Auxiliary fuel used: (type, how used, rate of use)_- ________ ITEM 9 f.IJ? PI.EMS NTART T >?FORMAT ION A. Ylza&z 6u.pp.iu a unit pzot plan ox nap w!Udi ikowi the Icccut.lonA o 6tack* [ox oihzx 6 ounces j, Zoo zX'hzx with ihz zciUlcc Id znlL^lcatLcn niuxbcxs freon IZorn $ the plant bturdaxics, a. cU.5-ta.ncz aca.Cc, and the dinzetLc>i Hoath.' Plzczz also 4no<o, on a 6zpaxatz d.Lennart 1% ncccozoxu, the location o$ the.plant In Xelation to nca/ccAt kigli'.'XLtji, xcildcntlal axcas, and tov:n&. Attach the maps to the back tULs &oxn7. B. Approximately how much money have you spent on air pollution Control equipment and operation in the past 10 years? Equipment $3.653.000 Operation $ 3.473.000 ITEM 10 . to: : 1 c cases & hazardous hater tale A. Arc there any substances used or produced in your facility x;hi;h could cause im mediate injury to life or property, _i_f they wore emitted to the atrr.ocphere, which arc net already listed in this form as one which isr presently being emitted to the atmosphere? (c.g., chlorine for water treatment, toxic gases, gases used as cata lysts, etc. , v.'iiicli ordinarily do not escape) Please list such substances below. If none, j>lease 30 sLntc. Nil-?__________________________________________________ _____ B. Does your facility use beryllium in .my amount .t.pareto sheet. If answer or produce asbestos v'hatsoevev? If are. is no, please write mercury (other chan laboratory use), vr is yes, give detail.'; be lev' or c* "no" below: NO DTH 000120401 EMISSION' INVENTORY QUESTIONNAIRE (Revised 11/74) Page 9 of 9 ^ ITEM 11... PERSONNEL & CERTIFICATION A. The manner of the facility, on location at the plant site, is as follows C Name : Title: Name of Company: Business street address/ P. 0. Box: City or town, parish. Zip code: Business area code/ telephone No.: James A___HpRprnsrdi , Plant Manager - VCM Plant. Congco Chemicals fnmnanyJ A Division nf Conoco Inc. P. 0. Box 605______________________________ . Westlake. LA 70669____________________________ 318/491-5064_______ B. Person to cantact at the site of the facility about air pollution control, if different from the above: -* Name: Title : Business telephone No./ extension: Gary L. Foshee_________ Chief Process Enaineer 313/491-5062 C. If the company's air pollution control correspondence and documents are prepared at a headquarters office, at a different site, give the Information on the person to be contacted below: Name: H. J. Neel d_________________________________ Title: ndrortor nf Environmental Control Name of company; or parent company: Conoco Chemicals Company_________ lusiness street address/ P. 0. Box: 1 City, state, Zip code: Business area code; telephone No.: P. 0. Box 727_______________________ Westlake. LA 70669_____________ _ 318/491-5436______________________ D. Person who prepared this report: Name: Title: Firm: (if prepared by a consultant) Company: (if prepared in-house) Street address/ P. O. Box: City, state, Zip code: Area code, telephone #, extension: {1(5 one of -the. above, just check appropriate block:) A. B. DC. Christopher W. Turner Process Engineer Conoco Chemicals Company_______________________ P. 0. Box 605 Westlake, LA 70669 318/491-5211 E. CERTIFICATION, j certify, under the provisions in Louisiana and United States lauo ichich provide criminal penalties far false statements, that this Emission Inventory Questionnaire, Including all attachments thereto, contains information tchich Is true and correct to the best of nwknoiclcdgC'^dJd^tief. (^^gnature of manager, or other company agenc) J. A. DeRernard i . Plan*- Menanpr - VCM Plant (printed or typed name & title of person above) DTH 000120402 Q item i. nili i.T oerss fUiir. UrrUnI \ij iI ni-TI U'vI i Psge 1 of 9 (Subpage 1 of Gaseous chlorine (supplied by pipeline from PPG Industries) and gaseous ethylene- (supplied across the fence by a COiiOCQ ethylene plant) is reacted to form crude 1, 2 diclilorocthanc (EDC). The crude IIDC is purified by two stages of distillation to produce a relatively pure F.DC. t Pure GDC is thermally cracked in a gas-fired furnace at about 500C and cracks into vinyl chloride (VCM) and anhydrous MCI. This mixture is purified by two stages of distillation to separate the heavy tars and the HC1 from the VCM and unrcactcd EDC. The VCM is then redistilled to separate uncracked EDC (which is recycled back to the process) and the pure VCM is dried, neutralized and stored in pressure spheres at about GO psig. The !IC1 separated in the above process is reacted in a multi-stage catalytic reactor wi t!i ex /gen and ethylene to form additional i* nr T!he vent from tii i S reaction makes up the primary stream to C-500, the main plant vent stack. This extra EDC is recycled into the two stage EDC distillation process and blends with the EDC produced by the chlorine/ethylene reactor. Storage is provided in the plant for several grades of EDC, VCM product and two liquid organic by-products. Essentially all of the VCM product is shipped out by shin cr railcars. A small amount of EDC is also sold in ships or railcars. Design capacity of the plant is 600,000,000 lbs/yr of VCM. C COMF1DEMTIALITY The brief process description (described above) is considered to be a trade secret. Item 1-1 relates to- technology obtained under license and in confidence from Stauffer Chemical Company. This technology is incorporated in our commercial plant. It is our understanding that it is also licensed by Stauffer to other companies. We consider this technology to -be quite valuable and proprietary to Continental and Stauffer and request that it be held in confidence. * DTH 000120403 "V PV \i | 4l 'I U VI 1i T3! -) } h--4 i ai 1L 1 [i **"11 h .. / / I -/[< --1 ii s 0. r. J i P i --V 1__ 1 f -W ijfi... .. -r Vfp. .0-.. 'r?r-: --PPPPpiGh 0:i;;w i! P 6 fll-A I r >I >ii v-^ex-r, ... !,* :! I lv-c O?/1 it j - - 11 -- %4CCi - il Ji__ : Ii! :.; ^ ( |i S 'i W ~S{ZL-- / oi i; ikrO d !! ft ^13 '0 r ii |.! 3 \ DTH 000120404 *i W !( m i- ?. (O^hNlMAV On (Omm n F 1 t, . m M 6 (< ic*j- / / / i. ^nF H iT T o r f-- \ K^ rr ( Sccck 11-A II-3 IV-a IV-c IV-j IV-k V-A TABLE II CONTAMINANT EMISSION DATA - VCM PLANT Parc. 1.01 l.OL - - 23.3 SO, 0.033 0.033 - - - 0.04 CONTAMINANT FLOW RATE (L3S/HR) no2- Hydrocarbons CO HC1 12.9 12.9 - - 72.4. 0.168 0.168 1,205.0 14.6 11.9 2.1 0.95 0.95 464.0 - - - 0.24 63.8 0.31 0.57 --2 - 7.79 - 2.2 VCM - 14.57 - 0.01 0.98 DTH 000120406 I ATMOSPHERIC DISPERSIOfl _ f ESTIMATE TABLE III t RESULTS OF AIR QUALITY CALCULATIONS - PARTICULATES Wind Speed (null) 0.56 1.12 1.68 2.2/1 2. SO 3.35 3.91 4.47 5.03. 5.59 . 6.15 f. 6.71 ' 1.12 2.24 4.47 6.71 8.94 11.10 13.41 15.64 17.07 20.11 22.35 26.02 33.52 4.47 5.03 5. 59 0.15 6.71 7.27 7.02 0.33 0.9 3 9.4 9 U>. n 10.61 n. 17 Stabi.lily Class A A A A A A A A A A A A D D 1) D 1) D 1) 11 * . .1) 1) D D D V F ) F F r F F F F F 1' F MAX. GLC Crf./ku m) 1.5 Min ' 24 Hr 191 217 224 222 .. 215 203 193 132 . 102 3:74 165 157 124 163 ; 161 142 . 124 109 97 07 79 72 67 58 40 16 15 14 13 13 12 12 11 11 11 10 10 10 69 78 81 80 77 75 7166 66 ci 59 57 45 59 . 58 51 .45 3`9 35 31 28 26 . 24 ' 21 17 6 5 5 5 5 4 4 4 4 4 4. 4 4 *Pt ! ]*. i it I : |'i i'pv 1 fin* vi-n 1 r;l *i<-! .. (IV-C) LOCATION (FT)* Cross `Downwind wind 1,100 600 400 300 200 200 100 100 100 100 100 0. 5,600 2,900 1,800 1,500 1,300 1,200 : 1,200 1,100 . .; l.ioo 1,100 1,000 1,000 1,000 25,000 24,000 23,500 23,000 22,500 ` `` 22,000 21,500 21,000 20,500 20,500 20,000 20,000 19,500 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -4C0 -400 -400 -400 -400 -400 -400 -400 0 0 0 0 0 0 0 0 0 0 0 0 0 DTH 000120407 / *9 Wind Spied (r.inh) 0.56 1.12 ' 1.63 2.24 2. CO 3.35 3.91 4.47 5.03 5.59 6.15. 6.71 ( 1.12 2.24 ~ 4.47 6.71 8.94 11 .IS . 13.41 15.64 17.87 20.11 22.35 26.82 33.52 4.47 5.03 5.59 6.15 6.71 7.27 7.G2 8.n;; R-93 9.4'J 10.0 5 10.61 .1.17 * 0: i ; i:: AM) S PI I CP. IC DISPERSION ESTIMATE ( Stability CJ ays A A A A A A A A A iV J\ i\ D D 13 D 1) D D D D n. 1) D n F 1 I I I 1 1 TA8LK IV t ni:nui/ru or aim quality CALCULATIONS - SULFUR DrOXlUF " "7 i t MAX. CLC Car./cu m) 15 Min 24 Hr 0.27 0.31 0.32 0.31 0.30 0.29 0.28 0.27 0.26 0.25 0.23 .0.22 0.10 0.23 0.23 0.20 . 0.18 0.15 0.14 0.12 0.11 0.10 0.09 0.08 0.07 0.023 0.022 0.021 0.020 0.020 0.019 0.01!'. 0.01 8 0.017 0.01 7 0.01 6 0.0 1 6 0.0 1 5 . 0.097 0.112 0.115 0.112 0.108 0.104 0.101 0.097 0.094 0.090 0.083 0.079 0.065 0.033 0.083 0.072 0.065 0.054 0.050 0.043 0.040 0.036 0.032 0.029 .. 0.02 5 0.003 0.008 0.008 0.00 7 0.007 0.00 7 0.006 0.006 . 0.006 0.006 0.00 6 0 .our. 0.00 3 . 1 i< , LOCATION (FT)* .Cross- Downwind wind 1,100 600 400 300 200 200 100 100 100 100 100 0 5,600 2,900 1,800 1,500 1,300 1,200 1,200 1,100 1,100 1,100 1,000 1,000 1,000 28,500 28,000 27,000 26-, 500 26,000 25,500 25,500 25,000 24,500 24;500 24,000 24,000 24,000 . -400 -400 -400 -400 -400 -400 -400 -400 -4C0 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 0 0 0 0 0 0 0 0 0 0 0 0 0 | t I'M'/ ! t r vmiL : t a cl;. ( IV - C ) DTH 000120408 I( ATKOSPIICRIC DISPERSION ESTIMATE TAIU.li V KF5UI.TS OF AIK (JWAI.1TY CAI.nil.ATTOH'S ~ NO ___ Wind Speed (uph) 0.36 1. 12 . 1.6C 2.24 2. CO 3.35 3.91 4.47 5.03 5.59 6.15 6.71; * 1.12 ' 2.24 f. 4.47 6.71 0.94 11.10 J 3.41 15.64 17.07 20.3 1 22.35 26.02 33.52 4.47 5.03 5.59 6.15 6.71 7.27 7.02 0.30 (!. 9 3 9.49 10.05 10.6 L U.37 Stability Class A A A A A A 'A .A A A` A A D D l) D D n i) D i) D D, 1) D F F F F F F F F ! F F F F MAX. CI.C 0u"/c in) 15 Min 24 tlr 488 556 574 ' 569 551 531 506 483 467 444 422 403 317 418 412 362 316 .278 24 7 223 202 184 170 147 122 40 38 36 35 33 32 31 29 20 20 27 26 25 176 200 207 205 198 191 102 176 160 J 60 152 145 114 150 148 130 114 100 89 80 73 ' 66 61 53 44 .. - 14 14 13 13 12 12 11. 10 JO 10 . 10 9 9 LOCATION (FT) * Cro.:?;;- ; Downwind wind 1,100 600 400 1' 300 200 . j1 200 100 100 100 100 100 0 5,600 2,900 1,800 1,500 1,300 1,200 1,300 1,100 1,100 1,100 1,000 1,000 1,000 25,500 24,500 24 ,000 23,500 * 23,000 22,500 22,000 21,500 2 J,500 21,000 21 ,000 20,500 20,500 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 -400 0 0 0 0 0 0 0 0 0 0 0 0 0 ipi i >; y 1 i*:i <' veil! .M.'h'K. (IY-C) DTH 000120409 y ATMOSPHERIC DISPERSION ESTIMATE TAHLl- VI RKSUI.TS OF A1U QUALITY calculation:^ _ii;/i u ;j u: a_! ;j u ins Wind Speed 0.56 1.12 1.6Q . 2.24 2. CO . 3.35 3.91 4.47 5.03 5.59 6.'15 6.71 1.12 ' 2.24 4.47 i 6.71 8.94 11.10 13.41 15.64 17.87 20.11 22.35 26.82 33.52 4.47 5.03 5.59 6.15 6.71 7.7,7 7.82 8.38 C. 93 0.4 0 10.0 3 10.61 11. 1/ Stability Cl a;;:'- A A A' A A A A A A A A A D D D 1) n n n n n D D ., . D. D 1' r ! V V V 11- K V V V MAX. CLC Ca.r,/cu in) 15 Min 24 Hr j LOCATION (FT)*. : Cross- ! Downwind wind 11 ,'688 9,576 7,8'84 6,704 5,764 5,079 4,542 - 4,100 3,733 3,423 3,160 2,933 5,604 4/43.1 2,896 2,124 1,675 1,381 ' 1,174 1,021 904 810 734 618 500 466 432 404 379 358 339 32 2 307 294 287. 2 70 260 251 ' 4,208 3,447 .v.v': 2,838 T-- . 2,413 - 2,075 1,828 ' 1,635 1,476 --- . 1,344 1,232 1,138 1,056 .; 2,017 . 1.595 ,. 1,043 - 2 r - , 765 603 49 7 423 363 325 . 292 264 222 180 163 - r- 156 14 5 136 129 122 1-16 11.1 106 102 97 94 90 700 -600 500 -600 400 -600 300 -600 300 -600 200 -600 200 -600 200 -600 ' . 200 -600 200 -600 200 -600 200 -600 5,200 - -600 3,800 -600 3,200 -600 2,900 -60C 2,800 -600 2,800 -600 2,700 -600 2,700 -600 2,700 -600 2,700 -600 2,700 -600 2,600 -600 2,600 -600 31,000 -1,000 30,500 -1,000 29,500 -1,000 29,000 -1 ,000 29 ,000 -1 ,000 28,500 -1,000 28,000 . -1,000 27,500 -1,000 27,500 -1,000 27,000 27,000 26,500 26,500 -1,000 -1,000 -1,000 -1,000 ) "Of i r.1" 1 p re; iy 1 cue veil t. 1 (IY-C) DTH 000120410 ATMOSPHERIC DISPERSION ESTIMATE .u. TAIM.i: Vi I KF.SIM.TS (IF A Hi QUAI.TTY CM.CUT.ATI ONE. - CO Wind Speed (mplO 0.56 1.12 1.68 .2.24 2. f>0 . 3.35 3.91 4.47 5.03 ; 5.59 6.15 6.71 1.12 ' , 2.24 ' 4.47 a 6.71 8.94 11 . 13 13.41 15.64 17.37 20. J 1 22.35 26.82 33.52 4.47 5.03 5.59 6.1 5 6.71 7.2 7 7.82 8.33 8.0] 9.49 10.0 5 10.Gl 11.17 Stnlii 1 ity Clnss A A A A A A .A A A A A A D D D D 1) 1) D 1) I) 1) n. D D` F F F F F F F F F F F F V MAX. Gl.C yttp/ru m) 3 5 Min ' 24 llr 4,501 3,683 3,037 2,583 2,220 1,956 1,750 ' . : 1,580 1,433 1,319 1,217 1,130 2,146 1,705 1,116 818 645 532 453 394 343 312 283 238 193 169 157 147 133 131 3 24 113 113 103 103 99 96 92 1,620 1,328 1,093 930 799 704 .630 569 513 4 75 433 407 773 614 402 294 232 192 162 14 2 125 112 102 36 69 61 - ' 57 53 50 47 45 .42 41 39 37 36 - 35 33 , - f *0i i;;! n pi'i'i'y I I-IU` ven1 .UK !-.. (! V-C ) ! LOCATION (FT)* Cross- Iluwnv i nj J wind ? 700 -600 500 -600 ' 400 -600 300 -600 .300 -600 200 -600 200 -600 200 -600 200 -600 200 -600 200 -600 200 -600 5,200 . -600 3,800 -600 3,200 -600 2,900 -600 2,800 -600 2,800 -600 2,700 -600 2,700 -600 2,700 -600 2,700 -600 2,700 -600 2,600 -600 2,600 -600 31,500 -1,000 30,500 -1,000 30,000 -1,000 29,500 -1,C00 29,000 2R,500 -1,000 -1 ,000 28,000 . -1,000 27,500 . .-1,000 2 7,500 27,000 26,500 26,500 -1 ,000 -1 ,000 -1.000 -1,000 26,000 -1,000 - DTH 0001204U ATflOSPHESIC DISI'LT.jION ESTiTlAT'i; <{ *TAIU.I-; vm 'M KKfUM/r:: nr Ain quality CALCULAT JONS - 1101. Wind Speed (npb) 0. 56 1.12 1.68 2.2A 2. BO 3.35 3.01 A. A V 5.03 5.50 6.15 6.71 1.12 ` , 2.2A .. A7 .[ i 6.7] 0.9 A 11.13 13. A1 15.6A 17.87 20.11 22.35 26.32 33.52 A.A7 5.03 5.50 6.15 6.71 7.27 7.82 G.3B B. 0 3 0 .AO 10.05 10.61 3 1.17 Stability Clnr.s A A A A A A A A A A A A D 1) n 11 D l) D D n n i) D D' F F F F F F F V F F F F F MAX. GLC _C\r./cu m) 15 Min 2A Hr r 621 5.10 A20 357 303 271 2A2 219 199 133 169 157 297 237 155 11A 90 74' 63 55 A3 A3 39 . 33 27 2A 22 21 20 19 18 J7 16 1.5 15 1A 1A 13 22A 184 151 129 111 93 87 79 72 66 61 57 107 85 59 AL 32 27 23 20 17 15 1A 12 10 9 " '3 0 7 7 6 6 6 5 Is 5 .. 5 5 LOCATION (FT) * Crons- 1 Downwind tv i n d i 700 500 A 00 300 200 200 200 200 200 , -. . * 200 ; 200 200 5,200 3,300 3,100 2,900 2,300 2,000 2,700 2,700 2,700 2,700 2,700 2,600 2,600 31,000 30,500 30,000 29,000 23,50C 23,500 28,000 27,500 27,500 27,000 26,500 26,500 26,500 : -600 -600 -600 -600 -600 -600 -600 -6C0 -GOO -600 -600 -600 -600 -600 -600 -600 -600 -600 -600 -600 -600 -600 -600 -600 -600 -1,000 -1 ,000 -1,000 rl,000 -1,000 -1,000 -1,000 .-1,000 -1,000 -1,000 -1,000 -1,000 -1,000 yOi in propylene vcnL slack. (IV -- C ) DTH 000120412 (/' I ATMOSPHERIC DISI'ERSlOFI ESTIMATE' TAIH.K IX Rl-SUI.TS OF ATR QUALITY . ___CAI.CtTI.ATIQflfi - Cl.,j Wind Speed (r.ij)fO 0.56 1.12 1.68 2.24 2. P.0 3.35 3.91 4.47 5.03 . 5.59 6.15 6.71 .. 1.12 i .24 . 4.47 6.71 S.94 11. IS . 13.41 *15.64 17.67 20.11 22.35 26.32 33.52 4.47 5.03 5.59 6.15 6.71 7.27 0.33 0.93 9.49 10.0 5 10.61 11.17 Stability . Class A A A A A. A A A A A A A D D D D D D D D D D 1) I) D F F F F F F F F F F F F MAX. Cf.C Cc-ft/cn in) 15 Min 24 Mr 84 73 62 53 46 41 37 33 30 28 26 24 44 38 26 19 15 13. 11 9 8 7 7 6 5 4 4 3 3 3 3 3 2 2 2 2 2 .. - 30 26 22 J9 17 15 13 12 11 10 9 9 16 14 9 7 5` 5 4 3 3 3 3 2 2 JL 1 1 1 1 1 1 1 1 1 ] .1 J LOCATION (FT)* 1 Cross- Downwind wind '* . : !. ( 800 500 400 300 300 300 300 200 200 200 200 200 5,400 3,800 3,100 2,900 2,800 2,700 2,700 2,600 2,600 2,600 2,600 2,600 2,500 31,500 30,500 30,0*00 29,000 28,500 28,000 27,500 27,000 27,000 26,500 26,500 26,000 -600 -600 -600 -600 -600 -600 -600 -600 -600 -600 -600 -600 -600 -600 -600 -600 -600 -600 - -600 -600 -600 -600 -600 -600 -600 -1,000 -1 ,000 -1,000 -1,000 -1,000 -1,000 -1,000 -1,000 -1,000 -1 ,000 -1,000 -1,000 / * 01 i p. i n i : pt opy 1 rlie vent :: t ;sc!;. (I7-C) DTH 000120413 Wind Speed (raoh) 0.56 1.12 1.6S 2.24 2.SO 3.35 3.91 4.47 5.03 5.59 6.15 6.71 1.12 2.24 4.47 6.71 8.94 11.18 13.41 15.64 17.87 20.11 22.35 26.82 33.52 4.47 5.03 5.59 6.15 6.71 7.27 7.82 8.33 8.93 9.49 10.05 10.61 11.17 TABLE X RESULTS OF AIR QUALITY CALCULATIONS - VCM Stability Class A A A A A A A A A A A A D D D D D D D D D D D D D F F F F F F F F F F F F F MAX. GLC Ons?/cu m) 15 Min 24 Hr 125.6 - 96.4 76.8 63.7 53.9 46.7 41.0 36.6 33.0 30.0 27.5 25.4 64.0 48.3 30.3 21.8 17.0 13.9 11.8 10.2 9.0 8.1 7.3 6.1 4.9 8.2 7.6 7.1 6.6 6.3 5.9 5.6 5.4 5.1 4.9 4.7 4.5 -4.4 45.2 34.7 27.6 22.9 19.4 16.8 14.8 13.2 11.9 10.8 9.9 9.1 23.0 17.4 10.9 7.8 6.1 5.0 4.2 3.7 3,2 2.9 2.6 2.2 1.3 3.0 2.7 2.6 2.4 2.3 2.1 2.0 1.9 l.S 1.8 1.7 1.6 1.6 *Orisin is propyLene venc stack. LOCATION (FT)* Cross Downwind wind 800 600 400 400 400 400 400 400 400 400 400 200 5,800 4,400 3,800 3,600 3,600 3,400 3,400 3,400 3,400 3,400 3,400 3,400 3,400 23,500 23,000 22,500 22,000 21,500 21,500 21,000 20,500 20,500 20,000 20,000 20,000 19,500 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 -800 DTH 000120414 TABLE XI RESULTS OF ANNUAL AVERAGE CALCULATIONS BASIS: Ambient Temperature a 82F Atmospheric Pressure a 14-7 psia Mixing Depth = 1,162 meters Stack Height Correlation s Briggs Program ss "AQDM" Contaminant Sulfur Dioxide Chlorine VCM Carbon Monoxide Nitric Oxide Hydrocarbons Particulates Hydrogen Chloride Max. Cone. (ig/cu m) 0.06 0.74 0.87 23.7 9.4 76.3 3.6 4.0 LOCATION (FT)* XY 0 -2,000 -1,000 -2,000 -1,000 -2,000 -1,000 -2,000 4,000 0 0 0 -400 0 -400 0 *Origin is propylene vent stack (IV-c). 000120415 dth ) SECTION III WASTE WATER REGULATIONS -1 AND GUIDELINES dth 000120-416 SECTION III NPDES PERMIT DTH 000120417 Permit No. LA0003476 Appllriltlllll Mm LA0003476 AUTHORIZATION TO DISCHARGE UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provisions of the Federal Water Pollution Control Act, as amended, (33 U.S.C. 1251 et. seq; the "Act"), CONOCO Chemical Co. Division of Continental Oil Company P. 0. Box 605 Westlake, Louisiana 70669 is authorized to discharge from a facility located at Calcasieu Parish, Westlake, Louisiana to receiving waters named Bayou Verdine thence to the Calcasieu River in accordance with effluent limitations, monitoring requirements and other conditions set forth in Parts I, II, and III hereof. This permit shall become effective on August 26, 1979 This permit and the authorisation to discharge shall expire at midnight, ^arch 31, 1981 Signed this 23 rd day of May 1979 Diana Dutton Oi.ce c tor Enforcement Division (6AE) DTH 000120418 4C<f--O>u <c3U S<c3u E 8 , ~CoES/3B &4^) f" TT0SJJ)Co<oui O o&o -SCh. CM 3cor <D (X Co a; *0 *N*--34 BO Coc 4- 'oc 2 S2E5 c si3a54;); h<i3en>,r c/> 3 C3 C CCOJ <<33 O3S tj --ro C S- 0 M M <D S- C 0CXr-)_-'ru<ao >e sa j* I2 cer LO r^. <u 2 2J f i-- M O .teo 3~ aa bo Ea .S c a "3 1 c u a 4> .2 `5 D fa* CJ 5 C -#3* 3 BO <> t3 >< a% < z E -mo J2 'C & a S 12 . aa 3 s9 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS 1 3 j? <u e s S ><e 01 < tj <5 = 5 o> j? tj-g .a <u -oa BO *"* .--OC5SSo TjSOONcJJ co S *3a3 *3 X41! Ztj BO > jeto < =*c>3 < ^3 a 53 c - 2. S 5 --a bo 'Sba CX jr c5 | & j= j 3 C/3 <g -- </> <c PARTI Page 2 0f 11 Permit No. LA0003476 c To5 hoi ^i c o .2 a w c E5 _o . 5 -- </> 6 ifT3 jia: 5 g TcJ n <" C CD 5a Sae3 * ! o 12 s ! Is < 0 '5 z a 15 cr. ec c(3 kCoJ *35 ,rx* > o C* *" s sM Mc -i ohi e oE<3 E s8- 3cr aZ. S3 ^ 2 g bo a 3 hoo OC j_ <3 a 1i J I *"3 (A bfl 4) -- .s O. (9 co .x co o ofcfl 8S l 9 ja: e.'g E O3 J8 o Oc W3 c c C -O u *3 VI J<nO3J um-- CO OJ c. 0) < J= ^ H= 8 -C 6- Cc. 4-> S DTH 000120419 -sp#** 3 -ic.'i rc 03 ai ai ai 4-3 r- +j r~ *P"j -+t---> c/> I/I I/I 1/1 x 03 O Q E O o oo o a. c. c. SEE ooo <_1 O <_) 3 c 03 54a1?. 4c1. T3 U S- s_ s_ s_ o -C J= f J= E >* u till 03 cr 03 <4 b-1 QC CSJ CM CVJ CSJ OT 03 4--3 (/ O c E O o s- -C 1 CSJ cr 03 ci <u -*-> c C>O> O co <o c S- 03 --e CL 4-3 X 03 CO c c o --4 Co 2 c >. E41 41 C 41 41 3 3cr a 41 41 r~T S to 3 O 3c o4oc-3 00533 r-- 00333 CSJ 0303) -- 00533 r-- *00s3*33n. 03 3 4- 4-> 0 9 s CD 40-33 4C-O3 (O rO o^ J3 <t c c < c a.41 41 a co Q 3T z as Z 2= cu "3 -C -- 4-> O .3 o c <S| 41 3 u> JUS --n. 1* Z W -* E O 41 a 41 .c <> <c < c <c <: </> O -3 ^ a zz z13 2 B 4i 'e A 3 5 C C 23 .ti *" 5 41 J2 C 2 TJ O' aes S o z 03 o5 ro *o 5 S? S S3 a O 00 CD -- jc 41 <-) w-- S in CO <COn in CM -o--o X .2 <r-Olr-IO - a 3rs>1 D >, (3 C oM ZNDOfr-vofsn 10 CSJ in 41 in r**. CO CO CO m z 03 > 0) c o o CO o Ui cS aj 3 JZ o -3 z 2 03 >> n -3 eB 40 > O^oc--- < < voo <--r min om o O in 'a Q nr c(vm. tonucfol in OCO < co z O CcO -wa CM CO CM --- Jo3 c i- 10 o o> c fsj 03 *0 OO .EC3b T" C 03 J2 o oo c S- u < u SS3 XL -- 23 2 "3 M *tn C a 4-> -O r- 3>T, 0C3 0) o> .2 vi i/) CJ Ui ,,-- CJ E- 03 CJ C. 03 0X3 ks rt Z w 03 c "y c>rtw oa T3 "--<T3- 40_3> j>--,-ri- ro w o 3 C 03 r-- u J !" c5 V) 4_) c 03 57 uc 5 O o O a O <u/>l c 9 t *s\ u ra -0 rca u h <2 C3 PARTI Pagc ^ of 11 Permit No. LA000347c 4o1 c o E *3 .e CO o c <0 e 3 a s o e 3 cn C (9 jC w I* 0) 4J 03 tb IO c c 3 -3 a *3 ert cca n (AA ^03 n03 o M "rt (A mm <c o03 T** s- .. o C CX. il o <9 --0 c C>-f e < 1 o- 5c ^O 03 xj * -CJ ~ C <U 5 * ai c *5 3 O ^s s s 3 o03 O 0>3 -<-11) d cgo cai O3 4) 5 SC. C01 o CO CA 03 e5 41 E <u <9 O 2 s- Jtt 3 '> M 2 k# c * O o s_ *3 ai s 41 Cfi .*_ u> /l 03 ao >> 4-> cz: o & s *U CA s +-> *3 03 0c3 <1 c03 E 4-3 "EL o 0<U3o 4-3 .40-=33 O 03 o c c 03 r* 4-3 03 c J0C3 C<T/3J 3 cn c C3 *35 0tm3 OJ023- w (A 03 X E^3 4-3 4-> < 4o-3 C/3 DTH 00120420 ( V 3 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS 3 ev I8- B J S 3 1 0o) a i. caouc> IU a: +smj_ 4<-D1 4O->) to cn BO C 1 'co 2 iO3n oo c s"O <T3 O T3 OJ -M C tsO- *-Qr- 5. 5 Xu OJ *o 9 2 >* a303 cao. 0) -- .4c-> oo o QJ s 3 BO -C ^ 9 o 2L 2o 5 5 >* c |JS 5e (4 33 a gz Q BcO 3e 41 3 B 3 II 1 I s s 5 "*> s 1 2 a 01 3O Ji " 3 3 3 ,2 g Q Tt3o O Bo OJ >r- qj 4--> OJ Jo= *5 o E T3 i .IXS 6>0 *< g CDas*""03* c rs 3 1 a '5 N .SSi oC J3J u C g 1 u .2 *4 -v5t iui 2g f JC 1s cs .2 a O2C 6 wC B c w 2 > e 4ftC3t--Q--J> r o S 0J h0a--J. <tc c PART I Pape ^ of 11 Permit No. LA0003476 _eo *o B g ; s5 S a-> 'co E .2 `5 ,2 SO3 0 OJ -C (A 4> C 5 o -3 Co *N-- -X 3s -3 JS S - 0) T3 c -o > "u J* 0 T3 "2 a^ is E5 J .i 3 3 s f fjij lo -a *OoJ BO C ."Ceo5S -<<<2i-Uu-3> Ec4) lMron 53 <u -- -e 5^ o 4) C* C &i .3 4-1 K S U Jl s 4oJ >, .33 Q C E* Q r- UO e0 C to TJ jajj -<iu- 5Ml 3 (9 a s jy .*-> f<u sc fi "S.4J i *-> * DTH 000120421 PART I Page ^ of ^ Permit No. LA0003476 B. SCHEDULE OF COMPLIANCE 1. The permittee shall achieve compliance with the effluent limitations specified for discharges in accordance with the following schedule: None 2. No later than 14 calendar days following a date identified in the above schedule of compliance, the permittee shall submit either a report of progress or, in the case of specific actions being required by identified dates, a written notice of compliance or noncompliance. In the latter case, the notice shall include the cause of noncompliance, any remedial actions taken, and the probability of meeting the next scheduled requirement. o00120422 T>1H PART I Pape of 11 Permit No. LA0003476 C. MONITORING AND REPORTING 1. Represen tative Sampling Samples and measurements taken as required herein shall be representative of the volume and nature of the monitored discharge. 2. Reporting Monitoring results obtained during the previous 3 months shall be summarized for each month and reported on a Discharge Monitoring Report Form (EPA No. 3320-1), postmarked no later than the 28th day of the month following the completed reporting period. The first report is due on October 28, 1979 . Duplicate signed copies of these, and all other reports required herein, shall be submitted to the Regional Administrator and the State at the following addresses: Diana Dutton, Director Enforcement Division (6AE) Environmental Protection Agency First International Building 1201 Elm Street Dallas, exas 75270 Robert A. Lafleur, Exec Secretary Louisiana Stream Control Commission Drawer FC, University Station Baton Rouge, Louisiana 70803 3. Definitions. a. The "daily average" discharge means the total discharge by weight during a calendar month divided by the number of days in the month that the production or commercial facility was operating. Where less than daily sampling is required by this permit, the daily average discharge shall be determined by the summation of all the measured daily discharges by weight divided by the number of days during the calendar month when the measurements were made. b. The "daily maximum" discharge means the total discharge by weight during any calendar day. 4. Test Procedures Test procedures for the analysis of pollutants shall conform to regulations published pursuant to Section 304fg) of the Act. under which such procedures may be required. 5. Recording of Results For each measurement or sample taken pursuant to the requirer.ients of this permit, the permittee shall record the following information: a. The exact place, date, and time of sampling; b. The dates the analyses were performed; c. The person(s) who performed the analyses; 000120423 dth r V r PARTI I 1A0003476 Perron No. d. The analytical techniques or methods used; and e. The results of all required analyses. T A dctitional Monitoring by Permittee If the permittee monitors any pollutant at the location(s) designated herein more frequently than required by this permit, using approved analytical methods as specified above, the results of such monitoring shall be included in the calculation and reporting of the values required in the Discharge Monitoring Report Form (EPA No. 3320-1). Such increased frequency shall also be indicated. 7. Records Retention AJ1 records and information resulting from the monitoring activities required by this permit including all records of analyses performed and calibration and maintenance of instrumentation and recordings from continuous monitoring instrumentation shall be retained for a minimum of three (3) yean, or longer if requested by the Regional Administrator or the State water pollution control agency. DTH 000120424 f 1 ( PART II Page 8 of 11 Permii No. LA0003476 A. MANAGEMENT REQUIREMENTS 1. Change in Discharge All discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge of any pollutant identified in this permit more frequently than or at a level in excess of that authorized shall constitute a violation of the permit. Any anticipated facility expansions, production increases, or process modifications which will result in new, different, or increased discharges of pollutants must be reported by submission of a new NPDES application or, if such changes will not violate the effluent limitations specified in this permit, by notice to the permit issuing authority of such changes. Following such notice, the permit may be modified to specify and limit any pollutants not previously limited. 2. Noncompliance Notification If. for any reason, the permittee does not comply with or will be unable to comply with any daily maximum effluent limitation specified in this permit, the permittee shall provide the Regional Administrator and the State with the following information, in { writing, within five (5) days of becoming aware of such condition: 1 a. A description of the discharge and cause of noncompliance; and b. The period of noncompliance, including exact dates and times; or, if not corrected, the anticipated time the noncompliance is expected to continue, and steps being taken to reduce, eliminate and prevent recurrence of the noncomplying discharge. 3. Facilities Operation The permittee shall at all times maintain in good working order and operate as efficiently as possible all treatment or control facilities or systems installed or used by the permittee to achieve compliance with the terms and conditions of this permit. 4. A duerse Impact The permittee shall take all reasonable steps to minimize any adverse impact to navigable waters resulting from noncompliance with any effluent limitations specified in this permit, including such accelerated or additional monitoring as necessary to determine the nature and impact of the noncomplying discharge. . 5. Bypassing Any diversion from or bypass of facilities necessary to maintain compliance with the terms and conditions of this permit is prohibited, except (i) where unavoidable to prevent loss of life or severe property damage, or (ii) where excessive storm drainage or runoff would damage any facilities necessary for compliance with the effluent limitations and 1 prohibitions of this permit. The permittee shall promptly notify the Regional Administrator and the State in writing of each such diversion or bypass. DTH 000120425 I tAmk* PART II Page 9 of 11 Permit No. LA0003476 6. Removed Substances Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of wastewaters shall be disposed of in a manner such as to prevent any pollutant from such materials from entering navigable waters. 7. Power Failures In order to maintain compliance with the effluent limitations and prohibitions of this permit, the permittee shall either: a. In accordance with the Schedule of Compliance contained in Part I, provide an alternative power source sufficient to operate the wastewater control facilities; or, if such alternative power source is not in existence, and no date for its implementation appears in Part I, b. Halt, reduce or otherwise control production and/or all discharges upon the reduction, loss, or failure of the primary source of power to the wastewater control facilities. B. RESPONSIBILITIES 1. Right of Entry The permittee shall allow the head of the State water pollution control agency, the Regional Administrator, and/br their authorized representatives, upon the presentation of credentials: a. To enter upon the permittee's premises where an effluent source is located or in which any records are required to be kept under the terms and conditions of this permit; and b. At reasonable times to have access to and copy any records required to be kept under the terms and conditions of this permit; to inspect any monitoring equipment or monitoring method required in this permit; and to sample any discharge of pollutants. 2. Transfer of Ownership or Control In the event of any change in control or ownership of facilities from which the authorized discharges emanate, the permittee shall notify the succeeding owner or controller of the existence of this permit by letter, a copy of which shall he forwarded to the Regional Administrator and the State water pollution control agency. .T A uailahility of Reports Except for data determined to be confidential under Section 30S of the Act, all reports prepared in accordance with the terms of this permit shall be available for public DTH 000120426 . ( '-1 . ( c PART II Page 10 of 11 Permit No. LA0003476 inspection at the offices of the State water pollution control agency and the Regional Administrator. As required by the Act, effluent data shall not be considered confidential. Knowingly making any false statement on any such report may result in the imposition of criminal penalties as provided for in Section 309 of the Act. 4. Permit Modification After notice and opportunity for a hearing, this permit may be modified, suspended, or revoked in whole or in part during its term for cause including, but not limited to, the following: a. Violation of any terms or conditions of this permit; b. Obtaining this permit by misrepresentation or failure to disclose fully all relevant facts; or c. A change in any condition that requires either a temporary or permanent reduction or * \, elimination of the authorized discharge. ' * 5. Toxic Pollutants Notwithstanding Part II, B-4 above, if a toxic effluent standard or prohibition (including any schedule of compliance specified in such effluent standard or prohibition) is established under Section 307(a) of the Act for a toxic pollutant which is present in the discharge and such standard or prohibition is more stringent than any limitation for such pollutant in this permit, this permit shall be revised or modified in accordance with the ~toxic effluent standard or prohibition and the permittee so notified. 6. Civil and Criminal Liability Except as provided in permit conditions on "Bypassing" (Part II, A-5) and "Power - - Failures" (Part II, A*7), nothing in this permit shall be construed to relieve the permittee from civil or criminal penalties for noncompliance. ' 7. Oil and Hazardous Substance Liability Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the permittee from any responsibilities, liabilities, or penalties to which the permittee is or may be subject under Section 311 of the Act. 8. State Laws Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the permittee from any responsibilities, liabilities, or penalties established pnrstmr* to any applicable State law or regulation under authority preserved by Section 510 of the ; Act. . 'I DTH 000120427 PART II Page 11 of Permit No. LA0003476 9. Property Rights The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any infringement of Federal, State or local laws or rceulntions. Hi. Severability The provisions of this permit are severable, and if any provision of this permit, or the application of any provision of this permit to any circumstance, is held invalid, the application of such provision to other circumstances, and the remainder of this permit, shall not be affected thereby. PART III OTHER REQUIREMENTS A. Monitoring Requirements In the event that either the Daily Average or the Daily Maximum Limitations are exceeded for any limited effluent characteristic, daily monitoring of that characteristic shall be made until fifteen (15) con secutive samples are obtained with an average equal to or less than the Daily average Limitaitons and no individual results greater than the Daily Maximum Limitation. B. this permit shall be modified, or alternatively, revoked and reissued, to comply with any applicable effluent standard or limitation issued or approved under sections 301(b)(2)(C), and (D), 304(b)(2), and 307(a)(2) of the Clean Water Act, if the effluent standard or limitation so issued or approved: a. Contains different conditions or is otherwise more stringent than any effluent limitation in the permit; or b. Controls any pollutant not limited in the permit. The permit as modified or reissued under this paragraph shall also contain any other requirements of the Act then applicable. C. Any bypass of wastewater through the Flood Control Box shall be ana lyzed for the effluent characteristics listed in Part I.A.2., using grab samples at one (1) hour intervals during the period of bypass. Flow will be monitored continuously and recorded. DTH 000120428 SECTION III LAKE CHARLES CONOCO VCM PLANT SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN APRIL 1981 000120429 dth GENERAL INFORMATION SPILL PREVENTION CONTROL & COUNTERMEASURE PLAN CONOCO VCM PLANT A. PREVIOUS SPILL EVENTS This facility did not experience a spill event (as defined by Section 112.2 (i) of Federal Register, Volume 38, Number 237, December, 1973) within the twelve months prior to January 10, 1974, nor during the time period from January 10, 1974, to the date of issuance of this plan. B. POTENTIAL EQUIPMENT FAILURE Past experience of this facility indicates that there is no reasonable potential for equipment failure which would result in a discharge to navigable waters. C. SPILL PREVENTION SYSTEM USED FOR ONSHORE FACILITY 1. DIKES, BERMS, AND RETAINING WALLS All bulk storage tanks that are diked have the dike drainage diverted to inplant sewers that discharge to the waste water treatment facilities. Dike drains serving T-411D, T-401A, T-401B, and T-401C are kept closed. All bulk oil storage vessels in the facility with the exception of T-76 and T-76A are located within an impervious earth dike or concrete retaining wall. T-76 and T-76A contain a Calgon Polymer (WT-1255) used at the secondary waste water treatment system. Curbing in the area of these two tanks will divert any potential spills to a large holding pond. Waste water contained in the holding pond is recycled to the Activated Sludge Unit (ASU). The ASU provides secondary bio-treatment for water received before being discharged from the facility. Should any oil be discharged to the ASU, the physical layout and retention times are such that the oil would not reach public waters. The ASU and associated equalization basins are not subject to flooding. There are several pieces of equipment used in the process which contain large quantities of oil. The propylene refrigeration unit (BL-501) contains approximately 620 gallons of oil and air compressor BL-301 contains 466 gallons. The probability of a spill from either of these units is remote, however a spill would collect in the inplant sewer and gravity drain to the secondary waste treatment system. The bulk of the spilt oil would be collected by vacuum truck and the remainder would be degraded in the ASU. This facility uses portable storage tanks occasionally to contain fuel for temporary equipment. Any oil spilled from a portable storage vessel which is located within the facility will either be discharged to an API separator, the Holding Pond, or a collection sump where the oil will be recovered, or will be contained and cleaned up in a manner that will prevent a discharge into navigable waters. 000120430 DTH T-902, in the incineration area, is diked. The entire incinerator area drains to the waste treatment facilities. The plant operates a dock, to load products, on the Calcasieu River. At the dock facilities there is only one large storage vessel T-415 which is included in the Refinery's SPCC Plan. This tank contains ethylene dichloride and has a capacity of 52,660 BBLS. Any spilled liquid would be contained in the diked area surrounding the tank and then removed by vacuum truck. CURBING Curbing is used throughout the processing area for containing potential spills. These curbed areas are drained to the facility sewer system. ELECTRICAL TRANSFORMERS Electrical transformers located in areas of the plant that could result in oil reaching public waters due to a spill are drained to the waste treatment system via inplant sewer lines. The following is a list of electrical transformers in the plant: TRANSFORMER I. D. NO. Substation A Substation B Substation C Substation D Large Transformer Secondary System RATING KVA 1000 1000 1000 1000 7500 50 OIL CAPACITY GALLONS 350 350 350 350 1300 180 LOCATION Transformer Bldg. Transformer Bldg. Transformer Bldg. Transformer Bldg. Transformer Bldg. Wast Treatment Facilities NOTE: PCB's are not used in any of the electrical transformers located on plant property. CULVERTING, GUTTERS, AND DRAINAGE SYSTEMS The processing area of the plant has been engineered to drain toward the process sewer system. Any potential spill would collect in the sewer system and gravity flow to the secondary waste water treatment system. The waste water treatment system consists of two equalization basins and an ASU basin. The equalization basins have the capability of impounding up to one million gallons. The rail car loading facility has a collection system for leaks and spills. Any spilt material and rain water run-off in the rail loading vicinity will gravity flow to the waste treatment system. DTH 000120431 (Prior to ena!filrtin'i Pm t I, refer to rrrjulatunis mi l instructions /xiffc !>.) SL'ILL PREVENTION CONTROL & COUNTER:,!EASURE PLAN PART I GENERAL INFORMATION 1. Name r>T facility CONOCO VCM PLANT 2. Typn Of fnriliiv CHEMICAL MANUFACTURING PLAMT 3. T.^tmnnf^;i;iv One and half miles west of Westlake, LA on VCM Plant Road. Calcasieu Parish. LA. Property bounded approximately bv latitude w. 93 17` 15" tn W 93 171 longitiidP N. 30 141 S5* tn N. 30 IS1 15" on Westlake Quadrangle U. S. Geoqlogical Survey Map. 4. Name and address of owner or operator: Name CONOCO CHEMICALS COMPANY, A DIVISION OF CONOCO INC. Address___LAKE CHARLES VCM PLANT__________________________________ P. 0. BOX 605______________________________________________ WESTLAKE. LOUISIANA 70669 5. Designated person accountable for oil spill prevention at facility: Name and title J. A. DeBernardi, Plant Manager - Conoco VCM Plant G. Facility experienced a reportable oil spill event during the twelve months prior to Jan. 10, 107-1 (effective date of -10 CFR. Fart 1121. (If YES. complete Attachment =1.)_Mq MANAGEMENT APPROVAL This SFCC Plan will bo jmnlemented as herein described. Signature Name J. A/ DeBernardi, Plant Manager r Conoco VCM Plant. ~ CERTIFICATION I hereby certify that I have examined the facility, and being familiar with the provisions of 10 CFR. Part 112, attest that this SFCC Flan has been prepared in accordance with good engineering practices. James L. Robertson Printed Name of Registered Professional Engineer (S-al) *Q sf _______ Signature m Kc'vinlcmi Professional Engineer ____________________ Registration No 3ZS'tiO cg.,)f, S DTH 000120432 (I*-.11 !) I c.f a TAUT ! G K N KKAL 1NI'OK AI AT 10 N * ,, ( 7. I'o ten 1 in I Spills -- I'rcdielion & Control: Source Major Type of Failure Total Quantity Jla.1 loins BL-501* - BL-301* Structural Failure Structural Failure 620 466 Eight individual* barrels of oil Rupture of barrel 336 T- 76+ Rupture of Tank i 1500 T-76A+ Rupture of Tank 100 Rate Gaiions/hr. Direction of Flow* Secondary Containment 620 466 42 1500 t into inplant sewer into inplant sewer Contained in waste treatment faciliti Contained in waste treatment faciliti small quantity will cover immediate area only Gravity flow into holding pond 100 Gravity flow into holding pond * These are the only large sources of oil in the plant. The following page lists other sources of potential spills. + Contains a polymer used at secondary treatment facilities. Discussion: 'Ailach ni.i)* if ain>!i);jri:ilc. IV __C0Nj0C0 _VCM_PLANT.... CONTINENTAI. OIL .COMPANY *"DTH 000120433 (I'.n t I) l`a;:c - iif i' 7. POTENTIAL SPILLS - PREDICTION & CONTROL CONT. The following tanks are located in diked areas: SOURCE CONTENTS T-401 A T-401 B T-401 C T-411 A T-411 B T-411 C T-411 D T-402 T-405 T-421 T-422 T-450 T-451 T-452 T-453 T-460 T-78* T-78 A* T-77* T-77 A* T-902 T-960 A T-960 B T-962 A T-962 B Vinyl Chloride Vinyl Chloride Vinyl Chloride Vinyl Chloride Vinyl Chloride Vinyl Chloride Vinyl Chloride Light ends storage Tars storage 50% NaOH 3.5% NaOH Ethylene Dichloride Ethylene Dichloride Ethylene Dichloride Ethylene Diehloride SLOPS Aqua Ammonia Aqua Ammonia Phosphoric Acid Phosphoric Acid Light ends storage Dilute Acid Dilute Acid Muriatic Acid Muriatic Acid TOTAL QUANTITY 84,000 84,000 84,000 840,000 840,000 840,000 1 ,237,000 60,000 60,000 20,000 75,000 500,000 780,000 115,000 420,000 30,000 3,000 200 1,500 100 15,228 51,700 51,700 51,700 51,700 *These tanks are not located in diked area. however, drainage is so that any spi 11 is diverted to a one million gallon diversion DTH 000120434 ['ART r (.t:m;ral information A (/,'< spotir.c. to stall )ii< at.i xhniiUl b`f: YK.S', SO, or jV.-l (Sot Applicable).] 8. Containment or diversionary structures or equipment to prevent oil from reaching navigable waters are practicable. (If NO, complete Attachment =12.) Yes 9. Inspections and Records A. The required inspections follow written procedures. Yes E. The written procedures and a record of inspections, signed by the appropriate supervisor or inspector, are attached., . Yes n.-on^.v.n- Written procedures for the inspections required by this SPCC Plan have been developed by the supervisor of the company's Inspection Department. These written procedures and a record of the inspections, signed by the appropriate supervisor or inspector, will be made part of this SPCC Plan and will be maintained for a perTod of three years. Records of faciljty inspections will be kept in the inspection records required bv RCRA. Appendix I lists facility inspection procedures.:; 10. I'crsonnc-I, Training, and Spill Prevention Procedures A. Personnel are properly instructed in the following: (1) operation and maintor.nnefi of equipment to prevent oil discharges, and Yes ^ (2) applicable pollution control laws, rules, and regulations. Yes l* Describe procedures employed for instruction r Operating Personne3~recei ve informal training in this area as a part of their on-the-iob training. B. Scheduled prevention briefings for the operating personnel arc conducted fre quently enough to assure adequate understanding of the SPCC Plan. Yes Tier.evibf*hrinf'inf pmowruw Ths VCi4 Plant has a pollution control manual which contains gufdelines for reporting spills and general inp-lant pollution control procedures. This manual Ts~updated at least once per year, "t CONOCO VCM PLANT_______________________________________________ n.CONTINENTAL OIL COMPANY r ' ----------------------------------------- ------------------------------------------------------------- DTH 000120435 (I'.m !) l\.n- :i uf PART II, ALTERNATE A DESIGN AND OPERATING INFORMATION ONSHORE FACILITY (EXCLUDING PRODUCTION) A. Facility Drainage 1. Drainage from diked storage areas is controlled as follows (include operating description of valves, pumps, ejectors, etc. (Note: Flapper-type valves should not be used):_______________________ Drainage from diked storage areas is restrained by valves to prevent spills or excessive leakages of oil into the drainage system or inplant effluent treatment system? Diked areas are emptied by gravity flow. All diked areas are discharged to sewers that discharge to the waste treatment system. The accumulation in the four above mentioned diked areas are examined before discharging to assure no oil is present. 2. Drainage from undiked areas is controlled as follows (include description of ponds, lagoons, or catchment basins and methods of retaining and returning oil to facility): Plant drainage systems are designed such that all processing areas drain inwardly to sewer systems that discharge to the wastewater treatment facilities. All waste water drainage is gravity flow wherever possible. Where it is necessary for pump transfer, two pumpT are provided. All four of the above mentioned tanks contain vinyl chloride monomer which is a highly volatile hydrocarbon which would ~ vaporize if rupture occured. 3. The procedure for supervising the drainage of rain water from secondary containment into a storm drain or an open watercourse is as follows (include description of (a) inspection for pollutants, and (b) method of valving security). (A record of inspection and drainage events is to be maintained on a form similar to Attachment #3): a) Visual inspection is made of all contained water prior to drainage. b The tank dike drain is kept closed when not being used. All drain valves are opened and closed under responsible supervision. Name of facility CONOCO VCM PLANT Operator CONTINENTAL OIL COMPANY 000120436 dth PART ir. ALT'ORNATM A df.sk;\ and opkuatinc information OKS! 10 UK FACILITY (LXCLCDINO PRODUCTION) V I (AVs/>/s-p to r.tntnncnln shnuUl he: YES, ,\'0, nr AM fS'<>( /l I'plicalih-).] D. T>ilJv Storage Tanks 1. Describe tank design, materials of construction, fail-safe engineering features, and if needed, corrosion protection:___ Thp mafpriai anH rnnctriirt-irm nf all Storage In this facility are compatible with the material stored and the conditions nf storage; e.g.. temperature, pressure, etc. See next page. 2. Describe secondary containment design, construction materials, and volume: All of the bulk oil storage tanks and product spheres in the facility, with the exception of those listed in the general information section, are provided with a secondary means of containment large enough to accommodate the largest single tank plus sufficient freeboard to allow for precipitation. These are ail in the form of dikes and curbs Which are impervious to spilled oil. ' 3. Describe tank inspection methods, procedures, and record keeping: Refer to Appendix I l 4. Internal heating coil leakage is controlled by one or more of the following control factors: (a) Monitoring the steam return or exhaust lines for oil. ___________ Describe monitoring procedure:__The Steam condensate from internal heating coils io T-421 and T;-422. discharge mithin-the tank dikes and drain to the sewer system that is sent to the waste treatment facilities. The feasibility of installing external heating systems was considered prior to construction of each tank._____________ ; (b) Passing the steam return or exhaust lines through a settling tank, skimmer, or other separation system. (c) Installing external heating systems. No No 5. Disposal facilities for plant effluents discharged into navigable waters are observed frequently for indication of possible upsets which may cause an oil spill event. Tss. Describe method and frequency of observations:__Effluents diseharged from this facility iof-n .navLioahlft. waiters are monitored in accordance with NPDES Permit LAQQQ3476. Ifafi disposal facil.ttifis-.are ob^ery.&d_frLe.auently _enough. to detect possible iy.5Ltnm{iiets that-could-cause oil spill event. The waste treatment facilijty i s. ohseoed_aULeas t_3_-times, on a daily b a sj A if visible oil leaks which resuIt-_irL.itJoss .of. oil..from tank seams, gaskets, rivets, and bolts suffjcjently large to cause the accumulation of oil in diked areas are promp11y corrected. .-it; -CONOCO _ VCM _PLANT. 0|.oral n-__CONTINENTAL_0IL COMPANY pTH 000120437 i B. BULK STORAGE TANKS 1. Fail-safe engineered tank installations (high liquid level alarms audible and visual signal in Control Room) have been installed on the following storage tanks: T-401 A T-401 B T-401 C T-411 A T-411 B T-411 C T-411 D T-402 T-405 T--421 T-422 T-460 T-450 T-451 T-452 T-453 Vinyl Chloride Vinyl Chloride Vinyl Chloride Vinyl Chloride Vinyl Chloride Vinyl Chloride Vinyl Chloride Light ends Tars storage 50% NaOH 3.5% NaOH SLOPS Dry EDC EDC Wet EDC Wet EDC ( 2. Direct vision gauges or their equivalent are used for fast response determination of all bulk storage tank liquid levels. 3. Liquid level indicating devices are regularly checked to insure proper operation. DTH 000120438 PAP'!' n. ai,ti:i:.\ati-: A I)KSION ANI> on;!:ATIN'C IM-'OU.M ATION 0NSIIOKI-: PACII.ITY (t J X ^ I. I' l) IN (.' HJOm.VTlON) f /.*# r.ptitt r la j/ : li'iaai: t ; ?!./,itht la': 3 A'.V, XO, ar N.l (Xat . I/i/i/icu C. I-'acilily Tiansfer Operations Pumping, and In-plant Process 1. Cono::;wi pro!octi<>ri for buried pipelines: (a) Pipelines are wrapped and coated to reduce corrosion. Yes (b) Cathodic protection is provided for pipelines if determined necessary by elec trolytic testing. ,.Yes_ (c) When a pipeline section is exposed, it is examined ami corrective action taken as necessary. Yes _ 2. Pipeline terminal connections are capped or blank-flanged and marked if the pipe- - line is not in service or on standby service for extended periods. Yes Describe criteria for determinin'; when to cap dr blank-flange:____________________________ If a pipeline is taken out of service for an extended period of time or for repairs, the terminal connection at the transfer point is capped or blind-flanged.; 3. Pipe supports are designed to minimize abrasion and corrosion and allow for expansion and contraction. ^es Describe' pipe support dosiVn All pipe supports for the facility are designed according to company standards to allow for expansion and contraction to minimize abrasion. ___________________ _______________________________________ f 1. Describe procedure.-, for regularly examining all above-ground valves and pipelines (includ ing flange joints, valve glands and bodies, catch pans, pipeline supports, locking of valves, and metal surfaces) All above ground pipelines and valves are subject to regular examination bv the company's inspection department, at whicTi time, the genera1 condition of the installation is assessed and the average thickness of the pipes is determined. These piping installations are also subject to constant examination by operating personnel. 3. Describe procedures for warning vehicles entering- the facility to avoid damaging above ground piping: Vehicular traffic of any type is prohibited from entering any area of the facility where pi ping a n_d_eflid pment would be susceptible to damage. Eqx_yehicle_.e.otry, th.e..cans.eQt._QfJth_epjs_rator_in charge of the area must be obtainsd,__These areas _are.._ciearly marked by signs and/or barriers. ef pur ... CONOCO.. _ VCM. ..PLANT. OrrCONTINENTAL OIL..COMPANY .. ----------------------DTH 000120439 i: ! it. \ II. I n.u<- A ) r :i ''Airr h. ai/i ::i;.x \ ri: a DhkUt'.'N AM) Ol'i.'iiA l'l !.M()!{.MATIOX ONSIIOKK KACIUTV (KXCU.TUNt; L'UOmjCTlO.N) [ ,V- . in statements r.l.uiil'i he: YKX, ,\'0, ir ,V.l (Xot A /ijUien/ile j.l D. Faeilily Tank C: r (v Tank Truck Loading/T.Inloadiiu; Hack Tank car and tank truck loarling/unlonding occurs at the facility. (If YES, complete 1 through "> bel.',.) Yps 1. Loading/unloadiug procedures meet the minimum requirements and regulations of the Department of Transportation. Yes . 2. The unloading area has a quick drainage system. Yes 3. The containment system will hold the maximum capacity of any single compart ment of a tank track loaded/unlondcd in the plant. Yes Describe containment system design, construction materials, and volume: The_______ loading rack area drainage for the facility, except for a portion of the tracks used for siding, flow into the sewer system which' discharge into waste treatment facilities. The waste treatment facility has capacity to collect up to one million gallons.~ ( 4. An interlocked warning light, a physical barrier system, or warning signs arc pro vided in loau.ng/unloading areas to prevent vehicular departure before disconnect of transfer lir.es. Yes Describe methods, procedures, and/or equipment used to prevent premature vehicular departure: Warning,$iqns are provided in loading/unloadina areas to prevent vehicle departure before complete disconnection of transfer lines. These signs are positioned bv the rack operator. There fs also a standard operating procedure to place wheel chocks around each vehicle. ? 3. Drai and 'mild:-, on tank trucks and tank cars arc chocked for lcnkag<- before /unloading or departure. Yes Nome of CONOCO VCM t Continental Oil Company DTH 000120440 ( l\i i ( II. \l\i ni.it v . \ / I r, .( V V I'AUT II. ALTERNATE A DKSH.'X ANU orKRATiNL I Nl-'OU.M ATIOsV ON.SIIOKK FACILITY (KXCLriUNL PRODUCTION) [}?t.:i>r, iki: In :;lil loin n I:: r.hnuhl : YICS, SO, nr SA (Sat /I jinhctthlc) ] Security 1. Plants handling, processing, or storing1 oil arc fenced. Xe o Entrance gates are locked and/or guarded when the plant is unattended or not in production. Yes 3. Any valves which permit direct outward flow of a tank's contents arc locked - closed when in non-operating or standby status. __________ 4. Starter controls on all oil pumps in non-operating or standby status are: ..(a) locked in the off position.; (b) located at site accessible'only to authorized personnel. ----ft?------Tes 5. Discussion of items 1 through -1 as appropriate: 3.__ The master flow and drain valves and.anv _a_thetL_Yalyes_ that permit direct outward flow of the tank*s content to ihe_5tirfa.ce_.are_ securely locked__ for equivalent) in the closed position when in non-operating or non-standbv status,, The loadina/unloadind connections of oil pipelines are securely capped or blank-flanged when not in service or standby service for extended__ time. 6. Discussion of the lighting around the facility:__ The lighting around the facility prrwirlog for safp working, ronditions and adequate visibility around all storage containers,---------------------------------------------------------------------------------------- i Name of facilityCONOCO.-VCM PLANT Opw.m.w... CONTI NENTA1_QIL_C0MP.ANY____ DTH 000120441 (I`.ut II. Alliin.tir A) I'.il'.c <-< OIL PRODUCTION FACILITIES (ONSHORE) - Not applicable. OIL DRILLING AND WORKOVER FACILITIES (ONSHORE) - Not applicable. OIL DRILLING,PRODUCTION OR WORKOVER FACILITIES (OFFSHORE) Not applicable. DTH 000120442 APPENDIX I -> FACILITY INSPECTION PROCEDURES / I. Above Ground Storage Tanks All above ground storage tanks will be inspected at least once every two years. The vessel will be visually inspected. External thickness measurements will be taken with ultrasonic equipment. An inspection of the foundation and support structures is also to be made. If the vessel is opened, an internal inspection is to be made. This will include a visual inspection and thickness measurements with ultra sonic equipment if practicable. If corrosion is found, the depth of the pits will be measured and recorded. ( II. Buried Piping Installations Any section of buried line which is uncovered and exposed at any time is to be visually inspected and external thickness measurements taken with ultrasonic equipment. III. Miscellaneous Process Equipment All other process equipment requiring inspection, will be inspected on a two year interval. Units will be inspected when down for cleanouts more often than the two year interval. When a vessel shows signs of DTH 000120443 corrosion, inspection will be made on shorter intervals as determined by the Inspection Department. Records/Administrati on All inspections and records will be performed and recorded in accordance with CONOCO standards. Letters detailing inspections will be written and distributed to the appropriate persons for information and/or corrective action.. DTH 000120444 INFORMATION TO BE FURNISHED TO REGULATORY AGENCIES WEN REPORTING A MAJOR SPILL The following information will be provided when reporting spills of oil or hazardous materials by telephone. A. Name of company reporting spill; time and date of call. S. Name of person reporting spill and telephone number at which caller can be reached if additional information is needed. C. Time and data spill occurred. D. Location of spill. E. Approximate amount and type of material spilled. F. Source of spill and action taken to control spill. DTH 000120445 REGULATORY AGENCY NOTIFICATION FOR MAJOR SPILLS INTO NAVIGABLE WATERS REGULAR WORKING HOURS (8-5, MONDAY - FRIDAY) Report spills greater than 100 gallons to: a. NATIONAL RESPONSE CENTER DUTY OFFICER 1-800-424-8802 (TOLL FREE CALL) If the National Response Center cannot be reached, contact: b. U.S. COAST GUARD CAPTAIN OF THE PORT PORT ARTHUR, TEXAS (713) 971-2261 OR c. U.S. COAST GUARD COMMANDING OFFICER NEW ORLEANS, LA. (504) 589-6275 If more than five (5) barrels, 210 gallons, also report spill to: d. DEPARTMENT OF NATURAL RESOURCES LAKE CHARLES, LA. LARRY RACCA (491-2091) or LOUISIANA DEPARTMENT OF NATURAL RESOURCES BATON ROUGE, LA. NIGHTS, WEEKENDS, HOLIDAYS 491-2082 (504) 342-6363 (504) 342-5595 NIGHTS, WEEKENDS, AMD HOLIDAYS ReDort spills areater than 100 aallons to: a. NATIONAL RESPONSE CENTER DUTY OFFICER 1-300-424-8302 (TOLL FREE CALL) If the National Response Center cannot be reached, contact: DTH 000120446 ( b. U.S. COAST GUARD CAPTAIN OF THE PORT PORT ARTHUR, TEXAS OR c. U.S. COAST GUARD COMMANDING OFFICER NEW ORLEANS, LA (713) 971-2261 (504) 589-6275 i DTH 000120447 si VM o| iuj cc] 2l o! to I 31 & - 1 +u* GO co Lrf*U*-> =3 CO OCO UJ 1C0O UJ CD 10 i1 40 e wo o uCUSi <\Z5w> 3 U. r% Cl o O to iO CC => 1 O C\J _cCcl =t--> CC zoh--r C5OT --*3"* ZC f<fCllO-0-- co<4co; 41 OH<V-I COMS GU<J4UOC)l3 iJ 2S* Sr~r cs w o 3U OGlu:j0u) 1-- c Cl. 5i O <-> 4woJ 2o21l h<G- 5 cc GcV 4W11 OwcCZ*j Oc<C3Jr HUCO&>3--C.-iHxG**tcCNowM CC o >C<c--O UOz, ej33-- o^~1+ cc u 0*1 *hG<<- < 3O <0 m zr 3UC.'- 0J w <* * OTH 000120448 REGULATORY NOTIFICATION FOR SPILLS OF OIL OR HAZARDOUS SUBSTANCES IN TRANSIT 1. STATE POLICE EMERGENCY RESPONSE TEAM Working Hours - (504) 925-6593 24 Hour Number - (504) 925-6595 2. DEPARTMENT OF NATURAL RESOURCES Lake Charles - 491-2082 (or) Baton Rouge - (504) 342-6363 24 Hour Number - (504) 342-5595 3. CHEM-TREC (For advice or assistance in reporting handling or cleanup) 1-800-425-9300 000120*49 SECONDARY WASTE WATER TREATMENT OPERATING MANUAL CONOCO VCM PLANT MARCH 26, 1932 DTH 000120450 INDEX Introduction General Description Detailed Description Raw Plant Effluent Storm Water Diversion Box Equalization Basins ASU Feed Activated Sludge Unit (ASU) Nutrient Addition Anti foam Addition Polymer Addition Clarifier and Sludge Recycle SI udge Thickener Effluent Re-aeration Effluent Weir Box - EPAStation 201 Dilution Water Control Samples Incinerator Wastewater Turnaround System 1 Appendix A Material Safety Data Sheet - Aqua Ammonia B Material Safety Data Sheet - Phosphoric Acid C Material Safety Data Sheet - Polymer WT - 1255 D Material Safety Data Sheet - Foamtrol C-144 E Operating Curve, Polymer Pumps, P-513 A&B F Operating Curve, Phosphoric Acid Pumps, P-514 A&B G Liquid Height/Volume Table - T-73, T-78A H Liquid Height/Volume Table - T-76, T-77, T-76A, T-77A I Secondary Waste Treatment Log Sheet J Control Sample Analysis Sheet K Secondary Effluent Discharge Analysis Sheet L Plot Plan f2 1 1 6 6 6 7 7 9 10 11 12 12 13 14 14 15 16 17 18 DTH 000120451 SECONDARY WASTE WATER TREATMENT OPERATING MANUAL CONOCO VCM PLANT Introduction This operating manual is intended to provide basic flow logic and operat ing data for the secondary waste water treatment system. A general flow logic description together with general operating philosophy is presented first. This section is followed by a detailed description of each major portion of the system. The method of operation of the Secondary Waste Water Treatment Facility will be continuously updated and refined as more experience and data are obtained. General Description All waters leaving the plant which flow into public waters are controlled by the Federal Environmental Protection Agency (EPA) or the Louisiana Department of Natural Resources (LDNR). The Conoco VCM Plant operates under a National Pollutant Discharge Elimination System (NPDES) permit issued by the EPA. The permit allows the discharge of limited quantities of materials which exert a biological oxygen demand (BOD) and/or chemical oxygen demand (COD). Also, limited quantities of chlorinated hydrocarbons, suspended solids, and ammonia may be discharged into the receiving body of water. The effluent pH is restricted to not less than 6.0 nor more than 9.0 standard pH units. In order for the plant effluent to meet these standards, the effluent is treated in an activated sludge unit (ASU) which is both preceded and followed by other treatment steps. The^fif^lHent^wateT^frorn ^imestone Neutral i zation, Pi t, T-500 f1 ows^south through*^ an^undergrsuodll 1 eas rhi t riinnr i Here caustic is added to raise the pH -to vbetwee/i 'tin i ts. " ' It continues to flow south until it reaches the storm-water diversion box located just east of the sludge thickener in the secondary waste treatment area. Under normal conditions, water-rflows out of the box and into the west* equalization basin.. However, during very heavy rains, the equalization basins may-.fiU,,up...Jtllso.xW.atenas-jiiverted directly to*-.the* bayou by flowing over the baffler.in the storm-water diversion boxr In this way the secondary treatment system is protected from being washed out or filled to overflowing. 000120452 DTH The EPA requires the reporting of any by-pass of the treatment system which results in water going untreated into the bayou. Therefore, should a by-pass occur, the depth of water flowing over the baffle and the duration of the flow must be recorded. The water must also be sampled hourly and the samples taken to the Laboratory for analysis. In the west equalization basirr, volatile components such as,EDOare`4Sllowe<J to evaporate,`thus reducing the organic loading on the ASU. Incoming solids are also allowed to settle in the west basin before the wastewater passes into the south basin. The west and south basins are connected by an undergrounqb?li.ne> Hater flowing into the soutfrrequalization basin is contacted by-wor:25 h/p. high-speed aerators which serve the:foil owing purposes:* 1) They mix the concentrated influent with the water in the basin to produce a homogeneous mixture, thus reducing the effect of concentration changes. '2) They further air-strip volatile components such as EDC, thus reducing the organic loading on the ASU. 3) They aerate the water to prevent septic conditions from forming in the equalization basin. THelsdutfreqifal 1 zation-basin'-is operated^approxirnTteiy 10T ruT.LJ.iuin mi iii--min? waterTContainment:capacity. Water^sgpumpedTfrom^thfe south-equal i zati on - bas i nsi nto .thei-ASUibvf.the;4SU^rj fedd-pumpS-PtSISTATin'd ~B. -fWirssiszcontrol 1 ed by*nc?702-^ TUrtHd1''level. The pumps are protected against operating at low liquid levels by automatic They are also protected against operating at their deadhead pressure "by an orXfi.ce^regula.ted recycle 1 i ne.jto,-t the "south'"equal i zati on basin from the pump dischargeheader. ` Normally, only one ASU feed pump is operated with the other as a spare/ However, during a heavy rainstorm, operation of both lift pumps may be necessary to control the level in the South Equalization Basin. If rain is forecasted to last for several days or if several inches of precipitation are expected, both ASU feed pumps may be started as soon as the rain begins to insure adequate level control and prevent stormwater bypasses. The Activated Sludge Unit (ASU) feed enters the basin at the southeast corner, , near the point where the recycle sludge is returned from the clarifier. The ASU is thoroughly mixed and aerated by seven, 40 h.p., high-speed aeratorsi In this way the bacteria that consume the organic materials which exert a BOO or COD are kept suspended in the water. Thus the bacteria have better contact with the DTH 000120453 waste and are in an area of high oxygen concentration which enables them to more effectively degrade the wastes. Bacteria that settle out in the system form a mud-like layer which becomes anaerobic due to the inability of the dissolved oxygen to penetrate the layer. After approximately a n the*ASU,, the treated water flows out of the northwest corner of the basin through an underground? line to the diversion box at the east end of the ASU where polymer is added;*- Polymer is used to flocculate the solids (bacteria) and thus improve their settling characteristics. The mixer in the box disperses the polymer in the clarifier feed so as to optimize the flocking effect. From the diversion box the liquid flows into the clarifier* Here the solids settle by gravity to the bottom and the clarified liquid flows out over the weir at the top. The clarifier rake moves the sludge around the bottom of the clarifier to the recycle pump suction sump. From there it is pumped back into the ASU. The recycling of sludge prevents the depletion of the bacteria population in the ASU. Recycle.s 1 udge -flow is measured by t* venturi flow meter and controlled by a manual globe valve located downstream .`oJti.*lBeter iriTthe metering loop. The normal recycle sludge flow raters 64J[Lgpm.' ^ Someofthe-recycle sludgewisidiverted-to the-Sludge Thickener- A^lT9~orv*aas entJaes-i-s--by^Tudge=*Wast4i^Pumpr*,P*'50$`. Here the solid sludge is separated from the treated wastewater by gravity settling in the Sludge Thickener prior to final disposal. -Bca&fiflJ;.l1y.F*Ahe"th:ickeneclsTiidge^isi*transferred .the^DAE^unitvat^LCCP^bysgravity -flow* The sludge is then sent to the filter press at LCCP for dewatering. The diverted sludge is then removed by truck. The clear water which overflows the sludge thickener weir, is returned-to the * ASU., By removing sludge in this manner, the bacteria population in the ASU an be controlled to prevent starvation due to too many bacteria or poor waste treatment due to too few. Tljg,,intermittent flowtto the sludge thickener*iswM cqjritroy.ed^at.approximately 16 gpm as indicated by a venturi meter located * e^tiof^the^thicken&r. *The manual globe valve used to adjust the flow rate is located immediately downstream of the flow meter. Treated water from the clarifier overflows into the re-aeration basin where it is contacted by a 15 h.p., high-speed aeratort The dissolved oxygen con-f centratipn is raised to the saturation point--approximately 8 ppm^ depending on the temperature--tb assure compliance with Louisiana State Law. The oxygen-rich effluent flows into the effluent weir bo* where temperature, y pH, dissolved oxygen and flow rate are continuously monitored. This is the EPA discharge station 201i The recording of these parameters at this location is either required by law or required to prove our compliance with the law. Therefore, all instruments must be kept in good working order. The NPOES permit under which the plant operates requires that a flow-proportioned refrigerated sample be collected twice each week and analyzed for several para-, meters.These samples are collected using the Collins sampler located at the southeast corner of the switchgear building. DTH 000120454 The treated effluent'Which flows out through the V-notch weir in the weir box goes via an underground clay tile line to the bayou. Three+ehemicals are stored in bulk at the sg^ondary, Aqua anrnooiafe.and phos-i phoric acid are added to the ASU only when required, and polymer is a<^ded continuously to the cl^iYfer*fffe'd?*t. All three systems utilize a bulk storage tank that gravity feeds into a smaller^ay^tanjc. Ammonia or phosphoric acid is added to the ASU only if the food suDply in the ASU is severely depleted, as shown by laboratory analysis. Care must be taken not to exceed the daily maximum discharge limit of 68-pounds of ammoniai Phosphoric acid has also been used in the past to lower the ASU pH during high pH upsets. Aqua ammonia and phosphoric acid are nutrients, necessary for the proper growth and functioning of the bacteria. Both chemicals are pumped from the day tanks, through underground pipes, to the east end of the ASU where they enter under the liquid surface. Diaphragm metering pumps are used to control the addition rates by changing the micrometer adjustable pump strokes. Excessive amounts of ammonia will cause a violation of the NPQES permit while insufficient quantities of ammonia or phosphorus will hinder the growth and operation of the bacteria, thus causing an upset condition in the ASU and clarifier. Tl'H--pm>!L flushed -hea de TM -downs tream of*%t!b'polymer--pump .discharge., The rate of polymer addition is controlled by the variable speed pump^motor controller located be hind the motor-starter panel in the switchgear building. The water flush is controlled by the globe valve downstream of the flow-indicating rotometer lo cated beside the polymer pumps. Water is used to dilute the polymer and thus improve its ability to mix with the clarifier feed liquor and to flocculate the solids. Also, the water flushes the viscous polymer through the pipe, preventing the line from plugging. Dilution water is added to the raw secondary waste to protect the bio-massy.j from high concentrations of 2-chloroethanol and other organics. This..situation 4 occurs.only rarely, and therefore dilution water is seldom added. If dilution water addition ever did become necessary, it could be obtained from any of the following sources:1 1) LCCP treated effluent. A steel line equipped with a flow indi-, cator and globe-valve can divert effluent water from the LCCP , dissolved air flotation (DAF) unit into the VCM Plant raw waste line just ahead of the storm water diversion box.. Water from this source can be measured and accurately controlled. However, opera tion of this source must be by LCCP personnel upon instructions from the VCM Plant Shift Supervisor. DTH 000120455 2) LCCP south lagoon effluent. The pipe from the LCCP south''lagoon connects to the line from the DAF unit downstream of. the-flow indicator and control valves Therefore, flow from this source is controlled by trial and error using a manual, non-indicating butterfly valve located at the inlet to the pipe. Like the first source, this one must also be operated by LCCP personnel upon instruction from the VCM Plant Shift Supervisor. 3) VCM Plant fresh water. Water is diverted through hoses from the fresh water line at the northeast corner of the VCM PIar\t cooling,tower to the process sewer on the north side of the... road.* This is the only source over which VCM Plant Dersonnel have direct control. Flow must be estimated, then adjusted by trial and error. Use of dilution water together with the source should be noted on the secondary waste treatment log sheet. This information will aid in the interpretation of analytical data received from the Laboratory. Information necessary to control the secondary waste treatment system is ob tained from Laboratory analyses of samples taken around the system. The sample number and locations are as follows: #1 - "Feed to the secondary" is collected from the diversion box located in the southeast corner of the plant, south of the railroad tracks. #2 - "Equalization basin outlet" is collected from the ASU feed pump discharge. =3 - "Clarifier feed" is collected from the diversion box where polymer is added. #4 - "Clarifier overflow" is collected from the north side of the clarifier overflow ring where the water flows into the re aeration basin. t4A- "Recycle sludge" is collected from the recycle sludge line where it flows into the ASU. #5 - "Effluent" is collected by the Collins sampler at EPA station 001. The control samples (#1 through ?4A) are collected by automatic, 24-hour com posite samplers. The half gallon sample bottles are picked up once each day and clean empty bottles are put in their place. Samples are taken to the Laboratory immediately for analysis. If a composite sampler fails to function, a grab sample should be taken, marked, and delivered to the Lab. The Shift Supervisor should then be notified of the malfunctioning sampler. DTH 00120456 `4 Under normal conditions, the Collins Sampler (~5) is operated twice each week. A clean sample container is placed in the sampler refrigerator and the power is turned on. When the samole is picked up, it is labeled with an appropriate tag, the power is turned off, and the sample is taken to the Laboratory. If the Collins Sampler fails to function, a work order must be issued. Do not collect a grab sample from EPA station 001. Detailed Description Raw Plant Effluent Raw plant waste water that flows to the secondary waste water treatment facility varies considerably in composition, ohysical properties, and flow rate. However, the three most important parameters of this stream for the proper operation of the treatment system are EDC concentration, 2-chloroethanol concentration and pH. pC and 2-chloroethanol are antimicrobial agents which will kill the bacteria . in the ASU if their concentrations are allowed to rise high enough. Present \ data indicate that 350 ppm EDC in the ASU feed and 250 ppm 2-chloroethanol in , the ASU may be toxic to the basteria. EDC is a chlorinated hydrocarbon that can be air-stripped out of water. Consequently, if a large quantity of EDC accidentally gets into the secondary treatment system it can be removed by the aerators. On the other hand, 2-chloroethanol is a biodegradable chlorinated hydrocarbon that cannot be air-strioped. Should a high concentration of 2chloroethanol occur in the feed to the secondary waste treatment system it must be diluted as discussed under "Dilution Water". Waste water pH is controlled by neutralization with limestone in T-500 and trim-neutralization with slops (303) or fresh (503) caustic (sodium hydroxide). The caustic addition at the trim neutralization pit is operated automatically from the control room to maintain the secondary waste treatment feed pH be tween 4 and 6 standard pH units. Some deviation outside this range can be tolerated for a short time due to the buffering characteristic of the ASU. However, pH corrections should be made within one hour. Major changes in any parameter of the secondary waste treatment feed can cause an upset in the ASU. However, a major change in EDC or 2-chloroethanol con centration or in pH can completely kill the biomass which would result in a permit violation. It takes many weeks for the treatment system to recover from such upsets and kills. Storm Water Diversion Box Waste water from the plant flows through the storm water diversion box before entering the west equalization basin. During rain storms, the equalization basins fill up until water begins to flow over the baffle in the storm water diversion box. In this v;ay the secondary treatment system is protected against high flow rates and flooding of the basins. DTH 000120457 Any time untreated water bypasses the secondary treatment system and goes directly to the bayou, it must be reported to the EPA and the Department of Natural Resources. A steel rule is mounted on top of the baffle in the storm water diversion box. During a bypass, the depth of water flowing over the baffle must be measured and recorded together with the length of time the bypass occurred. In addition to this data, an hourly sample of the bypass water must be collected and taken to the Laboratory for analysis. A one gallon sample bottle can be obtained from the Laboratory for collecting this sample. Equalization Basins The west (small) equalization basin and south (large) equalization basin are connected by an underground line and overflow notch and are operated as a single unit. The south basin is equipped with two, 25 h.p., high-speed aerators (A-106, A-114). The equalization system serves the following purposes: 1) Raw waste is mixed with the waste in the basins. In this way changes in waste composition are diluted and the ASU feed remains more uniform. 2) The agitation created by the aerators strips EDC out of the waste water. EDC concentration must be maintained below the toxic level to protect the biomass. 3) The aerators maintain the dissolved oxygen concentration in the basins high enough to prevent septic conditions from form ing. This reduces the problem of dispersed growth caused by anaerobic digestion. 4) The south equalization basin is operated about 40" full. The unused volume provides storm water containment capacity so that in only the very heaviest rain falls will untreated waste water enter the bayou. 5) Mechanical aeration of the basins causes some of the water to evaporate. In this way the water in the basins is cooled, thus preventing the discharge of hot water into the bayou. The operation of the equalization basin aerators helps optimize the secondary waste treatment system. However, their functioning is not imperative for the continued operation of the ASU. ASU Feed Water flows out the east end of the south equalization basin, through a trash screen and into the ASU feed pump sump. The sump is connected to the east end of the ASU by an underground line. Thus, when the equalization basin level is high enough, it is possible to gravity feed into the ASU. However, under normal conditions, the butterfly valve on the sump end of the underground line is kept* closed. This valve is equipped with a manually operated valve stem extension . which protrudes above the top in the northwest corner of the sump.- DTH 000120458 The lift pumps may be shut off during upsets in the feed to the Secondary. Such upsets would include high pH upsets, high organic material concentration toxic chemical contamination of the Secondary Feed, etc. By shutting down the lift pumps, the South Basin can be isolated and the upset condition can be corrected before the wastewater reaches the ASU. One ASU feed pump, P-516A, is a-horizontal self-priming sump pump, and the other ASU feed pump, P-516B, is a vertical sump'pump. Both are fitted with large basket suction strainers. Shaft bushings are lubricated with water* supplied from the pump discharge* This flushing water passes through a * Y-strainer which should be blown down daily. The Dumos-sare*pco.tect.<&agaM deadhead pressune^bya, restriction orifice and recycle line from the pump discharge" to"the south 1 equalization basin. > The manufacturer states that the vertical sump pump, P-515A,' should not be operated with less than eighteen inch (IS") submergence of the pump head. Due to the calibrated range of level controller LIC-702, this is equivalent to a 40% level indication on this meter. The-.pump is protected against'..^* operating with insufficient submergence by low-level shutdown switches LC-703 and LC-704.* These switches are set to shut down at 35% level and restart the pump at 45% level. However, for the switches to be operative, the pump must be started in the automatic (A) position. By starting the pump on manual (H) the switches are bypassed leaving the pump unprotected. The pump should be operated on manual only with the approval of the Process Superintendent. The.discharge from P-516A and B to the ASU is controlled by LIO702-. The level controller, located in the pump sump, is calibrated such that a 0% in dication is 7'0" below the top of the concrete sump and a 100% indication is 2'0" below the top of the sump. Consequently, each 10% of level indica tion represents a 6" liquid level change. Solids tend to accumulate in the sump around the end of the level controller dip tube, causing a false level indication. To prevent such inaccuracies, the dip tube should be shaken once each day. A visual check of the south equalization basin level should be made each shift. If the pipe connecting the south equalization basin to the pump sump is visible, the water level is too low (less than 40%) and corrective action must be taken. Under normal-operating conditions the level controller set point should be * at a 40% indication. This level provides sufficient submergence to protect the pump while maintaining enough reserve volume to satisfy rain water con tainment demands. Level in the pump sump is controlled by LIC-702 acting on LCV-702-. In the* event of a controller or control valve failure, a manually oDerated globetype bypass valve may be opened and adjusted to provide feed to the ASU. DTH 000120459 Normally, only one ASU feed pump is operated with the other as a spare. However, during a heavy rainstorm, operation of both lift pumps may be necessary to control the level in the South Equalization Basin. If rain is forecasted to last for several days or if several inches of precipita tion are expected, both ASU feed pumps may be started as soon as the rain begins to insure adequate level control and prevent stormwater bypasses. "Urgent" priority work orders should be issued for failures involving the ASU feed system. If the feed to the ASU is interrupted and the following day is not a maintenance work day, then a callout should be made on daylight hours. Activated Sludge Unit (ASU) Plant raw waste water contains organic materials that exert a chemical oxygen demand (COD) and a biological oxygen demand (30D). The ASU is filled with a concentrated collection of naturally occurring bacteria that consume the or ganic matter in the waste water. In order for the ASU to function properly it requires oxygen, nutrients, mixinq, sufficient food, and an adequate bacteria population. Oxygen and mixing are supplied by seven, 40 h.p., high speed aerators (A-107, 108, 109, 110, 111, 112, 113). Oxygen is required to keep the aerobic bacteria alive. Mixing keeps the bacteria (solids) in suspension allowing better contact with the waste water for more effective degradation of the organic materials. Bacteria that settle in the system form a mud-like sludge layer which becomes anaerobic due to the inability of dissolved oxygen to Denetrate the layer. Dead aerobic bacteria, or active anaerobic bacteria tend to float in water, thus ad versely affecting the operation of the clarifier and other downstream equipment. The loss of a single aerator will reduce mixing and allow solids to settle. Therefore, when an ASU aerator fails, an "Emergency" priority work order should be issued. If the aerator cannot be returned to service in less than 24 hours, maintenance should move an aerator from the south equalization basin into the ASU. The nutrients required to maintain the bacteria in a healthy condition are ammonia and phosphorus. They are added when required to the ASU in the form of 29.5" aqua ammonia and 75% phosphoric acid. The amount of nutrients added to the sys tem is proportional to the quantity of COD or BOD being fed to the ASU. Detailed operation of the nutrient addition system can be found under Nutrient Addition in this manual. Primary control of the ASU is based on the food to biomass ratio (F/M). Little or no control is exercised over the food supply to the ASU since the ASU feed pumps are operated to maintain a desired level in the equalization basins. Therefore, control of the ASU is maintained by controlling the amount of bacteria or biomass in the ASU. Bacteria concentration is measured by the volatile sus pended solids (VSS) in the clarifier feed (3 sample). VSS is controlled by batch wasting of sludge from the clarifier. If insufficient quantities of sludge are wasted, then the F/M ratio will drop, indicating an inadequate supply of food OOO12460 for the number of bacteria in the system. This condition can lead to bacteria starvation which results in a light pin-floc floating on the ASU and clarifier. On the other hand, too high a wasting rate will deplete the bacteria population (increase the F/M ratio). In severe cases, there will not be enough bacteria to adequately remove the COD and BOD, thus leading to an NPDES permit violation. In less severe cases, the overfed bacteria will form large, light floe that floats on the ASU and clarifier. Past experience indicates that the treatment system works well in an F/M range of 0.0005 to 0.2. This may change as more operating experience is gained. Changes in the ASU are slow and usually take days or weeks to develop. The exception is major upsets or biomass kills due to toxic compounds or very large changes in the ASU feed composition. Nutrient Addition Ammonia and phosphorus are nutrients necessary for the health of the biomass. They are added when required to the ASU in the form of 29.5% aqua-ammonia (ammonium hydroxide) and 75', phosphoric acid. Both of these products are hazardous and should be handled with care. Our NPDES permit does not have a phosphate emission limit. However, to pre vent wasting acid, the addition rate should be adjusted to control the phosphate in the feed to the clarifier (=3 sample) between 1 ppm and 5 ppm. Ammonia in the effluent is limited by the NPDES permit to a maximum of 68 lb. per day and a monthly average of 30 lb. per day. Ammonia concentrations greater than 10 ppm will cause a permit violation at effluent flow rates of 600 gpm or more. Consequently, ammonia addition is adjusted to maintain the ammonia concentrationin the clarifier feed between 0.01 ppm and 0.5 ppm. Nutrients are stored in bulk tanks on the chemical pad located at the north east corner of the ASU. They flow by gravity into their respective day tanks. The valves between the bulk and day tanks should be kept closed except during the filling operation. In this way only a limited quantity of material could flow into the secondary treatment system in the event of equipment failure or human error. Pumps meter the nutrients from the day tanks, through underground piping, into the east end of the ASU where they discharge below the liquid surface. The flow rate is adjusted by altering the pump stroke by means of the micrometer stroke adjustment on the pump body. Day tank liquid levels should be kept within the visable range of the sight glasses. Pumps should be checked once each shift to ensure proper pumping action. This is easily done by blocking in the pump suction at the day tank and observing the liquid level change in the sight glass. If there is an un expected or unusual level change in a day tank , check the pump system for proper operation. 00012461 I The bulk tanks are filled from trucks equipped to pump or pressure the liquids into the tanks. When filling a bulk tank ensure that the truck driver connects the hose to the proper fill line. Each line is labeled with the tank number and product name. When phosphoric acid is being transferred, the truck driver must wear boots, gloves, slicker suit and face shield during the entire opera tion. Before the truck driver opens any valves on the truck, close the drain valve between the hose connection and the block valve. Then open the block valve and have the driver fill the tank. Once the tank is full, close the block valve, carefully open the drain valve and drain the hose. After the hose has drained and the driver has disconnected it, wash down the entire area to remove all spilled material. Any time a valve is opened or closed that might discharge phophoric acid to the atmosphere, boots, gloves, slicker suit and face shield must be worn. If acid gets on skin or clothing, wash it off immediately with large quantities of running water. A safety shower and eye wash station are located at the west end of the chemical pad for this purpose. In the event of a phosphoric acid spill, notify the Shift Supervisor or control room of the spill. Put on a slicker suit, gloves, boots and face shield. Then proceed to clean up the spill while ensuring that the acid does not go into the bayou. If there is an aqua ammonia spill, put on the Scott-Air Pak found on the out side, west wall of the switchgear building. Notify the Shift Supervisor or control room of the spill and than proceed to aid anyone in the area. Two 5-minute excape capsules are located on the wall beside the Scott-Air Pak. These units are to be used for escape and to evacuate Deople from the area who are unable to do so without assistance. Hose down anyone who has been wetted with large quantities of the aqua ammonia. Clean up will consist of preventing the aqua ammonia from going into the bayou and washing down the area. Technical data sheets for these materials can be found in the Appendix. Anti foam Addition Foaming in the ASU often leads to the formation of a mat of bacteria on the surface of the basin. These bacteria become starved of food, nutrients, and oxygen and will eventually die. Consequently, antiform liquid is added to the ASU to disperse the foam and prevent the mat from forming. In the past, anti foam has been added periodically in batches as large as 5 gallons. Recent experience indicates that a small, continuous injection of antifoam provides better foam control. A temporary metering Dump has been installed at the point where ASU feed enters the basin. However, this pump clogs easily, and antifoam is usually added manually. Antifoam should be added at the discretion of the Process Superintendent until a permanent sys tem and rate are established. / DTH 000120462 Antifoan is flammable and should be handled with care. Do not smoke or cause an open flame or spark in the area around the anti foam drums and pump. A tech nical data sheet for this material can be found in the Appendix. Polvmer Addition . _ . . ~_ -- ------------------------- The NPDES permit limits the discharge of suspended solids to 1,256 lb. per day with a monthly average of 558 lbs. per day. Solids concentrations above 175 ppm will cause a permit violation at flow rates of 600 gpm or more. Therefore, polymer is added continuously to the mixed liquor from the ASU to improve flocculation and settling of solids in the clarifier. Polymer is stored in a bulk tank (T-76) on the chemical pad at the northeast corner of the ASU. The bulk and day tanks in this system are filled exactly the same way as those in the nutrient addition system. Polymer is pumped from the day tank (T-76A) into a water-flushed header by a variable speed progressive cavity metering pump (P-513 A&B). The injection rate is controlled by adjusting the pump speed by means of the controllers on the inside, north wall of the switchgear building (behind the motor-starter panel). Flush water dilutes the polymer and improves its ability to mix with the clari fier feed and to flocculate the solids. The water also keeps the polymer trans fer line clear of viscous polymer which could plug the pipe. The water flow rate is indicated by the rotameter located beside the polymer pump and is con trolled by the glove valve downstream of the rotameter. The diluted polymer flows into the east side of the ASU outlet diversion box where an agitator mixes it with the clarifier feed. This mechanical mixing provides better dispersion of the polymer in the mixed liquor and thus produces a more uniform floe for improved solids settling. If the mixer fails, an air sparger should be used until repairs can be made. If there is a spill of polymer, it should be washed down with water, flo special protective equipment is required. However, care should be taken when walking in the area since polymer is very slippery. Clarifier and Sludge Recycle The clarifier (T-704) is a gravity settler used to remove suspended solids in order to comply with the NPDES permit and to prevent large losses of bacteria from the system. ASU mixed liquor, which has had polymer added to it, enters the clarifier center feed well. Heavy solids sink to the bottom of the clarifier where two rakes move the sludge into the recycle pump suction. The sludge recycle pumps draw the solids from the bottom of the clarifier and return them to the southeast corner of the ASU. Recycling sludge in this manner helps prevent the depletion of the bacteria population. The sludge recycle rate is controlled at approximately 640 gpm by adjusting the manual globe control valve in the metering loop. Flow rate is indicated by a venturi flew meter (FI-703) located ahead of the control valve. This meter has a water purge which should be checked once each shift. DTH 000120463 I If the recycle sludge flow rate is too low, a sludge blanket will form in the clarifier. This layer will eventually become anaerobic, causing solids to float in the clarifier. However, if the flow rate is too great the clarifier may become hydraulically overloaded and the solids will be unable to settle. In the event of a failure in the metering loop, sludge recycle can be con trolled with the manual globe bypass valve based on pump discharge pressure. A 3-inch stream is taken off the recycle sludge line and pumoed approximately once every ten days to the sludge thickener (A-119) by P-509. This pump is an air-operated diaphragm pump. The sludge thickener is the primary means for wasting sludge. If the clarifier rake or both sludge recycle pumps fail, an "emergency" priori ty work order is to be issued. When the clarifier is restarted following a malfunction that has stopped the recycling of sludge for more than one hour, the recycle pump is started first. When the flow has stabilized, the rake is rotated one quarter of a revolution and stopped. This normally pushes solids into the recycle pumD suction, causing the recycle stream to appear dark. When the flow lightens in color, rotate the rake another quarter revolution. Again wait until the recycle stream color lightens. Repeat this procedure until the rake has made at least two full reS volutions. Then start the rake and observe the recycle system operation to * ensure that it is operating properly. Light solids entering the clarifier float to the surface where they are raked into a surface skimmer for recycling back to the ASU by the sludge recycle pumps. Any solids that neither sink nor float quickly are carried out over the clarifier overflow weir with the clarified water. The presence of large quantities of floating solids or solids being carried out of the clarifier should be noted on the log sheet. Such conditions may indicate a problem in the ASU. If the clarified water becomes muddy or hazy, it may be an indication of too much or too little polymer. Sludge Thickener Sludge from the clarifier is wasted on a batch basis. SIudqe is pumped by P-509 from the clarifier to the sludqe thickener A-119. The amount of sludge wasted helps control the concentration ofsuspended solids remaining in the ASU and thus the F/M ratio. The principles of operation of the sludge thickener are the same as those of the clarifier. The heavy solids sink to the bottom of the clarifier. The heaw '4 solids sink to the bottom of the thickener where they accumulate. Periodically, DTH 000120464 the thickened sludge is allowed to gravity flow to the DAF unit at the LCCP Secondary. During periods when sludge is being wasted,the flow of thickened sludge to the DAF unit is controlled by a timer on the west side of the sludge thickener. The timer is used to set the frequency and duration of sludge trans fers to the DAF unit. Light solids float to the ton of the sludge thickener where they are pushed into a trough by the surface rake. The trough drains through a hose into the scum sump at the LCCP DAF unit. Clarified water flows over the surface weir and back into the ASU. Normal operation of the clarifier calls for wasting sludge as soon as the total suspended solids (TSS) in the clarifier feed reaches 7500 ppm. Sludge is wasted until the TSS level has fallen to about 4000 ppm in the clarifier feed. Four sampling tubes are located at different depths on the sludge thickener. These tubes allow samplina to determine the depth of the sludge layer (visually) and the solids concentration of the layer (analytically). When sampling the thickener, the sample trough should be flushed thoroughly with water when finisned. Effluent Re-aeration Louisiana State Law requires that water discharged into public waters must not deplete the dissolved oxygen to less than 4 ppm. To ensure compliance with the law, clarified water is re-aerated after leaving the clarifier. The operation of the 15 h.p., high-speed areator (A-115) in the re-aeration basin virtually gurantees an effluent dissolved oxygen concentration of 8 ppm--depending upon the water temperature. If the aerator fails, a "critical" pri ority work order should be issued, and an air line should be submerged in the re-aeration basin until the areator is repaired. Effluent Weir Box - EPA Station 201 Water flows directly from the re-aeration basin into the effluent weir box located east of the switchgear building. Here all the continuous monitoring and sampling required by law are done. Sensors for the monitoring of effluent flow rate, temperature, pH and dissolved oxygen are located in the pit while the associated recorders are in the switchgear building. The flow meter should be checked once every three or four days. To do this, determine the depth of water flowing through the V-notch weir in the pit. The rule attached to the weir or a yard stick laid beside the rule may be used. Then, using the chart in the switchgear building and the measured water depth, determine the corresponding flow rate. Record this value on the secondary treatment log sheet under "remarks". If the flow recorder reading and the measured value to not agree within 25 gpm to 50 gpm, issue a work order to have the meter repaired. If the following day is not a normal maintenance workday, then a callout should be made on daylight hours. DTH 0012046S The NPDES permit requires that the effluent pH be not less than 6 nor more than 9 standard pH units and that it be monitored continuously. The monitor is set to alarm if the pH goes outside the range from 6.5 to 8.5 pH units. In the event of the alarm sounding, collect an effluent grab sample from the weir box and have it analyzed immediately in the Laboratory. If the monitor is reading incorrectly, issue a work order. However, if the reading is correct, quick corrective action is to be taken to prevent or correct a permit violation. In order to assure compliance with Louisiana State Law regarding dissolved oxygen (DO), the effluent water is aerated in the re-aeration basin and the oxygen content is monitored in the effluent weir box. If the dissolved oxygen recorder shows less than 4 ppm and the re-aeration aerator is operating, issue a "critical" priority work order for the meter. Louisiana State Law requires that the effluent water temperature not exceed 95F. Under normal operating conditions the temperature of the water leaving the effluent weir box will never be hotter than 95F. The NPDES permit requires that a flow-proportioned, refrigerated effluent water sample be collected and analyzed twice each week. These samples are taken using the Collins sampler located outside the east wall of the switchgear building. To collect a sample, place a clean sample container inside the sampler refrigera tor. Make sure that the sample tube is well inside the neck of the container and is not pinched off between the container and the top of the refriaerator. Check the counter located in the electronic package on top of the refriqerator. Nor mally, the counter should be set at 400 which collects approximately one gallon of sample in 24 hours at an effluent flow rate of 450 gpm. If a larger sample is required, reduce the counter setting proportionally to the increased sample volume desired. Conversely, the counter number is increased to obtain a smaller sample volume. Then turn the power switch on and check that power is indicated by the panel light. Before closinq the sampler enclosure door, observe one complete sample cycle to ensure proper operation. Every effort should be made to prevent excessive quantities of water from spilling or collecting inside the sample enclosure or refrigerator. Do not collect a grab sample if the sampler has malfunctioned. Dilution Water Current operating methods and philosophy are based on R&D data, information available in the literature and experience gained by successful operation of our secondary waste water treatment system. Dilution water is added to the secondary treatment raw feed as required to protect the ASU from high concentra tions of 2-chloroethanol and other organic materials. Large, sudden changes in any raw feed parameter may upset the biomass. Such changes can and do occur due to upsets and changes in plant operation. If these changes cause more than a doubling in the ASU feed parameter, then dilu tion water should be added to reduce the increase. DTH 000120466 1 Dilution water is available from three sources. The first source for dilution is the LCCP dissolved air flotation (DAF) unit clarified effluent. Flow is measured by an indicating meter (FI-706) and controlled with a manually operated globe valve located at ground level on the southwest side of the DAF unit. If the DAF unit is not operating or if its effluent is contaminated, the second source of dilution water is the LCCP south treatment lagoon. A manually operated butterfly valve in the overflow box at the west end of the LCCP south lagoon controls the dilution water flow rate from this source. The valve does not have a position indicator and there is no flow measuring device. Consequently, flow rate adjustments must be made by trial and error. These two sources flow through a common line into the raw feed line just ahead of the storm water diversion box. This common line has an automatic on/off control valve actuated by level switch LC-705 located in the ASU feed pump sump. When the level rises above a 55* indicated on LIC-702, the valve is closed. The valve can also be closed from VCM Plant property by turning off breaker number 26 in the breaker box located on the west wall of the switchgear building. Operation of these dilution water sources must be by LCCP personnel. When dilu tion water is required the Shift Supervisor or Chief Operator should contact one of the following LCCP personnel: 1. G. L. Satterfield - PB 61452 2. Ethylene Plant Shift Foreman 3. Steam Plant Top Operator 5426 (days only) 5421 5310 or 5426 Requests for dilution water should include which source is desired, the flow rate (if from the DAF unit) or the approximate valve opening (if from the south lagoon). Flow adjustments must be made in a similar manner. If the LCCP dilution water sources are not available or are not suitable for some reason, then the third source is VCM Plant fresh water. Fresh water is obtained from the fresh water header at the northeast corner of the cooling tower and is routed by hose north across the road and into the head of the sewer line. When adding dilution water, consideration must be given to other sources of dilution water to avoid overdiluting the raw waste water. Dilution water should be reduced in proportion to the amount of water entering the sewer from fire monitors, hoses, additional cooling tower blowdown, and others. Overdilution can increase the hydraulic loading on the clarifier, thus causing reduced efficiency and increasing the solids in the effluent. Nevertheless, it is better, under most conditions, to have too much dilution water than not enough. Control Samples Five samples are collected around the secondary treatment system each day. The analytical data obtained from these samples allows monitorinq of the system efficiency and provides a basis for changing nutrient, polymer and sludge wast ing rates. All samples are collected by 24-hour composite samplers. WH 000120467 The No. 1 sample, "Feed to the Secondary" is collected from the diversion box in the southeast corner of the plant, south of the railroad tracks. It pro vides data on the undiluted raw waste (unless fresh water dilution is in use) and should alert personnel to possible problems due to EDC, 2-chloroethanol, pH and COD. The No. 2 sample, "Equalization Basin Outlet", is collected from the ASU feed pump discharge and provides data on the fresh feed going into the ASU. The Mo. 3 sample, "Clarifier Feed", is collected from the ASU outlet diversion box where polymer is added. The general health of the bacteria population is determined from this sample. The difference between sample No. 2 and sample Mo 3 is used to determine the actual F/M ratio, the bacteria activity coefficient K, and the addition rates for aqua ammonia and phosphoric acid. The No. 4 sample, "Clarifier Overflow", os collected at the clarifier overflow ring outlet. This sample indicates how well the effluent is meeting the NPDES permit limits. The data should also alert personnel to possible trends which may cause a permit violation. The No. 4A sample, "Recycle Sludge", is collected from the sludge recycle line just prior to its emptying into the ASU. It provides data for determining the concentration effectiveness of the clarifier and the solids loading on the sludge thickener. This sample is seldom obtained because the sludge wasting process is now down on a "batch" basis. These five samples are an important part of the secondary waste treatment con trol system. The sample collected from the EPA station 201 is not a control sample, but rather, is a compliance sample. Nevertheless, it is called the No. 5 sample. If one of the control samplers (rl through #4A) fails, a grab sample should be collected, marked, and taken to the Laboratory for analysis with the other con trol samples. Grab samples should continue to be taken until the sampler is repaired. This procedure does not apply to the EPA compliance sample (#5). Information concerning this sample is in the section entitled, "Effluent Heir Box - EPA Station 201". Incinerator Wastewater Wastewater from the bottom of HC1 Absorber Column C-901 is fed into Neutralization Pits T-931 and T-932. These are filled with clam shell which contains calcium carbonate used for neutralization. The wastewater from these pits contain a high concentration of solids and thus cannot be treated in the VCM Plant Secondary. The wastewater from the incineration area flows to the diversion box at the Secon dary, and is then pumped to the North Lagoon at LLCP. The incinerator wastewater is treated and discharged through the LCCP Wastewater Treatment facility. dth 000120468 17 Turna-round S*ys---t-e--m--- During turnaround, the concentration of organic compounds in the raw plant wastewater falls to approximately zero. Thus, the food supply to the ASU is seriously depleted. To supply the ASU with an adequate supply of food during turnarounds, raw wastewater from LCCP is added to the secondary. The LCCP raw wastewater is added to either the ASU feed pump sump or the ASU through a 6" transfer line. Water is obtained from the LCCP raw wastewater header. A flow indicator-controller (FIC-710) and a continuous, flow-through pH analyzer (AI-710) are included on the transfer line inside the VCM Plant. The flow in dicating-controller is necessary because the pressure in the LCCP raw waste header fluctuates making it difficult to manually control the flow in the trans fer line. The pH analyzer is necessary because the pH of this stream also fluc tuates widely and is not continuously monitored by the LCCP. An alarm will sound if the pH of the LCCP raw wastewater exceeds 9 or falls below 5. If this should occur during the turnaround, the LCCP Steam Plant Control Room must be notified. The Shift Supervisor may then elect to cut the LCCP feed to the ASU. Laboratory analyses will be used to set daily wastewater flow rates from the LCCP. If any abnormal results or rapid changes in results are notices by the Laboratory personnel, the Shift Supervisor should be notified immeidately. The wastewater transfer line from LCCP can also be used to divert raw waste water from LCCP to the ASU during times when the bacteria in the ASU are not healthy. The LCCP wastewater contains compounds which are easily digestable by the bacteria, such as methanol. During turnaround, the Oxychlorination Reactors (R-301, R-302, R-303, and R-394), the HC1 Column C-202 and the Quench Column C-201 are cleared and washed. The wash water contains a concentration of copper ions which would be toxic to the bacteria in the ASU. The source of this copper is the copper-based oxychlorina tion catalyst in the oxychlorination reactors, the monel-clad HC1 Column, and the monel-clad Quench Column. Becuase this contaminated wash water cannot be treated in the Secondary, it is necessary to remove the copper ions from the water. Before the Oxychlorination Reactors and the HC1 Column are washed, the main plant trench is blocked in with dirt and rock at the end of Block 2 near the LCCP fence. Blocking this trench will prevent the copper contaminated wash water from flowing to T-500. Copper Removal Pump P-435 (temporarily located during turnarounds just south of Oxy Vent Stack VS-390 at the east end of Block 2) is a horizontal sump pump which is used to transfer the copper-contaminated wash water from the plant trench in Block 2 to the Copper Removal Pit north of the Incinerator. At the Copper Removal Pit (which is concrete lined) caustic is added to raise the pH of the wash water to above 8.5 units, at which point copper hydroxide, Cu(0H)2, will precipitate. The copper hydroxide settles on the bottom of the copper re moval pit and the decontaminated wash water flows through the plant trench system to the Secondary. The settled copper hydroxide is then vacuumed from the Copper Removal Pit and is disposed of as a hazardous waste. DTH 00120469 MAT2SIAL DATA SAF2 e W4 I FCR HAZARDOUS PRODUCTS USED I.',' PLACES OF EMPLOYMENT APPEND IX A lection t n*m d product m^nul^Cl^rcr Ul NATIONAL^AMMON I A COMPANY^ _ TACCNY t VANKIRK STREETS____ L-ty. Style. *0 PHILADELPHIA, P A_. _________________ onem-cai natv.B. (face r.ime ana synonyms AMMONIUM HYDROXIDE t_ ALSO KNOWN lufiMiiij 01 yrimafycomooneniisi ASt fr eroency onone no (24hOuisi' 1(6) 215-535-7530 tor\<m!>u:jtican- ^'due inn fo/m^tino-n suir^anoiac^.r^ji>v^p TE^rl 6 ER 2 Z. Sujiwt ji1f9l ot cort'ly.qg tarr^tnY on.Aril " 'Pi AQUA AMMONIA 1977 MHaoh section 2 Injredlanli NH 3 (AMMONIA) IN WATER (DEMINERALIZED) % TL'< (uni;, (not tcecincalion .alucsi section 3 c-Tysicai oat 2 DOiitng pomt c*? 1 MP -72.AC S speciixgravity____ J~ . 897 4 l 2a "BeT vapor pressure 4 v.ipcf Censiiy (aif 1) ' suiu3:My m water 20*c) 15.23 SCF CR 2S.6C 1 % volatile bv volume j 8 color and ccor |9 physical state CLAR_ AND PUNGENT "j "'liquid' Mciic.n 4 fire and exulojion naterd data I0iun poml ions meinco useei INGNITICN TEMP. OF 12 extinguishing media |--j water log NH3 651C I I foam 11 flammacm um.is (ST?) L.F.L. [--1 alcohol foam CO, dcnfyomical U.F.L. I 1 other <3 sweoai lira ligr.nng proieon.e equipment I-I unuSuJIlxc *nqeC'0S'Cn rjzjrci sections (etctly'ly data ,il Sl.itnMy tr 'uoinpal- normal ccndit.ons f - ------l f;re I ccnpiticns IQ Ificcnuuiunt iu avoid Q Jc,8 ^'5<i imaUMiaislO | .l*Vf<d| j G otnur i j viacort.ccvi'on d'^uncj 1J I jy.if JwiiS j injj, ! OCC^r 1 1 Nr 3 GAS GIVEN j Q CCfl.S,, [j DTH 000120470 UATuP.IAL /> i\ f; WJ DATA GHCEI-T (continued) APPENDIX A / y^CGIVi DESTRUCTION OF THE PHARYNX, ESOPHAGUS AND STOMACH? y<* Ct CAN CAUSE SEVERE OCULAR DAMAGE. ON EVEN SHORT CONTACT NAUSEA "VARIES FROM MILD DERMATITIS TO SEVERE 2URNS DEPENDING ON LENGTH OF CONTACT ...orpi.*on MINOR ' STRENGTH OR SGLUTTON^ 5ETTSTTIVTTY ii.njiji.cn i TLV or iug jailSO control ti'jumI INHALATION may cause SEVERE I RRITATION OF wf UOSU< NAUSEA. VOMITING, WEAK PULSE. CONVULSIONS RESPIRATORY MUCOSA AND COLLAPSE MAY OCCUR r.i SI .id DrCCcOurOS RESPIRATORY ECU IPMENT; SAFETY SHOWERS? BUBBLER DRINKING FOUNTAINS Mellon 7 asiH or liai crccactutoa .'nyt-ji iu larun.n CiM mjiorui.srouasoc or sound WASH CC'VN WITH WATER fcV<2*sous.n moinoa \( nelson S soccwal orot^cuon intormcuon >1 MllllUllOfl pocaie*naust 3DCCUI rrmcnarucai (genc/ji) )t <c>i>ifatory yioiecticn (sprciiy lype) MSA MASK. WITH CANNISTER l. l*01ev livti CIOtfiiAQ A-1*.*tv txoitfCiiun RUBBER CLOTHING, GLOVES not normally necessary solely glasses I--I sWwalithout side shieias ni--J1 3o1fSeo"u9wntai5e0m<39IM nL-J other u dviuiyinenj safety glasses with siCu snioius chemical workers goggles Mciion 0 ipaciit pr#csution* or ot<*wr commonu Jb yiwCrfutto'ii ioiMUdPin Minoi*ng a no sionntj COOL STORAGE CCNDI TONS IF PQS SIBLE t AOEQUATE VENTILATION iDTH 000120471 APr-ninix u FED. STO. NO. 313 MATERIAL SAFETY DATA SHEET Torn Asorovid Hurc-au Qu<7mc No. S 5R 033<1 MANUFACTURER'S NAME AMO F3CM (pootftl Su-siy Ccd fer Wnu(f.euirerj) FKC Corporation 6310 j EMERGENCY PHONE NO. | 201/541-4171 AO&fliiiS (Numow. ^trwt, CRy, Stata, na Z.O Co'>ai 500 P.coaovols Avenue. Carteret, N, J. CHEMICAL NV.Mu A, < U SYMO.N YMa ' Pho.sshcric .Acid 757. \ 07003 NiAhie AN3 jVNuiVi'irtw 757. Ho.rO/, OuA C H E >: 1C A L-! A M l LA'------------- -Acid FEDERALOTCCX flUM.IER (FSN) rOii.f/ULA H3FO4 GnCZZ .'.EIGHT ILiSI CUTSIQE PACKAGE DIMENSIONS tlncliMl MIL-STD-in/.i/NATlONAU Fine PKQTSCTIO;: ACSCCJATfON STD SIGNAL wH li a (is HO lli PAINTS, PRESERVATIVES. AMO SOLVEriTU LIMIT VALUti ALLOYS AND METALLIC COATINGS J j LIMIT VALUr (U.clwl i | % I <U.il:r> PIGMENTS KA 3AGE V.STAL NA CATALYST x., (alloys VEHICLE SSLVENT3 j j f/iiiTA LL.1 C CO ATI N GS ^ t j r5! L l. - i TA L MA (plus coatimg on core flux \r K HA. ADDITIVES O T H C fwi '7 A* j NA OTHERS HAZARDOUS MIXTURES OF OTHER UOUICS. SOLIOS, Of CASES NA t TMHGSWOI.P w LIMIT VALUE iUnlrst 11 \ soiling point (fi h< VAPOR PRESSURE (nimHij.l Z -f 2 u vapor censity (air-1) AAO 5.85 SCLU3ILITY mwflTER Connl.zr.a SPECIFIC GRAVITY '.H-O - 1) PERCENT VOLATILE CY VOLUME (Til EVAPORATION RATE (------------------------- - It t .SOJ APPEARANCE AND ODOR T*lc-r ]T^v.',l _ n ir! cep 4 PL/GH POINT (lifihwl Uxl) a< -< a,, lies. - LlG.crr.au la EXTINGUISHING MEDIA FLAMMAULE LD'.VEil EXPLOSIVE LIMIT j UPPER EXPLOSIVE UNIT LIMITS Non- f. lam.-ib la NA SPECIAL FINE FIGHTING PIIOCCCUHC5 .. . -............... --..................... -- > * ------- UNUSUAL FIRE AMO EXPLOSION HAZARDS -- br>l j -j , wV DTH 000120472 X UTO. NO. - apt e;:d ix TIIHiiiMJLJ LI- \ 1 T VALOc 1 w. />|3 s dG-i.CTC C.: Cv LML; Ai'CC'J .1. " 0 HOI--VUJ N*s.--3<. A.7id burns go i eyes - :-.a-.' involve both irreversible and reversible cn"r.o'~J .10c severe ^ .'CUy1 co cause ceac:'. or c c rrT-c *3 c '.i t i-1*j ury GMeiiGCiVCY AND rIKUT AlO r'flOC = 2 U r> e s Eyes - Acid burn - flush :;ich vater - call p hystcian. -<J Shir. - Acid bum - flush. :vibh 7-*atEr - call physician. Inhalation - P.crovc STABILITY UNSTABLE rs'I7CCT-,**2 call physician. cc.*.c;T;c>i5 r O AVOID r*o action vrith 77.et al3, mid; liberate Hp _ ><Q<>r* >h STABLE 4V*^ 1 NCG.V.t* A 7Abl LI T Y (.Materials ta AvO'G) Alkaline r-ntariais. *'cr, -- m etals can decccroosa to emit onidss of 2 > HACA..UGUG 2ECOMPOGlTIOlJ hSCCw'CTj pr*o3 pno>rcG3 r- u . r* H A2A R COL'S l MAY OCCUHj 007.2.7!CNS TO AVOID PO L Y \!5 3 1 CATION WILL NOT cccun x! i UJ _ \5aj G T H r 3 T C 5 7A s.'l IN CASE =. IAJ. .3 s l. A Dilute '.;ic'r vatar cr. d / or ~ ~mm ' i 0m ^ r-ith iSlI<2,li.nG rr.?.tG7iG 1 such as soda ash end flush to 5,.-7 * ---0U, i 5-J CO_-ij CC"L) 2 O fSg I'/AjTC OlOPCSAL V.STHOO NcucraLiue and dilut W*) T _ k.h encess vater, flush to sever. HcSPI n ATCPY PROTECTION (Suocilv lYpil U.S. Bureau of Minas arnreved 2as m.ask & canister for acid mists. VeNTI LATlCN LOCAL EXHAUST SPECIAL z0< C*---j -i. j O:2--r c-ij u<--uaC.l i7--1 Cl x-- J w^*7* ^ li <" 5>J-- u -Aj. L^**> ^ j v 1 CJ CJ C--L No MECHANICA L iGonaral) OTHCn pnoTtcrivc cloves tYH PROTECTION nf.% M 1 * c ryl 0 i`m:m HHCTGC r.vs LUUIPV a ;*i r Tull cover clothinn res isront to ac id - rubber. PmcCAVj MOHS VO db TAiscN i N H ,-.M C L i. . C AN O STORING Aiuv.vu vaar eve pros e.ctier. - rake sure lines ere heated fie:.'. Us t? acid reni OfHc.l WiiCAU no.NS r*.ctoIn C tA^nciu) > A M c 1 n <i to allcr material COT CLASSIFICATION V IV X . # ( c) *-* Pl'C^^HCTi Z acid LTC no. 7-2100 our V.AMM * o |.M^ HOE.'iO Y ACC! 3L.N r P IlSCAU .NON j A.NiJ PMQCC DUllLS llor.c liOr.o 1 Keen oticplu <v-w/ - slush. '.;ich v/acur. 'JO T J j r* rt U C A U ' . G ' < J 7 0 >: C 7 A K. C ` i ; n r i'ai*jf'O t r a : ic.n >r.? I Ko o ,, e---- - DTH 00012047 f or mr * in* i t cg-''* ^ *.i i r r !.^.n * t c^t 1 r tn t i <*Vju t *1 io tl 11 y Of Irvjjl f*L'Cn i y fv * v^Mn ( ui*v *r>i ro >f jm < <> < * u o * * ft J . *< t .n ri.'j*c( tO luCrt 0,1 y ,-./ FmC o* f MC'l ( M C * .me * fH H *m. fj.-,-"'.. ** ncm, c' r; *; <i .> f; ^ i vj*>r ' ' * * 3 ih,cm,'i. ja j*o * > < r 1 *u'<; *. 1 1 r* * % j I f J v*. n * . 1. !') m f * . n*** <m v jmjaj wwnvJ OV !..>'c* c-3^'J'!'J'H 0 / l; a 1179 10/79 6003-10-20-80 PRODUCT NAME MATERIAL SAFETY DATA SHEET DATE A??^hlbi>4 C WT-1255 March 18,1982 SUBSIDIARY OF MERCK i CO .INC. MANUFACTURER'S NAME ADDRESS Calgon Corporation EMERGENCY TELEPHONE NO. P.O. Box 1346, Pittsburgh, Pennsylvania 15230 CHEMICAL NAME ANO SYNONYMS Cationic Polymer FORMULA Polyquaternary Amines . (412)777-8000 1 PRINCIPAL HAZARDOUS COMPONENT (S) Bsarans % ORAL LD50 DERMAL LD50 TLV (Uni: ! !; ;| i ( ..... i BOILING POINT <F) VAPOR PRESSURE ImmHg.) VAPOR DENSITY |AIR = 1) SOLUBILITY IN WATER APPEARANCE AND ODOR ws.t . .&&; 1. `t-v ' > 212 Similar to Water Similar to Water Complete SPECIFIC GRAVITY (H20=1! PERCENT VOLATILE BY VOLUME (%) pH Amber liquid with slight amine odor ; A;..'. *!:. - - > ' - 'v-^'* -- *-- -*-F ^ - `r^ i--' ,.: ,'*A AllM? -T - -* *- -IV inili' - - ---' FLASH POINT (Method Used! Not Flammable iiAvr./.!;!: M -. AT . - -C. * y^' . FLAMMABLE LIMITS EXTINGUISHING MEDIA Product is not flammable. SPECIAL FIRE FIGHTING PROCEDURES None 1.08 - 1.18 60 4.5 - 5.5 Lei -f U' UNUSUAL FIRF AND EXPLOSION HAZARDS None DTH 000120474 '.%**!* this inform Ytton .jrtf `"t tcf; jr*.- bftu'vi'fJ tn hi' .iccur.<ti* k of :n. cjjtM CAL'^'V^ COrtPOHAriO\ MA< tS -O W A i ?; a \ T . ,. i TH Hf ji'fCr HtfU Kj AND DfSCLAIVS A l. L UABU.tTr f-fjc/;, On the basis of animal testing, we would not expect this product to produce any skin or eye irritation. Furthermore, results from acute toxicity testing show that the material would not be considered toxic as defined by the CPSC protocols. i Agency and first aid PROCEDURES Good First Aid should be followed in all cases of exposure. In case of eye contact, flush with cool water for at least 15 minutes. If irritation develops, call a physician. INCOMPATABILITY 'Materials to Avoid) HAZARDOUS DECOMPOSITION PRODUCTS Strong oxidizers Unknown i 3. - STEPS TO BE TAKEN IN CASE material is released Dispose of..in accord.ance wi.th. l,ocal,, state and.fe.de.ral.reg.ul.ations. Dike area to contain OR spilled as much spilled material as possible. Remove any remaining material by absorbing on vermiculite or other suitable absorbing material and place in a sealed metal container for disposal. ..`ASTE DISPOSAL METHOD Mix with a flammable solvent and incinerate in accordance with local, state and federal regulations. RESPIRATORY PROTECTION Specify Type) ventilation Normal PROTECTIVE gloves OTHER PROTECTIVE iouipv.ent Not Required LOCAL EXHAUST Not Required ^SPECIAL MECHANICAL (Generali Not Required OTHER Not Required EYE PROTECTION Not Required Not Required R-CAUTIONS TO BE TAKEN IN pLING AND STORING !Thcr precautions Exercise caution in the storage and handling of all chemical substances. DTH 000120475 6003 r; i n r at':' : /, ** c i jo 1 k *'V | L a 4li'k *-- V--' J ' n ,l-\l T!" CN F ]1 appendix d DATE: July, 1977 Ini'ormaticn on thi; form is furnished solely for tin* purpose o: corriili.incj sviih the Ocr.upntion.il Safety and Health /\<:t of I 1D70 end shill not be used for any other purpose. Use or dissemination of ill or any part of this information for any other | purpose may result in a violation of law or constitute rjrour.ds for Icon! action. j I. c n sm a u ? / 7 u c f t n am i; Ii (: tss T..<*i ho ra to r t c s. In c. AOOP.CSV .ruimnef Stt.'et. Cl; v.C!.iic,:ad Ell' Codl Ojii oomerton Ru. . irevose, chemical name ano `synonyms PA 19047 CHEMICAL F AMILY EMERGENCY TELEPHONE NO. 2 15:355-3300 7 FI A O E NAME ANO SYNONYMS ________ Foamtrol 144-CI AFORMULA . ,bl, end, ed, nvoc'iucIt j fi 2. HAZARDOUS INGREDIENTS PAINTS, PRESERVATIVES. & SOLVENTS PIGMENTS j CATALYST -j . % (tJ.MU) ! ALLOYS ANO METALLIC COATINGS j ' ASE META'. i alloys VEHICLE l VENTS ^3CITIVES METALLIC COATINGS fill:;', metal PLUS COATING on CORE FLUX j OTHERS OTHERS GENERIC DESCRIPTION A bicncl of fatty acid esters, fatty acids and modified polyglycols in a high boiling alkane solvent. </4 TLV fUn.td 11 % TLV | (Unit'll 1 3. PHYSICAL DATA OOILIHC POINT (F.l VA?On Pnf-GSURE (nwiHfl.) vapor density tAin*t) >2 12 M. D. N. D. SPECIFIC GRAVITY (II.OUI c:uf't r, volatile fiv VOUUMC C'.i I EVAi'O/tA 1 ION MATS 1 t_ liliu- " -n *,sou41 ,mi.-i.lol riiv;u-*UN v:v/>urur ln <11,,r.s*iubi!c to iWL;.*;/.i !) I I appcar ancc and noon A in be r liauid - h yd rn cr. r! .on odor ^Q-m 0. 847 N. D. <l 5. 9 4. Filin AMD EXPLOSION HAZARD DATA l am t t -.ur: r Dell CD I) Mil* closed cun - 126 !' \ i lav.maiu i. i.imi r I never <! i' [ t r mi n ed A. , Mi Ol A :!rv chemical, cnrbnn c!io::i<!p a:v! vv. Li: j* fo,r ei > 11 < i f 11,m I t ,*11. I' n f i Cl f;w!l * < * e, r | ; \ j n r >i >! : i v *. t ` w.v I e r it n m (. e n ** i r '. J l l: 4.MI . *i*l' V.-* HA.'.'i'U1 U*t DTH 000120476 AprL.-iorx d G. HEALTH HAZARD DATA 1 l l .1101.0 LIMIT V Al o 1: N ' -,- r\ i 1 i-1- r n t n ivi Z Ti; ov (III yi`f:;;i;n ( dvc f r] ( [ c y [ : i (* ' for lo r t o' 1 :< nr nr! it ft. n rociu cl 1 >ut mav cause skin and eye irritations. i C.'.iLilCfliCY A.'JO flllr.r AIO I'nOCiiliLNItS 1 Si:in cont.nct - Wash with soap ami writer. Eve contact - Flush thorourdilv and | ni-.-.'mptlv with dear wacor. Tn case of ingestion or eve contact obtain immediate j medical attention.___________________________________________________________________ "________ G. REACTIVITY DATA ; ST Aul LI TY UNSTAOLE CONDITIONS TO AVOIQ. .See 'Combustible1 statement on label. STAULE XX 1M C C A P A T A 31 L 1T Y 1tO vOiU) None to ou: knowledge. ; i:;,za r.zco'j oecc.-.l-osit:c.-; phcoucts ; Probably carbon dioxide and water. H A Z A P. CCU5 PC LY.V.c mzA7I0N \ MAY OCC'jn !f WILL .'JOT OCCUR CONDITIONS TO AVOID '" ' * I i f 7. S."!LL OR LEAK PROCEDURES S~' "3 TO 3= TA.CEN t'l CASE .VATSSl^L IS SELSASEO pa SPILLED . , .. f ontii-.n and ansoro on inert maicvial. incinerate or send to chemical waste r. ----------------- =--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- ;------------ i -^disposal area. Keep heat and open flame away. WAT". E DISPOSAL METHOD Sv-.rni.us material may be incinerated. Treated efflu.ent sliould be sent to sanitary sewer or waste treatment facility._______________________________________ 3. SPECIAL PROTECTION INFORMATION ilfS^i.lATO.Tf I-^OTECT :n.'i fSncu<'v (yool Norma llv not nct-ricci. ve.-jtilation LOCAL EXHAUSr No rma l MECHANICAL iGoft'trol) SPECIAL omen PflC ,'LCTIVE CLOVES Optional EYE erfOTF.CTtOrv Face mask or goggles optional. 0 ru^ ppo ti C7:vl rouMMr:j r , ,. riMiimni'iii nrri'ss.'irv to r>rnfnct .v::unst ino tls i-er.-ilerl nn Mio label. 0. SPECIAL PRECAUTIONS i- ii>". V V o t i.ur; to <. r. i u n > n i > am Oli'a; r.;.i i ']:1 )m *ir, .... ., i\lvi) ctmi a :iu- v cov ivo, 1'iomi.l iroin ! r r e r. i :ig. u^e m. -.tonal only as directed for the snrrific application. l f n l C AU I i ( K*> - i . i :u i L .sin r a i; r In ( I i mu* vn r mavimnm for ni'ininrt r pa r t i yjfr y. 1 in \ cmi (.'. n '. i ii. 11 < (! r1 <! h i m '! \ - b b i f 11 i i -<-M ir-i'/A !'m niton:).itlnu mu] rorninnuuut :'lon5 '.al truth lumun .irti ,'iclion J to tin r.ccur.ito ns nt !,`io doltl Imro'it, tJTTl L/.nCb ;on.'.' S. :.vc. .`aaslz \o y/mu:a::jy ,v;:ii id :;n.cr rucr.cro a::h oiiiclaims all liauility rnc.`. .v.-Cd Tn::r'L-:- DTH 000120477 \ '1 X U.J An'CillH.' u VCx \\ tl !i .`V 4 .\ m=Ll cz. 0 1, 1 - CJ a au m c >S "vt ~3 C "3 3 .E o IU C. C w CD Z3 OC L/> p Q ~a c o a o _a -- - tuSl o a c CO a c "3 ^oa NJ uj oc_ as O UO Ca _2 "3 a cn ot_ a. .E N > 1-- TJ ^ u O '5 5 0 oj >0 > o x-| 2 CJ Oc* 3 cr a i-o. c V. o -0o O U_ t. o 10 X lo c 33 V^45_ u>- (!) E . U I o ^7 K\ < os 2 5 o i/> U o H n -*02 -a sIS 1 S ,2> o o vo c-- o _ ~a m o .. Q a X d) 1g S3 O c- u 0) --U-- in 0 cr~ ^ m >- o c. LU "OO CO 3 oC- -- O ^ o o u ac --1 > ta O- 0 E 3--. "5 a 3 rr 8 `o' " CD LL. O -a O- *" E - S 1 b-Q 8 2o 3 _C o-- C. LLI 0 u3 rf < -- to E <y o w . ot x-- a W E 0 * <: "3 C a "o 2 .-3 c eumi ?-'L*"> , g O^ 2 C' O I- U_ t "TM w > _ oo o -"S' C J o u- s n $ c a VJ J Oo 5 ~7 (J c. n -3 -- 3 3 c; u c x3 2 2N _ o_ -- !"" o ..Cl rJ . O C2 _o Nco o ' o g. O ~ O Cc! Lt. CO wl *to c j CD C,c-T O CrHM o o o X H Q c.. O < b < o c a a 0 u2 c o0 u0 G. c a u 0 E to p-- o _o c x.CE c - c "3 -0 cc a0 1 C 0 u a. >s u. 0 0 0 O , c 0 to L_ C 2 *S\ a 's! CL 0 -- >0 "0 Ul D d "o "5 0 r- i/ 0 0 ECO a a x ov o --E < 0) Z. CL >c c 0 -- * *23 u 0 C ] 0. *3 w u 11 o c o O*O3 awD. u "g ao Ul a o o cl * ul u o u >a >c xa O r- -- a 0-- ul D a 0O> 0 0 Ou > --- rs a o LU c 2 Ul --1 c o u CL o 0 v; LU > O o C2 l~ o' UJ e/) o cr C3 c So Q. Oo o ~u c <i. O o a d, o ao o wl LiJ o L.'J r__ k c E 25 o o c o` d >C a c o > a 'O G0 0 rj O Ui u O '> C L rlfttF iS A r r .z 0 O- ^9' / M 'a/.) DTH 000120479 APPENDIX E APPENDIX F APPEu'HIX G LIQUID HEIGMT/VOLUP-E TABLE - T-73, T-78A T-7S Anya Armania Bulk Tank Liquid Volume 3elcw Outlet Nozzle - 473 Gallon Height Above Nozzle Ft.-In. Volume Gallon Height Above Nozzle Ft.-In. Volume Gallon Height Above Nozzle Ft.-In. O'- 0 0 0-1 0-2 24 2 - 1 47 2-2 0-3 71 2 - 3 0-4 95 2-4 0-5 119 2 - 5 0-6 142 2 - 6 0-7 166 2 - 7 0-8 190 2 - 8 0-9 213 2 - 9 0-10 237 2 - 10 0- n 251 2 - 11 1-0 1 -1 235 3 - 0 7 go 3 - 1 1-2 3-2 1 -3 355 3 - 3 1 -4 330 3 - 4 1-5 . 4C4 3 - 5 1 -6 427 3-6 1 -7 451 3 - 7 1 -8 475 3-8 1 -9 493 3 - 9 1 - 10 522 3-10 i -n 546 3 - 11 2-0 563 4-0 593 616 640 664 638 711 735 759 732 805 330 354 C / o0 201 925 849 973 986 1020 1044 1067 1091 1115 1138 4-1 4-2 4-3 4-4 4-5 4-6 4-7 4-8 4-9 4 - 10 4-11 5-0 5-1 5-2 5-3 5-4 5-5 5-6 5-7 5-3 5-9 5-10 5 - 11 6-0 Volume Gal 1 on 1162 1185 12C9 1233 1257 1280 1304 1328 1351 1375 1399 1423 1447 1470 1494 1518 1542 1565 1539 1613 1636 1660 1684 170S Height Above Nozzle Ft.-In. Vo 1ume Gallon 6-1 6-2 6-3 6-4 6.- 5 6-6 6-7 6 -8 6-9 6-10 6 - 11 7-0 7-1 7-2 7-3 7-4 7-5 7-6 7-7 7-8 7-9 7-10 7-n 8-0 1732 1755 1779 - 1803 1827 1850 1874 1898 1921 1345 1969 1992 2016 2039 2063 2037 2111 2134 2158 2162 2205 2229 2253 2277 T-7SA Aoua Ammonia Dav Tank Liquid Vo 1 u:me 3elow Outlet Nozzle - 29 Gallon (Not recoverable) Height Above Nozz1e Ft.-In. 0- 0 0- 1 0-2 0-3 0-4 0-5 0- 6 0-7 0-3 0-9 0-10 c - 11 1-0 Vo 1ume Ga11cn 0 6 12 IS 23 29 55 :i 4/ S3 59 j4 73 Height Above Nozzle Ft.-In. 1-I 1 -2 1-3 1 -4 1-5 1 -6 1-7 1 -3 1 -3 1-13 i-n 2-0 Volume Gallon 76 82 83 93 99 1C5 1 11 117 123 120 1V 11 * * Height Above Nozzle Ft.-In. 2-1 2-2 2-3 2-4 2-5 2-6 Vo 1ume Gallon 147 153 159 164 170 176 * Height Above Nozzle Ft.-In. Volume Gal Ion DTH 000120481 APPENDIX H LIQUID HEIGHT/VOLUME TABLE - 1-76, T-77, T-75A, T-77A S' f >, .. T-76/T-77 DoI'/mer'Phosphoric Acid Bulk Tank Liquid Volume Belov/ Outlet Nozzle - 282 Gallon Height Above Nozzle Ft.-In. Vo 1ume Gallon Height Above Nozzle Ft.-In. Volume Gallon Height Above Nozzle Ft. - In. 0-0 0- 1 0-2 0-3 0-4 0-5 0-6 0-7 0-3 0-9 0 - 10 0 - 11 1 -0 I-1 1 -2 1 - 31 . - 5 M-6 1 -7 1 -3 1 -9 I - 10 1 - 11 2-0 0 13 2 - 1 35 2-2 53 2-3 71 2-4 88 2 - 5 ICS 2-6 123 2-7 141 2-8 159 2 - 9 176 2-10 194 2 - n 212 3 - 0 230 3 - ] 247 3-2 265 3 - 3 233 3-4 3C0 3-5 318 3 - 6 335 3 - 7 353 3-8 371 3-9 333 3-10 405 3 - 11 423 4-0 441 4 - 1 453 4-2 476 4-3 494 4-4 511 4 - 5 529 4 - 6 546 4 - 7 554 4-8 582 4-9 599 4-10 617 4 - n 535 5 - 0 653 670 633 705 723 741 753 776 794 811 829 846 Volume Gal Ion 864 881 899 917 934 952 959 987 1005 1C22 1040 1053 T-76A/T-77A Polvmer/Phosnhori'c Acid Dav Tank Liquid Volume Selow Outlet Nozzle - 12 Gallon (Not recoverable) Height Above Nozz1e r t. -1 n. Volume Gal Ion Height Above Nozzle Ft.-In. Volume Gallon Height Above Noz zle Ft. -In. Volume Ga11 on 0- 0 0- 1 0- 2 0- 3 0-4 0- 5 0-6 ,,7 j- 3 40 - 9 0 - 10 0-11 1-0 3 1-1 6 1 -2 9 1 -3 12 1 - 4 15 1 - 5 13 1 - 6 21 1 - 7 24 1 - 3 22 1 - 9 31 1 - 10 J * J - t 37 2 - 0 40 2 - 1 43 2 - 2 46 0 3 49 2 - 4 C7c. 2 - 5 55 2 - 6 58 61 65 G3 71 73 76 79 82 85 S3 91 0120482 . .... ... i ' . . i , ..; i: .i / ........ . - 7 vlm n.ifu V"` " APPENDIX I v t. .. y . .i m \. 111 ;; I I i m j . 'n 'cirp-r/ -- l ii.:. . r r r.-.-. t -i ;r:v, ..t ,v O' (/). A.~ . ! l. r Plr J /.7/7. r.\ ^ ^ H.i-.v 1 i-i-.l |i * * 1 t ` * w i 1.11 * ( i i'\ 1 tf-\V 11 1 M'lf(V no. n? t;f 1______ ir.i_______________ >Vf C'j. i r * /-f A f f Y O'M! rn * ....... '"'"I O.i ;* Lv-rnr-i ,\z \ i r-i-i Level uo-?o; V..lv? Air LoodMn osir. Sludge J Ptim[> Pa-s. PS!G Oc Fl.j-.v Hioc gfm SMtify: V.'.v;: H'i, f;ri? rt Fl.-r.v nn,po\i\ Rcmrw:il n.uo Dilution VV.tMr l-'low R.no G PM Source | Ir ^i rru^.-I I'Al'/mor I >y.r,ls. Ft.-fn. Ifi-Arn,,. j T-77 I T-7 7 A 1 1 At.wJ Anvnorvs r-73 T-TCA 1. i j In.ivi ! rv'*irvi r.'i-hrs Poly m. A or fl P** rj ft K '/.'.Her II.IN: CPM f-!r:'1 i'.-iln.-r; riioi. A^ o* A or fi jA .tcKiHM Ami MO >) ~0<:d .*> utimj A of H !- i i i <? f-Tl.t. 1 n i ?"- M O 1 i!i"nC-'n Lt ! r.'.'j-o z~ -t.-.T-. r*/i3\aJ f< 'J ^ t C*>7^ O |Tr"- 1 ? <1 ii1 ^ .* i-'i p - | <? .7"- 70 O i ;?"A :< 1i J! 1 :i-` . ill r;f l\>n:!'.. f'!. r f i,-r .'111(1 TIliflki'll'.T Hr 11r; -- l n::. 10 u DTH 000120483 PARAMETER III PPM, UNLESS INDICATED <ly:t SAMPLE DATE APPENDIX J ANALYSIS DATE CCNCCQ YCM PLANT SECONDARY TREATING SYSTEM PARAMETER 0) FEED (2) EQUALIZATION SECONDARY OUTLET (3) CLARIFIER FEED (4) CLARIFIER OVERFLOW 1. COD, TOTAL 2. COD, FILTERED 3. BOD TOTAL 4. BOD FILTERED | 5. AMMONIA (N) t j 6. TGTAL 0-0?4 (As P) 7. EDC S. 2-CHLORO 9. CHLORINATED HYDROCARBONS (As EDO) 10. CHLORIDES 11. TSS 12. VSS 13. S.Y.I. 14. dH 15. FLOW RATE (GPD) lbs/day 16. F/M = __________ 17. k =* 19 20 13. Copoer ______ ______ __________ 19. Special Samples 20. CommonIZ: (5) 201 EFFLUENT ii I ( 7 S/3- * - o sjr\,, DTH 000120484 POINT - 201 DTH 000120485 i? .3!! lo+ VCM- HC1 NEUTRALIZATION UNIT LAKE CHARLES VCM PLANT INTRODUCTION The VCM Vent'Gas Incineration Unit was installed to comply with Environ- t. mental Protection Agency regulations on VCM emissions. Chlorinated hydrocarbons in the vent streams from the plant are burned at high tem perature and long residence time. The HC1 resulting from combustion is recovered from the off-gas in an HC1 absorber. This creates the prob lem of acid disposal. Sales was chosen as the primary means of disposal. A concentration unit has been installed to upgrade the acid strength from the HC1 absorber to a marketable level. The HC1 Neutralization unit is required to serve as a backup for the sales alternative.' Thus neutralization will be used only when the acid cannot be sold. Neutralization is also needed to handle an emergency acid dump from HC1 absorbers C-9Q1 and C-901B. An emergency acid dump occurs when there is a malfunction in the bottom circulation loop of either absorber which causes the liquid level in the absorber bottom to rise and trip the high level alarm and dump valve. Neutralization must always be ready for this dump even if acid is not being intentionally destroyed at the time. DTH 000120488 INTRODUCTION (continued) The neutralization unit consists of three main sections. (See Process Flow Diagram). The clam shell system is used to neutralize the aqueous HC1. CaC03 in the clam shell reacts according to the following reaction: 2HC1 + CaC03 CaCl2 + H20 + C02 Some HC1 is stripped from the liquid by the evolved C02. The Occupa tional Safety and Health Administration has set a maximum worker ex posure limit for HC1 at 5 ppm. The caustic system is used to trim neutralize clam shell pit effluent. Caustic also reacts with the dissolved C02. The two overall reactions are: C02 + 2NaOH -* Na2C03 + H20 HC1 + NaOH -+ NaCl + H20 dth 00120489 II. PROCESS DESCRIPTION A. Clam Shell System 1. Acid'Sources Acid solution flows through the absorber acid dump line to clam shell pit feed box, T-988. The normal source of HC1 is product drawoff from either of the two HC1 absorbers (C-901 or C-901B). Emergency dump valve lines from the bottom of C-901 and C-901B and a line from the Acid Concen tration Unit are also tied into this acid dump line. Vessel drains, sample drains, and area drains in the incinerator process area are tied into the incinerator acid sewer which drains to the existing clam shell pit, T-500. 2. Feed Rate The design HC1 feed rate to the neutralization unit is 4,800 Ib/hr dry basis. The normal HC1 production rate in the incineration unit is in the range of 2,000-2,000 lb/hr HC1. The HC1 concen tration in the feed to neutralization is in .the range of 10-25 weight percent. The total neutralization feed rate can vary from 20 to 80 GPM depending on the concentration and HC1 pro duction rate. During an emergency dump, the feed rate can average as high as 600 GPM for several minutes. For design purposes, it has been assumed that this high rate could be sustained for up to two-three hour and then diminish to 200-400 GPM for an additional 24 hours. 3 000120490 DTH '*>. j ' r* j-3 n , ' >, ; .. * 1 1 - 5' * > i II. PROCESS DESCRIPTION (continued) A. Clam Shell System Ccontinued] 3. Clam Shell Pits The acid flows from T-988 to either of the clam shell pits, T-981 and 982. There is a butterfly valve located in the lines feeding and leaving each pit. Consequently, each pit can individ ually be put on line or removed from service. Two pits are re quired so that one can be recharged with shell or cleaned out while the other is in use. Each' pit holds a one-day supply of shell at an HC1 flow rate of 4,800 lb/hr. Therefore, one pit has to be filled each day under maximum operating conditions. For lower HC1 rates, the pits will need to be filled less often. Clam shell contains inerts which accumulate in the pits. The amount of inerts in the shell varies. Regular-washed clam shell contains more inerts than douhle-washed clam shell because the double-washed shell is more thoroughly cleaned. Limestone con tains the same reagent (CaC03) as clam shell and generally has less inerts. The more inert material in the shell or stone, the more often the pits will need to be cleaned out. With the use of double-washed clam shell and an HC1 destruction rate of 4,800 Ib/hr (dry basis), each pit has to be cleaned out once per month (i.e., one pit every two weeks). The actual frequency of cleanout depends on the neutralization reagent used and the HCl neutralization rate. DTH 000120491 4 i II. PROCESS DESCRIPTION (continued) i VJ - J 'l -i A. Clam Shell System (continued) 4. Aerators Each clam shell pit contains two static aerators (A-982 A, B in T-981, A-983 A, B in T-982) in the outlet section. Blower, BL-982, supplies air to the aerators to mix and strip the liquid before it leaves the pit. This removes carbon dioxide from solution. The partially-neutralized liquid then flows from either clam shell pit to the effluent box, T-989. 5. Shell Pit Bypasses Precautions have been taken to ensure the clam shell pits will never overflow onto the ground. The wooden underflow baffles in the pits have holes built into them. These holes allow an internal bypass of liquid within the pits. The holes in the baffles are at * an elevation above the normal liquid level. If the underflow area of the baffles should become plugged with sludge or if the high flow rates from an emergency dump at an HC1 absorber cause the liquid level to rise in the pits, the liquid will bypass through the holes in the baffles. An external hypass line (Line No. 4) connects T-988 to T-989. This allows acid to bypass the acid pits if both are simultaneously blocked in for some reason. The liquid level in T-988 will rise and overflow to T-989 before the liquid overflows the acid pits. A level alarm (LAH-985) is activated if the external bypass occurs. DTH 000120492 5 .. i1i II. PROCESS DESCRIPTION (continued) B. Caustic System 1. Supply System The purpose of the caustic supply system is to fill caustic supply tank, T-986. Pump P-983 transfers 50 percent caustic from a line off existing storage tank, T-421, to Static Mixer A-981. Water from a 3-inch process water line mixes with the 50 percent caustic in A-981 to produce 20 percent caustic. The flow of 50 percent caustic and process water are each manually controlled by a local flow indicator and globe valve. All of this equipment is located in the area east of T-421 in the main plant tank farm area. The 20 percent caustic flows from A-981 to Caustic Storage Tank T-986 located in the neutralization process area. T-986 can hold.more than a five-day supply of caustic based on a flow rate of 160 GPM and a pH of 2 for the clam shell pit effluent. Normal pH of the shell pit effluent should be in the range of 3-4. T-986 should hold more than a ten-day supply of caustic based on this pH range. 2. Circulation System Circulation Pump P-982 A or B, supplies 20 percent caustic to the pH control valves at the caustic neutralization facility (T-983, 984, and 985). The caustic is circulated from T-986 back to T-986 through a back pressure controller, PC-981. A DTH 000120493 a ; 3^1 r:\r~s & j II. PROCESS DESCRIPTION (continued) B. Caustic System (continued) 2. Circulation System (continued) supply line for the pH control valves is connected to this loop. The pressure on the upstream side of each valve is head constant by PC-981. The control valves can be fully blocked in without adversely affecting the circulation pumps since the bulk of the flow is normally through PC-981. 3. pH Control System The pH of the clam shell pit effluent is normally in the range of 3-4 as it enters T-983. A lower pH (0-1) could result from an HC1 breakthrough in the shell pits due to low shell inventory or acid by-pass. A feedback pH controller (PHRC-982) controls caustic addition to T-983. The feedback pH signal is meausred in the exit weir of T-983 and controlled at a value of approxi mately 5.5. Two control valves (PHCV-982 A and B) are required to get the desired rangeability of caustic addition to T-983. Another feedback pH controller (PHRC-983) controls trim caustic addition to T-984. The feedback pH signal is measured in the exit weir of T-984 and controlled at a pH of approximately 7. Only one control valve (PHCV-983) is required. Bypass lines around the pH control valves allow manual addition of caustic to T-983 and T-984. 000120494 7 omi r \ A rJ c .J -vj i J a II. PROCESS DESCRIPTION (continued) B. Caustic System (continued) 4. Neutralization Sumps The partially neutralized liquid from the clam shell pit effluent box (T-989) flows into the caustic neutralization facility (T-983, 984, and 985). Agitators are located in T-983 and T-984 (A-984 in T-983 and A-985 in T-984). The agitators provide intense mixing for pH control. T-985 is used as a sump for the scrubber feed pumps (P-981 A and B). The neutralized liquid flows from T-985 to Diversion Box T-987. 3 DTH 000120495 II. PROCESS DESCRIPTION (continued) C. Diversion System Neutralization unit effluent gravity flows from the pump sump in the caustic neutralization facility (T-985) to Diversion Box T-987. There are two lines leaving this box. The neutralization effluent line is pumped to the North Lagoon at the Lake Charles Chemical Plant. The other is a diversion line which ties into a new catch basin in the sewer line to Equalization Basin T-701. There is a control valve located in each of these lines (PHCV-984A in the neutralization effluent line and PHCV-984B in the diversion line). If the pump to the North Lagoon fails, the incinerator effluent can be allowed to overflow the weir in the diversion box and flow into the polishing pond at the Lake Charles Chemical Plant. If overflowing into the polishing pond is unacceptable, then a temporary pump may be set up to pump the effluent into the North Lagoon at the Chemical Plant. Only in an emergency situation should the neutralization effluent be diverted to the Equalization Basin, T-701. At no time will the neutralization effluent be allowed to discharge directly to the Bayou Verdine since this may result in an NPDES violation due to a high concentration of solids in this stream. If the neutralization effluent is diverted to T-701, the main plant control room operator must be notified of the diversion. The problem causing the diversion action should be determined and solved as quickly as possible. DTH 000120496 SECTION IV HAZARDOUS WASTE REGULATIONS -AND GUIDELINES DTH 000120498 SECTION IV RCRA GUIDELINES DTH 000120499 (conoco) Interoffice Communication To J. W. Ware, J. R. Holcomb, and P. L. Fetzer From G. S. Hoenes Dote November 18, 1980 Sublet Compliance with RCRA'Hazardous Waste Regulations On February 26 and May 19, 1980, the United States Environmental Protec tion Agency (EPA) issued the first set of a series of regulations concern ing generation, transportation, treatment, storage, disposal and/or reclama tion of hazardous wastes. These regulations, mandated by the Resource Conservation and Recovery Act (RCRA), are extremely comprehensive in scope; and as a result, require extensive compliance actions by industry.' On November 19,' ~ 1980 Conoco did supply the EPA with an interim Hazardous Waste Permit applica tion. Submittal of the permit application will allow Conoco to maintain hazardous waste operations until a final Hazardous Waste Permit is approved by the EPA. Submittal of the permit application will also require that the hazardous wastes generated, treated, or stored at the VCM Plant will need to be closely and accurately managed and that special procedures will need to be followed to assure the minimum amount of hazardous wastes are generated. - ''Zu ' V'* Details of the hazardous waste storage and treatment facilities operated at 7:' the VCM Plant and the hazardous wastes generated are attached. Also included ..l; are special operating procedures for the hazardous waste facilities. These procedures should be incorporated into standard plant operating practices :-'7' immediately. The RCRA regulations carry the typical civil and criminal penalties associated with Federal environmetnal regulations, therefore proper hazardous waste management and compliance with all RCRA regulations is essential. Your coopera tion in this matter is appreciated. Should you have any questions or comments, please see me. Z Process Engineer is CC + enc: JAD-GLF-Hjri-MLH-DLD-CWT-PE JWW(4)-JRH(4) 000120500 DTH STORAGE AND TREATMENT FACILITIES According to RCRA regulations, the plant currently operates or plans to operate 14 hazardous waste treatment or storage facilities. Following is a list of the VCM Plant's storage and treatment facilities considered hazardous by RCRA regulations: I. Storage - Containers 1) Miscellaneous Hazardous Waste Dumpster (new) 2) Hazardous Waste Drums (new) II. Storage - Tanks 1) Tars Storage Tank, T-405 2) Wet Crude EDC Tank, T-452 III. Storage - Other 1) Limestone/Clamshell Waste Treatment Pile (new) IV. Treatment - Surface Impoundments 1) West Equalization Basin 2) South Equalization Basin 3) Activated Sludge Basin 4) Raw Wastewater Pit, T-l 5) Raw 'Wastewater Pit, T-2 6) Wastewater Neutralization Pit, T-500 7) Incinerator Neutralization Pit, T-981 8) Incinerator Neutralization Pit, T-982 9) Copper Pit There are two other hazardous waste treatment facilities operated in the plant. The two facilities are the Steam Striooers and the Closed Process ` ' Sewer. However, these facilities are exempt from RCRA regulations since they are considered to be "totally enclosed treatment facilities." Of the 14 hazardous waste storage and treatment facilities which are covered by RCRA regulations, three of the facilities are new and will be implemented prior to November 19, 1930 in order to provide a legitimate and practical way to handle various wastes considered hazardous under RCRA regulations. The three new hazardous waste facilities explained below are: 1) Miscellaneous Hazardous Waste Dumpster 2) Hazardous Waste Drums 3) Limestone/Clamshell Waste Treatment Pile The Miscellaneous Hazardous Waste Dumpster will be a 4 cu. yd. Browning Ferris Industrial (EFI) dumoster. The dumpster will be located to the north of the Light Ends Column, C-102, area (see the attached plot plan). The dumpster will DTH 000120501 Page 2 be clearly marked "Miscellaneous Hazardous Waste Dumpster" and should be used only for hazardous wastes. In addition to the Miscellaneous Hazardous Waste Dumpster, an area south of the Liquid Chlorine Tank, T-601, (see the attached plot plan) has been designa ted for the storage of 55-gallon drums containing hazardous waste. The 55-gallon drums, similar to the Miscellaneous Hazardous Waste Dumpster, are to be used for storing miscellaneous hazardous wastes which cannot be handled in a more effi cient manner. The drums are to be used only when the dumpster is not available or its use is not practical. For instance, the drums should be used if the volume of the waste exceeds the capacity of the dumpster. The Limestone/Clamshell Waste Treatment Pile has been developed to allow the 1imestone/clamshell used in the Wastewater Neutralization Pit, T-500, to be treated thereby rendering the material non-hazardous. The Waste Treatment Pile includes the dirt covered area to the north, east, and west of the In cinerator Neutralization Pits, T-981 and T-982, extending to the VCM Plant boundaries (see the attached plot plan). The waste 1imestone/clamshell should be spread over the Waste Treatment Pile area and allowed to "weather" thereby removing residual organics before reuse. No new procedures will be required for the existing hazardous waste treat ment and storage facilities. However, manifesting will be required when the facilities are cleared. PTH 000120502 HAZARDOUS WASTE As a result of extensive testing, it has been determined that the VCM Plant generates 26 wastes which are considered hazardous under RCRA regulations and should be handled as such. Following is a list of those wastes. HAZARDOUS WASTES 1) Heavy ends from the distillation of ethylene dichloride in ethylene dichloride production (EDC tars). 2) Heavy ends from the distillation of vinyl chloride in vinyl chloride production (VCM tars). 3) Asbestos insulation 4) Vinyl Chloride (VCM) 5) Ethylene Dichloride (EDC) 6) Copper Pit Sludge 7) T-l Pit Sludge 8) T-2 Pit Sludge 9) VCM Plant Wastewater 10) Incinerator Wastewater 11) Laboratory Hood Charcoal Beds 12) EDC and VCM Filter Cartridges 13) T-500 Pit Limestone 14) Spent Calcium Chloride 15) Laboratory Sample Bottles 16) Laboratory Chemical Reagent Bottles 17) Copper Chloride Catalyst 18) Raschig Rings 19) T-500 Pit Sludge 20) Secondary West Equalization Basin Sludge 21) Secondary South Equalization Basin Sludge 22) Secondary Activated Sludge Unit (A.S.U.) Material 23) T-931 Pit Sludge 24) T-982 Pit Sludge 25) Incinerator Overflow Box Sludge 26) Quench Column Coke EDC and VCM are included on the list even though they are not generated as wastes. The two substances have been included on the list since spillage of either substance or contact of either substance with another material might result in the generation of a hazardous waste. Materials which absorb VCM or EDC must be considered hazardous if they contact either of the hazardous contaminants. An example of such a contaminated material is EDC contaminated DTH 000120503 dirt. The dirt should be treated as a hazardous waste and should be stored in either the Miscellaneous Hazardous Waste Dumpster or the 55-gallon Hazardous Waste Drums prior to disposal. Materials such as teflon liners, scrap pipe, etc. which do not absorb EDC or VCM are not considered hazardous if they are rinsed to assure that none of the contaminant remains. RCRA regulations re quire the material to be rinsed three times with a suitable solvent (water is sufficient for EDC and VCM) to assure the material is decontaminated. There fore, to reduce the amount of hazardous waste generated at the VCM Plant, materials should be decontaminated whenever possible by triple-rinsing. The previously listed hazardous wastes generated at the VCM Plant and any additional "contaminated" hazardous wastes are considered hazardous under RCRA regulations and should be handled accordingly. Therefore, manifesting is required for disposal of all of these materials. The EDC and VCM tars. Copper Pit Sludge, T-l Pit Sludge, T-2 Pit Sludge and Asbestos Insulation should be disposed of as at present by contractors. The Laboratory Hood Charcoal Beds and EDC and VCM Filter Cartridges and other miscellaneous wastes should be stored in the Miscellaneous Waste Dumpster or 55-gallon Hazardous Waste Drums until a sufficient quantity of waste is col lected to warrant disposal or before 90 days have expired. The Incinerator Wastewater and VCM Plant Wastewater are considered hazardous wastes prior to their discharge points and should be treated as such. However, no special procedures for disposal are required since both wastes are handled through a treatment system (already permitted under MPDES). Finally, the limestone/ clamshell from the T-500 Pit, as previously mentioned, should be placed in the Waste Treatment Pile and allowed to weather. DTH 000120504 VM PLAhiT PLOT FLAM: aJuj HAZft&OOuS UJA STB BA CJriSZTTTB 5 UTMESTOVE/CLAWSrteLt- LJftHE TZEATmemT PXle A&A < ( SECTION IV y HAZARDOUS WASTE FACILITY INSPECTION PLAN i DTH 000120506 Hazardous Waste: Facility Inspection Plan I. General Applicability RCRA Part 265 Regulations and in accordance with DNR Analytical Operations Procedure Manual require an ongoing inspection program to prevent the release of hazardous wastes to the environment through un planned releases, equipment failure, or human error. This plan of in spection of hazardous waste storage and treatment facilities is imple mented with the primary objective to prevent those releases by locating and eliminating malfunctions, deterioration or operating problems before spills occur. The inspection program is to be a part of the daily rou tine of monitoring and checks which are normal operating practice so that problem prevention becomes a part of the everyday operations. I. Facility Standards A. Container Storage Containers shall be inspected once weekly to determine that (1) containers holding hazardous wastes are closed, (2) containers are not leaking or have not deteriorated to the point of being un safe. B. Tank - Treatment or Storage of Hazardous Waste 1) Tanks will be inspected daily to determine (a) the discharge control equipment is in good working order, (b) the tank is being operated according to design by data gathered from monitoring equipment, (c) the level in the tank, for un covered, undiked, or otherwise uncontained tanks; provides at least two feet of freeboard. DTH 000120507 2) Tanks will be inspected at least once weekly to determine (a) the tank materials have not significantly corroded and there are no visible leaks, (b) the construction materials of contain ment structures have not deteriorated or leaked and the area immediately surrounding the structures show no signs of leaks (e.g., wet spots). Surface Impoundments 1) Daily inspection to determine that there is at least two feet of freeboard. 2) Weekly inspection to determine that materials of construction have not leaked, deteriorated or failed. LandfilIs This section will be completed and implemented at the time the landfill begins operation, or at the time this information is required for submittal as a part of the second phase of the RCRA permitting process. Chemical, Physical and Bio-Treatment 1) Daily inspections of discharge control and safety equipment (which includes bypass, drainage or pressure relief systems) to determine that such equipment is in working order. 2) Daily monitoring data to ensure proper process operations. 3) Weekly inspections of the equipment of the treatment process to detect corrosion or where applicable, leaks. 4) Weekly inspection of containment structures to detect physical deterioration and possible leakage. 000120508 DTH = All applicable Facility Inspection Reports are contained in Appendix II for reference. r DTH 000120509 APPENDIX I FACILITY INSPECTION PROCEDURES I. Above Ground Storage Tanks All above ground storaae tanks will be inspected at least once every two years. The vessel will be visually inspected. External thickness measurements will be taken with ultrasonic equipment. An inspection of the foundation and support structures is also to be made. If the vessel is opened, an internal inspection is to be made. This will include a visual inspection and thickness measurements with ultra sonic equipment if practicable. If corrosion is found, the depth of the pits will be measured and recorded. II. Buried Piping Installations Any section of buried line which is uncovered and exposed at any time is to be visually inspected and external thickness measurements taken with ultrasonic equipment. III. Miscellaneous Process Equipment All other process equipment requiring inspection, will be inspected on a two year interval. Units will be inspected when down for cleanouts more often than the two year interval. When a vessel shows signs of 000120510 dth 2- corrosion, inspection will be made on shorter intervals as determined by the Inspection Department. IV. Records/Administration All inspections and records will be performed and recorded in accordance with CONOCO standards and are to be kept for a minimum of 3 years. Letters detailing inspections will be written and distributed to the appropriate persons for information and/or corrective action. ,l DTH 000120511 APPENDIX II FACILITY INSPECTION REPORTS .a DTH 000120512 VCft PLANT DATE Weekly Hazardous Waste Facility Inspection - Storage Containers 1) Are there any leaks in the Mi scellaneous Hazardous Waste Dumpster? 2) Are there any leaks in the Hazardous Waste Storage Drum? Circle Answer YES NO YES NO If yes to either, describe action taken to correct. Weekly Hazardous Waste Facility Inspection - Storage or Treatment Tanks Circle Answer 1) Are there any leaks in T-405? YES NO 2) Are there any leaks in T-452? YES NO If yes to either, describe action taken to correct. 3) Are any of the dikes broken through? If yes, describe. YES NO - ----- Facility Inspector 1) This forn must be completed once weekly for all hazardous waste storage or treatment facilities and any problems should be reported to the Shift Super visor immediately. 2) Please return this form in the mail to the Process Superintendent so that it may be placed in the Process Ennineerinn Environmental File. DTH 000120513 VCM PLANT DATE Weekly Hazardous Haste Facility Inspection - Surface Impoundments Are any of the following surface impoundments leaking? Circle Answer T-l Pit T-2 Pit YES NO YES MO T-500 Pit YES NO W. Equalization Basin YES NO S. Equalization Basin YES NO A.S.U. YES NO (If any were answered yes, describe action taken to correct). Facility Inspector Notes 1) This form must be completed once weekly. 2) Any problems should be reported to the Shift Supervisor immediately. 3) Please return this form in the mail to the Process Superintendent so that it may be placed in the Process Engineering Environmental File. DTH 000120514 VCM PLANT DATE Daily Hazardous Waste Facility Inspection - Surface Impoundments 1) Is there at least 2 feet of freeboard in the following surface impoundments? Circle Answer If Mo, How Much Freeboard? T-l Pit YES NO T-2 Pit YES NO T-500 Pit YES NO W. Eaualization Basin YES NO S. Equalization Basin YES NO A.S.U. YES NO Is one of the A.S.U. lift pumps, P-516A or P-561B, discharging to the A.S.U.? YES NO Is one of the Sludge Recycle Pumps, P-510 or P-511, discharging to the A.S.U.? YES NO Is the storm water diversion system flow chart operating? YES NO Daily Hazardous Waste Facility Inspection - Storage or Treatment Tanks T-405 T-452 Circle Answer Circle Answer 1) Are there any leaks in the piping or valves? ' YES NO YES NO 2) What is the liquid level in the tank? 3) What is the pressure in the tank? 4) What is the temperature in the tank? If yes to the first question, describe action taken. Notes Facility Inspector 1. This form must be filled out daily and any problems should be reported to the Shift Supervisor immediately. 2. Please return this form in the mail to the Process SuDerintendent so that it may be placed in the Process Engineering Environmental File. 000120515 HAZARDOUS SERVICE BLEED VALVE PROGRAM CONOCO VCM BLEED VALVE PLUGGING PROCEDURE HAZARDOUS SERVICE BLEEDER STANDARD BLEED VALVE INSPECTION PROCEDURE DTH 000120516 BLEEDER PLUGGING PROCEDURE PURPOSE The intended purpose of this procedure is to establish a criteria for plugging bleeders in plant piping systems and to continually assure that designated bleeders are physically plugged when not in actual use. SCOPE OF PROCEDURE This procedure will apply to bleeders in services that contain: Flammable Hydrocarbon Liquids Flammable Gases Ammonia Chi orine Products or Intermediates that have Health related Hazards Hydrogen Acid & Caustics Steam Condensate For the purpose of this procedure, bleeders are defined as openings in piping for use v.-hen draining, washing, injecting, product transferring, or clearing the piping. PROCEDURE 1. All bleeders in the specified services will have the outlet valve plugged or cappec with threaded pipe plugs when not being actually used. 2. All flanged bleeder valves will be capped with blind flanges. / 3. Non-threaded adaoters for various utility hose fittings will be removed before plugging. 4. To the degree ocssible, the plug:, or caps will be in the block valve body and extension piping will Oe kept to a minimum. 5. The use of "double block and bleeder" arrangements vjill not be an acceptable substitute for compliance with this orocedure. 6. All s: orocedure will be identified with a l*a"xl's" DTH 000120517 2 7. At least weekly, the unit Operating Supervisor will have an inspection made of units under this control to determine if this procedure is being followed. The records of these inspections and their results will be available for review. 8. Prior to start-up following a shutdown of any equipment, a specific in spection will be made by operating personnel to assure that bleeders are properly plugged. A notation that this inspection was made is to be made in the units' log book. RESPONSIBILITY The carrying out of this procedure is the specific responsibility of operating personnel. 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LO CO CM to to tn CM CM nr t t1 CO COCO fNNN dTH 000120520 x. I ll This procedure will be followed each Saturday, day shift, by the operator respcr.siDle for his/her unit or, that day. 31 eebers to Se Plucced and Tacced: Caustic Cl rr Steam Condensate Chiorine Ethylene i ars Ammonia Light Ends Phosphoric Acid Sulfuric Acid Treatment Chemicals ene (boiler & cooling water) Che c :0ut ccedure: 1) The cosrator responsible for the unit will perform a walkthrough of his/her MO 1 eac.n Saturday or. day shift to inspect for unplugged bleeders, 2) Each "ye 1 lev/ tagged" valve should : e plugged. If a plug is missing, it shou id be reo1 acec bv the ins pecto ~-J7\ The survey should a Is;e include but not be limited to: = ) iCcwiuh Oi r*8w b 128C8 rs which need to be tagged and cl u z z 2 d. b) (missed during the initial phases of this program) which need to be tagged and plugged. A) Complete weekly inspection report return to Process Superintendent. All unplugged bleeders detected during the survey must be plugged. Write a work crcer to get bleeder repair/revised if it cannot be plugged. Another major ste: to making this program work is to remember to replace the plug in all bleed valves you have removed for any reason, (ie: hook up a hose; take a sample) DTH 000120521 V CM PLANT Date Meek!-/ ua:ardous Bleeder Inspection A bleeder plug and yellow tag tour was made in the following areas: Circle Answer Block I Block II Tank Car Loading Rack Secondary Incinerators YES MO YES NO YES NO YES MO YES NO If there were any plugs or tags in need of repair, appropriate work orders were written. YES MO Chief Operator or Shift Supervisor NOTES: 1. This form must be filled out once weekly (Saturday on dayshift). 2. Any problems (ie: bleeders unplugged or tags missing) corrective action was taken. 3. Please return this form in the mail to the Process Superintendent. DTH 000120522 SECTION IV CONTINGENCY PLAN AND EMERGENCY PROCEDURES LAKE CHARLES VCM PLANT 000120523 dth I. GENERAL The Contingency Plan and Emergency Procedures, as called for under RCRA Part 265, consists of two sections. There are the Disaster Plan, in Section IV, and the Spill Prevention Control and Countermeasure (SPCC) Plant, refer to Section III. Encompassing all unplanned, sudden or non sudden releases of air or liquid contaminants, these plans are designed to minimize hazard to human health or the environment. This includes both equipment failure or "acts of God." Release of hazardous waste materials would be an incidental portion of an emergency release situation; both plans which make up this Contingency Plan would cover the release of those waste contaminants in an emergency situation. As those facilities are an integral part of the overall facility operation, these plans are designed to cope with emergencies at the VCM Plant, and are not specific to the particular hazardous waste management facilities.II. II. EMERGENCY COORDINATOR The Emergency Coordinator is designated as the Manager of the Lake Charles Chemical Operations. The title of Emergency Coordinator is equivalent to the title of the Disaster Manager, and is named as such in the Disaster Plan. The Emergency Coordinator (Disaster Manager) and alternate designees are delineated in the Disaster group organization table. The Emergency Coordinator (Disaster Manager) for the Lake Charles Chemicals operation is: J. A. DeBernardi Home Phono: 625-8202 Work Phone: 491-5063 DTH 000120524 2- - m. NOTIFICATION OF LOCAL AUTHORITIES In the event of a release requiring notification of Local Authorities, Conoco will utilize an areawide alerting system, accomplished through a "hotline" telephone system which notifies the Louisiana State Police, the Calcasieu Parish Sheriff, and other local area industries. In addition, an arrangement with the local municipal Fire Departments and other in dustries will make available outside assistance in the event of an emer gency. Procedures for implementation of these systems are contained in the Emergency and Disaster Plan. IV. MATERIALS RECOVERY All spilled materials, contaminated soil, or liquids from process or waste treatment, storage or disposal activities will be handled and/or treated as specified in the Spill Prevention Control and Countermeasure Plan. V. REPORTING All reports to the EPA, Louisiana authorities, or local officials concerning releases will be filed in a timely manner through the auspices of the Emergency Coordinator. DTH 000120525 EMERGENCY AND DISASTER PLAN VCM PLANT APRIL -- 1980 Prepared By /-/C W. V. Henry Safety Directo,,ro DATE 8^0 Approved A. DeBernardi Plant Manager DATE j/s'/Tc DTH 000120526 EMERGENCY AND DISASTER PLAN VCM PLANT CONTENTS Condensed Emergency Instructions ------------------------------------------------------------ iii I. Foreword--------------------------------------------------------------------------------------------------- 1 II. What is Emergency------------------------------------------------------------------------------------1 III. Primary Objectives ---------------------------------------------------------------------------------- 1 IV. Organization Structure ---------------------------------------------------------------------------- 2 V. Emergency Positions A. Plant Manager--------------- -------------------------------------------------------- 4 B. Disaster Officer ------------------------- ----------------------------------------------- 4 C. Security Officer ------------ *---------------------------------------------------------- 5 D. Chief Process Engineer------- --- ----------------------------------------------- 5 E. Safety Director-------------------- -- -- -------------------------------------- 5 F. Fire Chief------------------------------ ---------------------------------------------------- 7 G. Mechanical Chief--------------------- -----------------------------------------------9. H. First Aid Chief-------------------------------------------------------------------------9 VI. Emergency Procedures w A. Detection and Evaluation ---------------------------------- 10 B. VCM Plant Emergency Action ----------------------------------------------------------- 11 C. Duties --------------------------------------------------------------------------------------------- 11 D. Rescue and Treatment of Injured--------------------------------------------------15 E. Emergency Phone Operation-------------------- 15 F. Ambulance & Fire Truck Assistance ----------------------------------------------- 16 G. Evacuation of Non-Essential Personnel ---------------------------------------- 16 H. Plant Emergency Personnel Protection ------ 17 I. All Clear Notification & Requirements ---------------------------------------- 18 J. Emergency Assistance^------------------------- 18, 19, 20, 20/ K. Emergency Notification tToxi'c Gas Release--------- --------------------- 21 L. Emergency Public Relations ---------------------------------------------------------- 28, 29 M. Emergency Telephone Numbers ---------------------------------------------------------30, 31, 32 N. Emergency Callout List ---------------------------------------------- :----------------- 33 VII. Bomb Threat Procedures ------------------------------------------------------------------------------34 VIII. Hurricane Procedures A. Purpose-----------------------------------------B. Definitions ------------------------------------- 35 35 C. Preparation ------------------------------------------------------------------------------------35 D. Coordination and Communication --------------------------------------------- ----37 E. Plant Startup -------------------------------------------------------------------------------- 38 F. General Information and Precaution ---------------------------------------------33, 39 IX. Disaster Readiness--------------------------------------------------------------------------------------40 Figures S ' 1. Emerqency and Disaster Organization Structure --------------------------- 3 2. CONOCO Chemicals Co. VCM Plant Emergency Entrance Pass -------- 6 is mCNJ o eg oo o 3. Map of Residential Area ------------------------ 8 4. Remote Gate Mechanical Latch Location ---------------------------------------- 12 Q 4A. Fire Water Curtain Activation Procedure ---------------------------------12A 4B. Fire Water Curtain Activation P&I Drawing ----------------------------- 12B 5. VCM Plant Fire Water System----------------------------------------------------- 14 6. Mutual Aid Road Block Location Map ----------------------------------------- 17 Appendix A. Fire Incident Report Form---------------------------------------------------------41 B. Public Relations Data Sheet ----------------------------------------------------- 42 C. VCM Plant/LCCP Emergency Agreement ----------------------------------------- 43 DTH 000120528 CONDENSED EMERGENCY INSTRUCTIONS 1. In the event of emergency, the Shift Supervisor will be in charge of immediate action and notification of Emergency Services and Disaster Organization. 2. Shift Supervisor will instruct the Laboratory Analyst on duty that "call out" of Disaster Organization members is to be instituted. If, however, the lab analyst is tending to injured personnel, the Shift Supervisor will delegate another employee to "call out" the Disaster Organization. The employee should start at the top of the list located on page 27 and notify at least one member by phone indicating to him the general nature of the emergency. That member will then be responsible to notify the remaining members of the Organization by phone. 3. If an electrical power failure occurs, all phones in the plant are wired to automatically become battery operated and serve to provide communications to call for help or assistance, if required. Battery power will be supplied by the Refinery. 4. If emergency backup power from the Refinery should fail, a mechanical latch located on the remote control gate must be unlocked manually to open the gate. See page 12 for the location of the latch and more detailed information. 5. If additional help or evacuation of adjacent areas is necessary contact the Lake Charles Chemical Plant and/or the Mutual Aid Association. 6. If the emergency ambulance or fire truck should be summoned from the Lake Charles Chemical Plant (LCCP) into the VCM plant, the Shift Supervisor or his designee must instruct the LCCP driver what equipment to bring, what gate to enter and provide an employee at the entrance to the gate to direct the LCCP driver to the emergency. 7. Account for employees in plant as soon as possible. EMERGENCY TELEPHONE NUMBERS See pages 24, 25, 25 and 27 of this plan. Revised 7/22/76 DTH 000120529 111 EMERGENCY AMD DISASTER PLAN VCM PLANT WESTLAKE, LOUISIANA I. FOREWORD Fires, explosions, toxic fume releases, and the forces of nature have all to frequently resulted in heavy loss of life and property and serious interruption, to production in chemical manufacturing plants. These experiences emphasize the importance of planning and organizing in advance so there will be an effective means available for handling an actual or potential disaster situation. A petrochemical plant contains many of the ingredients necessary to create emer gency situations. These include highly flammable, as well as highly toxic, ma terials. Linder normal conditions these materials will be contained and controlled. However, due to acts of nature, human error or mechanical failure, emergency situ ations can, and do, develop. These conditions must be met with a planned and organized approach. It is the purpose and intent of this plan to define specific areas of responsibility such that if faced with an emergency situation quick, decisive, and appropriate action may be taken with the least possible confusion or delay. II. WHAT IS AN EMERGENCY An emergency is considered to be "a condition or situation requiring assistance over and above that which can be supplied by the normal personnel present at the time or which cannot be handled in the normal manner." j With respect to disaster planning, an emergency will exist when there is danger to people, property or equipment. Some of the conditions that could create or contribute to such a condition are: A. Release of toxic or flammable material B. Fire and explosion C. Hurricanes D. Tornados E. Flood F. Conditions occurring outside our plant which affect our operation such as a power failure or emergency within an adjacent plant. G. Bomb Threat This plan is divided into various parts with each having specified areas of re sponsibility and each concentrating on reducing or eliminating the problems created by the emergency. III. OBJECTIVES The basic objectives of this emergency plan are to: A. Assure the safety of our employees and the safety and welfare of the general public. B. Minimize property damage in our plant as well as that of other companies or individuals and provide for the prompt resumption of operations. C. Satisfy the legitimate concern of our employees, their families and the general public by providing prompt accurate information on the extent and the effects of the emergency. DTH 000120530 ^Manufacturing Chemists Association Safety Guide SG-4 IV. ORGANIZATION STRUCTURE During an emergency condition, a clearly defined organization will be used. Page 3 defines the structure and job assignments of the organization. This organization will be headed by the Plant Manager or Plant Superintendent. He will act as the executive head of the Emergency and Disaster Organization and will bear the overall responsibility to see that the objectives of the plan are met. The Plant Manager or Plant Superintendent will monitor all activities being carried out. Members of the Emergency and Disaster Organization will keep him informed of the conditions throughout the emergency. Organization members will be responsible to carry out those duties as defined in Section V, Emergency Positions. DTH 000120531 2 EMERGENCY AND DISASTER ORGANIZATION STRUCTURE ) Figure 1 DTH 000120532 V. EMERGENCY POSITIONS A. Plant Manager The Plant Manager and/or Plant Superintendent will be responsible to: 1. Establish leadership over the disaster group and coorindate all activities connected with control of the situation. 2. Maintain close communication with the Disaster Officer. 3. Act as liaison with management of other local plants, keeping them informed of the situation and/or advising them of what effect the emergency could have on their operation. 4. Promptly release factual information to the news media preventing erroneous reports. 5. Notify next of kin in cases of serious or fatal injuries. 6. Assure that corporate management is informed and kept constantly up-to-date on the situation. 7. Determine what information may be given out by the switchboard operator. B. Disaster Officer The Process Superintendent will serve as the Disaster Officer. He will report directly to the Plant Manager and will be in overall charge of emergency control activities. He will be assisted in the duty by the Safety Director and the Chief Process Engineer. Specific Duties of the Disaster Officer Will Be To: 1. Work closely with the Fire Chief in determining the most effective manner in establishing control of the situation. 2. Keep the Plant Manager informed of the situation and the measures being taken to bring it under control. 3. Rely on the advice and help of the Chief Process Engineer and Safety Director. NOTE: The Safety Director will be involved in actual fire fighting and rescue. The Chief Process Engineer is to be utilized in a technical capacity to reduce or control equipment damage or spread of emergency. 4. Issue instructions for the "call out" of off-duty employees and ad vise the Security Chief of who is authorized to enter the plant. 000120533 IYTH 4 C. Security Officer The Security Officer position will be filled by the Office Manager and he will report directly to the Plant Manager. His specific duties are to: 1. Provide for the protection of all plant property and material. Preserve and protect nonreplaceable records. He will procure and assign guards, selected from plant personnel, as needed. 2. Establish a list of all employees or others in the plant and keep this list up-to-date at all times during the emergency. He should work with the Chief Chemist who will be in charge of first aid. 3. Provide for external communications during the emergency. ' To do this, he may have to call in telephone repair crews or procure radio equipment. 4. Dispatch personnel to the various road blocks so that VCM Plant personnel may be identified and allowed into the area if needed. 5. Authorize legitimate visitors access to the plant after they have been identified. The curious and those having no legitimate business in the plant must be turned away in a firm, tactful manner. ( NOTE: Access of plant personnel will be made upon proper identifica tion using the Continental VCM Plant emergency entrance pass card(see Figure 2). Cards should be carried at all times. Cards will be in effect for one year from the date of issuance. 6. Provide food, water and any other emergency supplies that might be needed during the course of the emergency. D. Chief Process Engineer T~. Ihe Chier Process Engineer will work with the Disaster Officer and assist him in evaluation of the situation and the planning of action necessary to establish control of the emergency. 2. The Chief Process Engineer will provide any technical information regarding equipment and process that might be necessary. He will keep the Disaster Officer informed of his whereabouts at all times. 3. He will coordinate and assist the Plant Manager and/or Plant Super intendent in his duties, as requested. E. Safety Director The Safety Director will assist the Disaster Officer in any way necessary in bringing the situation under control. His primary responsibility is to support any fire fiqntinq operations, toxic materials controls or rescue efforts. He will work closely with the Fire Chief and First Aid Chief. He will issue the Emergency Entrance Pass Card to all plant (permanent) emDloyees. 5 DTH 000120534 / V EMERGENCY ENTRANCE PASS 1 fconoco) V.. VCM Plant Emergency Entrance Pass Employee________________ Date Approval. -( Figure 2 6 DTH 000120535 F. Fire Chief 1. The Shift Supervisor or his designee on duty will act as the Fire Chief. If the Shift Supervisor is injured during the emergency, the chief operator will act as the Fire Chief. He will actually direct the fire brigade and others involved in fire control or other emergency action. He will work closely with the Safety Director in the effective use of manpower and equipment necessary to bring the situation under control. 2.. He must make the immediate decisions regarding emergency action and continue in this capacity until the Disaster Organization can assemble. The Shift Supervisor, actinc as the Fire Chief, will initiate notification necessary to put this plan into actior 3. In addition, notification of other plants and Mutual Aid will be made by the Shift Supervisor or his designee. This includes the Continental Emergency Center, Lake Charles Chemical Plant and Refinery supervision, PPG Chlorine Control Room and others. A complete listing of emergency notification numbers is located in Section VI, Pages 24 through 27. 4- The specific duties of the Fire Chief in time of emergency are to: a. Evaluate the emergency situation and direct the fire brigade to take necessary action to control the problem. (See Disaster Team Section VI, page 14 for specific duties. b. Notify the necessary emergency services required to assist in the ( control of the situation, as required. 1 c. Provide rescue support to injured personnel. d. Direct the "calling out" of the Disaster Organization. He will also call out any additional manpower he feels necessary to cope with the situation, including calling out dry chemical truck or Refinery Pumper. e. Appoint available personnel to man plant entrance gates until they can be relieved by personnel provided by the Security Officer. f. Assume leadership over the Fire Brigade and immediately take action to control the emergency until the Disaster Officer and Safety Director have arrived; at which time he will report to the Disaster Officer. g. Take steps to warn adjacent plants and residential areas if they are threatened by explosion or gas release. This may be done through Mutual Aid if time allows. If immediate action is required to evacuate adjacent residential areas, plant personnel should be used until Mutual Aid assistance can be obtained. A plot map of the area west of the plant is provided on Figure 3, Daae 8 for this purpose should such a situation occur. There is also a battery-powered "bull horn" in the first aid room for use in warning these residential 1 areas. The area north and northeast of the plant (near Houston River Road) may possibly require evacuation 1 if the wind is out of the south or. southwest. tflH 000120536 7 Revised 4/SO DTH 000120537 h. Complete the Fire Report form (see Appendix A) within 48 hours if a fire has occurred in the plant. G. Mechanical Chief The Mechanical Superintendent will function as the Mechanical Chief during time of emergency. In this capacity, he will report to the Disaster Officer. He will carry out the following duties: 1. Organize and direct damage control work as directed. 2. Assist the Disaster Officer in any way necessary to bring the situation under control. 3. Organize and direct cleanup and repair crews for the purpose of getting the plant back into production as soon as possible. 4. Take steps necessary to assure adequate transportation facilities are available during and following the emergency. 5. Establish relations with outside utility companies and work closely with them in maintaining service or restoring service as soon as possible. 6. Keep the Disaster Officer informed of his whereabouts at all times. 7. Notify the Security Chief the names of those people in the plant under his direction and of any who have been called out. This is to assure that the Security Officer will be able to maintain an uD-to-date personnel list and can arrange for identification of those "called out" at the road blocks. H. First Aid Chief The Chief Chemist will serve as the First Aid Chief and will report to the Disaster Officer. He will be responsible to: 1. Render first aid treatment to personnel injured during the emergency. He will utilize his lab technicians and, if necessary, request assistance from the LCCP or Refinery Medical personnel. 2. Arrange for ambulances for transporting the injured. He should use Comqany equipment but if additional equipment is necessary he should obtain through Mutual Aid. 3. Keep the Plant Manager and Security Officer informed of injuries, including names and estimates of severity. 4. Establish first aid station and facilities west of.the.main office building or other safe area if the laboratory buildinq is involved in the disaster. 5. Work with rescue squads in transoortinq injured nersn^npl to ambulances. DTH 000120538 9 VI. EMERGENCY PROCEDURES Emergency procedures defined here are necessary to familarize each employee with the planned steps that must be performed during an emergency. Essentially, the basic steps consist of: 1. Detection and assessment of the emergency. 2. Evacuation of all non-essential personnel 3. Rescue and treatment of injured personnel. 4. Immediate action taken to prevent further damage and/or injury. 5. Notification and request of assistance of other plant personnel and/or other agencies to control the emergency. A. Detection and Evaluation 1. Employee's responsibility Each employee is responsible to report any potentially dangerous condition to the Shift Supervisor, for corrective action. The Shift Supervisor has the responsibility to take whatever action necessary to reduce or eliminate the potential emergency. Plant employees will be called on during an emergency to assist the Shift Supervisor in controlling the situation. 2. Shift Supervisor The Shift supervisor at the VCM plant will normally be the first in * dividual in authority to recognize the existence of an emergency. He is responsible to evaluate the emergency and direct the actions of others in the plant to rescue injured personnel, take immediate pre ventive action, and notify other agencies for help to control and eliminate the situation. 3. Emergency signals a. VCM Plant 1. The VCM plant contains two primary sources of emergency situation' these are, fire and release of toxic material. In order to take care of these two possibilities, two separate alarm signals are used. 2. A fire is signaled by a continuous blast of nitrogen-fed whistle on top of the DeMag building. It is actuated from the panel board. When a fire is discovered, the situation must be communicated to the control room as soon as possible. 3. A toxic gas release is signaled by an oscillating siren, audible throughout the plant. This alarm should be actuated from the control room when an unexpected and massive toxic gas or liquid release occurs. i DTH 000120539 in B. VCM Plant Emergency Action 1. General a. Employees who first detect an emergency condition (i.e. fire, explosion, toxic gas release, etc.) should immediately notify the Shift Supervisor, for corrective action. b. The fire horn or toxic gas siren will be sounded by the Shift Supervisor or his designee to alert essential personnel to proceed to their emergency stations and non-essential personnel to evacuate the plant immediately. NOTE: Evacuation should take place immediately, except when the fire horn and gas siren are tested each Friday at'10 am. c. Should the normal electrical power source fail, emergency power will be furnished through the Lake Charles Refinery. If normal electrical power fails, the remote gate must be manually opened by pulling the level located on the remote gate control box "out" to unhook the latch. (See Figure 4, page 12) d. In every case, it is imperative that warnings of emergency situations be given as soon as possible and that employees throughout the plant know the meaning of the alarms. It is also necessary that adjacent plants be notified of the situation in order that they may take action to limit the exposure. e. A fire water curtain located on the north and west sides of the R-201A & cracking furnaces are provided to prevent releases of flammable gases in the process area from reaching the furnace burners. Activation of the curtain can be both manual and automatic. Operation of the curtain is explained on pages 12A and 12B. C. Duties 1. Shift Supervisor a. The Shift Supervisor or his designee, recognizing the emergency situation or the probability of one, will immediately issue instructions to his operating personnel of the necessary action they will take in dealing with the problem. b. The Shift Supervisor will make a list (written) of all Operations personnel in the plant and account for them. c. The Shift Supervisor or his designee will be responsible to sound the fire horn or toxic gas siren and direct the evacuation of all injured personnel and non-essential personnel to a designated safe area. d. The Disaster Organization should be notified immediately to assist in providing necessary support. e. Other agencies should be notified for help if required (see pages 24-29) 000120540 DTH 11 I 2. Laboratory Analysts Duties a. The lab analyst on duty shall be responsible first to rescue and/or treat the injured. Refer to paragraph D, page 15 for instructions relative to the first aid station during an emergency. b. If time permits, the lab analyst will be instructed by the Shift Supervisor that "call-out" of the Disaster Organization is required. The lab analyst will start at the top of the emergency call list and notify at least one (1) member of the Disaster Organization. DTH 000120541 iia 1 FIGURE 4-A R-201 A & B WATER CURTAIN ACTIVATION PROCEDURE Description The water curtain north and west of cracking furnaces R-201A and R-201B is designed to prevent releases of flammable gases in the process area from reaching the furnace burners. The water spray creates an air.pumping (dov/n-draft) action that forces vapor away from the furnaces. ' Water is supplied to the curtain through a deluge valve that can be activated both manually and automatically. The valve is normally held in a closed position by water pressure on top of the diaphragm. The water is supplied through a restriction orifice from a tap below the deluge block valve. Releasing water pressure on the deluge valve diaphragm opens the valve and supplies water to the curtain. Panel mounted trips release air loading on the deluge pilot valve, which will then open and release water pressure on the deluge valve diaphragm. The local manual trip is a V ball valve located at the deluge valve which, when opened, will activate the curtain. Panel Mounted Trips 1. Automatic The J & W gas detectors in the propylene and quench column areas will . automatically activate the water curtain at 50% L.E.L. (Lower Explosive Limit}. At 50% L.E.L., a 3-way solenoid valve is activated that releases air pressure to the H" deluge pilot valve. Pressing the "test" button on the above two detectors will also activate the curtain. 2. Manual The panel mounted trip when switched to the on position also activates the curtain by releasing air pressure on the deluge pilot valve. The switch is located by the VCM sphere deluge system trips. Local Manual Trip The curtain may also be activated by opening a V1 ball valve located directly above the deluge valve. Opening this valve releases water pressure on the deluge valve diaphragm. Freeze Protection The deluge valve and associated V tubing will be steam traced and insulated. During freezing weather, the drain valve at the deluge valve discharge should be opened slightly. This will allow the header to drain, but will not signi ficantly reduce water supply to the curtain should it be activated. DTH 000120543 \ 20) J1 * s lV /ir R C u z rm M l<\ i v h t / q m P *"JCf /''/z e t'S rtT tf/C VJ 0 I I * * r>> - VI O' sk Vj k ^ L-fe----- ^ i!S Vs Kr oi } *i \ ir l I j i DTH 000120544 That Disaster Organization member will then be required to notify the remaining members of the Organization by phone. The member should indicate to each other member contacted the general nature of the emergency and inform them that the Disaster Plan is to be put into action. Mutual Aid assistance and other emergency assistanc shall be requested only by direction of the Shift Supervisor, Disaste Control Officer, Plant Manager or Plant Superintendent. c. If the lab analyst cannot perform the "call out" duties described above the Shift Supervisor will designate another employee to perform these duties. 3. Disaster Team a. An emergency fire brigade is organized on each of the operating shifts. This same brigade shall act as the primary team to control or otherwise eliminate all emergencies that arise in the plant. b. In order to assure that critical duties are carried out in a timely manner, each operator shall have a specific function to perform, if required, during the emergency. The following duties are providec as guidance but the Shift Supervisor's instructions shall take pre cedence. THE FUNCTIONS HEREIN SHALL BE KNOWN BY THE EMPLOYEE. 1) Loading rack - Pumper/Loader - upon instruction of the Shift Supervisor close all shutoff valves or feed lines supplying flammable and/or toxic materials into the plant; assist lab analyst to rescue any injured personnel and transport them to the first aid room/station for treatment; assure proper acid suits or fire protection equipment provided. 2) Off-sites Pumper/Loader - assure that the fire water and electric power necessary to fight the emergency is provided to the proper plant location and with sufficient fire water pressure and gpm; upon instruction of the Shift Supervisor activate and cut off deluge systems; assure dike drains are closed, as required. (See figure 5 page 14 for Fire Water System Layout.) NOTE: Each Pumper/Loader should know the other Pumper/Loader's function during an emergency. 3) Two outside operators - man the fire water monitors and trip the furnace fire water curtain, as required, to disperse a flammable vapor cloud away from any heat and/or ignition sources; when out side help arrives, assist in locating and directing other fire fighting equipment, as required to disperse the toxic gas; assure all non-essential personnel have evacuated the area. 4) Roardman-shutdown equipment as necessary to prevent continued release of flammable or toxic gases or liquids. 5) Chief/Breaker Operator - be knowledgeable in the functions of a, b, c and d above. DTH 000120545 13 i \r~ o p- Revised 4/30 & ^ DTH 000120546 c. Disaster team responsible to stop and/or control the emergency will be required to don the proper respiratory and/or protection equipment and clothing prior to attempting to control the emergency in accordance with paragraph H. D. VCM Plant Rescue and Treatment of Injured 1. The plant first aid room located in the lab building will serve as the first aid treatment area of injured personnel. If the safety of this building is threatened by the emergency, a first aid station will be established in a safe area away from the disaster, preferrably at the northwest corner of the plant. 2. The lab analyst on duty will be primarily responsible to perform the rescue and first aid treatment of the injured. 3. The LCCP and/or Refinery Medical personnel may be requested to assist. Other plant personnel may also be called on to assist in transporting injured employees, etc. 4. Ambulances and other transportation arrangements for the injured may be made through the LCCP and/or Refinery Medical. The lab analyst shall be responsible to initially notify these plants. E. Emergency Phone Operation All plant phones on the Centrex system can be operated should the primary electrical power supply fail. Battery power is supplied by the Refinery automatically for 24 hours. After this time Refinery generators will supply power to continue the phone operation. i Revised 7/22/75 I>TH 000120547 15 F Chemical Plant Ambulance & Fire Truck Assistance 1. When calling for an ambulance or fire truck, please state what type equipment is needed (i.e. pumper, more oxygen supply, etc.) 2. Tell the LCCP driver of the vehicle exactly what gate you want him to use to enter the plant (north, south or main entrance.) 3. Have someone meet the LCCP driver at the respective gate (be prepared to unlock it if necessary) and direct the driver to the scene of the accident, fire, etc. NOTE: Don't expect the driver to find his way alone. He has been instructed to stop at the gate until a VCM employee instructs -~*'r him where to go. G. VCM Plant Evacuation Non-Essential Personnel 1. Personnel not part of the Disaster Team (i.e. maintenance, office and warehouse) will immediately evacuate the operating area should the toxic gas release siren be blown or instructed to do so over the gia-tronics system. 2. Wind direction at the time will determine the evacuation routes. Evacuation route should be at right angles from the direction of the wind or crosswind. Use the wind socks provided`atop the columns and storage tanks to determine the wind direction. 3. Assembly points will be the main entrance gate on the public road or the secondary waste area entrance gate on the Trousdale road extension, depending on the wind direction. CAUTION: DO NOT LEAVE THE PLANT'AREA. It is important that a headcount be taken as soon as possible. This is necessary to assure all personnel are accounted for. 4. Certain trained personnel may be requested by the Shift Supervisor or the Disaster Control Officer to assist in one or more of the functions described in para. C. 3, Daoe 13. 5. During the day shift, each maintenance supervisor will account for each of his men and make a list (written) to be passed on to the Mechanical Superintendent who, in turn, will notify the Shift Supervisor or Disaster Control Officer. G. The Shift Supervisor, Disaster Control Officer, Plant Manager & Plant Superintendent must be notified immediately of any persons that cannot be accounted for. * DTH 000120548 16 Residential Evacuation Should the need arise to warn local residential areas near the plant to evacuate, plant personnel not directly attempting to control the emergency situation should begin notifying the local residents. A "bull horn" is available in the First Aid Room for this purpose until Mutual Aid and law enforcement authorities arrive. (See Figure 6 page 21 for residential area map.) The Shift Supervisor, Disaster Control"Officer, Plant Manager and/or Plant Superintendent shall notify such personnel to assist in the residential evacuation. H. VCM Plant Emergency Personnel Protection 1. An emergency involving a fire, explosion or toxic gas release may require some of the Disaster team personnel to don the appropriate personnel pro tective equipment and clothing to handle the situation. 2. Appropriate personnel protection shall consist of, but not be limited to, the following: Table 1 Protective Equipment/ Clothing Description Toxic Gas Release Fire/Explosion a. Slicker Suit or Tyvek Coveralls b. Rubber Boots/Gloves c. Scott Air-Pak d. Type C Air Respirator & auxiliary air supply e. Acid suit & Scott Air-Pak f. Fire Boots & Bunker Coat g. Proximity Suits X X X See A below X See B below X See C below X See A below X See C below X See D below X See E below CAUTION: The above personnel protective equipment/clothing recommended may not be adequate for certain types of emergencies for which the equipment is not designed. Good judgement shall be used where other protection should be used in place of or in addition to the personnel protection recommended here. NOTE A: Should be used when exposed to toxic gases such as CO, HC1, Chlorine, Ammonia. VCM, EDC, liqht ends and tars involving environments (atmospheres) immediately dangerous to life. NOTE B: May be used when working in toxic atmospheres not exceeding 3600 ppm of VCM provided adequate supply and length of air hoses are provided. NOTE C: Should be worn where toxic or harmful gases or liquid can be absorbed through the skin causing irritation or 2nd degree chemical burns. Normally worn with Scott Air - Pak if oxygen deficient atmospheres are suspected. NOTE D: Should be used when fire fighting within 200-500 ft. of a fire and slicker suit, etc. is not adequate protection. DTH 000120549 NOTE E: Should be used when entry into an area on fire is renin row 3. Sufficient number of Scott Air Paks are provided in the control room for each Operations' employee. In addition, two air paks are located in (a) the acid suit room of the No. 2 warehouse & (b) west end of the VCM loading rack, (c) near the chlorine loading rack, (d) south end of the main office building and (e) laboratory. Four additional Scott Air Paks are located in warehouse #1. There are three spare air cylinders in the control room plus a refilling station on the east outside wall of the control room. 4. Coveralls, rubber boots and gloves and type C air respirators are already provided to operations personnel. Additional equipment can be obtained from the NO. 1 warehouse. 5. Proximity suits, bunker coats, fire boots, gloves and fire helmets are located in the portable building north of maintenance building. 6. The acid suits are located in the No. 2 warehouse, west side of the building and inside the incinerator control room. I. All Clear Notification & Requirements - VCM Plant 1. The Shift Supervisor, Disaster Control Officer, Plant Manager and/or Plant Superintendent will notify the plant employees when it is safe to return back to their.normal duties. 2. Employees will be notified to return to work when the fire is extinguished and/or toxic gas concentrations have been reduced below the TLV and/or the proper respiratory protection is worn. 3. Plant emergency reporting requirements under the OSHA standards shall be completed by the Safety Department. J. Emergency Assistance This paragraph of the plan provides the current instructions and telephone number listings to notify the necessary agencies discussed in paragraph C. 1-e, page 11 of this plan. 1. Southwest Louisiana Mutual Association Radio Instructions a. Purpose of Mutual Aid The local Mutual Aid Association is composed of the various industrial plants and municipal departments. Its function is designed to make available outside assistance in the event of an emergency. The association will provide equipment and an experienced operator only. This organization v/ill not furnish active fire fighting manpower. Revised 4/30 3 t,TH 000120550 b. Mutual Aid Radio In the event of a disaster occurring within the plant, assistance from the Mutual Aid Association may be obtained by calling the Lake Charles Fire Department which serves as the Mutual Aid communications center. A Mutual Aid radio in the main office building will be used for this. In case of power failure this radio will be out of service. In such cases, the Lake Charles Fire Department (Mutual Aid Center) should be notified by phone (436-3347 or 433-4633). The Mutual Aid radio is a fixed frequency, 10-watt transmitter and receiver for use strictly in emergency situations. The radio transmits directly to the Dispatcher of the Lake Charles Fire Department, who will act as coordinator of all emergency aid. Operation of the unit is under license through the Lake Charles Fire Department and by FCC regulations- It must not be used except for emergencies. c. Use of Radio The Lake Charles Fire Department will receive any incoming calls. In order to use the radio, depress the key switch to talk and release it to listen. The radio should be manned until the emergency is over. The following information should be provided to the Lake Charles Fire Department when requesting Mutual Aid assistance: ( 1) ( 2) ( 3) ( 4) ( 5) ( 6) Location--CONOCO VCM Plant, Zone 28 Nature of disaster (fire-gas-injuries) S whether blue or yellow alert. Type of equipment Areas to be evacuated (if needed) Whether or not road blocks should be set up Identity of person calling (only Shift Supervisor or Disaster Officer may call Mutual Aid). The Mutual Aid Association has established several disaster control signals. These are for use to make radio or telephone communication simple and easily understood. Some of the more common codes and what they mean are: 20 Escaoing gas 30 Fire 40 Explosion 50 Ambulance needed 60 General Emergency 71 Set Road Blocks Revised 6/73 19 DTH 000120551 ( c There is a system of Mutual Aid alerts designed to handle potential disaster situations. 1 A BLUE ALERT indicates a particular zone is in trouble but should be able to handle the situation using their own facilities and that no outside equipment is needed at the time. 2 A YELLOW ALERT indicates that it is anticipated that outside help will be needed shortly and that equipment is to stand by. The VCM Plant is located in Zone 28, as indicated above. Road block points are on Old Spanish Trail at Trousdale Road and at Michigan Street. A plot is included in Figure 6. NOTE: Any equipment or material going into the VCM Plant on a Mutual Aid basis comes under the command of the Disaster Officer. 2. CHLOREP - Chlorine Emergency Support PPG Industries is available to provide emergency support to the VCM Plant in case of Chlorine emergencies. This team is composed of trained personnel affiliated with the Chlorine Institute, Inc. and ( possess the necessary equipment ot stop or otherwise control the spill, leakage or spread of Chlorine from tank cars, tank trucks and vessels. They are on call 24 hours/day and will respond to Chlorine emergencies upon our request. Their telephone numbers are located on page 20. 3. Emergency Telephone Numbers See pages 31, 32 and 33 for these listings. Revised 4/80 20 000^0552 Lake C harles FIGURE 6 20A jyjH 000120553 EMERGENCY NOTIFICATION - VCM PLANT - TOXIC GAS RELEASES In 1979, the Louisiana Legislature enacted a law that affects plants and industrial facilities engaged in the manufacture, storage or use of toxic gases. The law requires that each facility must formalize a plan for reporting the release of any toxic gas inside their plant which may affect the general public. The law further requires that the plan is to be put into effect should such a release occur. The law becomes effective on December 8, 1979 and a formal plan must be submitted to both local and state officials by that date. Violation of the provision of this act can carry a fine of up to $25,000.00. What is to be Reported The law simply states that notification to "proper public safety authorities" must be made when a toxic substance is released "in sufficient concentrations to cause death or serious bodily harm to persons outside the facility." In addition, the act defines toxic substance as "those substances which are gases under ambient temperature and atmospheric pressure and are enumerated in code of Federal Regulations, Title 40." As it applies to the VCM Plant, the following materials are subject to the notification requirements of this law. 1) Hydrogen Chloride or HC1 (also includes decomposition products burning Vinyl Chloride or Ethylene Dichloride) 2) Vinyl Chloride (VCM) 3) Chlorine 4) Flammable Gas - ethylene, ethane, propylene or others in large quantities. Although not necessarily considered toxic, sizable vapor clouds of these gases could be considered a threat to the general public. 5) Sulphur Dioxide 6) Ammonia DTH 000120554 ( f ( i Plant Notification Plan The required notification under this law will be based, in part, on the plant's existing Emergency and Disaster Plan. Actual notification will utilize a special telephone network which functions as a "hot line" type communication system to several locations at once. A single call over this system will serve to alert numerous pre-selected locations of the emergency. The "hot line" notification telephone is located in the LCCP Main Guard House. The guard on duty will be the person designated to notify the "out of plant" locations by using this phone. In all cases, it is the responsibility of the Shift Supervisor to specifically instruct the guard to notify "out of plant" locations. Under no circumstances is the guard to initiate a toxic gas release report over the system without specific instructions to do so. In addition to the Shift Supervisor, the following plant personnel are also authorized to instruct the guard to notify "out of plant" locations of a toxic gas release. 1) Plant Manager 2) Plant Superintendent 3) Safety Director 4) Process Superintendent Information to be Reported It is the responsibility of the Shift Supervisor, or other authorized personnel, to furnish specific information regarding the release to the guard on duty. The information necessary must include the following: 1) Type of gas or gases if mixed 2) Direction of travel (downwind direction) 3) Judgement of severity 4) Expected duration of emergency situation 5) Suggested action on part of general public Although not specifically required by the law, the following is also to be furnished to the guard: 6) Report that the emergency situation is passed. The guard may be contacted by the emergency phone (5777), regular phone (5450), or the mutual aid radio in the front office. y Item five above is advisory in nature and should be kept as brief as possible. Im most cases the suggested action will probably involve evacuation of the downwind area. Item three also requires a judgement on the part of those who initiate an alert. This can best be accomplished by classifying the threat to the general public as either low or high. Telephone Notification System CONOCO Chemicals is participating with 01 in Corporation and PPG Industries in an area wide alerting system. Each of the three can use the system to notify interested governmental agencies and industrial facilities of an emergency situation in their plant. We will receive warnings from PPG and 01 in over the same phone. At the present time,.the alerting telephone system is connected to the following: Louisiana State Police (Troop D) Calcasieu Parish Sheriff City of Westlake ( City of Sulphur 'r CONOCO Refinery CONOCO VCM (receive only) Certain-Teed Jupiter Chemicals Liquid Air 01 in Corp. (send and receive) PPG Industries (send and receive) CONOCO Chemicals(LCCP) (send and receive) Except for the three member companies, those connected to the system can receive only. Testing of the system will be done on a routine basis by the three sponsoring companies. 4/30 23 DTH 000120556 ( : ~i In-Plant Action In addition to warning the general public and adjacent industry when we have a release, the plant must also be alerted to a release either inside or outside the plant. This is accomplished by sounding the toxic gas siren or fire horn. (Detailed information can be given, if necessary, on the Gai-Tronics--plant communication system). The in-plant system for accomplish ing this is in effect and is detailed in the Emergency and Disaster Manual. Since we are required to notify agencies and facilities outside the plant only when a release travels outside of plant property, there will be situations where only in-plant personnel need to be alerted. LCCP Guard Action The guard on duty at the LCCP Main Gate will be responsible for actual use of the "hot line" alerting phone to notify outside facilities and agencies. He will report the information given to him by the Shift Supervisor in the order listed on the form provided. Under no circumstances is the guard to add information or speculate on the seriousness of the release. No information beyond that provided to him by the Shift Supervisor is to be given out. After recording the release information on the form, the LCCP guard is to call the LCCP Laboratory Shift Supervisor and inform him of the emergency. The LCCP gua is then to make the call on the "hot line" to outside locations. The message of the alert is to be given over the telephone at least three (3) times to assure that each location has been answered. The guard is to record those locations who received the alert. (Remember, if we call the LCCP Main Gate Guard for a toxic release that will get out of the CONOCO Chemicals Complex boundaries, the "hot line" in our control room will also ring.) Immediately after completing the call to the LCCP Guard, who will complete the notification over the "hot line" the personnel on the "Emergency Call-Out List - Group I" are to be notified. 000120557 DTH 24 / The CONOCO VCM plant will participate with the Chemical Plant (LCCP) in the outside notification system. The Shift Supervisor or other authorized personnel in the VCM plant will notify the LCCP guard of reportable releases that occur in our plant. The person making the call will inform the guard on duty if the emergency will effect the Chemical (LCCP) Plant alone or if it will effect locations outside the CONOCO Chemicals Complex. If outside areas are involved, the information will be filled in on the form and the "hot line" used to alert surrounding areas. If the LCCP has a toxic gas release that only involves their plant as well as the VCM Plant, the LCCP Lab Supervisor will notify the VCM plant by calling the main control room. When the LCCP Guard is informed by the Shift Supervisor that the emergency release is under control, a second call over the "hot line" phone is to be made. This will be to inform the locations that the threat of toxic gas no longer exists. During an emergency release situation, no one is authorized to give out information to anyone over the normal phone system. Calls from individuals or the news media should be responded to by saying the "specific emergency information has already been transmitted to public safety authorities and that additional information will be made available to them should the situation change." . (. ; Follow-Up Following any emergency, it is important that a complete follow-up review is conducted. It can be anticipated that further questions from the news media will be received and that statements to them will have to be made. In these cases, it is important that the basic facts and other details of an emergency be accurate and that they be made available as soon as possible. Also it must be recognized that following any releases that have threatened the general public, numerous public inquiries for information will be recieved. In all cases, these will be handled by the Plant Manager or his alternate. Assistance in dealing with these inquiries from "experts" in medical treatment, pollution, legal, and public relations will be requested through the Manager or his alternate. > I /'CcDu 000120558 DTH CONOCO CHEMICALS/OLIN/PPG EMERGENCY TELEPHONE ALERT SYSTEM PROCEDURE ) CONOCO Chemicals (LCCP), 01 in and PPG will test the system as per Test Log (Attached). ) CONOCO Chemicals, 01 in and PPG will alert appropriate participants in the system when a vapor release occurs in the respective plants which is expected to go beyond that plant's perimeter and could adversely affect persons in the community. The following information will be given to participants by CONOCO Chemicals (LCCP), 01 in or PPG's Main Gate Security Guard: Location of vapor release (CONOCO Chemicals, 01 in or PPG) Type of gas or gases released Direction of travel of gas Severity and expected duration of gas emission Other information as is available All Clear message when emergency is over ) System Participants Should: Record emergency information in Log. -A Activate appropriate emergency plans. ) Below is a suggested sample log which could be used by system "receivers" of emergency messages from CONOCO Chemicals, 01 in and PPG. VAPOR RELEASE INFORMATION LOG Location of Vapor ReleaseTimeDate Type of Gas or Gases Released _ Wind Direction of Travel of Gas Release Wind Speed Severity and Expected Duration of Gas Emission Other Information (as is available) All Clear Message when Emergency is Over - TIME ALL CLEAR NOTICE GIVEN BY SECURITY GUARD a /on NAME AND LOCATION DTH 000120559 NOTE: "RECEIVER" - The above information will be given slowly by the message "initiators" Security Guard and repeated three tines only. "Receivers" telephone receivers should be oic'<ed uo inredi ate! v and the message locoed. DO NOT STCP.THE INI TI-``.TIR. -S-: INTERFERE WITH ; z. UJ t to >00 Vcc UJ __ 1 <c UJ z 0 rc CS CL. O UJ --J --J UJ 1-- 1-- to u >(r UJ SZ CD UJ cc St uj o- zz m LU ZD o-o UJ Cl. cu >- -X _J zc C CD O 00 --X < 0 >-- jr* UJ cc 0 0 t-J 0 0 t_J f . OOf ZT , 0; K- Oj cn! to ^ >1 0 c <D 4J cn 0 c u 4-> 03 CD r-- E c. UJ CJ JZ CJ 0 4-> JZ sz 4-J 4-> QJ to >, 0 > <-- "3 +J 03 O to C QJ -O 4-J c c (O r 3 O 4- to O r- r- O -- ai tn 1-- to J2 ---- 3 -C cnci 1-- Own r-- u -O C CJ " c OD L ro E a >> c ro a. E 0 (J -0 0 3 3 U C to 0c U CD 03 OJ JZ S_ 4-> O c 0 C CD 4ro C c0 ro CD -= E Cl CD -- rO QJ U r-- Ci-- QJ rO O QJ > c u >,-*- -r- C CD to #-- <0 >> O pw C--a CD x: ro E t- 0 O r-- 5s CD 0^-5- rtj D C 03 *r- n d a) >, CJ 41 J- u) XT J3 -C 3 WD 1-- 4J 4-> CD -- (0 1-- TD Dl-r- ^ to r- C "0 3 0 ro -- ad QJ CJ 0 0 3 <-- T3 JZ C c ai 3 s- u 3 19*0 u 0 to s_ -- C 3 O > <0 3 ^ C14U "U <0 3 4-> u C 3 cn (O CD >, fl3 to 4-> XT C >) D'r O -*-> ro >1 G JZ +-> CD *3 "O -a -u> CE TJ *- cd <0 -a cj 0 01 L- "2 1- u. CaD. CJ JZ 4^ 0 3 r c a ui QJ jz -0 0 0 l. 03 * C f-- c to 0 "O O a; 3 r- (U 03 * XI DC >. 5s O *-- -0 <V CO to 003 ,-- QJ 1-- 0 *0 4-> *-- -- CD C 01 r/i c\J CD i" 5 0 0 >)-- in 3 C z 3 Ol C j-- .C 1-- 4-> 4-> 03 u ^ -- <D U CJ S0 4U O QJ U r 0 5s 4-J QJ ro to CD JZ 4-J 0 4-J c 0 "O T-- QJ 4-J 4-> U (O c QJ 3 a. 4QJ r-- S- 03 E QJ X3 QJ 4U 4-J 0 tl C 5S 01 03 U 0*0 = <D fO D 0 CJ OJ tl ,-- r 5cs CD ^ V - rtj <0 e O u to CJ u O s 4-> O >, s- C u> b; 4U 4U O 0- m 0c QJ u VI 4- to u u !-- Qj 0 >, tO -- CJ 4-> C w UJ u to c. Ol >> 03 01 u CL U oj <0 - n -- _c c 4U >> Cj to u 4-> -- CJ " C. L u u </) 4- s x> < **-- 33 D 4- 5s! 4-1OJ ol CJ 4-> O C <-- 4-> O *-- CD 3 Su > *c*-o0o 0 LZJ O 4U O *-> C -- 0 0 +J 0 c_ O UJ 0 rr O(J -- 3 U> to hC*J 0U J= 0 CJ CL 00^ r0-- 07-^ C *^-> HCJ 0<*-0 0u to >> QJ u w D d Cj -Z V. CJ j ro| Cj l e| 1| --'--' - ' ' '" ` -* UJ *-- u 00 0 0 LU 0 iH2Z = 0 CD O LU CJ3 1-- a. Q- a s: LU 1-- -j <=c 0Q 0 u> LU 0 c 0Q 0 LU CJ3 1-- a. <c a. a Z. LU 1--1 -J <c c CD UJ 1--4 -a: 0 CD 0 UJ mi 0 J-- Z 00 t_) LU C3 j-- CL =c Cl Q z UJ HH 1-- u <= 0O 0 t-J 0 LU 1-- 0 <c O0 LU CD J-- a. a. O z LU --* H- C 0a . zr CD to H-- < to (--4 CC. u. cc ZD zz 1-- 0 LU * LU Z3 t-- * z 0 2: z CD to t-- < to 1--4 o: La- CC ZD DC 1-- a LU LU ZD t-- ZD 0 i CD! r^l 0 LO l p-- 1-- zr <5 __ i CL UJ z> 1 pLJ, O, LU o2: CL. o ClOD O 00 <M to O 0ZD0 oo CO >- CO Q oz U- o LU oLU U) UocJ <toc LHLUU- co _J oCsoL. 00 1/1 o X I<oc--_c> LU cc Q Q Cc/1 oUQJ UJ o O2: o<c LU C/1 t/1 sa z LU tn LU I L. Emergency Public Relations During or after a disaster or serious accident, we must keep in mind that the Company has an obligation to provide prompt and factual in formation to the public through the news media. This section of the Disaster Plan is directed toward fulfilling this obligation effectively while protecting the Company's public image at the same time. Press releases will normally be provided through Public Relations office for the Lake Charles area. The Plant Manager, or in his absence the Plant Superintendent will notify the Public Relations office as soon as practical following the emergency to provide them with the necessary information. The Public Relations representative can be contacted by phone, shown on page 27. Where the Public Relations office representative cannot be contacted the Plant Manager, or in his absence the Plant Superintendent is the only individual authorized to speak for the Company during or after an emergency situation. Under no circumstances should any other unauthorized employee provide information to the news media, unless directed to do so by the Plant Manager and then only if the informa tion is a written statement issued by the Plant Manager, or in his absence the Plant Superintendent. In case of a fatality or serious injury, under no circumstances are names to be released to news media before next of kin have been properly notified. In the case of serious injury or fatality, the nearest kin will be notified in person. The following guidelines should be used in providing information to the Conoco Public Relations representative or news releases during emergencies. (1) Report all available facts concerning the situation. (2) Do not give out unconfirmed information. (3) Make arrangements for photographs if safety and security is assured Remember that newsmen on Company property are our responsibility and must be protected at all times. (4) News media will usually want certain information. Some of this can be developed prior to an emergency such as general information about the plant. In addition, they will want to know: 23 o00i What happened? (Cause, if known, time, units involved) Injuries? (Nature and extent, names, ages, addresses, job titles, disposition of injured. REMEMBER before injury lists are given out, next of kin must have been notified and extent of injuries should not be guessed at.) Damage? (Amount of equipment or property involved, estimate of damage; i.e., light, moderate, extensive) Do not speculate on dollar amount of loss. Remedy? (What are we doing to correct the situation, outside companies helping through Mutual Aid). A fact sheet is included as a part of this plan, (Appendix B) giving pertinent details regarding the CONOCO Chemicals Co. VCM Plant, such as; Capacity Number of employees Type and size of unit Products made and uses Raw materials Storage capacity 00012662 dth EMERGENCY TELEPHONE NUMBERS Medical, Ambulance & Fire *L.C. Chemical Plant *l.C. Chemical Plant Guardhouse CONOCO Refinery Day or Night 5777 or 491-5345 5450 or 491-5450 5333 Emergency Assistance Mutual Aid 433-4633 or 436-3347 Radio or 433-4633 or 436-3347 Chlorine Emergency CHLOREP Team-PPG Direct Line or 491-4500 **Direct Line or 491-4500 Emergency Notification, Toxic Gas Release & Personnel Evacuation L.C. Chemical Plant Guardhouse 5777 or 491-5450 Mutual Aid Radio or 433-4633 or 436-3347 Services available will be supplied under the general agreement stated in Appendix C of this plan. Direct line from control room only NOTE: Dial the extension number only for phone numbers within the Lake Charles Centrex system. Call made from outside the Centrex system dial 491 then the extension. Revised 4/80 30 ADDITIONAL EMERGENCY TELEPHONE NUMBERS r Medical Gordon Monroe, R.N., L.C. Chemical Plant Margie Black, R.N., CONOCO Refinery Dr. F. W. Bennerscheidt (Call No. 123) Dr. E. W. Nagem (Call No. 72) Doctor's Answering Service Eye Dr. W. Mixon The Eye Clinic, Drs. Blocker. Archer & Emerson Orthepedic Dr. E. Campbell Dr. E. W. Phillips Dr. N. P. Morin Ear, Nose and Throat Dr. C. R. Karam Dr. W. K. Cutrer Dermatoloqist Dr. M. Kent Dr. J. Stubblefield Hospitals St. Patricks Lake Charles Memorial West Calcasieu-Cameron Dept, of Labor U.S. Department of Labor Occupational Safety & Health Admin. 2156 'v'ooddale Blvd. Hoover Annex, Suite 200 Baton Rouge, LA 70806 OR 31 Office/Day 5497/5498 5362/5364 439-0808 478-2784 Page Boy 61-483 Home/Niqht 855-4258 625-3038 477-0237 477-2801 439-3333 625-3130 478-3810 433-5344 439-3333 433-3647 433-3647 433-0311 436-5152 477-7437 436-0556 478-3520 478-2888 478-7456 478-5250 477-5585 477-1526 478t8583 436-1369 436-2511 478-1310 527-7035 436-2511 478-1310 527-7035 Dept, of Labor, Region VI Occupational Safety & Health Admin. 555 Griffin Square - Room 602 Dallas, Texas 75202 (214) 749-2477, 78, 79 000120564 dth ADDITIONAL EMERGENCY TELEPHONE NUMBERS i Raw Materials Day Page Boy Night PPG Industries Chlorine Control LCCP (Ethylene Control Room) Other Agencies LCCP Shift Supervisor RFY. Shift Supervisor L.C. Fire Department Gulf States Utilities Law Enforcement **Direct Line **Direct Line **Direct Line **Direct Line 491-5357/5421 or 5357/5421 5307 or 491-5307 433-4633/436-3347 61-459 61-431 436-4351 'Same I Same Radio or 433-4633 433-4645 LCCP Guard Gate CONOCO Refinery Security Calcasieu Parish Sheriff Dept. Louisiana State Police FBI Coast Guard News Media 5450 or 491-5450 Same 5333 or 491-5333 Same 433-7372 433-7372 436-2505 436-2505 433-6353 433-6353 433-3765 (713) 971-2261 Capt. of Port) Newspapers: Lake Charles American Press Beaumont Enterprise Westlaker 439-2781 436-3681 435-0583 Radio Stations KAOK KLOU KIKS KLCL KNSW-FM Television Station 436-7541 436-7277 527-5202 433-1641 527-5202 KPLC KAOK 439-9071 436-7541 ** Direct line from the control room only ' Revised 6/73 32 000120565 DTH EMERGENCY CALLOUT LIST i Group I (Disaster Organization Members) Name Position Mike Ashby J. W. Ware J. A. DeBernardi Process Supt. Plant Supt. Plant Manager J. R. Holcomb R. Bryan J. H. Brunson P. L. Fetzer Mechanical Supt. Chief Process Engineer Office Manager Chief Chemist Group II (Plant Supervisory Personnel) Off i ce 5036 5065 5063 5040 5062 5061 5067 Page Boy 61-496 61-490 61-499 Home 625-4832 855-9208 625-8202 855-7952 855-6400 436-5384 477-3957 To be called out at instruction of Shift Supervisor on duty and/or the Disaster Control Organization. C. H. Kroske Clarence Landon Chariie Buller Ken Cash H. 0. Adkison C. R. Heddins Shift Supervisor (A) Shift Supervisor (B) Shi ft Supervisor (C) Shift Supervisor (D) Mech. Maint. Supvr. Inst. Maint. Supvr. ciroup III (Corporate Management Personnel) 5071 5071 5071 5071 5048 5044 61-494 61-498 436-8237 435-4783 436-2531 433-2524 625-4935 527-8551 To be notified by either Management Group Memeber. R. T. Ferrell R. D. Gamblin R. E. Lemkuhl J. D. Burns R. W. Gerwig C. H. Klunick C. Whetstone J. A. Begley E. L. Lively Mike Reynolds Manager, L. C. Operations 5341 Manager of Manufacturing (713)531-3460 Vice Pre., Operations (713)531-3580 Executive Vice President (713)531-3590 President, Conoco Chemicals (203)329-3731 Corp. Safety Director (713)965-5336 Medical Director 75-412-2235 Insurance 75-412-9818 Public Relations 5270 Communications 75-2806 (713)780-1270 (713)664-2552 (405)762-5824 (405)762-1140 478-1682 (713)781-3254 Insurance Representative (Local) Hartford Insurance Travelers Insurance Oil Insurance ''ssociation Lake Charles, La. Lafayette, La. Dallas, Tx. (318)478-6600 (318)232-8910 (214)526-7219 DTH 000120566 VIII. Bomb Threat Procedure In a bomb threat the caller is usually attempting to shake up the plant personnel. Seldom is the caller serious. However, should the plant get a call of this nature, attempt the following: 1) Try to involve the caller in a prolonged conversation during which time you attempt to: a) Activate the call-out plan r b) Conduct a security check of the plant c) Notify the telephone company (so they can trace the call) and the sheriff's department for assistance. d) Attempt to establish the location of the caller by background sounds, music, road noise, etc. e) Use the following checklist as needed: Telephone bomb threat checklist Instructions: Listen. Do not interrupt the caller except to ask: When will it go off? Certain HourTime Remaining Where is it planted? Building----------------------------------Area-------------------------------------What does it look like? . What floor is it on? Did Caller appear familiar with plant or building by his description of the bomb location? Name ~ Time of Call Action To Take Immediately After Call Date 1. Notify your supervisor. Talk to no one other than instructed by your supervisor. 2. Write the message in it's entirety as received from the informant: Caller: SEX: __Male _Female APPROX. AGE: Years_ Origin of Call: --Local --Long Distance Booth Internal (from within bldg.?) VOICE CHARACTERISTICS __ Loud __ High Pitch --Raspy __ Intoxicated __ Soft ___Deep Pieasant (other) SPEECH ___Fast __ Distinct __ Stutter Slurred Slow .--Distorted Nasal (other) ACCENT --Local __ Not Local --Foreign --Regional --Race --Other Explain ! * ! _ i MANNER Calm Rational ..Coherent .Deliberate Righteous __Angry Irrational --Incoherent --Emotional Laughing LANGUAGE __Excellent __ Good --Fair __ Poor Foul (other) --Use of certain words or phrases BACKGROUND NOISES --Office Machines __ Traffic --Factory Machines __ Trains __ Bedlam ___Voices .--Animals ___Music __ Quiet __ Party --Airplanes ___Atmosphere DTH 000120567 VIII. HURRICANE PROCEDURE * A. PURPOSE--This procedure provides a guide for the orderly preparation for and recovery from a hurricane. B. DEFINITIONS 1. Hurricane Season--The hurricane season is generally recognized to be between June 1 and November 30. 2. Hurricane Arrival--Time when winds reach 73 M.P.H. C. PREPARATION 1. Pre-Hurricane Season a. Operations--The Process Superintendent is to maintain the operations area in the best practical state to withstand a hurricane. Specifically, all building doors, windows where applicable, and ventilation openings should be kept in proper order. Assistance is to be requested from the Mechanical Superintendent ^ as needed. i b. Maintenance and Outside Areas--The Mechanical Superintendent will see that proper preparations are made in the shop, warehouses, office buildings, and outside areas. All scrap material should be secured where practical. Location of all loose equipment and supplies, such as small buildings, barrels, trash containers, etc. are to be noted. c. Major Construction Area--If construction is in progress, the Project Manager and Project Engineer will be responsible for coordination of contractor preparation. It is to be emphasized to the contractor that protection of existing plants is of prime importance. 2. Hurricane Threat a. General--When a hurricane actually threatens the Lake Charles area, the Process Superintendent and Mechanical Superintendent will survey their area of responsibility and determine necessary action. b. Sequence or Timing and Action Phase I Time--First notification of hurricane or storm for Lake Charles Area. V DTH 000120568 Action-1. Process Superintendent to have operators secure loose materials in the operating area. 2. A check of all safety lighting, emergency, and fire fighting equipment will be made to insure proper operation. 3. The Mechanical Superintendent will survey his area and have loose material moved or secured as needed. 4. The Process Superintendent and Mechanical Superintendent will review the hurricane prodedure with their personnel. 3. Hurricane Hit Probable a. Planned and orderly action will be taken to place the plant in a safe and secure condition. b. Sequence and Timing of Action Phase II Time--24 Hours before hurricane arrival. Action-1. Complete securing operations on all loose equipment buildings, etc. 2. All tank cars to be coupled together and brakes applied. 3. Establish and maintain most stable plant operating conditions. 4. Establish liquid level in any vessels subject to floating off their foundations (add water, if necessary). Phase III (NOTE: To be determined by the Plant Manager) Time--12-16 Hours before hurricane arrival. Action-1. Office Manager to arrange for food supplies and water for standby personnel. 2. Operations to begin an orderly shutdown. DTH 000120569 Phase IV Time--4 hours before hurricane arrival. Action- 1. All but designated personnel to leave the plant. D. COORDINATION AND COMMUNICATIONS 1. Coordination--The following representatives participate in the coordina tion of the preparation, shutdown, cleanup and startup: Plant Manager Plant Superintendent Safety Director Office Manager Mechanical Superintendent Process Superintendent Chief Process Engineer Project Engineer (Major construction projects) The decisions and timing of the various phases will be based on: a. The plans of outside sources of raw materials and utilities where they affect our operations. b. Analysis of the information accumulated by the weather collection on matters not affected by outside supplies. It will be the responsibility of the Process Superintendent to act as liaison for shutdown and startup. It is important that close communication be maintained, both internally and externally, to insure orderly shutdown and startup of all plants involved. 2. Weather Communications--In order to keep the coordination representatives informed of the hurricane danger, a weather collection center will be established. The Office Manager will assign someone from his department the responsibility of compiling and distributing weather forecasts and hurricane tracking charts. 3. Standby Crew--Should the plant be shut down and secured, a standby crew will be maintained in the plant during the actual hurricane. The crew will consist of the following: Process Superintendent Mechanical Superintendent Shi ft Supervisor (1) Operator (1) Maintenance Supervisor (1) DTH 000120570 77 4. Public Statements--Any public statements concerning decisions affecting the plant or employees will be issued by the Plant Manager. E. PLANT STARTUP 1. Damage Survey--As soon as the storm subsides, an evaluation of the damage will be made. Action will be taken to put the plant back on stream. 2. Personnel Reporting a. After the storm has passed, all employees are expected to report back to the plant according to their regular schedule, unless specifically notifed. b. The Office Manager will assist in setting up communication facilities to contact off-shift employees. c. If possible, the Plant Manager will issue a statement to the local broadcastinq stations concerning the resumption of operations. (This may not be possible due to damage to telephone and power systems). 3. Coordination Coordination of the startup and shutdown will be handled by the same personnel. F. GENERAL INFORMATION AND PRECAUTIONS 1. General a. The time at which precautions are taken will generally be left up to the supervisor of the area. The supervisor should take care to allow sufficient time to complete the precautions. The speed and course of the hurricane could change so as to allow less time than anticipated. b. Safety and fire protection equipment will be kept in operation throughout the hurricane. c. The fire water loop fed from our cooling tower is tied in with the Ethylene Plant loop. The fire water pump on our loop is electric driven and that at the Ethylene Plant is steam turbine driven. A diesel driven water pump in the LCCP waste treatment oond can also be used in case of both power and steam failure. e. Other Continental Plants will be shut down also and will have standby personnel available. Fire brigade procedures will not be affected. f. The Continental "in-plant" telephone system is backed uo by battery and generator, so should be continuously available. DTH 000120571 1 -t* 2. Operating Area a. Secure all loose material. b. Secure all loose barrels. c. Secure all valve chains. d. Establish levels in storage tanks. e. Isolate equipment. f. Couple and lock brakes on tank cars. 3. Offices a. Secure all doors and windows. b. Place all valuable records above floor level if flooding is expected. 4. Laboratory a. Remove all bottles and reagents from precarious positions and place in a secure location. b. Move all testing equipment from doors and secure doors. c. Lay down and secure all bottles outside building. d. Shut off all utilities possible at block valves and main breakers. e. Remove all glassware possible to storage area. f. Do away with all VCM samples in the laboratory. 5. Maintenance Shop a. Secure all light weight loose spare equipment, vessels, pipe construction materials. b. Relocate any material which can be damaged by water. c. All welding machines, water blasters, vacuum cleaners, scaffolding, ladders, tarpaulins, and other portable maintenance equipment should be stored inside a building. d. See that all tools and spare part cabinets, bins, and shelves inside the building are adequately anchored or secured by lashing to the building. e. Close off all possible utilities at main block valves and breakers. f. Close all doors and secure. 6. Other a. Trucks and vehicles should be parked at the gate so there is less likelihood of them being blocked in case total evacuation becomes necessary. b. There is a direct line between our control room and the chlorine control room at PPG. This should be used for coordination with PPG. DTH 000120572 IX. DISASTER READINESS It is essential that a plan of this type be continually evaluated to assure that it is kept up-to-date as conditions and circumstances change. After the preparation of a disaster plan and the setting up of the organizaton are complet a training program must be instituted to include every employee, at least to the degree necessary to insure that they will function as planned under emergency situations. In addition, protective equipment and the tools with which to control an emergency situation must be maintained continuously. It is the responsibility of the Safety Director to continually appraise the effectiveness of this disaster plan and, with approval, make changes necessary for increased reliability. Semiannually members of the Disaster Organization will meet periodically to review the plan and make changes as necessary. The Safety Director will assume the responsibility of seeing that these meetings are held and that the recommended changes are incorporated into the plan as soon as possible. The Safety Director will be responsible for the following areas of preparedness: A. Work with each department head in training and educating personnel in the functions of the plan and in employee acceptance. B. Organize and regularly train an emergency fire brigade in fire control methods and in emergency action. C. See that all plant employees are exposed to basic fire fighting techniques pertaining to the use of extinguishers, emergency alarm systems and evacuation procedures. D. Assure that sufficient fire fighting equipment and emergency devices are provided and that this equipment is maintained in operable condition at all times. E. Maintain the Company's active participation in the area Mutual Aid Association. F. Following a disaster, work with department heads in restoring safe conditions throughout the plant. He is also to see that emergency equipment is restored and make a detailed study, working with the Disaster Organization, of the causes, action taken, and any recommenda tions arising out of the emergency. 40 DTH 000120573 APPENDIX A CONOCO CHE?-'I CALS CO. Fire Incident Reporn This form is to be used co report all unplanned fires which occur within the VCM Plant. Report must be completed within 48 hours. Date and Time of Fire____________________________ Shift Foreman on Duty____________________________ Description of situation at time of fire_ ata.m. p.m. Equipment Involved How fire was controlled Damage resulting from fire Cause of fire Have all extinguishers and other fire fighting equipment been put back in service? Yes No DATE OF REPORT Person making report Revised 4/30 41 DTH 000120574 APPENDIX B CONOCO CHEMICALS CO., division of CONOCO INC, VCM PLANT The CONOCO, Inc VCM (Vinyl Chloride Monomer) Plant was constructed by The Ralph M. Parsons Company in 1967 at a cost of approximately $20 million. The plant was designed by Stauffer Chemical Company, the process licensor. At the time of startup in 1968, the plant was the largest single-train vinyl chloride plant in the world; with an annual capacity of 600 million pounds per year. The primary product of the plant is vinyl chloride monomer which is the basic raw material in the production of vinyl plastics (polyvinyl chloride). Shipments from the plant are by rail car and ships. An intermediate product, EDC (1,2 dichloroethane), is also sold and is shipped by rail, truck and ship. EDC is used as a solvent, as an additive in antiknock products, and as an intermediate in the production of vinyl chloride. The basic raw materials used in the plant are ethylene and chlorine. These are supplied by the adjacent CONOCO Inc. Ethylene Plant and the local PPG Industries Plant respectively. Electricity is supplied by Gulf States Utilities. Steam comes from adjoining CONOCO, Inc. facilities. The VCM Plant is a part of CONOCO Chenvicals Co. a division of CONOCO, Inc. with headquarters in Houston, Texas. The unit employs 8 operating personnel plus one or more laboratory technicians per shift. Additionally, 70 persons are employed in maintenance, clerical, engineering, warehouse and supervisory positions. DTH 000120575 APPENDIX C TO: DATE: SUBJECT: J. A. DeBemardi June 8, 1976 VGA PLANT EMERGENCIES The following are guidelines for handling VCJ.' Plant emergencies which require calling in help from either the Lake Charles Chemical Plant or the Refinery. 1. In the event that emergency equipment is needed, dial 5777 to get the Chemical Plant fire trucks and/or ambulance. Give the nature of the emergency, equipment desired, location of gate that the equipment should report to, and the caller's name. VGA Plant personnel will meet the driver of the equipment requested to direct him inside the plant. 2. The Lake Charles Chemical Plant has the following vehicles: a. A 2,000-lb. dry chemical truck which will be manned by one lab analyst. b. A 1,000 gpm pumper truck with hose and nozzles manned by a second lab analyst. c. An industrial ambulance manned by 2 men. Under certain situations, VGA personnel may have to assist to make up the two man team. 3. If additional equipment is still needed, the Refinery Fire Department can be called out by dialing 5333 and repeating the information as given to the Chemical Plant Fire Department. 4. The VGA Plant will have to provide manpower to operate hose lines since only one man/vehicle will be sent. Revised: 6/73 Plant 000120576 DTH . SECTION IV MANIFEST SYSTEM DTH 000120577 (conoco) Interoffice Communication to Distribution From J. A. DeBernardi ojio November 17, 1980 subiect Manifest System - Hazardous Waste Disposal As you are aware, the Federal and State Governments have put laws into effect regulating the disposal of waste materials defined as hazardous under these laws. In order to comply with the laws, the VCM Plant established a mani festing system late in 1979. Revisions and additions to the laws since that time now require an update of our system. This letter refers to heavy-ends (tars) disposal paperwork specifically. Our objective in updating our disposal paperwork system is to reduce the paperwork in the system to one form which satisfies Federal and State disposal laws as well as Department of Transportation (DOT) laws. The attached speci men copy of the waste manifest for heavy-ends leaving our plant for delivery to PPG accomplishes this task. The following information outlines how the manifest for heavy-ends shipments to PPG is to be used. Other shipments to hazardous wastes will be handled in a similar manner. General Information 1. Pre-typed manifests will be available for heavy-ends shipments in the Chief Operator's office located in the EDC/VCM area control room. 2. Each manifest is pre-numbered and all must be accounted for. If for some reason an error is made in filling out the manifest, it should be voided and sent to the Office Manager. 3. All required signatures and dates must be filled in on the mani fest. Complete signature is required--not initials. 4. The manifest must be kept with the load while it is in transit to satisy DOT regulations related to bills-of-1ading. Filling Out Manifest 3. Generator Information Section The VCM Plant is responsible for filling out this section of the manifest. The Shift Supervisor, or in his absence, the Chief Operator will sign and date the manifest in this section. 000120578 DTH Page 2 November 17, 1980 4. Transporter Information Section It is the responsibility of the Surface Transportation Department driver to complete this section. The driver should sign and date this section in the areas provided. Date and pick-up time must also be filled in by the driver. . The Transportation Department dri-ver will also certify the trailer being proper for the movement of heavy-ends to PPG by signing the form in the bottom section on the "Transporter Signature" line. This certification must be signed before the truck leaves the VCM Plant. 5. Disposer Information Section It is the responsibility of the person at PPG receiving the heavy-ends shipment at their plant to complete this section. PPG will sign and date this section. Also, the Transportation driver will note date and time of delivery at PPG in Section 4 when he arrives at PPG.- Paperwork Distribution 1. After signatures, dates, and pick-up information are completed in the Generator and Transporter Sections, and the certification on the bottom section of the form are signed off, the "Goldenrod" copy should be removed from the packet. The "Goldenrod" copy should be sent to the Office Manager using the plant mail system. The remaining copies in the packet should be given to the Trans portation driver to be kept with the load on its trip to PPG. 2. On arrival at PPG the driver will obtain the disposer signature and date for the Disposer Section of the manifest. The driver will also fill in the delivery date and time in the Transporter Section on arrival at PPG. DTH 000120579 1. MANIFEST NUMBER 00 3 3 STATE OF LOUISIANA DEPARTMENT OF NATURAL RESOURCES HAZARDOUS WASTE MANAGEMENT For Dept. Use Index H Dnrp 2. WASTE INFORMATION: HM RO SHIPPING DESCRIPTION HAZARD CLASS Combustible Liauid. NOS Combustible Ethvlene Dichloride Liauid WASTE NUMBER State No. 514-30 WEIGHT (TONS) 23 PACKAGING QTY TYPE 1 T/T (Placarded. .Combustible). (Havv Ends EDC/VCM)___ ; GENERATOR EPA I.D. Number 3. GENERATOR INFORMATION: Idenrriication Number: GD-514 Teleohone: 31 8/491 - 5437 name of company- Conoco Chemical s' Company. Division of Conoco Inc.________ address: P. Q. Box 605. Westlake. LA_____ shipping i nr.AiinN- VCM Plant, VCM Plant Road , Westlake. LA 7IP- 70669 CERTIFICATION: This is to certify that the above-named materials are properly classified, described, packaged, marked and labeled, and are in proper condition for transportation according to the applicable regulations of the Department of Trans portation, and the Louisiana Department of Natural Resources, and the EPA. 0*t 4. TRANSPORTATION INFORMATION: Identification Number:________________ Telephone: 318/491 -5265 NAME OF COMPANY- ConOCO TflC . DATE OF PICK UP: Surrace i ransporta non Department date of delivery- _ ________________ TIME:________ ________________ TIME:________ CERTIFICATION: This is to certify that the above-named materials were picked up at the date and time above, that the above named materials were delivered without incident to the disposer at the date and time above, and that to the best of the transporter's knowledge, his portion of the manifest is accurately and correctly filled out. DiirUbc.R cPA i.U. iiumcer LAL) uuSuabSub 5. DISPOSER INFORMATION: Identification Number: name of company- PPG Industries, Inc. GD-50S Telephone: 318/491 -4500 Chemicals Division location where shipment RFCFivFD- Columhia Southern Road. Westlake, LA CERTIFICATION: This is to certify acceptance of the hazardous waste, that the waste has been or will be disposed of in accordance with Department of Natural Resources relations, and that to the best of the disposer's knowledge, his portion is accurately and correctly filled out. C'toot** 6. EMERGENCY INFORMATION: immediate R-cnons information Contains combustible hvdrccarbons. Contain spills. Keep out of sewers, drains, ditches, and waterways Telephone- 318/491-5070 Special Handling instructions- Keep ignition sources away from spill, Control fire with, water fon. drv chemical, or foam._______________________________________________ Comments: Wash areas of skin contact thoroughly. Contaminated clothing must be _j washed before reuse. Report an emergency situation to the above 24-hr.number immeaite Carrier hereby certifies that the cargo tank used for this shipment is a proper con- tainer for the commodity loaded therein, and complies with Department of Transportation specificaticns. Transporter Signature: If for any reason the disposer does not accept shipment, the transporter must return tne shipment to the point of origin. DTH 000120580 DtSTn:3uT:0\ Whit? C f "l ,r* tor. G hfon Tr j n Pin* S t j t*. Go>d?nroct Distribution Page 3 / V November 17, 1980 The driver will then remove the "Pink" page from the packet and deliver it to the Transportation Department office. The driver will remove the "yellow" page from the packet and give it to the person receiving the load at PPG. The driver will return the "Green" and "White" copy to the Shift Supervisor when he returns to the VCM Plant to pick up a second load or leave the trailer in the plant. 3. The Shift Supervisor will send the "Green" and "White" copy of the manifest to the Office Manager in the same manner as was done with the "Goldenrod" copy. Any questions related to this sytem should be directed to the Process Superin tendent, Operations Engineer, or Plant Manager. J. A. DeBernardi is Distribution Marion Palmore - Surface Transporation, Lake Charles Arlen Greathouse - PPG Industries, Lake Charles HJN-JWW-CWT-JHB-CB-KCC-CHL-CHK-GLF-GSH BTH 000120581 1 TABLE I WASTE DESCRIPTION LIST VCM PLANT EXAMPLE NUMBER 1 4 5 6 2 3 7 8 9 19 11 12 13 ID NUMBER V-lOO V-101 514-16 514-17 514-13 514-14 514-25 514-26 514-24 514-33 514-31 DESCRIPTION____________________ Bauxite Drying Agent Bio-Sol ids Alumina Catalyst R-305 Hydrogenation Catalyst Copper Catalyst EDC Tank Bottoms Copper Pit Ppt. T-l East Pit Sludge Miscellaneous Dumpster Solids Asbestos Equalization Basin Sludge T-2 Pit Sludge EDC Coke Sludge "1 TH 000120582 (conoco) Interoffice Communication To Distribution From S. W. Sommer Date March 3, 1982 Subject Chain of Custody Record for Samples of Hazardous Materials - Procedure for Use Whenever small-quantity samples of hazardous materials from the plant are transported or disposed of outside of the plant, chain of custody records must be kept. The attached form must be used when a hazardous material sample is given for transport or disposal. Samples of hazardous materials sent to other Conoco locations for analysis are not required to be accompanied by a Chain of Custody record. The Chain of Custody Record is a form for manifesting samples (a record of shipping and disoosal) and is used in lieu of a regular hazardous waste manifest. Should there be an accident as a result of or involving the sample, the Chain of Custody form will be used to answer questions of liability. Any hazardous waste shipped or given to a disposer must have a Chain of Custody form provided. Chain of Custody forms can be obtained from the plant Process Engineering Environmental Coordinator. The procedure for completing a Chain of Custody record is outlined below: 1) Section 1 should be completed by the VCM Plant employee who is providing the sample to be transported or disposed. a. Sample Description - enter a description of the sample to be transported, indication of major components, sample size, physical state, number of containers, etc. For examole: "Activated carbon, slightly moist with chlorinated hydrocarbons. Seven 1-pint polyethylene containers." b. LA. I.D. `lumber - obtain the proper Louisiana Manifest I.D. number from the environmental coordinator and enter the number on this line. See attached table for common I.D. numbers. c. Date of Transfer - enter the date on which the sample will be trans ferred. d. Enter your name, signature, and date in the spaces provided. DTH 000120583 2) Section 2 of the form should be completed by the transporter, e.g., UPS, 4 BFI, Acme Truck Lines, etc. before he leaves the plant. a. The transporter should enter his name and company in the spaces provided. b. Reason For Accepting Custody - transporter should enter reason for accepting custody of sample; e.g., deliver for analysis, deliver for reclamation, deliver for recycle, disposal, etc. c. Final Disposition of Sample - enter "Transfer" if sample is to be delivered to a third party, and enter name and address of third party. Enter "Disposal" if transporter is to dispose of sample, and enter name and address of disposer and location to be disposed. d. Transporter must sign and date Section 2 in the spaces provided. ***N0TE: Before the transporter leaves the plant, take the Chain of Custody form, check for accuracy, and return a coov to the Process Engineering Environmental Coordinator. We must have a copy of the form before the transporter leaves.*** 3) Section 3 of the form should be completed by the party who accepts the sample from the transporter. Section 3 should be completed in the same manner as Section 2. I' 4) After disposal of the sample, whether the disposer is the party in Section 2 or in Section 3, a copy of the completed Chain of Custody Record must be returned to the Director of Environmental Control (Mike Hayes) at the address at the bottom of the Chain of Custody Record form. Be sure the transporter understands this policy before he leaves the plant. Mike Hayes will return a completed copy of the Chain of Custody Record to the pi ant. This procedure must be followed each time a hazardous waste sample is transported from the VCM Plant. If you have any questions or comments, please contact me at 5058. Scott W. Sommer Process Engineer br Distribution JAD-JWW-RB-MLA(5)-SRA-JRH(4)-MGH-PLF-DLD-GSH-JGC-VMF-PDD-MWC-MJM-SJR / DTH 000120584 CHAIN OF CUSTODY RECORD HAZARDOUS MATERIALS SAMPLE 1. NAME OF UNIT CONOCO Chemicals VCM Plant_____ Westlake, Louisiana SAMPLE DESCRIPTION ____________________________________________________ LA. I.D. NUMBERDATE OF TRANSFER ____L EMPLOYEE PROVIDING SAMPLE ____________________________________________ SIGNATURE DATE 2. PERSON ASSUMING RESPONSIBILITY ____________ ORGANIZATION ___________________________________________________________ REASON FOR ACCEPTING CUSTODY _________ FINAL DISPOSITION OF SAMPLE (TRANSFER OR DISPOSAL) ____ ( i------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ SIGNATURE ^DATE 3. PERSON ASSUMING RESPONSIBILITY ___________________________ ORGANIZATION ________________________________________________ REASON FOR ACCEPTING CUSTODY ______________________________ FINAL DISPOSITION OF SAMPLE (TRANSFER OR DISPOSAL) SIGNATURE DATE UPON DISPOSAL OF SAMPLE, PLEASE RETURN CHAIN OF CUSTODY RECORD TO: Director, Cnvi ronir.snlal Control Conoco C'nor.irals Lake diaries Chnnical Plant P. 0. Box 727 7 Westlake, LA 70f>69 cool**686 COMMON MAINFEST NUMBERS Miscellaneous Solids Copper Catalyst EDC Tank Bottoms Alumina Catalyst Hydrogenation Catalyst Equalization Basin Sludge Copper Pit Precipitate Asbestos Insulation Tars Solids Heavy Ends - VCM/EDC EDC Coke Residue T-2 Pit Sol ids Bauxite 514-02 514-13 514-14 514-16 514-17 514-24 514-25 514-26 514-27 514-30 514-31 514-33 V-100 DTH 000120586 (conoco) Interoffice Communication To Distribution From M. G. Hayes ate February 6, 1981 Suoiect TRANSPORTATION AND DISPOSAL OF HAZARDOUS WASTES APPROVED CONTRACTORS Attached is an update of Louisiana and EPA Identification numbers for the transporters and disposers used by Conoco Chemicals Corporation. Haulers which are not on this list must be approved through established criteria prior to their hauling wastes from the plant. If you have a contractor which you wish to add to the list, please let me know. The listing for Conoco Transportation applies only to the Transportation Department, not to equipment, such as vacuum trucks or lugger trucks which are the property of the Chemical Plant. Please attach the list to the Manifest Example package so that all ID numbers are handy. If you have any questions, please let me know. M. G. Hayes co Attachment cc: HJM RDG RHG DKW GGD WAM PLJ LL RLP JRR SFP GLS BRF RW DWF TSR MR JACE3 JW GLF JHB CT (VCM) MP (Conoco Transp.) DTH 000120587 1. Conoco Chemicals (LCCP & VCM) 2. Conoco Transportation Dept. 3. BFI Transportation Division BFI Disposal (HN) Division 4. Hydro Services 5. Hydro Tech 6. . Serv-Tech 7. Chemical Waste Management Transportation Department Oisposal Department 8. Universal Engineering ( -*. STATE ID NO. EPA ID NO. GD-514 585-H 278-H D-529 2171-H 280-H 549-H LAD086478047 TXD096030697 LAT230012999 LAD000618256 TXD026856021 NYD063650873 LAD098873961 507-H DT-507 GT-554 LAD000777201 Same As Above LAD065100547 DTH 000120588 1 SECTION IV SUPERFUND REPORTING t DTH 000120589 Superfund Law and Reportable Incidents The "Comprehensive Environmental Response, Compensation and Liability Act of 1980", commonly known as the "Superfund" regulations, was passed and became effective on December 11, 1980. According to these regulations, the VCM Plant must notify the National Response Center at 800-424-8802 whenever there is an unpermitted release of a reportable quantity of a hazardous substance into any media-air, water, or land. A "release" is defined to mean any "spilling, leaking, pumping, pouring, emitting, empty ing, discharging, injecting, escaping, leaching, dumping, or disposing into the environment". Incidents which result in a sudden, accidental, or episodic release must be reported to the National Response Center. Notification of the National Response Center is not required for routine, continuous, or intermittent releases. "Hazardous substances" include those substances listed in the Resource Conservation and Recovery Act (RCRA) regulations, the Clean Water Act (CWA), and the Toxic Substances Control Act (TSCA). A list of the "reportable quantities" of hazardous substances released in a 24-hour period is contained in the Superfund regulations. The "reportable quantities" according to the Suoerfund regulations which concern the VCM Plant are: Material Quantity (Lbs/24 Hrs) 1) Ethylene Dichloride (EDC) 2) Vinyl Chloride (VCM) 3) Carbon Tetrachloride (CC14) 4) Chloroform (CHClo) 5) Ethyl Chloride (ttCl) 5000 1 5000 5000 1 Applying the above definitions to practical application in the plant environ ment means there is almost a limitless number of possible sources for reportable Superfund incidents. Some of the possible sources for unpermitted re leases (and therefore potential reportable Superfund incidents) are pipeline leaks, rupture disc releases, relief valve discharges, heat exchanger leaks, tank spills, incinerator bypasses, leaking pumps and flanges, and leaking columns and vessels. These sources can be grouped into four main categories: leaks, relief valve discharges, rupture disc releases, and incinerator bypasses The reporting requirements listed in the-Superfund regulations state that re leases that are "sudden, accidental, or episodic" require immediate notifica tion to the National Response Center. However, it is also stated that releases that are "routine, anticipated releases from facilities or vessels which are incidental to normal business operations" are not required to be reported. Of the four categories of possible sources, incinerator bypasses are considered routine releases. Incinerator bypasses are expected to occur from time to time The incinerator was designed with a control system that allows for bypasses to prevent the equipment from overpressure and from flowrates above design capacity. These occurrences are incidental to normal plant operation. DTH 000120590 .4 The categories of relief valve discharges and rupture disc releases, however, are not considered routine occurrences. These releases occur during upset conditions in the plant (i.e., overpressure, plugged eguipment, misaligned valves, etc.) and are therefore considered "sudden, accidental, or episodic". The category of leaks has to be broken down further before being designated as routine or non-routine releases depending on the source of the leak. In the daily operation of a chemical plant, leaks will develop in the equipment (i.e., a leak caused by corrosion in a vessel, a loose flange, a leaking seal on a pump, etc.). These leaks are not unexpected; the leaks are re paired and the operation of the plant continues as usual (i.e., they are in cidental to normal plant operation). However, it is conceivable that leaks could develop from accidental or epi sodic conditions in the plant such as a worker rupturing some pipeline or a forklift being backed into a vessel and puncturing it. This type of release would have to be considered non-routine and therefore reportable. Table I outlines the VCM Plant's current reporting policies. Potential Super fund release examples are given in Table II, and heat exchangers in the VCM Plant which possess the potential for reportable Superfund leaks are given in Table III. ( rf* DTH 000120591 TABLE I. CURRENT REPORTING POLICY Source Leaks (1) routine 71 lb. VCM 7 5000 lb. EDC 2.1 lb. VCM non-routine 71 lb. VCM 75000 lb. EDC 21 lb. VCM Relief Valves in vinyl chloride service /I lb. VCM 7 5000 lb. EDC 1 lb. VCM Superfund NESHAP (within 10 days) NESHAP (Semi-annual Repor x X Not reported to any Federal agency x x Not reported to any Federal agency xx x x not in vinyl chloride service (and greater than 10 ppm VCM) 7 1 lb. VCM 7 5000 lb. EDC d lb. VCM not in vinyl chloride service (and less than 10 ppm VCM) 71 lb. VCM 75000 lb. EDC d lb. VCM Rupture Discs 7 1 lb. VCM 7 5000 lb. EDC d lb. VCM Incinerator Bypasses 71 lb. VCM >5000 lb. EDC d lb. VCM x x Not reported to any Federal agency (2) x x Not reported to any Federal agency x x Not reported to any Federal agency x(3) (4) (4) DTH 000120592 (1) We do not distinguish in reporting requirements between routine and non-routine releases at this time. (2) The following statement was made in the NESHAP semi-annual report of 9-15-81: "Relief valve discharges that were not in vinyl chloride service but released over 10 ppm vinyl chloride are not considered reoortable incidents and are not included in this report". (3) Rupture disc releases will be reported in future NESHAP semi-annual reports as stated in the phone conversation to the national Response Center on 11-4-81. This release, however, falls under the same category as that described in footnote (.2). (4) Currently, we consider an incinerator bypass a routine occurrence and do not report the bypass under Superfund. (A bypass of 12 seconds would release P' 1 lb. VCM. However, to release >5000 lbs. of EDC, the bypass would have to be 2 weeks long.) DTH 000120593 c TABLE II. POTENTIAL SUPERFUND EXAMPLES jpurce/Descript ion Detection Typical Range of Possible Amount Discharged (lbs.) Final Disposition LEAKS - ROUTINE Heat exchanger tube leak in Quench Col. Condenser, H-202, due to corrosion of the tubes. (Note: there are 16 heat ex changers in the plant, all with potential for Superfund releases) Daily lab samples of the cooling water 1,000-5,000 Atmosphere at the cooling tower and to the secondary from the cooling tower blowdown. Pump seal leak on Quench Col. Reflux Pump, P-202, due to corrosion of the seal (Note: there are 46 pumps in the plant.) Visual, smel1, or fixed point monitor detection. 15-50 Atmosphere or washed to the secondary. Pump seal leak on Vinyl Col. Feed Pump, P-203, due to wear and weathering of the seal (Note: 46 pumps) Visual, smel1, or fixed point monitor detection. 15-50 Atmosphere or washed to the secondary. P/"'o seal leak on Vinyl Col. iux Pump, P-204, due to ,;<saligned valve causing the pump to dead head and burst the seal (Note: 46 pumps) Visual, smell, or fixed point monitor detection. 50-100 Atmosphere or washed to the secondary. Flange leak on line between the Vinyl Col., C-203, and the Vinyl Col. Condensers, H-207, due to vibrations in the pipe which loosen the flange. (Note: there are thousands of flanges in the plant.) Visual, smell, or fixed point monitor detection. 15-50 Atmosphere or washed to the secondary. Flange leak on line between Vinyl Col. Accumulator, S-203, and Vinyl Col. Reflux Pump, P-204, due to a corroded gas ket (Note: thousands of flanges) Visual, smell or fixed point monitor detection. 15-50 Atmosphere or washed to the secondary. Flange leak on line between the Caustic Decanter, S-206, and the Flake Caustic Dryer, S-207, due to wear and weathering on the gasket (Note: thousands of flanges.) Visual, smel1, or fixed point monitor detection. 15-50 Atmosphere or washed to the secondary. 'Ive leak on block valve on the oischarge of the Vinyl Col. Re flux Pump, P-204, due to corro sion of the packing on the stem of the valve. (Note: thousands of valvcrt; -jn thp nlantl. Visual, smel1, or fixed point monitor detection. 15-50 Atmosphere or washed to the secondary. DTH 000120594 Source/OescriDtion eline leak on the line beween the Vinyl Col. Reflux pump, P-204, and the Caustic Decanter, S-206, due to in ternal or external corrosion of the metal (Note: there are thousands of feet of pipe in the plant) Vessel leak on the Vinyl Col. Accumulator, S-209, due to internal or external corrosion of the metal(Note: there are 37 vessels in the plant with Superfund potential.) Col. leak on the Vinyl Col., C-203, due to internal or ex ternal corrosion of the metal (Note: there are 9 columns in the plant.) Leak at the head of the Vinyl Col. Condenser, H-207, due to expansion and contraction of If' metal from heating and .''piling. (Note: there are 16 .2 ^at exchangers.) Leak from a flexible hose due to wear and age of the hose. Leak at the bottom of the EDC Storage Tank, T-451, due to corrosion. LEAKS - NON ROUTINE Leak in pipeline due to a heavy object falling from one of the distillation towers. Cracked and leaking vessel due to the ball on a crane swing ing and hitting a vessel. Vessel leaking because of an exolosion that blows the top of the vessel off. H . leaking because it dis' 'pnnected while loading a tank tar due to operator error or a bad hose. Detection Typical .vange of Possible Amount Discharged (lbs.) Visual, smel 1, or fixed point monitor detection. 15-50 Final Disposition Atmosphere or washed to the secondary. Visual, smel1, or fixed point monitor detection. 15-50 Atmosphere or washed to the secondary. Visual, smel 1, or fixed point monitor detection. 15-50 Visual, smel1 , or fixed point monitor detection. 15-50 Atmosphere or washed to the secondary. Atmosphere or washed to the secondary. Visual, smell , or fixed point monitor detection. Visual, smell, or fixed point monitor detection. 15-50 10-1000 Atmosphere or washed to the secondary. Soaked into the ground. Visual, smel1, or fixed point monitor detection. Visual, smell , or fixed point monitor detection. Visual, smell, or fixed point monitor detection. Visual, smel1, or fixed point monitor detection. 10-1000 10-1000 10-10,000 10-1000 Atmosphere or washed to the secondary. Atmosphere or washed to the secondary. Atmosphere or washed to the secondary. Atmosphere or washed to the secondary. DTH 000120595 c 5 rce/Description Detection Typical Range of Possible Amount Discharged (lbs.) tM Caustic Dryer, S-207, valve Visual, smel1, or left open to the vacuum unit fixed point monitor (supersucker) during recharging. detection. 10-1000 Overfilling a tank car or tank due to operator error. Visual, smel 1, or fixed point monitor detection. 10-1000 Bleed valve (sample point) left open due to operator error. Visual, smel 1, or fixed point monitor detection. 15-50 Punctured and leaking vessel due to backing a forklift into the vessel. Visual, smell, or fixed point monitor detection. 10-1000 RELIEF VALVE DISCHARGES Mote: There are 108 relief valves in the plant with the potential for Superfund releases. Relief valve discharges due to overpressure in the system d ng an upset in the plant during start-up and shut down of the plant. Visual, smell, or fixed point monitor detection. 10-1000 Final Disposition Atmosphere or washed to the secondary. Atmosphere or washed to the secondary. Atmosphere or washed to the secondary. Atmosphere or washed to the secondary. Atmosphere Relief valve discharges due to equipment obstructed downstream of the relief valve (for ex ample, a plugged sparger in the Flake Caustic Dryer, S-207) Relief valve discharges due to equipment blocked in downstream of the relief valve (for ex ample, a misaligned valve.) Visual, smell or fixed point monitor detection. Visual, smel1, or 10-1000 10-1000 Atmosphere Atmosphere Relief valve discharges due to the 7CM Col. pressure control ler, PRC-206, malfunctioning causing the Caustic Decanter, S-206, to overpressure. Visual, smel1 or fixed point monitor detection. Relief valve discharges due to Visual, smell, or the Vinyl Col. Reflux pump, fixed point monitor P-204 tripping out causing detection. backed up flows and increased pr sure in the Vinyl Col., C-203. ,lief valve discharges due to ioss of cooling water to the Vinyl Col. Condenser, H-207, causing the Vinyl Col., C-203, to overheat and overpressure. Visual, smel1 or fixed point monitor detection. 10-1000 10-1000 10-1000 Atmosphere Atmosphere Atmosphere Bffl 000120^96 ( rce/Description Detection Typical Range of Possible Amount Discharged (lbs.) Final Disposition ,belief valve discharges due to mechanical failure of the rel ief val ve. Visual, smell, or fixed point monitor detection. 10-1000 Atmosphere RUPTURE DISC RELEASES Note: There are 113 rupture discs in the plant. Most of the rupture discs are under relief valves. If the rupture disc releases due to some overpressure condition, the relief valve will almost always release also. In this instance, the rupture disc would be a reportable release. However, if the rupture disc re leases and the relief valve does not release, it is not a reportable release. There are rupture discs in the plant which serve as the only pressure relieving device on a piece of equipment. In this instance, any release (due to overpressure or premature failure) would be a reportable release. Rupture disc releases due to overpressure in the system during an upset in the plant or during startup and shutd< of the plant. Visual , smel1, or fixed point monitor detection. l^lpture disc releases due to equipment blocked in downstream of the rupture disc (for example a misaligned valve.) Visual, smel1, or fixed point monitor detection. 10-1000 10-1000 Atmosphere Atmosphere Rupture disc releasing due to the teflon lining collapsing in the exit line of the Oxy Reactors, R-301, 2, 3. Visual, smel1, or fixed point monoitor detection. 10-1000 Atmosphere Rupture disc releasing due to the VCM Tar Stills Reflux pump, P-206, tripping out caus ing backed up flows and in creased pressure in Tar Still Reflux Col., C-204. Visual, smel1 or fixed point monitor detection. 10-1000 Atmosphere Rupture disc releasing due to loss of cooling water to the Quench Col., Condenser, H-202, causing the Quench Col., C-201 , to overheat and overpressure. Visual, smel1 or fixed point monitor detection. 10-1000 Atmosphere Ru 'ure disc releases due to ir, .rnal or external corrosion the rupture disc. Visual , smell or fixed point monitor detection. 10-1000 Atmosphere Rupture disc releases due to mechanical failure of the rupture disc due to a manufac- Visual , smel 1 or fixed point monitor 10-1000 Atmosphere DTH 000120597 Source/Description Detection, TMCINERAT0R BY-PASSES , ,,inerator by-pass due to The by-pass ''high pressure in the vent alarm will sound. header from a surge of vents or upset conditions in the plant. Incinerator by-pass due to a flame failure in one of the burners. The by-pass alarm will sound. Incinerator by-pass due to venting the Flake Caustic Dryer, S-207, too fast while recharging. The by-pass alarm will sound. Incinerator by-pass due to a slug of O2 in the Cl2 from PPG causing R-101 vents to surge. The by-pass alarm will sound. Incinerator by-pass due to a power failure. The by-pass alarm will sound. Incinerator by-pass due to a high level in the Vent Recovery Tank, T-490, from the vents while loading tank cars. The by-pass alarm will sound. >.^cinerator by-pass due to ~iow combustion in the burners caused by a low air flow. The by-pass alarm will sound. (\ Typical Range of Possible Amount Discharged (lbs.) 1-10,000 1-10,000 1-10,000 1-10,000 1-10,000 1-10,000 1-10,000 Final Disposition Atmosphere Atmosphere Atmosphere Atmosphere Atmosphere Atmosphere Atmosphere ) dth 000120598 TABLE III VCM PLANT HEAT EXCHANGERS WHICH POSSESS POTENTIAL FOR REPORTABLE SUPERFUND LEAKS Exchangers Design Process Operating Hazardous Pressure Material (PSIG) Design Cooling Water Operating Pressure (PSIG) Design Cooling Water Flow Rate (Lbs/Hr) 24-Hour Reportable Quantity Concentrat (PPM) 1) Reactor Cooler, H-101 EDC 50 50 3,860,000 53.9 2) L.E. Column Condenser, H-106 EDC CC14 CHC1 -3 EtCl 45 50 2,400,000 86.8 86.8 86.8 0.017 3) H.E. Column Condenser, H-109 EDC 45 50 2,680,000 77.7 4) EDC Product Cooler, H-110 A&B EDC 45 50 525,000 396.3 5) Quench Column Condenser, H-202 A&B ( i VCM Column Condenser, H-207 A&B 7) EDC Cooler, H-209 EDC 105 VCM VCM 100 EDC 100 50 2,640,000 78.9 0.016 50 2,646,000 0.016 50 600,000 347.2 8) Reactor Effluent Precooler, H-302 EDC 61 50 309,000 674.2 9) Primary Product Condensers, H-303 A,8 ,C EDC 60 50 2,145,000(1) 97. l(D 10) Finishing Reactor Effluent Condenser, H-305 EDC 56 50 245,000 350.3 Notes: (1) Quantity per each exchanger. DTH 000120599 (cCoornoco Interoffice Communication to B. I. Raffle - Houston From S. W. Sommer oaie May 13, 1982 subject Reportable Superfund Incidents Regarding Vinyl Chloride Emissions On April 20, 1982, a meeting between personnel from the VCM Plant and the Legal Department was held at the VCM Plant in Westlake. The NESHAP Regulations, the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (Superfund laws), and vinyl chloride emissions were discussed and the following conclusions were made: 1) The VCM Plant considers all vinyl chloride (VCM) releases over 1.0 lb. which are subject to NESHAP regulations as being federally permitted releases, and therefore, not reportable under the Superfund Laws. 2) The Legal Department will draft a letter which will state our inter pretation of the Superfund and NESHAP regulations and will forward the letter to Region VI of the EPA. 3) The Legal Department will draft a letter (similar to the one to be sent to the EPA) for internal use by Conoco personnel regarding which VCM releases will be considered to be reportable under Superfund and which VCM releases will be considered to be federally permitted (subject to NESHAP regulations). Below is a summary of the possible sources of VCM emissions of greater than 1.0 lb. with a justification as to why or why not the VCM Plant believes the emission would be reportable under Superfund. Emission sources at the VCM Plant can be grouped into four main categories: leaks, relief valve discharges, rupture disk releases, and incinerator by-passes and other vents. LEAKS Leaks must be categorized further into episodic or accidental leaks and leaks resulting from the normal operation of the plant. Episodic or accidental leaks would include leaks resulting from objects falling on pipelines, rupturing lines with a forklift, explosions, puncturing of vessels, tank spills, etc. These leaks would be reported under Superfund because they are not incidental to normal plant operation and are not subject to NESHAP regulations. Flange leaks, valve leaks, pump seal leaks, leaks due to normal metal corrosion in pipes and vessels, and leaks in hoses due to wear all result from normal plant operation, are not episodic, and are not unexpected. More importantly, these VCM emissions are all detected by the VCM Plant's Leak Detection and DTH 000120600 (r Elimination program and are therefore subject to NESHAP regulations and are not reportable under Superfund. Leaks in heat exchanger tubes may allow VCM to be emitted into the plant's cooling water system and into the atmosphere via the cooling tower. Leaks of this nature are detected by routine sampling of the cooling water of ex changers in VCM service. Although this sampling is not written in our Leak Detection and Elimination Plan, the plant considers the cooling water sampling as part of the Plan. Under this premise, leaks in heat exchanger tubes are considered to be subject to NESHAP regulations and will be reported accordingly. An opinion is requested from the Legal Department as to whether or not our Leak Detection and Elimination Plan must be formally revised and submitted to the EPA to include cooling water sampling as a part of the Plan. RV Discharges Discharges from relief valves which are on vessels that are "in vinyl chloride service" (contacting a fluid which is at least 10? VCM) are not Superfund reportable discharges because these releases are reported to the EPA under NESHAP. For example, a release of 100 lbs. of vinyl chloride from the relief valve on the Vinyl Purification Column C-203 would not be reported under Superfund because such a release would be subject to the NESHAP regulations. However, releases from relief valves on vessels not in vinyl chloride service are reportable under Superfund if more than 1 lb. of vinyl chloride is emitted since NESHAP does not cover these relief valves. Rupture Disk Releases The VCM Plant has many rupture disks which provide overpressure protection to vessels. All of the rupture disks in the plant are in one of three con figurations. 1) All rupture disks which are in VCM service are located under relief valves. In an overpressure situation, it is likely that both the rupture disk and the relief valve will release. VCM will be released to the atmosphere only if both the rupture disk and relief valve release. Any discharge in this manner will not be reportable under Superfund because relief valve discharges are subject to the NESHAP regulations and are reported to the EPA under NESHAP. If the rupture disk fails but the relief valve does not release, no VCM will be discharged to the atmosphere and the rupture disk failure is not reportable under NESHAP nor Superfund. 2) On vessels which are not in VCM service and which have rupture disks and relief valves in combination, VCM can be released to the atmosphere only if the rupture disk breaks and the relief valve opens. If this occurs and more than 1.0 lb. of VCM is released to the atmosphere, the release is reportable under Superfund since relief valves on vessels not in VCM service are not subject to the NESHAP regulations. 3) There are some rupture disks in the plant which serve as the only pressure relieving device on a piece of equipment, all of which are not in VCM service. In this instance, any release of VCM greater than 1.0 lb. due to overpressure or premature failure would be a reportable release. DTH 000120601 (( Incinerator By-passes and Other Vents Incinerator by-passes are considered non-reportable releases since they are reported under NESHAP. Previously, these were considered to be non reportable because by-passes were expected to occur from time to time during normal plant operation. The incinerator was designed with a control system that allows by-passes to occur to prevent the equipment from overpressure conditions. Presently, incinerator by-passes are reported to the EPA under NESHAP and are therefore considered to be covered under NESHAP regulations. It is for this reason that incinerator by-passes are not considered reportable releases under Superfund. There are other control system vents and manual vents which could result in a VCM release of greater than 1.0 lb. These vents are on equipment which is not in VCM service; therefore, releases from these vents in excess of 1.0 lb. of VCM would not be covered by NESHAP. These vents would be reported to Superfund. Table I attached summarizes the releases that the VCM Plant considers reportable and non-reportable. If you have any questions or comments, please call me at ETN 640-5058. Scott W. Sommer Process Engineer br CCI JAD-JWW-MGH-RB-PLF-DLD-JCL-DDE-CAG-JJH-CRH DTH 000120602 c c F" Fu*o o I/I CL QJ l/> qj tToO CO _J r--0-) ib o ck ov <b 4-> c z < ro U kJ x3 o go UJ <CO c 0 a: 0 O u *0 c r-QmJ 0) t3v rDo CD u k. CO QJ CL OC- OGO t3n 0) a: CL co. *oo kk O u o. < o x c t/3 <0 LiJ z k rfto) o 3 k> wCO r-- L>-~' re Qi -O kE 0 ao O 310 C to >> <b i> 0} k ro a a u. (0/)I i/l --o- 3 it) O ai r- to (aA* k0) 10 c o aj 0 k -j h- a Q- cn o Cl ro ro --QJ cc O QJ O) O a. CJ k V a. o O <3; 1/1 Z to k 4J k > #0 0 o. X >, GO fO UJ *3 >1 0} tQoJ ro z QJ 0 *0 r-- T3 0) V k> 0 o4) 4o-> 4-> >,rc *3 *" 0) 0 k k> QkJ QkJ Q>J U O O *D <b T? O <b "O (A k 4) -- >X 0u a. 0 O C rOt--o CL *- j a -x o-- c QkJ tXo CJ k QJ <0 k^ QJ 00 k- JO fO UJ z 4/1 QtoJ k4) I'D C QJ to -O QJ *0 tO 3 O 0U --LT-) CJ " LO 00 >l J" ITS *0 QJ C r-- 3 QJ k E ft) t--QJ QJ k to a> k. f0 0 <o o CJ 0 kO- QJ sc_u > ak> xo s_,, 4-> < cu rr-- oaorv. r-- ITS -- Ek to O CL c u_ 0 0k . G~ k> k to 0 Qj 0 to QJ 03 k QJ QJ 0 k3 C QJ C c 0 Osz 0 c QJ i.< *- X 3 GO O' UJ QJ Z c > O0 QJ 09 k 0) 10 k to 0>) 00 cu QJ >0 3E O QJ QJ QJ QJ QJ 03 n*toj L. O a. cQcJ 1 c iO 0 <0 4-J lO 4-1 k. O O. QJ ac U QJ 0) O CL *-- 0) 0 CQJt fO ro k> 1 k. k. 4-> k QJ O0 CL cOc 4r-o> s_ 1 c c O CL O a. 1 c 0CL 0 z z0 z0 CQCJ 0 a: 0 QJ a: to QJ k 3 4-> 0 3 QC 0) to c k to c 0 _J 0 QJ kk to k 3 4-* r-- lO UJ 0 Q_ rO -- c 0 4--* >f- O k c k. c c. v O 3 O QJ GO to kJ CL to ~o O ro QJ r- r-- k J4f a u c Q. Qj C U ro X CL <0 QJ C h- UJ O h 0 k. 3 0 ro GO r-4 to c ro )-- k O to QJ 0 F CL to C ro QJ c 0 3 ro to QJ 0X to k -X k k ro O QJ to 0) k> Cl to to C E to ro a> 10 r~ O -X 0 QJ ro k ro u QJ *- QJ X QJ GO _J UJ C71 CJ to C> QJ 0 to 1-- E ro to ro 03 3 QJ O QJ u. > CL _J X to ro QJ __1 QJ 0 3 t-- k QJ o> c ro 0 O X UJ k> ro QJ 0U ^4 r-- c QJ to > v> C rO a> > > <v QJ a> U V E QJ kJ to > QJ a kk > GO u QJ r-- GO O V- > kX C O k QJ 0 O GO > c to ro 2T c QJ O tO QJ kJ C to O QJ L_> to > rc U to k V) QJ -- ro QJ C 0 F-- > 0 0 c QJ k 1 v> CC QJ >> O to to to -- CD QJ QJ -x C to > > to X O k v> r-- -- k> -F- O C rO ro O > 4-) V> QJ >> ro rO QJ C C k tv tv k *F" <V aj QJ 3 0 c ro r-F r- 3 F-- Q- OO u C QJ QJ 3 C U c ro G cs: CL --- X 0, fO CNJ CNJ ro 0 ro TT | < IV^LW if -... MlfcT'tfi* >4*FU<*-'k ^ DTH 0 0 0 1 2 0 6 0 3 (conoco) Interoffice Communication To Distribution From S. W. Sommer Date subject March 30, 1982 VCM Plant Policy for Removal, Handling, Storage, and Disposal of Asbestos Attached are the updated guidelines for the removal, handling, storage, and disposal of asbestos at the VCM Plant. These guidelines are in accordance with OSHA and NESHAP regulations concerning asbestos. The only major change which has been made from existing asbestos pro cedures is that the plant will notify the Louisiana Department of Natural Resources and the Environmental Protection Agency (Region VI) of all scheduled and anticipated asbestos removal operations, in accordance with the attached guidelines. This procedure will be included as part of the VCM Plant Environmental Information Manual. Scott W. Sommer Process Engineer br Distribution JAD-JWW-RB-JRH(4)-MLA(5)-SRA-PLF-MGH-DLD-PE DTH 000120604 TABLE OF CONTENTS INTRODUCTION -......................... -.....................-..................................................... - 1 WRITTEN NOTIFICATION TO GOVERNMENTAL AGENCIES.............. ......................... 1 PLANT PRE-REMOVAL PROCEDURES.............. -.......................................................... 2 REMOVAL AND HANDLING----------------- ------------------------------------- --------------------- 3 WET REMOVAL PROCEDURES......................................................... -........................... 3 STORAGE AND DISPOSAL........................................................................-.......... --- 4 APPENDICES A. NESHAP REGULATIONS--.................................................................................-- 5 B. OSHA REGULATIONS............................... ................................................... ............ 10 C C. ASBESTOS REMOVAL NOTIFICATION LETTER ................................................... 14 D. ANNUAL NOTIFICATION OF ASBESTOS REMOVAL ................................... ........ 15 E. PREDISPOSAL NOTIFICATION LETTER -........................................................... 16 F. SAMPLE MANIFEST FOR ASBESTOS DISPOSAL ................................................ 17 DTH 000120605 CONOCO CHEMICALS VCM PLANT Removal, Handling, Storage and Disposal of Asbestos Introduction Asbestos is a fibrous material derived from naturally occurring mineral silicates. The fibers are non-combustible, high in tensile strength, good thermal and electrical insulators, and resistant to most solvents. In the plant, asbestos material is used in heat-resistant insulation, cements, fireproofing and hot pipe coverings. Asbestos waste is generated by the removal of insulation from equipment and piping, Haveg materials, asbestos gaskets, etc. Removal of insulation containing asbestos is regulated by both the En vironmental Protection Agency (EPA) and Occupational Safety and Health Administration (OSHA). Work practices during removal and disposal are covered by EPA regulations (see APPENDIX A), and worker protection is covered by OSHA regulations (see APPENDIX B). Any insulation or/and fireproofing material suspected to contain asbestos should be analyzed for positive identification by the VCM Plant laboratory. If the asbestos content is less than 1% dry weight the material can be disposed of via normal solid waste disposal methods. If greater than 1% the following procedure should be used. Written Notification to Governmental Agencies The following items will be prepared by the Process Engineer with the Environmental area of responsibility: a) Conoco VCM Plant shall notify the Environmental Protection Agency, Air Facilities Branch, Region VI, of a scheduled removal of asbestos material greater than 260 feet of pipe insulation or 160 square feet of flat insulation at least 10 days prior to commencement of removal. See APPENDIX C - "Asbestos Removal Notification" for a typical notification letter. b) The VCM Plant should notify the EPA on January 1 of each year of anticipated removal operations of less than 260 feet of pipe insulation or 160 square feet of flat insulation. This letter should include all anticipated minor removals throughout the year. See APPENDIX D - "Annual Notification of Asbestos Removal" for a typical notification letter. c) A report will be submitted to the State of Louisiana Department of Natural Resources, Hazardous Waste Management Division, at least 10 days prior to disposal. A copy of the report must be sent to the US EPA, Air Facilities Branch. See APPENDIX E for a sample letter. d) No hazardous waste will be shipped without a manifest prepared by the . Process Engineer with the Environmental area of responsibility and signed by the appropriate plant personnel. See APPENDIX F for a sample of a manifest prepared for asbestos disposal. dTH 000120606 Page 2 Plant Pre-removal Procedure The following procedures shall be followed by persons who are involved in the removal or stripping of asbestos material : 1) Notify the Safety Director in advance, extension 5039 (PB 61-491). 2) Obtain a completed work permit from Shift Supervisor for the Safety Director's approval. 3) Discuss with the Safety Director method of asbestos removal, use of required safety equipment, and use of any monitoring device. 4) Minimum safety equipment required for asbestos removal: a) Particulate respirator or dust mask approved for asbestos use. b) Disposable coveralls, head covers, and gloves. c) Eye protection, hard hat, and boots. kf -N--o--t-eThe Shift Supervisor will be in charge during the Safety Director's absence. DTH 000120607 x Removal and Handling Asbestos material should be handled in wet state, whenever practicable, to prevent the emission of asbestos fibers to the atmosphere. Dry Removal Dry removal of friable (easily crumbled or pulverized) asbestos material is not recommended, but may be necessary in instances of unavoidable damage through the wet removal techniques. Because this material may result in heavy contamination, it requires specific EPA approval. As a rule, asbestos should never be removed dry. Wet Removal Wet removal of asbestos is based upon the ability of water to lower the friability of the wetted material and the movement of the released fibers. Water or wetting agent will render the material less friable and more co hesive, thus reducing airborne asbestos. Fibers that are released will fall rapidly if wet. Wet Removal Procedures 1) Isolate the work area to prevent contamination and fiber dispersal to other areas during stripping. Cover equipment and other items with polyethylene sheets if necessary to prevent them from getting wet. 2) Isolate the work area with flags or rope and display caution signs at all entrances or passageways. Example: ASBESTOS .DUST HAZARD AVOID BREATHI MG DUST WEAR ASSIGNED PROTECTIVE EQUIPMENT DO NOT REMAIN IN AREA UNLESS YOUR WORK REQUIRES IT BREATHING OF ASBESTOS DUST MAY BE HAZARDOUD TO YOUR HEALTH 3) Wet insulation. Re-spray as required if dust occurs during removal of the materi al. 4) Use wetting agent if water run-off poses a safety and cleanup problem, and during the winter. 5) Remove asbestos material in small sections with two-person teams, on scaffolding platform if needed. Never drop asbestos material to the ground. Transfer the material into 6-mil pre-labelled asbestos bags prior to starting the next section. DTH 000120608 Page 4 The asbestos disposal bags should bear the following label: CAUTION CONTAINS ASBESTOS FIBERS AVOID BREATHING DUST BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM 6) Clean up debris and other fallen material by wetting before placing in pre-label!ed asbestos bag. Brooms or airhoses are never to be used in cleanup operations. 7) Keep the collected materials wet and sealed in bags during the entire operation. 8) When removal work is completed, notify the Safety Director for: a) Post-removal inspection and monitoring. b) Personnel decontamination procedures. 9) Inspect the work area visually to insure adequate and complete removal . I of asbestos fibers. Additional cleanup and inspection should be conducted after 24 hours. Any settled fiber should be v/etted before placing in pre labelled asbestos bags. Storage and Disposal 1) All asbestos material, scrap, debris, containers and asbestos-contaminated clothing should be collected in pre-label led asbestos bags, adequately wetted and sealed. See "Wet Removal Procedure," item 5 for bag labelling requirements. 2) Sealed bags containing asbestos material will be temporarily located in the Hazardous Waste Area south of the chlorine compressor building until disposed of. 3) All asbestos bags should be tagged indicating the weight (or volume) of each bag and the date of removal. 4) The asbestos bags, with the properly completed mainfest, should be given to the designated EPA- approved disposer for final disposal. / V2-0609 oO Page 5 121:04GG APPENDIX A FEDERAL REGULATIONS 'Support Cl--National Emission Standard iriduded. provided a number of such op for Asbestos erations car. be predicted to occur during 61.20 i|`Im jIi i 11 .. a Riven period of time based cn operating experience. The provi >io13 oC ".his subpart arc a,.'- (o) "Emergency renovation" means a ph table to those t-ouiccs rpccified its renovation operation that results from, a 5 gi.22. sudden, unexpected event, and is not a (> 1 .2 t D.Tinilinii-. Terms used in this subpart arc dcfir.td in tltc net. m subaart A o: l:us part, or m this section a.< fohows: (a) Asbestos'' tr.cnr.s actiiioiite. nrr.ositc. anthophyllite. chrysotile. crocidohte. trcmolnc. (b) "Asbestos material" means as bestos or any material containing as bestos. <c) "Particulate asbestos material" means finely divided particles of asbestos material. id) "'Asbestos tailir.es" means any sclid waste product of asccstos raining or nulling operations which contains as bestos. <c> "Outside air" means the nir out side buildings and structures. planned renovation. Operations necessi tated by non-routune failures of equip ment arc Included. <p) "Adequately wetted" means suf ficiently mixed or coated with water cr an aqueous solution to prevent dust emissions. (q) "Removing" means taking out friable asbestos materials used on any pipe. duct, boiler, tank, reactor, tur bine, furnace, cr structural member from any building, structure, facility, or installation. (r) '"Stripping" means taking off fri able asbestos materials from any pipe, duct, boiler, tank, reactor, turbine, fur nace, or structural member. [Paracraoh (q I and f;) revised by 43 FR 26373 June 19, 197S1 <M "Viable emissions" meatts any emissions which are vi.-tially detectable without the aid of instruments and which contain particulate asuestos material. fs) "Fabricating" means any process ing of a manufactured product contain ing ccmmcrciai asbestos, with the ex ception of processing at temporary sites (?) "'.\sbcstos nidi" means any facility encased in the conversion or any inter mediate step m tltc conversion of asbestos for the construction or restoration of buildings, structures, facilities or instal lations. ore Into commercial asbestos. Outside ft) "Inactive waste disposal site" storage of asbestos materials is not con means any disposal site or portion, sidered a part of such facility. thereof where additional asbestos-con Ut) "'Commercial n..be:tcs" means any taining waste materia! will not be depos variety of asbestos mn:m is produced by ited and where the surface is not dis r vetin: asbestos i.-ciu asacstcs ore. turbed by vehicular trade. \ "Manufacturing" means the com fu) "Active waste disposal site" means ping of commercial asbestes. cr in the ar.y disposal site other than an inactive fuse of woven frtttion products the com site. bining of textiles containing commercial (v) "Roadways" means surfaces cn asbestos with any ether materials). in which motor vehicles travel including, cluding commercial asbestos, and the but net limited bo. highways, roads, processing of this combination into a streets, parking areas, and driveways. product as specified in 5 1.22(0. <w) '"Asbestos-containing waste mate <J) '"Demolition" means the wrecking rial" means any waste which contains or taking out of ar.y lead-supporting commercial asbestos and is generated by structural member and any related re- a source subject to the provisions of this rr.ovung or stripping of friable lubestes materials. fit) " Friable asbestos material" means subpart, including asbestos mill tailings, control device asbestos waste, friable as bestos waste material, and bags or con any material that contains mere thart-l tainers that previously contained com percent asbestos by wen:;:: and that can mercial asbestos. be crumbled, pulvcnccd. cr reduced to powder, when dry. by hand pressure. [40 FR 43252. October 14, 1973; tl> "Control device asbestos waste'' (x> "Structural member" means ar.y means any asbestos-containing waste load-supporting rr.err.b'w, such as beams material that Is collected ::i a pollution and load-supporting walls: or any non- control device. (m) "Renovation" tnearts the remov ing or stripping of friac:-' asbestos ma terials used on .any pipe. duct, boiler, load-supportim: member, such as ceilings and non-load-supporting '.'.nils. [42 FR 12127. Marii 2. 1977] tank. rtactor, turbine, furnace, or 61.22 Fini-rinii Miiiui.inl. structural member. Operations In wh:>h load-supporting structural members arc wrvcteb or taken out are excluded. fa) Asbestos mills: There shall be no \tsiole tmiu.ions to the outside u:r from any asbestos mill except as provided in p.iragra; h if) of th'< section. j PjriiTii'h (ml revved bv-4 .1 1 It ;S3?j. June 19. IV7A | [39 I R 1 59 it), Mji 3. |9">4f in) planned renovation" means a renovation operation, or a number of ' -xtriitiosu, la which Lie amount i ..c auesuts that will be ov<--t -r veil *a given rt- 11') P.oivJujvs' The ui!-.cinc of riv.d- os s Mini asbvsios uii-.n-w or with .v rv's'.usc.'enuiiniiiu w-ve :ia( is e-.'iief.'rii fv .irv> t.-iuric vuC.tri M I'sii.': irlis It). -J). let or ill). o! thn Million i\ 1 o'. tune r.-.n ue r reu-J. Operations prohibited, except far temporal'"/ read- '-''.at -re tnc.vidujuly r.or.-.'.seOilivl arc ways on r.n ftreii of uiocatus lie uei.-osiu. Tlie deposition of asbestos tailings or as bestos-containing waste on roadways covered with snow or ice is considered "surfacing." tc) Manufacturing: There shall be no visible emissions to the outside air. ex cept as provided in paragraph ft) of this section, from any of the following op erations If they use commercial asbestos or from any building or structure in which such operations are conducted. [40 FR 43292. October 14. 1975| fl) The manufacture of cloth, corn, wicks, tubing, tape, twine, rope, thread, yarn, roving, lap, or other textile ma terials. (2) The manufacture of cement prod ucts. (3) The manufacture of fireproofing arid insulating materials. (4) The manufacture of friction products. (5) The manufacture of paper, millboard. and felt. (6) The manufacture of floor tile. (7) The manufacture of paints, coat ings. caulks, adhesives, -sealants. S) The manufacture of plastics and rubber materials. (0) The manufacture of chlorine. (10) The manufacture of shotgun shells. (11) The manufacture of asphalt con crete. (d) Demolition cr.d renovation. The <r requirements of this paragraph shall apply to any owner or operator of a demolition or renovation operation who intends to demolish any institu tional. commercial, or industrial build ing (including apartment buildings having more than four dwelling units), structure, facility, installation, or por tion thereof which contains any pipe, duct, boiler. tanX reactor, turbine, fur nace, or structural member that is cov ered or coated with friable asbestos materials, except as provided in para graph (d)(1) of this section; or who in tends to renovate any institutional, commercial, or industrial building, structure, facility, installation, or por tion thereof where more than 80 meters (ca. 260 feet) of pipe covered or coated with friable asbestos materials are stripped or removed, or more than 15 square meters, (ca. 150 square feet) of friable asbestos materials used to cover or coat any duct, boiler, tank, re actor. turbine, furnace, or structural member are stripped or removed. (1) (i) The owner or operator of a demolition operation is exempted from the rcqti;remeii|,s of this paragraph: I'm tided. (A) The amount of friable asbestos materials in the building or portion thereof to be demolished is less than 60 meters (ca. 2S0 feet) used on pipes, and less than 15 square meters (ca. ICO square feet) used on any duct, boiler, tank, reactor, turbine, furnace, or structural member, and (3) the notification requirements of para graph idh'lhii) are met. (n > Written notification shall be pfritin.'ir-irri e.elitereil to tile Admin istrator at ;i-.v,t `23 days prior to coni- Erv, O om# <"* f R pc -* (S#. 61.2?!cj|MJ(,,H sj Page 6 HAZAnDOUS EMISSIONS s-j i: 121: Ol G 7 mmTr.ioiU of rfemo'.ition and shall' in amount of frm.ble asbestos materia! to adequately wetted to ensure that surh clude ilit* information required by be removed or stripped slm.lt be the total materials tem tin wet during all remain pnraeraph (d)(2) of this section. with amount c-f friable asbestos material that ing stages cf demolition or renovation tho exception of the inforin.v.ion re will be removed or stripped as a result and related handling operations. Such quired by paragraphs (d)(2) (iii), (vi>. of the sudden, unexpected event that materials shall not be dropped or thrown (vii). (viii). and tix) of this section, and shall slate tho measured or estimated amount of friable a-.tiesfos materials .which is present. Techniques of esti mation shall be explained. |Pa:ji);jp|i (J) reviseJ by -I l I R 2637-1, June 10, 197S| necessitated the renovation. (4> The follow::*.? procedure.* shall be used to prevent emissions of particulate asbestos materia', to outs:de air: (i) Friabie asbestos materials, used on any pipe. duct, boiler, tank, reactor, turbine. furnace, or structural member, shall bo removed from any to the ground or a lower :!oor. Such ma terials that have been removed or stripped more tiian 50 feet above ground levci. except those materials re moved as units or in sections, shat! be transported to the ground via just-tight chutes or containers. (vi) Except as specified below, the wet > (2) Written notice of intent:an to de building, structure, facility or installa ting requirements of this paragraph are molish or renovate shall be provided to tion subject to this paragraph. Such suspended when the temperature at the the Administrator Cv the owner or opera removal shall occur before wrecking or point of wetting is below O'C (32'F>. tor of the demolition or renovation cpcv- dismantling of any portion of such When friable asbestos materia's are not auon. Swell nonce shall be nest.narked building, structure, facility, or installa wetted due to freezing temperatures, such, or delivered to the Administrator at least tion that would break up the friable materials on pipes, ducts, boilers, tanks, 10 cavs nnor to ccmrr.enccmcr.t c-f demo lition. or as earl" as possible prior to commencement of emergency demolition subject to paragraph (d(G) of this sec tion. and as early as possible prior to commencement of renovation. Such no tice shall include the following informa tion: u) Name of owner or operator. (ii) Address of owner or operator. (m) Description of the building, structure, facility, or installation to be demolished or renovated, including the size. age. and prior use of the struct'..: e. and the approximate amour.: of friable asbestos materials present. |Parsersr!i fiii) revised by 43 fR 26374, June 19. 197b: Civ) Address cr location of the buildin?, structure, facility, or installation. (v) Scheduled start:::*: and comple tion dates of demolition cr renovation. tvi) Nature of planned demolition or renovation and method*.*> to be em ployed. (viil Procedures to be employed to meet the requirement.-, of this paragraph and paragraph <j> of ties section. Cviii The name and ntitirccs or loca tion of the waste disposal she where the friable asbestos waste will be deposited. fix) Name. tide, and author::;* of the State or local governmental representa tive who has ordered a demolition which Is subject to paragraph (d)<G> of thjs section. (3)(i> For purposes of determining whether a planned renovating operation constitutes a renovation within the rr.eamn.: of tlr.-, paragraph, the amount of friable a--.bc.twS material to be re moved or stripped shall he: (Aj For planr-.x! renovating opera tions involving individually r.on-schcduied operations, the additive amount of friable asbestos material that can be pre dicted will be removed or stripped t a source over (.he maximum ;vr:cd of time for oi.l.-h a prediction can be made. The period shall b? r.ot less than 33 days and not long*1.- than cr.e ymr. Ml* For cacti r'.iuad rrr.ov.vinir op erati..is not co-.e-.f.) bv paragraph '<1> *2' (i*'.-\*. the toi.il ur.'Wid of friable r-ibr.-u.x mater: d '.not ran re predicted u hi be removed or 5tr:pr,".l :.t a source. asbestos materials and before wreck reactors, turbines, furnaces, or structural ing or dismantling of any other por members shall, to the maximum extent tion of such building, structure, facili possible, be removed as units or In sec ty. or instaJlation. that would preclude tions prior to wrecking. In no ease shall access to such materials for subse the requirements of paragraphs (d)i-i) quent removal. Removal of friable as (:v) or (d)(4) (v> be suspended due to bestos materials used on any pipe, freezing temperatures. duct, or structural member which are (vii) For renovation operations, local encased in concrete or other similar exhaust ventilation and collection sys structural material is not required tems may be used, instead of wetting as prior to demolition, but such materials shall be adequately weu.ru whenever exposed during demolition. (ii) Friable asbestos materials used on pipes, ducts, boilers, tanks, reac tors. turbines, furnaces, or structural members shall be adequately wetted during stripping, except as provided in paragraphs (d)(4Xiv). (d)UKvi). or (ciitvii) cf this section. (iii) Pipes, ducts, boilers, tanks, reac tors. turbines, furnaces, or structural members that are covered or coated with friable asbestos materials may be taken out of any building, structure, facility, or installation subject to this paragraph as units or in sections pro vided the friable asbestos materials ex posed "during cutting or disjoining are adequately wetted during the cutting or disjoining operation. Such units shall not be dropped or thrown to the ground, but shall be carefully lowered to ground level. <iv) The stripping of friable asbestos specified m paragraph (d) (4) (ii), to pre vent emissions of particulate asb-estes material to outside air when damage to equipment resulting from the wetting would bo unavoidable. Upon request and supply of adequate information, the Avlmimrtrator will determine whether dam age to equipment resulting from wetting to comply with the provisions of this par agraph would be unavoidable. Such local exhaust ventilation systems shall be de signed and operated to capture the asbes tos particulate matter produced by the stripping and removal of friable asbestos material. There shall be no visible emis sions to the outside air from such locai exhaust ventilation and collection sys tems, except as provided in paragraph (f) of this section. (5) Sources subject to this parograph are exempt from the requirements of l! 61.05(a). 61.07. and G1.09. (6) The demolition of a building, struc ture. facility, or installation, pursuant to an order of an authorized representative of a State or local governmental agency, materials used on any pipe, duct, issued because that building is structur boiler, tank, reactor, turbine, furnace, ally unsound and in danger of imminent or structural member that has been collapse is exempt from all but the fol removed as a unit or in sections as pro lowing requirements of paragraph (d> of vided in paragraph CdH4Kiii) of this this section: section shall be performed in accord (i) The notification requirements spec ance with paragraph (d)UKii) of this ified by paragraph (d) (2) of this section: section. Father than comply with the wetting requirement, a local exhaust ventilation and collection system may be ust.-tl to prevent emissions to the (ii) The requirements on stripping of friable asbestos materials from previously removed units or sections as specified m paragraph (dmxiv) of this section; outsioe air. .Such local exhaust ventila tion systems shall be designed and op erated to capture the asbestos particu late matter produced by the stripping of friable asbestos materials. There shall be no visible emissions to the outside a;r from such local exhaust vent..auc,n and collection systems (Iii) The wetting, as specifie-i by para graph (d)(4)(v) of this section, of fri able asbestos materials that have been removed or stripped: liv) The portion of the structure being demolished that contains friable asbes tos materials shall be adequately wetted during the wrecking operation. except as provided m paragraph (f) of 139 IK l S*436. Mjy 0. 1974; 40 1 R 4K292. this scenen. Ck:i*>tvr 1 4. 1 97 5 i 1 :i* For pur;* vex if heiermii-mg a `..'*.;;i .ip, rg:rrgc:i''V renovating op- I-hi) -- (ivi revived by 43 PR 26374. June ]9 19 ,M; (e) Spravino. There shall be no visi ble emissions to the outside air from c-r.it.on r.;:-_s:v a rrr.oi jbiir. w:'.:.;n (v* .Ml fri.vnlc asl-.'Rins inat.-rinl; that the spray-on ircncition of materials (? im-.inin*,- of ;nrtu.-auii. u.e hlVc* been removed or svrip; 'J shall be containing more man l percent asbes- S-13 78 fS*e. C1.22(tU I'il I.* Till. ULKl Al' or N i i ION At. AI 1 VIKS. IV'. \V 4 SHI SUTON. D C. 2')') 3 7 5) 121:0403 FEDERAL REGULATIONS tcs. on a dry weight basis. used on equipment and machinery, except as province! in paragraph (!) of this secf n. Materials : prayed on buildings. ' uctures. structural numbers. pipes, .tc! conduits shall contain less than 1 percent asbestos on a dry weight basis. [rarsvt.v.'li id rvvivtJ be -tI K 2657-1. June 19.197x| (1) Sources subject to :hi> paragraph are exempt from the requirements o: i 61.05ia>. { 61.07. and J C1.C3. (2) Any owner or operator who in tends to spray asbestos materials which contain more than 1 percent as bestos on a cry weight basis on equip ment and machinery shall report such intention to the Administrator at least 10 days prior to the commencement of the spraying operation. Such report shall include the lollowmg informa tion: (i) Name of owner or operator. (u> Addrcrs of owner or operator. (ill) Location of spmyip.g operation. tiv) Procedures to be followed to meet the requirements of this paragraph. (3) The spray-on application of ma terials in which the asbestos fibers are encapsulated with a bituminous or re sinous bunder duria: spray im: and wr-.tch are not friable aiior oryme is exempted from tin: requirements of paragraphs (e) and icK2) of tins sec tion. (Ps.-jcrjphs t:i or.d (3' revise-! by 13 r'P. -i> Rather than meet the no-vi-nalo_.Mission requirement i as specified by paragraphs ta>. ic). id'. <e>. !t i. iji. and ilci o; tins section, an owner or op erator may elect to use the methods rpecified Ly J 61.23 to clean cm lesions con taining parricuiutc asbestos material be fore such emu-ions escape to, or are vented to. me outside air. <Z< Where the presence of uncombmcd water is me sole reason for failure to meet the no-visiblc-eini.'Jlon require ment of paragraphs ia). <c>. (d>. tp>. th'. <ji. cr <>.) of t.'iis section, such fail ure shall ttet tc a violation of such emis sion requirements. (hi Rule iratuug: There shall be no visible emi-sior.s to the outside air. ex cept us pros tbed in paragraph if) of this section, from any of the following op erations it they use commercial asbestos or from am/ building or rtruc'.ure h) vInch, r.uch operJlioms arc conducted. < 11 The fabrication of cement r.mldin.g products. (2> 'I lie fabrication uf friction prod ucts. t*cc-; ti.ore operations th.at primariiy install asbestos fnctxn materials on motor vehicles. <3i The fabrication of ceniriit or t;hratc board :;r vcm.l.uior. hoods; ovens; electrical pan'-ls: l.itu; awry furniture; bulkheads. partitions anti cesiums for marine eottstructicn: and flow ccr.trol devices fer the moiteti metal industry. (i) Ii.'Sidat.uq: Maided insulating ma terials winch arc friable and vet-applied insulating materials winch are friable alter drying, inn.filed alter the eifective date of these regulations. shr.il contain no commercial asbestos. The provisions of tiiis paragraph do not apply to insu lating materials vviucii are spray applied; such materials are regulated under 5 61.22ie>. fj) Waste disposal for m.ar.ufactuiir.e, fabricating, demciicion. renovation and spraying operations; The owner or op erator of any source covered under the provisions cf paragraphs (c), <d>. (e), or th) c-f this section shall mc-et the fol lowing standards; (1) There shall be no visible emissions to the outside air, except as provided in paragraph t j> <3> of this section, dur ing the collection: processing, including incineration; packaging; transporting; or deposition of any asbestos-containing waste material rclucii is generated by such source. (2) All asbestos-containing waste ma terial shall be deposited at waste dis posal sites which or-.- operated in accord ance with, the provisions 0; j ul.25. (3) Rather than meet the requirement of paragraph (j)il' r: tins section. an. owner or operator may elect to use cither o: the disposal method:; specified under (;) 3: it) arm (:i> cf this section, cr an altorr. itivc disposal method which has iv:c:v:a prior approval by the Ad ministrator: (!) Treatment of asbestos-containing waste material with water: (A) Control device asbestos waste shall be Litorout.r.ly mixed with water into a slurry and other asbestos-containing waste material shall be adequately wetted. There shall be no visible emis sions to the cutstce ai: from the collec tion, mixing anti wetting operations, ex cept as provided ir. paragraph (i) of this section. IB) After wetting, all asbestos-con taining waste materia! shall be sealed into leak-tight containers while wet, and such containers shall be deposited at waste disposal sites which are operated in accordance with the provisions of 3 61.25. (C) Tiie containers specified under paragraph 'j)i3iiiMl3i of this section shall be labeled with, a warning label th.at states: Cvutio.-i Conl.v.r.s Aahc-.'cs Avoid Op-r.mu or h.-eakSiu: Container Pro.1 ne Asbestos ts HscnrCous 10 Vour ll-jltb Alternatively, warnin r labels specified by Occupational Safety ar.d Health. Standards cf the LVp.u tmcr.t of Labor. Occupational Safety aud Health. Adir.in- utr.Uicn 103!!.'. 1 uttder 23 Cfit 13I'J.02a1 it) id! 'in may bo used. (it' Processing of asbestos-containing waste material into non-friab!e forms: (A> All asbestos-containing waste mater:.'.; ska;! be formed into non-friable peile'.s cr other shapes .md deposited at waste disposal sites which are operated in r.ccordai'.ce with the provisions 0! 5 G1.25. (S) "There shail be no visible emis sions to the outside air from the collec tion and processing of asbestescoi'.tair.ing waste material, except as specified in paragraph if) of this section. (4' Per the purposes of this para graph ij>, the term all asbestos-con taining waste material as applied to demolition and renovation operations covered by paragraph (d> of this sec tion includes only friable asbestos waste and ccr.trol device asbc tos waste. (k) Waste disposal for asbestos mills; The owsier or operator of any source covered under the provisions of para graph (a) of this section shall meet the following standard: (l) There shall be ns visible emis sions to the outside air. except as pro vided in paragraph <k> (3) of this section, during the collection, processing, pack aging, transporting or deposition of any asbestcs-cor.tair.mg waste mate rial which is generated by such source. (2) All a.xbesios-containin? waste ma terial shall be? deposited at waste disposal sites which are operated in ac cordance with the provisions of 3 61.25. (3> Hather than meet the requirement of paragraph i-:)il> of thus section, an owner cr operator may elect to meet th.e following requirements in para graphs ik) (3) (1) and up. or use an alternative disposal method which has received prior approval by the Admin istrator: (i) There shall be no visible emission: to the outside air from the transfer cf control device asbestos waste to the tailings conveyor, except as provided ia paragraph (f) of this section. Such, waste shall be subsequently processed either as specified in paragraph <k)(3)(:i) of this section or as specified in paragraph (j) (3) of this section. <ii> All asbestos-containing waste material shall oe adequately mixed, with a wetting agent recommended by the manufacturer of the agent to effectively wet dust and tailings, prior to deposition at n waste disposal site. Such agent shall be used ns recommended for the partic ular dust by the manufacturer of the agent. There shall be no discharge of visible emissions to the outside air from the wetting operation except as specified in paragraph (f) of this section. Wetting may be suspended when the ambient temperature at the waste disposal site is lens than -- P 5`C <ca. 15 Ft. Tl'.e ambient air temperature shall be determined by an appropriate measurement method with an accuracy of ~1'C <r;2:F> and recorded at least at hourly intervals dur ing me rernd that Lie operation of the aettmg v..item ts suspended. Records o! DTH 000120612 Page 8 HAZARDOUS EMISSIONS s-ii: 121:04G9 such temperature measurements shall he tit .The asbestos-containing waste only for so long as it takes to shut down retained at the source for a tuiiinmtm of material shail be covered with r.t letvt the operation generating the particulate `wo years one! made available for mspec- 15 centimeters (ca. G incitesj of com asbestos material. t'ou by the Administrator. pacted r.cn-asbestos-contaiiiir.g mate (1) The owner of any inactive waste ria1.. and a cover of vegetation shail bo 61.21 Itcqiorimg. disposal sue. which was operated by sources covered under j Cl.2d ia), <c> or <h> and where asbestos-containing waste material produced by such sources was deposited, shall meet the following grown and .maintained on the area ade quate to prevent exposure of the asbes tos-containing waste material: or (ii> Tiie asbestos-containing waste material shail be covered wit'.; at least GO The owner or operator of any existing source to which this subpart is applicable shall, within 90 days after the effective date, provide the following information to the administrator: standards: (1> There shail be no visible emissions to the outside air from an Inactive waste disposal site subject to this paragraph, except as provided in paragraph il)i5) of tins section. (2' V-'animp signs shall be displayed at all entrances, and along the property ir.c o; the site or along the perimeter ot the sections ot" the sue where asbestoscci.tanuna waste material was e^posttea, at intervals of 100 m tea. 330 it) or less, except as specified in paragraph (1)14) of this section. Signs shail be posted in such a manner and location that a person may easily read the legend. The wanting signs required by this paragraph shall centimeters tea. 2 feet) cf compacted non-asbcstos-containmg material and maintained to prevent exposure of the asbestos-containing waste; or (iii)For inactive waste disposal sites for asbestos tailings, s. resinous or petro leum-based dust suppression agent which, effective!" binds dust and controls wind erosion shall be applied. Such agent shall be used as recommended for the partic ular asbestos tailings by the dust sup pression agent manufacturer. Other equally effective dust suppression agents may be used upon prior approval by the Administrator. For purposes of this para graph. waste crankcase oil is not con sidered a dust suppression agent. (n> A description of the emission con trol equipment used for each process; ib' If a fabric filter device is used to control emissions, the pressure drop across the fabric filter in inch.es water Base. tl) If the fabric filter device utilizes a woven fabric, the airflow permeability in ftVmir..'ft=: and. If the fabric is syn thetic. indicate whether the fill yarn is spun or not spun. t2) If the fabric filter device utilizes a felted fabric, the density in os/yd*. the minimum thickness in inches, and the airflow- permeability in ft'/min/ft'. (c> For sources subject to f S 61.22tj) and 51.22 Ck): conform to the requirements of 20" x 14" [40 FK 4S292. October 14. 19I5J (1) A brief description of each process upright format signs specified in 29 CFH that generates asbestos-containing waste 1D 10.143 <dt (4 i and this paragraph. The signs shall display the following legend In the lower panel, with letter sires and styles of a visibility at least equal to these specified in tins paragrapn. 5 61.23 Air-rleiwiiiie. If air-c'.car.mg is elected, as pe:r.'.:::eu by $5 GI.22' f; and Ol.ilJ'd) >4 > i iv . the requirements o: this section must be me:. (40 l it 4S292. OcioLwr 14. i a75 i material. (2) The average weight of asbestoscontaining waste material disposed of, measured in h.g/day. (3) The emission control methods MCINO (r.) Fabric filter collection devices used ir. all stages of waste disposal. Ajocstps v.'hstc Oisrcs.iL tun rm'.-.l be used, except r noted in para (4) The type of disposal site or incin Do Net Create Dust graphs ib) and (c) of this section. Such eration site used for ultimate disposal, devices must be operated at a pressure the name of the site operator, and the Drcatiiir-g Asbesica Is Hazardous drop of no more than 4 inches water gace. name and location of the dispos 'Asite. t to four Henna p.s measured across the filter fabric. The ui) For sources subject to i i .22(1): Notation 1" Sans Serif. Goil.lc or bloc it. *V Sana SorU. Gothic or Elocic 14 Point Gothic eirfiosv permeability, as determined by ASTf.f method D737-09. must not exceed 30 ft'/tnui ft' for woven fabrics or 35 ft'/min ft' for felted fabrics, except that 40 ftyinin/ft' for woven and 45 ft'/ (1) A brief description of the site. (2) The method or methods used to comply with the standard, or alternative procedures to be used. Spacing between lines shall te at least equal to the height of the upper of the two lines. (3) The perimeter of the site shall be fenced in a manner adequate to deter access by the general public, except as specified in paragraph (iitfi of this section. (4) Warning sign-, and fencing are not rcqu.rcd where the requirements ol paragraphs it) <3t lii or ui) of this sec tion arc met. cr where a natural barrier adequately deters access by the general public. Upon request and supply of ap propriate Information, the Adminis trator determine whether a fence or a r.aluif.l barrier adequately deters ac cess to the general public. <5> Uath.cr than meet the requirement of paragrapn HM1) of tins section, an owner may elect to meet the require ments cf this paragraph or may use an alternative control method fer emission-", mir./It* for felted fabrics is allowed for filtering air from asbestos ore dryers. Each square yard of felted fabric must weigh at least 14 ounces and be at least onc-sixtcorth inch thick throughout. Synthetic fabrics must not contain fill yam other than that which is spun. (b) If the use of fabide, filters creates a fire or explosion hazard, the adminis trator may authorize the use of wet col lectors designed to operate with a unit contacting energy of at least 40 inches water gage pressure. fc> Tlie administrator may authorize the use of filtering equipment ether than that cic'cribed in paragraphs 'a) ar.ti 'b> of this recti',n if the owner or operator demonstrates to the satisfaction of the adniipi.stiliter that the filler::;;,' of par ticulate asbestos material Is equivalent to that of the described equipment. 'di .All air-cleaning equipment an th u i.-ed b- th.i.i icelion mu t be me.-I" (e) Such information shall accom pany the information required by 5 61.10. The information described in this section shall be reported using the format of Appendix A of this part. (40 FR 45292. October 14. 1975; 61.25 VTaste dhpo^al silci. In order to be an acceptable site for disposal .of asbestos-containing waste material, under I 61.22 fj) ana (k), an active waste disposal site shall meet the requirements of this section. (a) There shall be no visible emissions to the outside air from any active waste disposal site where asbestos-containing waste material has been deposited, except as provided in paragraph (c) of this section. tb) Warning signs shall be displayed at a'.', cntrar.cts. ar.d alyng the property line of tiie site or along the perimeter of the sections of the site a here asbestoscontaining waste material is deposited, from inactive waste dtrposAl site;; whnh iM.drJ, u. i.ii, ..peruted. and maintained, at intervals of 100 m 'ca. 329 ft> or less has received ymr appioi.il by the liypt.si novices may be used only during except as specified in paragraph ul) of Administrator. upM.-t or erne: qeuey conditions and then tr .-. section. Signs shah be posted in such i bTH 000120613 8-13-73 (S.C. G1.25(bil PjI I . lilt i.lt'IM f;| \\!l"\l, 111 IIHVIM . A \MIIN( IhiV D C. 20*>Jr Page 9 121.04/0 FEDERAL REGULATIONS a manner am! location that a person may eadv read the iertrud. 1\:c warning required 'ey th:.: paracr.'.ph shall ( i i:n to lac requirement ; of JJ" x 14" chi format ruins s hied in 20 CFH .D.lij'iii'P ami ii:;.; paragraph. The signs di.-play the issy: lcacr.it in the lower pond. with letter si.-.cs ar.ri stjlcs of a visibility a*. least cc.ua! lo Luxe specified in this paragraph. agent manufacturer. Other equally ef fective dust supprctsion a cents may be used upon prior approval by the Admin istrator. Tor purposes o: this paragraph, waste crankcase oil is r.ot ccihiuered a dust suppresiion a sent. [40 I K 4S:?2. Ctiul-cr 14. 1075; (Sec. 114 of the Cl.-aii .Air Act :s emended M2 U.S.C. 7414)1 Liccxa Asjcstcs Wicts Disresat. Srrn Do Not Create On: Drcatf.ir.q Asbestos Is Kaa.vrd.jus to Your lUalth No:s*.!->n 1" S.vrvs Srrlf. Cjttilc or Blocl; 'V Sons SerK, Oo:5::c or Utcck 14 Point Gblllr Spacing between lines shall lie at least equal to the liciglit of the upper of tltc two ! .ncs. <c> The perimeter of the disposal site shall be fenced in r.rrier to adequately deter access to the general public except as specified m paragraph > cJ j of tins section. (d) Warning signs and fencing arc r.ot required where the requiremcnto of paragraph (0(1) of th.s section aro ;r.c:. or where a natural banter ade quately deters access :o the general public. Upon request and supply of ap propriate nu'omtation. tltc Adnui'ditrator will deternune whether a fence or a natural barrier adequately deters access 'h* general public. ( .niter than meet the requiro- ) .of paragraph <a> of tins section, an o _ .r or operator tr.ay clot to :r.eet die requirements of paragraph 'c'U) or (e)(2) of this section, or may use an al ternative control method for emtssions from active waste disposal sites which .'os received prior approval by the \dndnis:rator. (1) At the end of each, operating c'av. r at least once every 24-hour period vhilo the site is in continuous operation. Ac asbestos-containing waste material vhich was deposited at the site during ac operatir.g day or previous 24-hour -er:ad shall be coiered with at least IS "iitimetcrs (ca. G Inches) of compacted on-ascestos-containir.g material. (2) At the end of each operating day. r at hast once every 21-hour pcnad niie the tii.posai rite ts in continuous aeration, the iisoestos-coni-iinir.': waste .atcrial which was deposited at the site inn; the operating day or previous 24aur period shall be covered with a rcsaus or pctroicuir.-bvcd dun suppreum agent which, cffectlvrly binds dust vJ controls wind cr.viqn. fiuth agent alt he utrd as r'woinm'miiec! for iiic articular dust t>y die oust su;ipri,.v*,o:i Subp.-rt C--National Emission Standard for Beryllium 61.30 Applicability. Tltc provisions of this subpart are ap plicable to the following stationary sources: (a) Extraction plans, ceramic plants, foundries, incinerators, and propellant plants which process beryllium ore. beryl lium, beryllium oxide, beryllium alloys, or beryllium-containing waste. (b) Maclune shops which process beryllium, beryllium oxides, or any alloy when such alloy contains more than 5 percent beryllium by weight. 61.31 Definition?. Terms used in this suupart arc de fined in thq act. in stiopart A of thus part, or lit this section ns iqllows: (a) `EcrylUpin'' means the element beryllium. Where a etc fits or concentra tions arc specified, suer, weights or con centrations apply to eery.fun cniy, excluding the weight or concentration of any associated elements. <b) "Extraction plant" means a fa cility chemically processing beryllium ore to beryiiium metal, alloy, or oxide, or performing any of the intermediate steps in these processes. (c) "Beryllium ore" means any natu rally occurring material mined or gathered for its beryiiium content. (d) "Machine shop" means a facility cerforming cutting, grinding, turning, honing, milling, deburrir.g. lapping, electrochemical machining, etching, or other similar operations. te) "Ceramic plant" means a manu facturing plane producing ceramic items. (f) "Foundry" means a facility en gaged in the melting or casting of beryllium metal or alloy. (g) "Eoryilium-ccntninuig waste" means materia! contaminated with beryllium and. or beryllium compounds used or generated during any process or operation performed by a source subject to tin.; subpart. (h) "Incinerator" means any furnace used in the process of Summ.g waste for the primary purpose of reducing the volume of the waste by removing com bustible matter. (i) "ProptT.anl" means a fuel and oxidiiter physically or che:r_ca!l> combined which undergoes combustion to provide rocket propulsion. (j) "Beryllium alloy" means any metal to which beryllium has been added in orcior to increase its beryllium content and which contains more than 0.1 per cent beryllium by weight. <k) "Ercpeiiant plant" means any facility engaged in the mixing, casting, or machining of propellant. 61.32 I7mi?-ion standard. <a> Emissions to the atmosphere from stationary sources subject to the provi sions of tliis subpart shall not exceed 16 grams of beryllium over a 24-hour period, except as provided in paragraph <b) of tliis section. (b) Rather than meet the require ment of paragraph (a) of this section, an owner or operator may request ap proval from the Administrator to meet an ambient concentration limit on beryl lium in the vicinity of the stationary source of 0.01 pg/m*. averaged over a 30-day period. (1) Approval of such requests may be granted by the Administrator provided that: (i) At least 3 years of data is avail able which in the judgment of the Ad ministrate.- demonstrates that the fu ture ambient concentrations of beryllium in the vicinity of the stationary source will net exceed 0.01 pg/m'. averaged over a 30-day penod. Such 3-year period shall be the 3 years ending 30 days before the effective date of this standard. <ii> The owner or operator requests such approval in, writing within 30 days after the effective date of this standard. (iil) The owner or operator submits a report to the Administrator within 45 days after the effective date of this standard which report Includes the fol lowing information: (a) Description of sampling method Including the method and frequency of calibration. <b> Method of sample analysis, fe) Averaging technique for determin ing 30-day average concentrations. i <d) Number, Identity, and location . faddress. coordinates, or distance and ; heading from plant) of sampling sites. (e) Ground elevations and height above ground of sampling inlets. (!) Plant and sampling area plots showing emission points and sampling sites. Topographic features significantly affecting dispersion including plant budding heights and locations shall te included. (g, Information necessary for esti mating dispersion mciudir.g stacl: height. Ir.jide diameter, exit gas temperature, exit velocity or !!o:v rate, and bcrylhum concentration. <):> A description of data and proce dures (methods or models) used to clc- 0100^'06^4 (S-*c. 6l.2T<h)i 92 Page 10 APPENDIX B Cum j; 57:0-01 OCCUPATIONAL SAFETY AND HEALTH STANDARDS SU HP ART Z--TOXIC AND HAZARDOUS SUBSTANCES (Excerpts from Code of Federal Regulations, Title 29, Chapter XVII, Section 1910.93 of Subpart G redesignated as 1910.1C00 at 40 FR 23072, May 23, 1975; amended at 41 FR 11505, March 19. 1976; 41 FR 35134, August 20, 1976; 41 FR 46784, October 22, 1976; 42 FR 3304, January IS, 1977 (Corrections); 43 FR 2586, January 17, 1978; 43 FR 5963, February 10, 1978; 43 FR 11527, March 17, 1978: 43 FR 13563, March 31, 1973; 43 FR 195S4, May 5. 1973; 43 FR 27962, June 1973; 43 FR 28-172, June 30, 1978; 43 FR 45762, Octoln'r 3, 1978: 43 FR 49726, October 24, 197S; 43 FR 51759, November 7, 1978; 43 FR 52952. November 14, 1978; 43 FR 57601. December 8. 1978; 44 FR 5446, January 25. 1979; 44 FR 14554. March 13, 1979; 44 FR 50338. August 23, 1979; 44 FR 60980. October 23. 1979; 44 FR 6X827, November 30. 1979 (Corrections): 45 FR 35212. May 23. 1980; 45 FR 54333, August 15. 1980 (Corrections); 46 FR 6134, January 21, 1981) Editor's ,Yore: The effective date of the .Fan. 21, 1931. amendments to section 1910.1025 was ex tended from Feb. 20, I9S1, to March 30. I9SI, in the Feb. 6 Federal Register in accordance with President Reiman's Directive. Sub*>A Z--To.i; ,nd Mjvrdui i-ubltinccs See.: 1810.1000 Air Contaminant*. jto teot A5bti*v* J910.1002 Coi ur pitch roJat'.les: tr.tcrpre* oJ term. iPioicoj f-NI-.rcStuhenyl. 1910.1 sot aipha-.ViphthyUmlue. 1910.1005 -M'--Mnhylvn* tt (2-chlOfoam- line). J 0v'ic!cd| 19IO.1C0S Methyl chiorometbyl ether. 1910.2007 2.3'--Dl :hlorobcr.zid;rv (od Its 1910.1005 1910 1003 1910 1010 bis-Chlaroniethvt ether. be:*-:* aphtnyUmine. Se'v/ltfi-.e 2910.1011 4 * Am!r,>itphervyl. 2910.1013 E^hyt'r.firr.lne 1910.1QI 3 1910 1014 2919 )01i Id to 2 01c 29io ion b<t*r*?om*!*ctor.e. 7-e cr i v: \ rr.lnor. uorene. < D!;n`,:r,.y!aninrKr4,t>?nieoc. ' * V11*re.\ rr e.hy 1 nid 1 oe. Vinyl ehlcrt<Je. 1910.lOlS Ir/.fejfuc >rsei'.c. 1910.n;5 Lead. ioio.io:.? Bm/ere. 1910 tOD 1910.1-U J 1910 IC-W I9ii> itu; 1910.10-*-* Coke osen emissions. C^unn dan. JOm tied) 1.1 -libiomo-J-inlofoj'fot'jr.e. a.tv lor.ufile. Liposure io tot'on dost in cution gini 1910 |430 Vcfce ol sur.tl.irCv Dio t:oo wUnJ^rOt oyjm:jnoni. 5 l')l 0.1 GOO \u cornaminjrm An tr-npiiivvi.' ,,IIC ar.> mite- nil lltlfd ,n / I. ' ,< l-3 ol Uni sectiirt shall he limited In accord ance uh me recjuijcmenix of the follow ing paragraphs of this section. (a) Table Z-l' (1) .foiertetj with names preceded by "C"--Ce:l:r.g Values. An employee's ex posure to any material in Sibic Z-I. the name of which Is preceded by o. "C" te.g.. C Boron trif.uonde). shat; at no time exceed the ceiling value given for that material in the table. (2) Other materials--S-hour time weighted averages. An employee's expo- Mire to any material in table Z-l, the name of which Is not preceded by "C". la anv 8-hour wort: shift of a -to-hour work week. shall not exceed the 8-hour time weighted average given for that material In the table. (b) Table Z-3: r < 1) 8-hour tiMO weighted averages. An employee's exposure to any material listed in table Z-l. in any 3-hour work shift cf a -iO-hour work week, :,,V.:4I now exceed the 8-hour time welgntcd average limit given for that material In the table. (3) Sscmple. During an 8-hour wort shift, an employee may be exposed to a concentration of Benzene above 25 p.pen. (but never above 50 p.p.m.) only for a maximum period of 10 minutes. Such ex posure must be compensated by expo sures to concentrations less than 10 p.p.m. so that the cumulative exposure for the entire 8-haur work shift dees not exceed a weighted average of 10 p.p.m. (c) Table Z-3: Arv employee's expo sure to any material listed in table Z-3. In any 8-hour work shift of a 40-hour work week, shall not exceed the 8-hour time weighted average limit given for that material in the table. <d) Computation formulae: (DC) The cumulative exposure for aa 8-ho'ir work shift shall be computed as follows: z=c.T.fC.ri+ . . . c.r. a .(2) Acceptable ceihng concentrations. An employee's exposure to a rutir'*1 li-ted in >i-lt Z-l. that! not exceed a> any t:;r.e during an 8-hour shift me ac ceptable rrilins! cor.c-ntratlon lir-.t: given .'or the :::a*er:sl in ll.e '.able. ex ent for r tlm<: P'T.n,!, and up to n roncentra'.iur. not exceeding the maximum duration ivnd cyr.rer.iraf.cn .-.Howell in Ihs coiutr.n under "ar.-eutiiblc maximum peak above the a.-ceptabh* ceiling concentration for an 8-hour shift". where: E !> the cqulvilent eiposure ter tie work ing \ht:t. C li the eoncentritton during xr.y orrlcd at time T where the coneentrxtton tiailu cont-.iat. T !i the nir*.'..'. is V/.irj of tbt exposure *t '.he ct.r.cea:re'-:on C. The value of E shall not exc*-d the 8Iicur time weighted avrraze l:mt* In table 2 1381 1 Sec 1910.3,jOCM5.'1!'.-'I P ,Mi,heJ lv Tilt tUIRUl Of S VflONVl. ,v!'l vlKb, IM . '* \M1! Nf ",T(!-. l).C. 2Co) I DTH 000120615 '. lOdfJd Page 11 REFERENCE FILE Table Z-: (c) Methods o/ compliance__U) En- pinernr? methods, ip Engineering con M*W ruJ Ii'.rs* tuiMW * * *4 ifuin{ C030*nirki;i>n ACt-ppUM* r*4tlc:tin o+\t sr. '* vi*Ht'c C3*ice:*.irB tion tit bii 6-houf jluU. Coc;:u ration dyrmc-a trols. Engineering controls, such as, but net limited to. isolation, enclosure, ex haust ventilation, and dust collection, shall be used to meet the exposure limits prescribed in paragraph (b) of this section : i * -- *................................ 10 o p *........... *J?P^.............Wp.jn............. ]'. nf^'.iiun -0 ivry.li-.ua ccapccr.ji ........................................ 3J*4.,Vi........... (I!> l.ccal exhaust ventilation, (a) Local exhaust ventilation and dust col V.-si-jr: (mt** (Z3T.^)(T0)..................... 0.1 mf V*.......... -1 2 3 >!................................... Cfci;:.vw. .Jj'i 7.a: 5-u:o>........................... ................................ 0.9 rre M1............................ .............. C*ruu\ .jcty.n v {/j: ................... ?lp? :a........ V P p..............1*' ? p ci............ I'-o. J*.bon ifirxMonJ* ............ ........... ^p;vc............. PX p.y.m........... Jtr.tlomyK4rshtonurs. e'Sjiwr.ul* <iir Jl-JSW............. topptn.............40 P p ta............. Vp.p.T:.............J m!r.u:. ............. iJppx............. SOI p p.c.......... iupp.i'a............4 rr.l."..uri in toy 3 htiin. r v'.r.aM *r4* .73? '4.iw?i............... 3??b.............3 ?P--.............. JOp.p.sj........... 30 rjJnuto. :ty ;*.jcrd* .23: ....................... do..................................................................... U .V-U <Z3.\2<-M.*.................. 3 4 J7.J >l*............................................................... w; IU jftsffiniecoapound* (2jr.ll- 0.3 s:c-/M..... .................... -..................................* lection systems shall be designed, con structed. installed, and maintained In accordance with the American National Standard Fundamentals Governing the Design ar.d Operation of Local Exhaust Systems. ANSI 29.2-1971. which is In corporated by reference herein. lb> See 5 1S10.6 concerning the avail ability of ANSI Z9.C-1971. and the ' rr*t vM-'HwC 17.1'. 2.J*...... ......... 100 p p a........ iOO p.p.a,................ 3.X) p.p.m.............. 3 ralmiCAs In tnv 3 heun. tt.*tyl*n CPJorlda (ZJ?J-t>W)......... . 300p p.a.l.ooo p.p.a.............J,cn p.p.a..... irr.tnu'.M in tay .' hours. maintenance of a historic file In connec tion therewith. The address of the Amer ican National Standards Institute Is vvft* (titTil rtvrurr <Z3?.3J-1M).......... ;)*,*.* *.UT,l3*t^W). ..................... Vlo-o.| pC.pf..a.......?oup^.p,,.a.'..i..............................C......X.....p......p......r...a..............3 rr.JntitM la toy 3 hours. <2J; .................. ....do............ ....do................... JOOp.p.a........... SmiinuMtn nny 3 houn. t'.rv--(217.--............. . ....do...................Uo...... ...................d:...............5 mlnutiM in ft v 3 fccun. J*n. ............................... rx p p.m...... jx ...............CO) p r r............. icmnutM. j;.v*n i-jlT.2 (2Jr,2~l4)................... ..................... .............. Wp p.ii............. 10 :s;r:uttfj cnc Or ly If r.o oth-rr rret.njr tblo h;<mk% '7.3? H#?l)............................... \:zt.:s w.d LSJtSrj.T.iM i2J7.?l*?I... 1 r* i'W 1 0>:cur. , i* h^^rr ne . jr\ uJ iwIS.j-'Ij Htxurfi :j t>.e ?f 5*C` `.n IS I 3 J5!i *\ #ie:r-!rfl fcv it >aj i JiO i.;i *< 2 co*rrr-j '_*n stni-.t ; j;u-j; ' `:rv ,**n \gjj 'c:urr.*J ;o tjpl. j: J-i I k' U* M.f*:i I *. !>*'! T jbJr T..3 -- Mirteiiit Cti4U ,\frrlv-.,mic ? <*r-.*;rr (cr.it Ccuity ir 'fi p^*r.fc* s*l:Wf given in 5 1910.100. (UO Particular tools. All hand-op erated and power-operated tools which may produce or release asbestos fibers in excess of the exposure limits pre scribed in paragraph <b> of this section, such. as. but r.o; iimiteu to. saws, scorers, abrasive wheels, and dn.ls. shall be pro vided with Ic-cal exhaust ventilation sys tems lr. accordance with subdivision til) of this subparagraph. (2) '.V*-'!: or-.'-fices --11 U*--f methods. Insoar as praciicabie, asoesios shall be handled, mixed, applied, removed, cut scored, or otherwise wo-fced in a wet Su^V.n? Mrrw <( . j crpir*V.K.................... ^3* l?ret M - : :.i 33 10 10 90 :i state sufficient to prevent the emission of airborne fibers in excess of the ex (0 posure limits prescribed in paragraph 23 0 <b> of this section, unless the usefulness of the product would be diminished Q :im 'uul ftsio.-> ........................................ rjtjttNt*: k.af r% (.'om CM ccuM cr 'orrr.u.M '** i` ij i/i i l* u t?*r v*:u % fr^"3 (or* -imm tar t.---*l.......... .. 7> rc>iv-2 3rr, M r.r (Cs-cM* r.-to, Th.t r.\ji:rrr.er.; unu*r thu notr **Ur t j ih* u> <*( .n A }.C ir.s:.'cr*.-"C. If ih r^kpirtbie ?'AcU%>n of er.Ti dust :i ^ttf* MRS th r.^urc corr**:^' U.nt tc cm; of 3 4 M* ;.n th U3U for Cuil lUat Is 4.3 .Me MJ S 1910.1001 Ajbtgios. (a) Definitions. For the purpose o' this section. (1) "Asbestos'1 includes chrysotiic. an-.csit*. crocidclite, tre.T.o* llte, ar.thcphyUite. and actir.ollie. (2) "Asbcsoos r.bcrs" means asbestos f.bcrs longer man 5 m:cro;ncters. thereby. (ii> Particular products and opera tions. No asccstos cement, mortar, coat ing. grout, plaster, or similar material containing asbestos shall be removed from bags, cartons, or other containers in which they are shipped, without being either wetted, or enclosed, or ventilated so as to prevent effectively the release of airborne asbestos fibers in excess of the limits prescribed in paragraph lb) of *i Lra ls.cfy> 11* **(.....f.t.*.......................................................................... 4 < / -.3* -t ljrrt ?rct!*.;rewJ. I'm vtiflti n 39 TO9 (b) Permissible, exposure Co airborne concentrations o! asbestos fibers--(1) Standard effective July 7. 1972. The 8-hour tlmc-a-ciuhtcd average airborne concentrations cf asbestos fibers to tills section. (!!U SpraviiiQ. demolition, or removal. Employees engaged in the spraying of asbestos, the removal, or demolition of pipes, structures, or equipment covered 'W* t%t. 1 *-^*-t.......................... F*f. ^ X*I . ......................... ^-sj < *h;< {(Kbin aj (fi.ifi i'\ ;'>>)............... m 19 =or *r. S:0.......... ........................... or w N'yJmf.'-* n.-*4. S PI* ^ '`SCfalfl. ........ rt*l iut....................... . n ts-4. H* >i l*c<. H* which any employee may be exposed shail no: exceed five fibers, longer than 5 micrometers, per cubic centimeter of sir. as determined by the method pre scribed In paragraph <c) of this r.cctlon. (3) Standard effect ire July t. 197S. The 8-hour tur.e-wet'hte.i average air borne concentrations of asbestos iiuors to which any employee may he exposed or Insulated -v:th asbestos, and In the removal or demolition of asbestos in sulation or coverings shall be provided with respiratory equipment m accord ance nnh paragraph 'd)(2i(i;ii of this sectij.t and w.th special clothing m ac cordance with paragraph <d)i3 of this section. fd 1 Personal protretif' revinmenf -- ' '*.-,nr*ran fvu.n- **'<^4 3 - i ;*f cut.'c sih^t .* pur e r - \f % -*r f.t>> * r.\ `,t iif, V i**l on *.*f *l a-r-***o,m.,,* f^ir^i * il ' * > i ) i*\t r, j >* r.n-.r* Y| n *. hfSul* r r* m*-| ('n t.l'UlU 'jir.V.M * ^ *n ''.l.'ft cthf t ** >n . : i *-*v * *p*:!on rtd n'-t'Sk * * %h. ^ -i v -j t *. u* #:**] f*/!o (/it 'ri ikaa ^ --fOi/v >/ . ** i .1 t % Qji/Si um / shall r.ot exceed two libers, longer than 5 micrometers, per cubic centimeter of air. as determined by the method pre scribed l.n paragraph iei of this section. (3) Cei/np concentration. No em ployee shail he exposed at any time to airborne cent iniratlons of asbestos fibers m excess of 10 fibers, longer than 5 tnitrometers. ;>:r cubic centimeter of air. aa determined by ih.e metnod precr.ocd in paragraph (et of thu section (1) Compliance with the exposure limits prescribed by paragraph 'b> of this sec tion may net be achieved by the use of respirators or sh.ft rotation of em ployees. except: <!> During the time period necessary to install the er.y.ncerir.g controls and to institute the *orX practices required by paragraph 'c of tins section: fin In o.`< situations ua which the methods p-'-erlbed ir. paragraph `9* Of 2*Cai a<*Ju'il'4.h *30'**' 10 DTH 000120616 V Page 12 OCCUPATIONAL STANDARDS 57:0*05 this section arc cl liter technically not feasible or feasible to iui extent ::isu:llc:eiu to reduce the airborne concentra tions of asbestos fibers below the limits prescribed by paragraph ib> of bins section; or (1:11 In emergencies. (iv) Where both respirators and per sonnel rotation arc allowed by paragraphs (J)ll'(i). (ii). or tiii) of this section, and both arc practicable, personnel rotation shall be preferreJ and uieJ. (2) Where a respirator is permitted by paragraph tJHU of this section, it shall be selected from among those approved by the bureau of Mines. Department of the Interior, or the National Institute for Occupational Safety and Health, Educa tion. and Welfare, under the provisions of 30 CFR Part II (37 F.R. 62AJ. Mar. 25. 1973). and shall be used in accordance with subdivisions (i). (ii). (iii). and (iv) of this subparagraph. (i) Air fturi/yi/:? respirators. A reusable or single use air purifying respirator, or a respirator described in paragraphs (d)(2) (ii) or (ui) of tins section, shall be used to reduce the concentrations of airborne asbestos fibers in the respirator below the exposure limits prescribed in para graph (bl of this seelton. when the ceil ing or the S-hour tunc-weichted average airoornc concentrations of asbestos fibers are reasonably expected to exceed no more than 10 times those limits. (ii) Powered air ;iunf\./iq respirators. A full facepiece powered air purifying respirator, or a powered air puritying res pirator. or a respirator described in para graph (d)(2j(iiit of this section, shall be used to re.luee the coneemrations of airborne asbestos fibers in the res pirator below the exposure limits pre scribed in paragraph (b) of this section, wb.cn the ceiling or the 3-hour tirr.ewenthted average concentrations of asbestos fibers are reasonably expected to exceed 10 tim.es. but not 100 lim.es, those limits. tiii) Type "C" supp!ied-cir respirators, continuous /Tow or pressure-demand class. A type "C" continuous flow or pres sure-demand. supplied-air respirator shall be used to reduce the concentra tions of airborne asbestos libers in the respirator below the exposure limits pre scribed m parneraph <b) of this section, when the ceiling or the 3-hour ti.'.newct/.otej average airborne concentra tions of nxuestos libers are reasonably expected to exceed 100 times those limits. iiv) Establishment oI a respirator propram. <a> The employer shall establish a respirator program in accordance with the requirements of the American Na tional Standards Practices fer Respira tory Protection. ANSI 33.2-1063. wr.ich t< mrnrnor.-.ted t.v reference herein. (h> be: ii'/iufj eoruanun* the availability f,r ANfil ZTi j-ir.J ar.a tr.c rnainunaner of an ntstortc file tr. connection therrr. nn. The address of ttie American National Standards Lastltute is given in } 1 310.ICO. 'c> No emptevee shall be as.v.med to '.tvslci requiring the iw>e of respirators if. based upon his most recent examination, an examining physician determines that the employee will be unable to function normally wearing a respirator, or that the safety or health of the employee or ether employees will be impaired by his use of a respirator. Such employee shall be rotated to another job or given the opportunity to transfer to .a different po sition whose duties he is able to perform with the same employer, in the same geo graphical area and with the same senior ity. status, and rate of pay he had just prior to such transfer, if such a different position is available. (2) Special clothing: The employer shall provide, and require the use of, spe cial clothing, such as coveralls or similar whole body clothing, head coverings, gloves, and foot coverings for any em ployee exposed to airborne concentra tions of asbestos fibers, which exceed the ceiling level prescribed in paragraph (b) of this section. (4)Change rooms: (i) At any fixed place of employment exposed to airborne concentrations of asbestos fibers in ex cess of the exposure limits prescribed in paragraph ib) of this section, the em ployer shall provide change rooms for employees working regularly at the place. (ii) Clothes lockers: The employer shall provide two separate lockers or con tainers for each employee, so separated or isolated as to proven*- contamination of the employee's street clothes from his work clothes. tin) Laundering: (a) Laundering of asbestos contaminated clothing shall be done so as to prevent the release of air borne asbestos fibers in excess of the ex posure limits prescribed in paragraph (b) of thia section. (b) Any employer who gives asbestoscontaminated clothing to another person for laundering shall intonq such person of the requirement in paragraph (d;(4)(iii) (a) of this section to effectively prevent the release of airborne asbestos fibers in excess of the exposure limns prescribed in paragraph (b) of this section. (c) Contaminated clothing shall be transported In sealed impermeable bags, or other closed, impermeable containers, and labeled in accordance with para graph (in of this section. (e) .'tdhed of measurement. All de terminations of airborne concent.-atlcns of asbestos libers shall be made by the membrane filter method at 400-450 x (magnification) (4 mfilimeter ob;ectivc) with phase contrast illumination. (f) .'! onitcnr.c--(1) Initial determi nations. Within G months of the publi cation of this section, every employer shall cause every place of employment where astxstos fibers are released to be monitored m such tv way as to determine whether every employee's exposure to asbestos fibers is below the limits pre scribe.! In paragraph it) of this sec tion. II the '.'.nuts urc exceeded, the cm plover shall immediately undertake a compliance program in accordance with paragraph (c> of tins section. (2) Prrson.il monitoring--*1) Sam ples shall be collected from w'.tnln the breathing cone of the employees, on membrane filters of 0.8 micrometer po rosity mounted in an open-face filter holder. Samples shall be taken for the determination of the 8-hour timeweighted average airborne concentra tions and of the ceiling concentrations of asbestos fibers. (U> Sampling frequency and patterns. After the initial determinations required by subparagraph (1) of this paragraph, samples shall be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of em ployees. In no case shall the sampling be done at intervals greater than 6 months for employees whose exposure to asbestos may reasonably be foreseen to exceed the limits prescribed by paragraph <b) of this section. (3) Environmental monitoring--(1) samples shall be collected from areas of a work environment which are represent ative of the airborne concentrations of asbestos fibers which may reach the breathing zone of employees. Samples snail be collected on a membrane filter of 0.8 micrometer porosity mounted in an open-face filter holder. Samples shall be' taken for the determination of the 8hour time-weighted average airborne concentrations and of the ceiling con centrations of asbestos fibers. (ii) Sampling frequency and patterns. After the initial determinations required by paragraph (0(1) or' this section.' samples shall be of suen rrequency or.c pattern as to represent with reasonable accuracy the levels of exposure of the employees. In no case shall sampling be at intervals greater than 6 months for employees whose exposures to asbestos may reasonably be foreseen to exceed the exposure limits prescribed in para graph (b) of this section. (4) Employee obserueftort of monitor ing. Affected employees, or their rep resentatives. shall be given a reasonable opportunity to observe ar.y monitoring required by this paragraph and shall have access to the records thereof. (gj Cctufion signs and labels. (1) Cau tion signs. (I) Posting. Caution signs shall be provided and displayed at each location where airborne concentrations of asbestos fibers may be in excess of the exposure limits prescribed in paragraph (b) of this section. Signs shall be posted at such a distance from such a location so that an employee may read the signs and take necessary protective steps be fore entering the area marked by the signs. Signs shall be posted at all ap proaches to areas containing excessive concentrations of alrbcme asbestes fibers. (ii) Sign specifications. The warning signs required by paragraph (g)(l)(i) of lht< section sltail conform to ih< re quirements of 20" x 14" vertical formal signs specified In ! IDiO.li jid) (4). and to tins subdivision. The signs shall dis play the following legend In the lower panel, with litter dees and styles of a visibility at least equal to that specified in tfus subdivision. [Sec. l9l0.100inXIX>*)] 1 1 ' 50 r'tv tit'HKA U OK NATIONAL At'KAtRS. INC.. WASHING 70*1, D C. 2COJ7 >' DTH 000120617 57.CWQG Page 13 Reference fil Lc jcrta Vutatiori AjBasUii______ _________ '* ftASArd____________ J'.i BreMMi 5 Dust__ Wear As.:<:ied rrstecllva Equ-.pnrnt. Du IXoi Rfmtln Jn Arfg Unlj Tour Won Re quire It. i" Sam S<c'.f. Oottile or Uloci. ai`* Tnns 3crtf. O o t h t c or Dluc *. U " Gouxie. Gucmc. k, " Gothic. BrraUunr Astvato* Dust 1* point Gothic. U*j Be H-ts/aju Tu "Your HeAllb. Spacing between lines shs'.l be at leost equal to the height cf the upper of any two lines. t2) Ccuiirtit labels--(D Labeling. Cau- tlon labels shall be infixed to all raw materials, mixtures. scrap, waste. debris, and other prcauct-i ccntainu'.g asbestos fibers, or to their containers, except that no label is required where asbestos fibers have been modified by a bonding agent, coating. tinder, cr other material so that durum: any reasonably foreseeable use. handling, storar.e. disposal, processing. or transportation, no airborne concentra tions ol asbestos fibers :r excess of the exposure limits prescribed in paragraph <b> of this section wd! be released. (ii) Label srt\`:'!c./r:'i>':s. The cau.ion labels required 0> pjrnur.irh tv5(2!ii) Ol' lliit sect;c:t shall be pruned in letters of sufficient sice .iivd contras: at to be readily visible and lee-.bie. The label shall state: Ca-jtiom Conuins .Saaejuss Fibers Avoid G.-eitr.< Dust ntftlae Aa3<s;os Davt I.!a>- Cauic Serisus Dodi.'y H.-m . I) .Vcasebrep:np -- '11 Cleaning. All external suriaccs tn any place of employ ment shall be maintained free of accu mulations of asses toy fibers if. with ti'.C'.r dispersion, there would be an excessive concentration. (2) Wate disposal. Asbestos waste, scrap, debris. ba;s. containers-, equip ment. and asbcsbcs-confHmir.ated cloth ing, consigned for dlspcsai. which tnay produce in any reasonably foreseeable use. handling. storage. prc-cesstnr,. dis posal. or transportation ni.-horre concen trations of .Vibestos fibers in excess of Uiv exposure limits prescribed in paragraph <b> of this .section shail be collected and disposed of In seuied i.'r.prm.ieable ties, or other closed. impermeable containers. <11 /feconJ',.Ci';.'i7--<11 E~>0\ure rec ords. Ilvrry employer si'.all matnuun rec ords of any person d or envirc'tinteiu.il monitoring required by this section. IU-<"orrts shall lie maintained for a ivrirl of at least JO years and sh.alt be made avail able upon rcnmx.l to the Aasistam St<:rruiry of r.slAir for Occupational Safety and 1!<mIUi Use Director of the .Vatlona! testitutc for Occutat:on.il Safety and Health, and to a nth or: red representa tives of eu.-..-'. (2) .-lifC'i. Cmpiniee opiiv.fe records required bv i:.:> (\ira/riipii shall be pro ided upon re jucs! io etr.phneex, des.e- nated representative*. nnJ the Assistant Secretary in accordance wit!t 29 CFR 1910.20 (.i)-(c) and (c)-(i). [95 FR 55212. May 25. WJ; (3) Employee m.'.-f.ve.vne. Any em ployee found to have been export'd a: m.v time to airborne cor.cent.-iilcr.s of asbes tos fibers ip. excess of '.ho limits pre scribed in paragraph ib> of this section shall be notified in wr.tu-.i of the expo sure .as soon as cractic.'.cle but not later than a days o: tl.o findin*. Th.e employee shall also be timely notified of the cor rective action being tel-:on. tj) Medical ezaTnir.r.liors--(I) Gen eral. Tlie employer shall provide or make available at his cost, medical examina tions relative to exposure to asbestos re quired by this paragraph <2) PrepLacement. The employer shall provide or make available to each of his employees, within 30 calendar days fol lowing his firs: employment in an occupation exposed to airborne con centrations of asbestos fibers, a compre hensive medical examination, which shall include, as a minimum, a chest roent genogram (postcrtar-ap.terior 14 x 17 inches), a history to ciicit symptom atology of respiratory disease, and pulmonary funetten tests to include forced vita! capacny <FYC) ar.d forced expiratory' volume at t second u-'2V. si. "(3) Annual ezammofio-.r. On or be fore January 31. 1373. and at less: an nually bhereaiter. every employer shall provide, or make available, comprehen sive medical examinations to eocr. of his employees engaged ir. occupations ex posed to airborne ccr.cent.-atioi'.s of as bestos fibers. Such annual examination shall Include, as a minimum, a chest rc-entgenegram <posterior-anterior 14 x 17 Inches), a history to eilcit symptom atology of respirator:.' disease, and pulmonary function tests to include forced vital capacity (FTC) and forced expiratory volume at 1 second <rilVf,,). (4) Termination. o/ employment. The employer shall provide, or make avail able. within 30 calendar days before or after the termination of employment of any employee engaged in an occupation exposed bo airborne concentrations of asbestos fibers, a comprehensive medical examination which shall include, os a minimum, a chest roentgenogram tpos terior-anterior 1 i x 17 inches), a history to ehett symptomatology cf respiratory disease, ar.d pulmonary function tests to include forced vital capacity <FVC> and forced expiratory volume at 1 second (HV,.). (0i Recent ersvtinc.'iont.'No medical examination is required of any em ployee. if adequate records show that the err:p!ov- h teen examined in ac cordance Aith tins paragraph within the past 1-year period (G) Jfedir-; records -- `1) Mctntcnar.ee. IC.r.gl-.. er; cf cm;'!;-rri examined purv.ior.t to this par`.ur.-.pn .'nail cause pi re maintained comp let-* ar.d accurate records of u.i such medical examina tions. Records shall be retained by employers for at leas: 30 years. (ii) Access. Records cf the medical examinations required by ihis paragraph s.inil be prowJed upon request to em ployees. designated representatives, and Assistar.. Secretary in accordance with 29 CFR 1910.20UMS) and ic)-(i). These records sh.'.ii also he provided upon the request to (he Director of MOSH. Any phvsieiar. who conducts a medical exam ination required by this paragraph shall furnish to the employer of the examined employee ail ihe information specifically required by this paragraph, and any other medical iniormatiori related to occupa- lional exposure to asbestos fibers. [45 FR 35212. May 23. 1950: 45 FR 54333. August 15. I9S0] 1910.10152 Coal tu pitch volatiles; in terpretation of term. As used i.n See. 1910.100-3 t Table Z-1 haul tar pitch volatiles include the fused poly cyclic hydrocarbons which volatilise from the distillation residues of coal, petroleum, woo<i. ar.d other organic mat ter. 1910.1903 4-Nitrohipheny|. (a) Score end application. (1) This secuor. applies to any area in which 4-Nitrobiphcnyl. Chemical Abstracts Service Registry Number 92J33 Is manu factured. processed, reyackaecd. re leased. handed, or stored, but shall not apply to trai'.rshipmer.t in scaled con tainers. except for the labeling require ments under paragraphs te) <2). (3), and (4) of this section. (2) Tl-ds seetton shall not apply to solid or liquid mixtures containing less than 0.1 percent by weight or volume of 4-Nitre-binhcnyl. (b) Definitions. For the purposes of this section: (1) "Absolute filter" Is one capable of retairdng 99.97 percent of a mono disperse aerosol of 0.3 particles. (2) "Authori2ed employee" means on employee whose duties require him to be In the rcT-dhted area ar.d who has been specifically assigned by the employer. <3) "Clean change room" meatus a room where employees put on clean clothing and/or protective equipment in an environment free of 4-Niiroblphenyl. The clean change room shall be con tiguous to and have an entry' from a shower room, w-hen the shnwet room facilities acre otherwise required in this section. (4) ''Closed system" means an opera tion involving 4-ffitrcbiphenyl where containment prevents the release of 4Nltrcblphenyl into rr gull led areas, tionrcir-'duted areas, or the external environ ment. (5) "Decontamination" means the In activation of -t-NitrcbiphiTvyl or its safe disposal. (G) "Director" means the Director. National ` Institute for Occupational Safety and Health, cr any person di rected by him or the Secretary of Health. Education, and Welfare to act for the Dli ex tor. c A Cbem.cji P<rq-,,;.,ticn H l^oc. 131C )C0>b<Si| 12 DTH 000120618 APPENDIX C Lake Chart** VCM Plant DATE: ^ ,-v.- Conoco Chemicals Company A Division of Conoco Inc. PO Box 605 Westlake. Louisiana 70669 (318) 491-521 1 U.S. Environmental Protection Agency Air Facilities Branch, Region VI First International Building 1201 Elm Street Dallas, TX 75270 Re: Asbestos Removal - Notification Dear Sirs: This letter is to inform you of our intention to remove asbestoscontaining pre-cast insulation from existing equipment on (1). This removal is necessary to __________________________(2) and will generate approximately (3) of insulation, (1) Fill in inclusive date. (2) Fill in why?, repair tracer, make tie-ins, etc. (3) Insert unit measure of insulation to be removed, e.g., 300 feet of 1-inch thick insulation on 2-inch pipe or 180 square feet of 2-inch thick insulation on 10 feet diameter tank. It should be noted that we require our personnel and contractors to use the wet method for asbestos removal discussed in 40 CFR 61 and 29 CFR 1910.1001. All insulation containing asbestos material, scrap, debris and asbestoscontaminated clothing will be stored wet in sealed pre-labelled asbestos bags until shipment. We plan to continue to notify you at least 10 days prior to any shipment. Please contact us if you have any questions. Very truly yours, J. A. DeBernardi Plant Manager br cc: JWW-MGH-RB-MLA-DLD-JRH-SRA x 000120619 dth Page 15 APPENDIX D Lake Charles VCM Plant Date: --* * i ; 1 ). m** Conoco Chemicals Company A Division of Conoco Inc P O Bo* 60S Westlake. Louisiana 70669 1318) 491-521 1 U.S. Environmental Protection Agency Air Facilities. Branch, Region VI First International Building 1201 Elm Street Dallas, TX 75270 Re: Asbestos Removal - Annual Notification Dear Sirs: This letter is to inform you that we anticipate the removal of asbestoscontaining pre-cast insulation from existing equipment during the next year. We currently do not have any planned removals. However, historically, we have found it necessary to remove some of this insulation due to routine maintenance, e.g., valve replacement of steam leaks, making tie-ins, repairing steam tracers, etc.. We do not anticipate any single removals of nearly 260 feet of pipe insulation or 160 square feet of flat insulation; however, because we accumulate this material prior to disposal, there is a chance we may ship more than this amount at one time. Note that we plan to continue to notify you at least 10 days prior to any shipment. Also, we will notify you of any significant removals (greater than 260 feet of pipe or 160 square feet of flat insulation) in advance if possible, i.e., it is not an emergency removal. It should be noted that we require both our personnel and any contractors which we employ to use the wet method for asbestos removal discussed in 40 CFR 61 and 29 CFR 1910.1001. After removal all asbestos-containing material, asbestos-contaminated clothing and debris are stored wet in sealed pre-labeled plastic bags until shipment. Please contact us if you have any questions. Sincerely, J. A. DeBernardi Plant Manager br bcc: JWW-MGH-R8-MLA-DLD-JRH-SRA 000126Z0 APPENDIX E (.aka Charles VCM Plant DATE: r"> CD Conoco Chemicals Company A Division of Conoco Inc P.0 Box 605 Westlake. Louisiana 70669 (3181 491-5211 State of Louisiana Department of Natural Resources Hazardous Waste Management P 0 Box 44066 Baton Rouge, LA 70804 Re: Asbestos Disposal - Notification Gentlemen: Conoco Chemicals VCM Plant wishes to inform you of our intended disposal of approximately (Quantity) C.Y./# of asbestos material removed from (Source: Pipe, Tank, etc.) insulation. This material is temporarily located at VCM Plant Road, Westlake, Louisiana, 70669, and will be hauled by (Transporter: Name and Address), (EPA No.) on (Date) 1982. The material is wetted and sealed in pre-labelled asbestos bags and will be disposed of at (Landfill: Name and Address), (EPA No.). This landfill is approved to handle industrial waste No. 27. Please contact us if you have any questions. Very truly yours, J. A. DeBernardi Plant Manager cc: U.S. EPA Air Facilities Branch, Region VI First International Building 1201 Elm Street Dallas, TX 75270 bcc: JWW-MGH-RB-MLA-DL D-J RH-S RA Environmental File 000120621 DTH 1. MANIFEST NUMBER 0o8 7 APPENDIX F . state of Louisiana DEPARTMENT OF NATURAL RESOURCES HAZARDOUS WASTE MANAGEMENT For Dept. Use Index Date 2. WASTE INFORMATION: HM SHIPPING DESCRIPTION /sstu. ? o i i :_____________ -1 n c. y/Y~ / HAZARD CLASS ' J _ WASTE NUMBER j "i t. --, . / ' -4 * / > WEIGHT (TONS) y i. ` -J '. - _2-/ >./ 7S / PACKAGING QTY TYPE 1 Dumos P.i-t'L. '5',Ts *? O : T ; 1 i)"< 1 ,-,J -Jc'4/ ~j y-t l 3 GENERATOR INFORMATION: Identification Number: NAME OF company- FcnocO r.ie-nicais n.n_^vi Tplpphnne- 491- 5437 annpFCC- SHIPPING LOCATION: 'OK 808. *-*stlnks. L A "l'1 C '-nr . 'C-i "'n-n 7ip- 70669 r- CERTIFICATION: This is to certify that the above-named materials are properly classified, described, packaged, marked and labeled, and are in proper condition for transportation according to the applicable regulations of the Department of Trans portation, and the Louisiana Department of Natural Resources. -.v-%. -:~ .- '.`v /.y .f Gertrstoi S^atut*. Oar* - . L. ' ! - c J u x--,r ; 4. TRANSPORTATION INFORMATION: Identification Numner:. _____ Telephone: NAME OF COMPANY:____ _________________________ DATE OF PICK UP:. 3-- DATE OF DELIVERY: ' i 832-0539 t HiTIME: TIME CERTIFICATION: This is to certify that the above-named materials were picked up at the date and time above, that the above named materials were delivered without incident to the disposer at the date and time above, and that to the best of the transporter's knowledge, his portion of the manifest is accurately and correctly filled out. . . Trnaonr :yst >* P*l* . riTson^r.'? ...j Ili-i - 57 DISPOSER INFORMATION: ldahtifinaimn'^Iinc<ir:::j.p ^0 ' NAME OF COMPANY:___________LZI__________ p^Q,;f =?] j-527-6S57___-- Telephone: 88?-05 30 LOCATION WHERE SHIPMENT RFCFlVFry SF!: V/ASTE' SYSTEMS ; r~~;r-"1 .,'estlake. LA~- CERTIFICATION: This is to certify acceptance S^JhAjiasaFftCj<STYaste'that the waste has been or will be disposed of in accordance with Department of Natural Resourcq^efJ.ycX^BptSiRgt.to the best of the disposer's knowledge, his portion is accurately and correctly filled out. 0<eotr S^atyr* 6. EMERGENCY INFORMATION: W'S-LAKE, LA P.0. BOX 54IS LAKE CHARLES, LA 70606 -ffA-cU&lOSStiBSS- ; *.vV-vv,:. /z-yj-ss ' : :rv Immediate Response Information: Telephone: Special Handling Instructions: Comments: * I f f or -jny r iascn ..s ;i ;.:cs ,1j -T i n ,, ,,3 :f- . j i i C <* s :o; icc.-Dt .',<1 i _.vonc, t.ij transporter is to'return c^c:d7 DTH 000120622 DISTRIBUTION Whit - Gf9*nAtor. Gf een* Tr <*n j porter. Canary Disposer. Pink S t Jt, Golden rod Fil