Document 7MMv8p9xkZ7Jx3MbGKJZOaQ7B

Interoffice Communication to Environmental File From S. J. Reynolds ate December 7, 1983 Subject HCL VENTING FOLLOWING UNSCHEDULED SHUTDOWN OF OXY ON DECEMBER 4, 1983 REPORTABLE SUPERFUND INCIDENT NON-REPORTABLE STATE 17.11 INCIDENT On December 4, 1983 at 2:30 am an unscheduled automatic shutdown of the oxychlorination system occurred due to a low HC1:0? ratio caused by a momentary interruption or "Blip" in the HC1 flow while putting T-204 back in service. HC1 venting from the HC1 column Pressure Controller, PRC-216A, took place for six hours following the oxy shutdown until the cracking furnace feed rates had been lowered, the HC1 column stabilized, and a level built-up in T-204. The total amount of HC1 vented from the column to the Vent Scrubber, C-500, was approximately 40,800 lbs., of which 10,200 lbs. were emitted to the atmosphere (a 75% HC1 removal efficiency of C-500 was used). The maximum hourly HC1 vent from C-500 was calculated to be 2,255 lbs./hr. which was below the 2331.8 lbs./hr. allowed by our EIQ permit for unscheduled oxy shutdowns and also below the 2831.8 lbs./hr. limit interpreted under State of Louisiana Air Quality Regulations Section 17.11. Therefore, this does not constitute a reportable 17.11 incident. However, the total 10,200 lbs. of HC1 emitted is above the 5000 lbs. reportable quantity set under the Superfund regulations. This occurrence was reported to the Coast Guard National Response Center at 9:30 am on December 4, 1983 as required by Superfund. An account of the telephone call to the Superfund NRC and a calculation of the quantity of HC1 released are attached. Please contact me if there are any questions. S. J. Reynolds Process Engineer br cc: RAC-JWW-MLA-MCM-RB-DLD-MGH CCR 000018761