Document 6Bn3ZV39dy3qEOk77Lj8XVxm3

INTER-ORGANIZATION cc: H. E, Jewett R. W. Laundrie E. R. Senra J. E. Simon H. Graff TO: R. L. Jackson ATTENTION: VCS/T FROM: Jerry Brumbaugh DATE: October 12, I98I SUBJECT: Vinyl Chloride Safety Meeting September 24 and 25 1981 There are 46 companies represented in the Vinyl Chloride Safety Association -- 25 from the U.S. and 21 outside the U.S. 1. Major Safety Incidents a. Furan Process Sewer Explosion John McCulley Conoco A collection vessel for spent furan exploded. This was an above the ground fiberglass lined vessel rated at 50 psig. The tank was not grounded and the incoming pipe was above the liquid level. Traces of copper and peroxides were found in the residue of the plant. There were no injuries from the explosion. Possible causes of the explosion were -- static spark, peroxides and large volume of air in the vessel. They tried to correct all three causes by -- 1) Using a R2 purge on the vent system. 2) Controlling pH by addition of caustic. 3) Replacing with steel vessel and grounding the vessel, 4) Have incoming line go below liquid level. b. Control Room - Laboratory Explosion Bob Oubre Dow: Canada FORM 1 KINO In a vinyl chloride plant at Dow an explosion occurred in the laboratory injuring four employees. A leaking caustic drain valve from a scrubber designed to remove acid from VC1 drained large amounts of VC1 into the process sewer. This was also the process drain from the laboratory. The VC1 vapors went backwards in the sewer and out the floor drains into the laboratory. The laboratory is a non-explosion proof area. When sufficient VC1 collected in the lab, it exploded, destroying the lab and blowing concrete blocks into their control room. The lab was designed to stand an explosion outside the lab but not an inside explosion. This is another case where flows going the wrong direction from the planned caused a hazardous situation. "BETTER Service Is Our Business' 6ENC 015433 . L.. Vinyl Chloride Safety Meeting 2- - The corrective action taken was: 1) Separate lab from process sewer. 2) Blind caustic drain line when not in use. 3) Install liquid traps in process sewer. c. Nitrogen Inhalation Incident Glen Scbaaf b. F. Goodrich A mass autoclave was being prepared for entry for maintenance. The autoclave was pressured to 50 lbs. with nitrogen then vented to atmosphere. The vessel was blanked and locked out. A maintenance man who did not routinely enter vessels, then entered the vessel without purging the vessel or wearing a -respirator. The vessel had not been tested for VCM or 02- The maintenance man passed out for lack of 025 and his alarm system warned fellow workers. The main tenance man was wearing an alarm system that must be acknowledged or a general alarm is sounded. The lead technician entered the reactor with 2 respirators and rescued the man. B. F. Goodrich found: 1) People do not understand N2 -- think it is safe. 2) Do not know the importance of VCM and O2 analysis. 3) O2 measurements were not always taken. U) Check sheet was being filled out prior to doing the work. B. F. Goodrich has started further training and tighter vessel entry procedures. d. Lauryl Peroxide Fire Ron Kalminski B. F. Goodrich In the Plaquimine, La. resin plant, an operator added LK) to an empty autoclave through an open manway. The jacket was at 80" C instead of the normal 40 C. The reactor was blanked off and the VCM level in the reactor was low. While he was installing the gasket on the manway, he was badly burned from a fire in the autoclave. The LPO on the bottom Of the reactor decomposed into r.lammahle gases which ignited. This was demonstrated to occur by later tests in the lab. Other operators have done this -- put LPO in a hot, empty reactor -- and not been burned, but in some cases the reaction did not start either. The practice of adding LPO to a hot reactor has been stopped. GENC 015484 Vinyl Chloride Safety Meeting -3- e. VCM Column Explosion Ron Kalminski B. F. Goodrich This report was not given in sufficient detail for me to understand. Ron Kalminski was giving this presentation because the person who was familiar with the incident was unable to attend. However, B. F. Goodrich at their VCM plant in Convent, La. had a waste gas decomposer explode. This was a liquid scrubber which de composed the EDC in the vent stream, (a liquid oxidizer serving the same function as our incinerator). On this day the level gage was out of service, and there was a much larger than normal vapor space in the scrubber. To correct this situation they have taken steps to make sure the column remains full. Any further details may be received by a request to the Convent plant. . f. Reactor Lockout Device Report Glen Schaaf B. F, Goodrich B. F. Goodrich is investigating with the Best Lock Company, a system of manually interlocking valves. This system would be de signed to eliminate the possibility of opening a drop valve-while the reactor is running. Likewise, it would eliminate the possibility of charging with the drop valve open -- -which we do occasionally. Literature describing a system made by Castell was made available during this session. The idea behind both systems is to have a lock and key system that would force operators to open and close valves in a required sequence. The system could be designed so the operator could never open the drop valve unless the charging valve was locked out. A simple system would be with two valves on a reactor that must not be opened at the same time. M Valve A M Valve B GENC 015485 Vinyl Chloride Safety Meeting -4- To prevent Valve A and Valve B from being opened at the same time, both valves are locked using the same key. When either valve is open, the key cannot be removed from that valve, and the other valve must remain closed. This system can be made as. complex or as simple as you need to control the process. This appears to be something we should investigate. g. Polypropylene Plant. Fire ' Darwin Rhoads Amoco An explosion destroyed a polypropylene plant at New Castle, Delaware because maintenance employees removed the wrong bolts from a pneumatic valve controller, and the contents of the 10,000 gallon reactor escaped into the atmosphere. See attached OSHA writeup and hazard alert. (Attachment I) 2. Small Reactor Safety Survey Report Jerry Brumbaugh General Tire See Attachment II for summary of this safety survey report. 3. Regulatory Update a. EPA (our best guess) John Barr, Air Products EPA section: Gary Baise Law Firm of Beveridge & Diamond The proposed EPA revised VCM standard will be withdrawn, and in its place will be a proposed standard with the following changes: -- The new standard will not include offsets or a zero goal for VCM emissions. -- No change on the 10 ppm allowable discharge of vent streams (incinerator discharge) -- EDC production using oxygen instead' of air would be investigated. -- No change will be proposed on residual VCM in the slurry - present level of 400 ppm will be maintained. -- Fixed monitoring requirement will be withdrawn from the leak detection program. ' : -- Will require best available technology (B.A.T.) on leak detection and repair. B.A.T. will be defined by EPA and will be the best system they have seen at FVC plants. GENC 015486 Vinyl Chloride Safety Meeting -5- -- Some relief on the requirement to test every reactor opening. No proposal on lowering the reactor opening losses. --'Do not see any need for further regulation of PVC landfill operations. b. OSHA Current OSHA standard will not be changed for 2-3 years until OSBA's carcinogen policy is complete. Cannot use Cost/Benefit for Health standards but must show health effects at present levels. May be some restrictions placed on union or labor representatives' access to medical records, . No further restrictions on the individual's right to see his own records. 4. Hazardous Materials Notification Harold Dubec Hooker Hooker was introducing a new molecular weight modifier (technology purchased from another company) into their plant. The union did not seem upset at the time but later -walked out and went on strike. At first the use of this material was not a major issue, then it became the only issue. Hooker felt it did not properly inform t'he union personnel of the safety and health concerns with the new material and left themselves open to criticism. Hooker also felt the union used the introduction of this material as a reason for their actions after they had gone out on strike. Anyway, the news media, OSHA, EPA, and union health experts- became involved. After the end of the strike Hooker had 5 OSHA inspectors and 3 EPA inspectors go through the plant, and Hooker received citations from EPA and OSHA. Hooker stressed the need for communications with the union and the com munity on the type and amount of chemicals (hazardous or otherwise) handled in a plant. 5. OSHA Respirator Protection Dave Lull Diamond Shamrock Only 3 companies require respirator protection when the monitor registers 1 ppm. All require it when it is at some level higher than this -- 3 ppm or 5 ppm. Nine companies exclude has changed its policy and will allow women to work in regulated areas. Air Products has determined they have no reason to exclude fertile women from regulated areas. GENC 015487 t Vinyl Chloride Safety Meeting 6- - 6 * Operator Training Survey Report See Attachment No. III. Doug Frey Diamond Shamrock 7. Computer Safety Survey Report See Attachment No. IV. Jim Gabbett Georgia 8. VCM Safety Condensation System B. Terwiesch Chemische Werke Huls. A system for condensing the V.C. escaping through a relief valve on a reactor was described. This system is covered by U.S. Patent No. 4004880, dated January 25, 1977- The vapor from a relief valve is vented through a large K.O. tank to a condenser. The condenser is sized so it can handle the maximum flow through the relief valve. The vinyl chloride is condensed and collected as liquid V.C. The cooling water storage is located above the condenser so it will travel by gravity through the con denser. System is designed to be self-sufficient, needs no external energy source. This is a system of large equipment and high capital investment. It has proven itself in operation in Germany, but I doubt if we could,afford this kind of installation. 9. Summary of OSHA/EPA Inspection Questionnaire See Attachment No. V. 10. Fluid Bed Dryer Explosion and Fire John McCully Conoco During a dryer startup, the inlet air temperature to the plug flow . section of the dryer reached 215 C. The dryer was shut down. An exhaust fan was started to purge the HC1 from the dryer. Immediately there was a mild explosion and fire inside the plug flow section. Based on lab tests and other similar experiences Conoco concluded: -- PVC resin and dry blend decomposition can become exothermic at 185 C when exposed to air at atmospheric pressure. The explosion and fire in the fluid bed dryer probably was an exothermic decomposition of PVC. 11. Vinyl Chloride Rail Car Accident E. Weekly Pantasote A slide presentation of the derailment of VC cars at Point Pleasant was given. JB: sm GENC 015488 t i i '-' . . ' "^vTv'-V^-;- -.-.-''i-YY j , : *jiS,'" ,'?t- ' . ' , 'ATTACHMENT- I '.?" . ,^ OSHA Issues Hazard Alert in Wake of Amoco Explosion Y To , prevent, further tragedies like ..the . , October, 1980 fire and explosion-at the -Amoco,.New Castle'Delaware polypropy^ ' Y`. . -,-lcne plant which leveled the plant, killed six ` - : .' ^"people and injured 28 .others,- the' OSHA'-Y/: Philadelphia.' Regional Office .sent outa'Y/ y- hazard alert to OSHA compliance officers.-Y/ /'and others in the chemical process and oil- Y Vindustries,- Y- YY/:/?7-YYY-- t^Silhe.alert addresses the underlying'cause . the Amoco explosion -- failure to train / craftsmen that removing attachments to ' block valves will cause the valve itself to fall '' - ' _ apirt as the attachments'--in this case a r- pneumatic controller--are'an Integral part Y'of the.Valve as shown in the sketch on this YY.vTbc following is excerpted from the Alert 1 -/Sent out by OSHA Regional Administrator v \ David Rhone. It should be studied carefully v-'.by all OCAW members in the oil apd ' chemical process industries."Y \-s<rh,Y\ r.f.: >Y..;-Ihe, employers' responsibilities . with . - - regard to this hazard include but are not : -' necessarily limited to the following items: Y 1, Mechanics or operators whosejob it is to assemble, adjust or disassemble valves or attachments to valves shall be trained in the safe assembly, disassembly, . pr_ . ' adjustment of each type of valve-- - attachment assembly.. ; '. 2. Mechanics or operators who have not ' been so trained shall not be assigned to perform such duties without supervision by those foremen or operators who have /. been trained. OCAW HEALTH AND SAFETY NEWS VoL 8. Nos. 1, 2 . - April 1981 Published in cooperation with the OCAW Union News, 1636 Champa St., Denver, Colo. 80202. . - E. J.'Rousselle, Vice President Anthony Morxoechi Director, Health and Safety Dept. . 3. 'Attachments to valves which regulate : YY hazardous materials shall not be con `i\ ; nected to the valves with the same bolts -.-YYwhich preserve the integrity of the valve, ^without assurance that such attachments ' : would not be removed while the valve is .in service.. Background: A recent investigation of an explosion and fire at a chemical plant revetted that when workers removed the pneumatic controller from a block valve, the .valve itselffell apart. The reason for this was that the bracket which connected the controller to the valve was attached to the valve with the same four bolls which held the bonnet of the valve to the body (sec sketch). Syltic krcki-: Occupational Health Specialist kofael Moure < ' Industrial Hygienist Steve Wndko, Inti, Representathre Items of interest for Ihe May issue ' should be sc-nt In by April 20. ;' Subscription price for non-members is 55 per year. On October 21, 1980 four mechanics were assigned to pcrformaslurrylinecleanoutfor a ten thousand gallon polypropylene reactor. The slurry line tan from the bottom of the reactor through a pump, a slurry cooler (heat exchanger) and then back to the -top of the reactor through a four inch line. The slurry line had been isolated from the system bythe closing of the two block valves, one at the top and one at the bottom of the reactor. Each block valve had a pneumatic controller attached but the connecting -mechanisms wtre different. The valve at the ..top was a plug valve. The controller was attached to a bracket which was in turn 1 attached to the valve bonnet by the same bolts which held the bonnet in place. The valve at the bottom was a ball valve. Because of its configuration the same type of bracket connection could not be used. The controller on this valve was connected to a bracket which in turn was held in place by two large *TT" bohs which attached around the top and bottom flanges of the valve. The mechanics split into two groups. Two men began opening lines at the top of the reactor while the other two broke the linesat the bottom. They cleaned out the slurry lines and broke'for dinner. When they returned they were asked by the chief operatorto rodout the block valve at the top of the reactor. That valve still had the controller attached. The company operating procedure required that the controller be removed prior to the opening of any lines to determine the position of the valve, but since this had been overlooked, the mechanics decided to remove it even though the valve was obviously dosed. It was at this juncture that the two mechanics made the fatal error. They removed the four bolts which attached the bracket to the valve. Those tame four bolts held the valve together. Upon removal, the plug and bonnet shot out and contents of the reactor, ten thousand gallons of propylene and hexane at 150 psi, poured out through the four inch opening. An enormous gas cloud formed and within lluce minutes an explosion occurred which could be beard over ten miles away. GENIC 015489 ATTACHMENT II SMALL REACTOR SAFETY SURVEY REPORT GENC 015490 Question Mo. 1: Most Important Safety Considerations What are some of the most important safety considerations that you would investigate to evaluate the overall plant safety status? (a) Containment of vinyl chloride Number of Replies 1 Relief valve and rupture disk system and condition 2 Emergency relief containment capacity and recovery system 3 Cooling and electrical backup for reactors 1+ Reactor controls 5 Unloading and storage and handling of VCM 6 Reactor S/s system 7 Control of reactor bottom valve 8 Emergency shutdown systems 9 Agitator alarms 10 Reactor area manned at all times 11 Maintenance records for vessels .in VCM service 12 Vessel integrity program `. (6) (3) (3) (2) (2) (2) (1) CD (1) (1) (1) (1) (b) Contingency - preventing fires and explosions in the event of V.C. escape 1. Fire protection system 2. Plant layout 3- Presence of safety equipment 4. Plant emergency plan 5- Electrical equipment properly grounded 6. Use of fire safe valves 7- Ability to handle large quantities of V.C. gas (6) (4) (2) (1) (1) (1) (1) (c) Good safety and operational management 1. Up to date procedures - complete operating manual - plant follows procedures 2. Training ana education of all personnel 3- Maintenance status - P.M. program 4. Housekeeping 5. Attitude of management and personnel 6. Safety organization 7- Operator involvement in safety 8. Inspection system 9* Engineering standards - design criteria being followed 10. Proper raw material storage 11. Regular safety sessions 12. Inter-action between Production and Maintenance (H) (10) (7) (6) (5) (2) (1) (1) (1) (1) (1) (1) (d) Indicators 1. Past Records - frequency and severity records 2. Monitoring and emission records 3- Most recent systems safety analysis review (4) (2) (l) 6EHC 015491 Question No. 2: Reactor Discharge Valve Control How do you prevent the wrong reactor from being opened? 1. 2.' 3. 4. 5. 6. 78. 910. 11. 12. 13. 14. 15- Operator training and procedures Clear identification of reactors Mechanical locking system - two people to open Discharge port is covered with a locked cover' Fixed discharge piping - batch always contained Reactor discharge valve interlocked with reactor pressure Two valves Software' interlocks Warning light system - indicates safe to open Electrical interloekk Communications Pressure gauge mounted beside valve Slow opening valves - time to discover mistake Drop valve actuated from reactor top - near.pressure gauge and sight glass Working on a locking device Number of Replies (8) (6) (U) (4) 00 (3) (2) (2) (2) (1) (1) (1) (1) (1) (1) Question Ho. 3: Charge Volume Control (a) How do you measure water, VCM, catalyst, suspending agents? Water VCM Catalyst Suspending Agents Weight 0 7 9 8 Meter 15 10 0 2 Volume 1 1 3 1 (b) How do you prevent over or under charging? 1. Visual checks on levels 2. Operator training, procedures, signing charge sheet 3. Calibrating meters - maintenance 4. No independent mechanism to prevent over/under charging 5. N/A 6. Dual meters 7- Computer controlled (c) How do you control charging sequence? 1. Operator training and procedures 2. Computer 3. Sequence controlled by mechanical stepper switch 4. n/a 5. No answer (7) (6) (3) (2) (2) (1) (1) (12) (3) (1) (2) (2) GENC 015492 Question No. 4: Gasket Replacement Control (a) Do you replace gasket -- 1. After each opening Yes No No Answer N/7 75 7 l 2. After major -maintenance 15 0 4 l 3. Once per year .. ; ' 3 1 Ik 2 Number of Replies (b) Pressure of the pressure test -- 1. After each opening psig - 50, 200, 90, 30, Vacuum, 80$ of R/D rating, 15" Hg vacuum 2. After major maintenance psig.- 100, l4o, 150, 85, 120, 150, 135, 120, 180, 60, reaction pressure, rating 10$ 3. Once per year psig - 170, 175, 180 (c) How often is a manway gasket re-used? 1. Inspected visually and re-used if passes inspection 2. Never re-used 3. 10 - 15 times 4. 10 - 20 charges 5- 50 charges 6. 100 - 150 charges 7. No answer 0-Rings 10 (d) Are your manway gaskets O-rings or flat gaskets? Flat N/A 82 (8) (3) (3) (1) (1) (1) (2) Question No. 5: Safety Valve Control on Reactors (a) How often do you inspect your safety valve nozzle? 1. Each time the reactor is entered or opened 2. After every charge 3. Approximately every 3 days 4. Once per week 5. Once per month 6. Once every 30 - 50 batches 7. Two parallel relief nozzles - each with 2 rupture discs and no pop safety valves 8. Do not use safety valves on reactors - use double rupture discs 9*- No answer (7) 00 (1) (1) (1) (1) (1) .(1) 00 GENC 015493 Question Mo. 5: Safety Valve Control on Reactors (b) How often do you test your safety valves? 1. Once per year 2. Every 6 months 3- N/A . .. ..... Number of Replies (14) (1) (5) (c) Are safety valves removed and cleaned after each release? Yes 15 No 0 Yes was the only answer if the question was answered, except -- "no reactor releases - should be done - no policy." Question No. 6: Reaction Shortstop (a) Do you have a reaction shortstop system? Yes 17 No 2 N/A 1 Automatic Operator No answer (b) Is the injection automatic or done by an operator? 5 16 3 If automatic, what initiates the operation? -- Agitator RBI -- High reactor pressure -- Loss of power to agitators -- Over pressure or temperature or loss of agitation -- Loss of agitation, agitator motor, high water pressure, power failure GENIC 015494 Question No. 6: Reaction Shortstop (c) Is this system independent for each reactor or a common system for several reactors? Independent 10 Common 6 Both systems . 1 No answer 4 Number of Replies (d) How often was your system operated last year? Less than 10 6 10 to 100 times 4 Over 100 times 4 N/A 6 Many times the shortstop system was used in non-emergency situations. (e) How often was your system tested last year? Daily 2 Weekly 1 Monthly 3 Yearly 1 N/A 13 Question No. 7: Reactor Pressure Control (a) How do you prevent pluggage in reactor pressure transmitters? 1. Water injection 2. Inspection and manual cleaning 3- Solvent cleaning system 4. Dual pressure systems 5- N/A 6. Not a problem (6) (10) (l) (2) (1) (l) GB'IC 015495 t Question No. 7: Reactor Pressure Control (b) Do you have alarms for high pressure? Yes 18 No answer 1 n/a 1 (c) Approximately what percent of normal operating pressure is the alarm set for? 1. Less than 110% 2. Between 110 - 120% 3. Over 120% k. No answer Question No. 8: VCM Pump Control What protection do you have to prevent remote operated VCM pumps from starting with suction and discharge valves closed? 1. Operator training, procedures, etc. 2. Automatic valvesinterlocked with pump 3- None ' U. Wo answer 5. CRT display 6. No remote pumps Question Wo, 9: VCM Storage Tanks (a) Do you have sprinkler protection for your VCM storage tanks? Yes 20 No 2 -- Use monitor nozzles on older installations. -- No, for some larger tanks Number of Replies (9) (5) (2) (4) (5) (5) (6) (2) (l) (l) GENC 015496 Question No. 9: VCM Storage Tanks (b) How often are these tanks opened for internal inspection: 1. Once per year 2. 2 ~ 5 years 3. 6 - 10 years 4. Over 10 years 5- No regular basis 6. No answer . . (many useultrasonic inspection) Virgin monomer tanks inspected infrequently. Day tanks inspected more frequently. Number of Replies (3) (8) (3) (2) (3) (1) (c) Have you had any corrosion problems in VCM storage tanks? Yes 4 No 16 Those indicating they have corrosion problems are in recovered VCM tanks or day tanks, not virgin VCM. Question No. 10: Recovered VCM Handling (a) Do you distill your recovered VCM? Yes 3 No 17 N/A 1 (b) How do you control polyperoxide formation in your recovered VCM system? 1. Short retention time 2. Add an inhibitor 3. pH control - keep basic 4. Keep O2 levels low 5. No precautions taken 6. No answer (7) (6) 00 (3) (3) (3) GENC 015497 Question No. 11: Reactor Entry Do you require: 1. All flanges "blinded 2. VCM flanges "blinded only 3- Manway watch 4. Mechanical manway watch 5- Safety belt only 6. Safety belt and wristlets only (3 answered - wristlets only) 7* Safety belt and wristlets with line attached (2 answered - safety belt with line attached) 8. Lab entry analysis VCM/O2 9- Portable analyzer entry analysis VCM/02 10. Respirator worn at all times n. Respirator worn at certain jobs 12. Gloves to be worn No Yes No n/a Answer .13 6 1 3 12 16 4 1 1 5 4 11 1 4 6n 2 11 1 1 3 3 2 12 1 3 2 i4 17 2 15 3 66 13 4 1 1 1 2 1 3 1 6 2 GENC 015498 I ATTACHMENT III SUMMARY OF OPERATOR TRAINING QUESTIONNAIRE The following is a summary of the 32 responses to the operator training questionnaires: 1. What is the approximate number of people in your total work force involved in manufacturing?. 0 to 100 100 to 300 300+ 19 8 6 Some responses covered several different plants. 2. Do you have a formal training program for operating personnel: Yes 28 No 4 3- Does your plant organization have a fuTlrtime person whose primary responsibility is training? Yes 17 No 15 4. If your answer to No. 3 is "yes," to which functional part of the organization does this person report? (Employee relations,, manufactur ing, technical, etc.) Typical responses: a. Manufacturing department (8 responses) b. Employee relations department controls overall program with a coordinator from the manufacturing department implementing most of program at unit level (4 responses) c. Employee relations d. Safety e. Technical 5. If your answer to question No. 3 is no, who in your organization is primarily responsible for training? Typical responses: a* Operating supervisor or foreman b. Safety Department c. Manufacturing engineer d. Personnel 6. How long does the typical operator spend in the training program? At least half of the respondents indicated the length of their program as 3 to 6 weeks. GENC 0154?? Page Two Summary of Operator Training Questionnaires 7- Is your program one continuous cycle or is it divided into several stages separated by practical on-the-job experience? Could you please describe (Example: Orientation/limited training - 1 week, advanced - 1 week, recycle training - 2 days) Typical responses: a. Five phases (l - Orientation - 3 weeks; II - Departmental Training - 2-3 weeks; 111 - Onhthe Job and Advanced; IV - Self-study Pilot Book'Training; and V - Advanced Classroom Training) b. Three weeks operator training; 2 weeks supervisor training 3 months OJT, annual review c. One continuous cycle of classroom and OJT d. Three days formal classroom, 1 month OJT, 2 days recycle classroom training per year e. 90-day apprentice training; k5 days OJT and classroom, qualification courses in process, mechanical, electrical, instrument f. Orientation one-half week; Buddy on the job 2-3 months, probationary period until passes test. 8. Please check those of the following topics which are included in your training program: X Orientation X Safety X Fire Fighting X Process Technology X Instrumentation X Basic Equipment List others not mentioned above: X Regulatory (EPA, OSHA, RCRA) X Industrial Hygiene X Respirator Protection X Company Philosophy X Company Organization EEO, Company Policy. 9. As a part of your operator training program, do you use proficiency tests to evaluate the effectiveness of the program? Yes 22 No 10 10. Do you use tests to qualify operators for promotion: Yes 1^ No 18 11. What do you feel are the strengths of your program? GENC 015500 Page Three Summary of Operator Training Questionnaires Typical responses: a. Six weeks formal training b. Locally produced video tapes c. Management supportd. Operator input e. Uniform format for procedures f. Company philosophy and attitude 12. What area of your program would you like to improve: Typical responses: a. Supervisor training b. Detailed orientation for advanced program c. Operator retention of material d. Improve higher technology training e. Add formal followup f. Formalized testing g* More formal procedures h. Full time supervisor for training i. Follow-up on a more formal basis 13. Which, if any of these training aids do you use in your operator training program? All of the following are being used to some degree: Film Slide/tapes Presentation Video Tape Commercially Produced Video Tapes Home-made Video Tapes Mock-up Equipment or Process Area Demonstration Instruments lA. Do you use video tape recordings produced at your facility by your own people? Yes 11 No 19 If "yes," could you please comment on the effectiveness of this technique? Do you recommend this technique to others? GENC 015501 Page Four Summary of Operator Training Questionnaires Typical responses: a. Good for repetitive routine information b. Very good because, of local background c. Very relevant . d. Prepared by a special training division e. Good - but still learning how to do it f. Only 25% good enough to re-use g. Two respondents said not using but plan to start. 9/18/81 GENC 015502 ATTACHMENT IV T Page 1 of la COMPUTER CONTROL SAFETY QUESTIONNAIRE Dear VCSA Member, - Computer control of PVC plants has very definite safety benefits. However, there are some safety problems which computers introduce which are not readily apparent. The purpose of this questionnaire is to survey computer-operated plants to discover any special problems related to computers, either design or operator interface related, and how these have been solved. 1. COMPUTER/MANUAL OPERATION A) Do you have provisions for independent computer and manual operation? 1. No 2. Yes 3. Not Totally 4. Yes 5. Yes 6. Yes B) How do you isolate the computer from the plant during manual operation or when the plant is down for computer repairs? 1. The portion.of the computer used for tempera ture control- is kept active when the computer is in repair. No manual control-is possible in other portion when computer is down. 2. A key switch which turns complete plant control into manual operation. > 3. Mechanical disconnect, at I/O and at remote (air supply to valve, etc.) 4. Switch all devices to manual operation 5. There is a relay switching system that is ' activated on computer failure or by manual request. This system deactivates panel push buttons during computer operation and isolates the computer I/O from the device relays during manual or panel mode. 6. Have MANUAL/AUTO switch which electrically isolates computer. Had one incident during trouble shooting of computer when switch was bypassed accidentally. Future design will consider more tangible isolation than switch. GENC 015503 Page 2 of .21 C) Have you had any problems with the computer opening valves or reactors which were out of service for maintenance? 1. No operation is possible without computer. 2. No-air is removed from.solenoid operated valves when out of service - 3. Once - installed lockout on positioners. 4. One occasion due to human error. 5. No - All valves on reactors down for mainte nance are "air-failed" so that they cannot open. 6. Air supply to reactors is locked out during maintenance. D) How do yon maintain operator proficiency on manual operation during long periods of computer operation? 1. No manual operation is made. 2. We do not run full production without conputers. 3. Don't try. 4. Once per month each operator must operate manually for at least four hours. We do not, at this time, have a specific program or method. This has not been a problem for us because our computer up time averages about 98#. 6. Schedule periods of MANUAL operation in order to maintain proficiency. 2- OPERATORS. TRAINING A) How do you train new operators? 1. Through education in special lecture program and on the job training. 2. On-the-job with a background of basic theory once familiar with job. 6ENC 015504 Page 3 of 11 3. Some classroom and theory - mostly on the job buddy system. 7-~ 4. Formal Class Room Training for approximately four weeks. Then work with existing operator for approximately-two months. 5. New computer operators receive most of their training by working with experienced operators. They also spend approximately eight'hours with one of the computer programmers for technical instruction about the computer. 6. New operators are not trained on the computer until all other jobs., in plant are mastered. Training involves several, weeks of on the job dual operation with experienced operator, on both MANUAL and COMPUTER modes. B) Do you have refresher training for experienced operators? 1. Yes 2. Yes - Limited to last job rotation otherwise operators'are encouraged to keep current at all times. 3. Yes 4. Sometimes when operating procedures are updated. 5. We do not.have regularly scheduled retraining classes for experienced operators,. but retraining is done if operational performance indicates the need. 6. No C) How do you retrain after major program revisions? 1. By lecture and simulation training. 2. Process and staff engineering will assist in this effort. 3. Written, classroom, and demonstration. 4. Systems Engineer conducts training sessions. Includes practice on CRT. 5. When possible, major changes are made gradually and training classes are held to inform operators of the effects of the changes on them. GENC 015505 Page 4 of-11 6. (1) 12-15. hours classroom (2) 1 to 3 days water batching. D) How do you communicate minor program revisions to all operators? 1. Either by an official transmittal note or either by starting meeting of the day. 2. Memos and log book. 3. `Written -- notice and description. 4. Operator log book and notices. 5. This is done through operation department communication channels. (IE., instructions in supervisors instruction log). 6. Have separate log book to record all revisions. 3. FIRST-LINE SUPERVISOR TRAINING* 1 2 3 4 5 A) How do you train new supervisors? 1. By on the.job training. 2. Allow upgrade system to cover vacancies. 3. A - Senior operator system leads to promotion. B - No formal method - probationary period. Both - Use outside training programs. 4. New first line supervisors are promoted from the- operators ranks and are already familiar with operation. Other training consists of familiarization with maintenance procedures, company policy, etc. 5. New supervisors do not undergo any formal training because they are all ex-computer operators. GENC 015506 Page 5 of 11 6. Had problems, during startup of plant because supervisors had no time for first hand solo operation of computer, following the classroom sessions. .Since then, however, all new super visors selected have come from best computer operators. B) Do you have refresher training for experienced supervisors? 1. Not done usually, except on emergency training. 2. They participate in all training sessions for each unit. 3. Yes 4. Yes - Same as with operators. In addition they get refresher on1 supervisory skills. 5. No 6. No C) How do you retrain after major program revisions? 1. By a lecture and simulation training. 2. Process engineering will assist in this effort. 3. Same as operators. 4. Same as operators. 5. They attend the same training classes that^ operators attend for major changes. 6. (1) 12-15 hours classroom. (2) 1 to 3 days water batching. 6ENC 015507 I _s- v _ Page 6 of 'll D) How -do you communicate minor program revisions to all supervisors? 1. By an official transmittal note. 2. Memos and log book. f 3. Written and discussions. 4. Same as operators.. 5. The same as for operators, through operation department's communication channels. 6. Separate log book to record all revisions. E) Have you had any problems with first-line supervisors losing proficiency with computer operations because of problems in other non-computer-operated parts of the plant?How are these. problems overcome? 1. Very few case only. We give them refreasbing education and make them supervisors. 2. No - Most first-line supervisors have only a limited working knowledge of computer operations. 3. Some refresher period and assignment with capable operators. 4. No 5. We do not attempt to keep a supervisor completely up-to-date on computer operations. We feel that with two console operators and two senior operators on.each shift, it is un necessary to keep supervisors proficient on the computer.6 6. Yes - Require supervisors to spend more time in control room and place more responsibilty on outside operators. GENC 015508 cT: i K- -V'. Page \ of 11v ' ' ~ V ... 4. INFORMATION OVERLOAD - 1 4) Have you had any problems of operators being swamped with computer messages and alarms so that some are ignored? _______________How are these problems overcome? 1. No - Only important messages and alarms are kept, sorthere will be no neglecting possible. 2. Yes - Use of two people helps to overcome problems when the extra person is available. 3. Yes - ... 1. Establish higher threshold for emergency alarms. 2. Have some data indicated, not alarmed. 3. Hardwire really critical alarm. 4. Training employees. 4. Yes - Added a second operator in control room to handle all operations after the reactors. In another plant the supervisor assists the operator. 5. Yes - We are constantly working to eliminate unecessary messages and redundant alarms to reduce the amount of information being fed to the operators. 6. Yes - 1. Revised program to reduce number of alarm messages. 2. Use separate printers for messages and alarms. 3. Some critical alarm messages are printed with exposed type in order to make them stand out. 5. OPERATOR COMPLACENCY A) Have you had any problems with operators relying too heavily on the computer to correct all mistakes? How are these problems overcome? 1. No - Cross checks by operators are inserted at important locations. 2. No 3. A- No B- Yes - have mandatory log sheets to record reaction to alarm. 4. No - Not since instituting manual operations once per month. 5. No 6. Yes - Diligent follow up on all incidents (major and minor) where mistakes using the computer are made. Operator making mistake is counseled and other operators are informed. GENC 01550? Page 8 of 11. 6. MAJOR PROGRAM REVISION SIMULATIONS A) Do you perform any plant-scale simulations when major program revisions are made? 1. No-.-.2. On start-up we provide dummy batches to walk through the program.' 3. No-- Except water batch tests. 4. No 5. No 6. Yes - Charge full batch quantities of water, VCM, and all additives except catalyst. Use catalyst solvent to simulate catalyst. Simulate alarm conditions, including emergency shortstop. Period lasts from 1 to 3 days. 7. OPERATOR/SUPERVISOR PROGRAM VARIABLE CONTROL A) Do you use an operator/supervisor control key to limit changes to program variables through the CRT? 1. No 2. Yes - Key switch 3. Yes - Many are not accessible to operators. 4. No 5. Yes 6. Have key - but do not use it. go* B) How do you limit program variable changes by operat3re&s? 1. 2. Some parameters cannot be charged from CRT - engineer has to charge (key-switch). 3. Yes - written authorization and record. 4. Through directed operator CRT keyboard function. GEHC 015510 Page 9 of 11 5. By requiring them to obtain permission and key from supervisor. 6. Program variables are changed by engineers. Have not had problems with operatiors changing program variables. Had some problems with operators tampering with FLAG changes in order to get programs to run. Educated operators to high danger of this and revised programs for better operability. C) How do you change formulation variables, such as catalyst and suspending agents? 1. No operators are involved in recipe changes. t 2. Done with consultations with process engineering group through supervisor. Engineer normally makes changes. 3. By CRT, but only as written1 2a3u4 thority. 4. Process Control Engineer or Shift Supervisor accomp-., lishes through CRT keyboard. 5. We have programs' that allow operators to change the amount of ingredients used within certain limits and this is not a permanent- change. Permanent changes to recipes are made by the programmers on request from the technical group. 6. Formulation page has variables which can be changed from CRT entries. The change must be input twice in order to be accepted. CRT changes are valid for one batch only. Long term formulation changes are made by engineers. 8. REACTOR CHARGE VOLUME CONTROLS A) If you have primary and secondary measurement devices on charge quantities, how do you allow operator acceptance of deviations between primary and secondary devices? 1..0nly one measurement is present. 2. Yes - Deviations are questioned by operators, and supervision makes decision. Also process engineering can be consulted. 3. Computer queries, then operator must get visual field verification before proceeding. 4. Variance limits set, but Shift Supervisor has some discretion if barely over limit. GENC 015511  5. "We have no secondary measuring devices I 6. Deviation during charge -- steps charge, operation must .-repair problem or deselect one of devices. Deselection procedures are'written, with accept-!, a : able limits. -On some chemicals, high value is : accepted, on others,, low value is selected. 9* VALVE STATUS INDICATIONS A) How do you handle problems with valve status indicators, such as microswitches? Do you override the computer hold or alarm, or do you manually ad.-just in the field on each batch? * 2. a) We override only after manually checked ' in field, b) Adjust in field if problem persists". 3. Allow override after field inspection, then write ASAP work order. 4. Device is visually checked in the field before over riding computerhold status. Device is not operated post next work day without repair. . 5. If a position indicator fails (valve in the proper - . -v- position and in contact with switch) an "override" "r'T !%;. can be placed on the device by using the "supervisory - key" until it can be repaired by the I & E Group. Yl' 6. Diligent maintenance is required to keep micro- ' switches in good condition. Use override and manual- field adjustment to overcome problems. Neither is an acceptable solution, but is necessary for operation. Repeat that follow up on problems must be prompt and diligent. 10. PLEASE DESCRIBE OTHER COMPUTER-RELATED SAFETY PROBLEMS OR INCIDENTS AND HOW YOU RECOMMEND TO CORRECT THEM. 1. 2. Operators do not always respond to computer initiated emergency type alarms - Computer print-out is reviewed duly by process engineer and recommendations made to production - Training sessions W/operators helps. 3. Preparing thorough fault-free analysis of computer operations on corporate basis. GENC 015512 Page 11 of 11 . None 5. In some instances, operators in the field have resorted to manipulating the instrument to.process.transducers (I to P*s) by hand to force a valve or device to move contrary to computer command. This is a rather simple procedure that, only involves unscrewing the cover and using a finger, nut, bolt, rock or some'other object "to hold the pneumatic switch in the desired position. Our solution to the problem was to make this act a severe violation of safety procedure with resulting severe penalties for violators. Since instituting this policy, we have had no futher problems. 6. GENC 015513 attachment V SUMMARY OF OSHA/EPA INSPECTION QUESTIONNAIRE The following is a summary of the 26 responses to the OSHA/EPA inspection Questionnaire: 1. Do you have, for your supervisors and other employees, a written set of guidelines for-use when a regulatory agency inspector'arrives at the plant gate? Yes 15 No 11 2. Have you had either an OSHA or EPA inspection of your plant in the past 12 months: OSHA 10 EPA 18 None 7 3- If you had an OSHA inspection was it regarding the VCM standard or was it involved with another area? ` a. VCM standard (five responses) b. VCM, noise, heat, dust lead c. General - triggered by employee complaint k. If you had an EPA inspection, was it regarding NESHAP5-VCM or was it about something else? Typical response: a. NESHAPS b NPDES permit c Hazardous waste - RCRA .d Permit to burn coal e Landfill permit f Incinerator operation g PCB 1 s h PVC dust i. Safety relief valve discharges 5. Did you receive any citations or notices of' violation? If you wish, could you please describe the nature of the violation? Typical response: a. Notice of violation - improperly labelled PCB tank b. No violation but not satisfied with aqueous effluent sampling procedure c. Two OSHA citations on record keeping - one invalid - the other due to math error in number of injuries reported GENC 015514 pag*e Two Summary of OSHA/EPA Inspection Questionnaire d. OSHA citations: Inadequate maintenance on area monitoring equipment and working in an area with greater than 5 ppm VCM, not wearing respirator e. OSHA - serious and fine; other and no fine f. OSHA - High VCM levels in reactors during cleaning -'no ' respirator g. Incomplete compliance with VCM opening loss regulations and non-compliance with relief valve emissions even though all emissions were reported correctly and on time. 6. Could you give a brief summary of your recent experience with an OSHA or EPA inspection? Typical reponse: a. OSHA inspection included 3 days of personnel monitoring for VCM and 1 day of PVC dust monitoring and other visits to the plant b. EPA was in the area and noticed black smoke from the incinerator stack and demanded an immediate inspection of the facility. We obliged and corrected the problem also sent a letter to the EPA.expla ining the problem. 9/18/81 GENC 015515