Document 93dvEQejx5kLRVNk4rOgBQRMp

CHEMICALS INTEROFFICE / LAKE CHARLES TO: DISTRIBUTION DATE: JANUARY 12, 1990 FROM: ESTHER S. LIGGIO0s SUBJECT: SPILLS AND RELEASES, 1989 Attached for your review is a summary of the spills and releases which occurred at the Lake Charles Complex during 1989 (Attachment I). Included are the December incidents which are broken down into the following causes: Releases 1989 1988 People Mech Instr Int. Other Dec., 1989 Total Total Error Prob. Prob. Corr. Problem Total 11 Reportable 3 106 32 144 45 4 2 2 11 001 3 0 Several changes have been made this year concerning spill reporting guidelines. These changes include a revised internal definition of a leak which now requires reporting all leaks whether to containment or to the ground. This change will only affect the total number of releases and not the number of reportable releases. The number of reportable and total releases will be affected (increased) by the action of the EPA in lowering the reportable quantity on several chemicals which we have in this complex. Even with these changes, the 1989 Complex spill record shows improvement over previous years and is expected to continue to improve due to an increased environmental awareness and diligent effort by all workers. Figure 1 represents the 1989 total/reportable spill record for the complex on a month by month basis. The average number of total releases per month in 1989 was 9 compared to 12 in 1988. This represents a 26% decrease in total releases. The average number of reportable releases per month in 1989 was 3 compared to 4 in 1988. This represents a 29% decrease in reportable releases which is a significant achievement. A goal for 20% reduction in releases has been set for 1990. Figure 2 illustrates the complex spill/release record since 1985. This graph further demonstrates the reduction made in release incidents in 1989 (both total and reportable). Figure 3 depicts the releases by month from the Chlor/Alkali and Derivatives areas in 1989. The remainder of the releases not shown occurred in the Complex and Shipping areas. The pie charts in Figure 4 compare the percentage of total releases attributable to each area of the complex in 1989 vs. 1988 . Figure 5 compares the breakdown of release incidents by causes in 1989 vs. 1988. A new category of "design problem" was added in 1989. This is one reason for the reduction seen in the releases SI S8530 caused by "Other Problems". Releases caused by "People Errors" rose in 1989 from 29% to 33%. Because of_the large number of oeople errors experienced, this category is now broken down into the areas of Operations, Maintenance, Construction, and Shipping personnel. Figure 6 is an illustration of the amount of chemicals released to the environment due to spills/releases over the past three years. The total amount of chemicals released to the environment in 1989 showed a 5% increase from 1988 after the tremendous 80% decrease experienced in 1988. Also shown is a breakdown of the major chemicals released comparing 1988 to 1989 release figures. Each of these categories showed a reduction in the amounts released with the exception of chlorinated hydrocarbons and process wastewater. The amount of chlorinated hydrocarbons released increased by 28% in 1989. A single Perchlor spill of 8632 pounds accounts for 56% of the total pounds of chlorinated hydrocarbons released in 1989. The amount of process wastewater (corrosive hazardous waste) released to the environment increased by 12% in 1989. A single spill of 9098 pounds of wastewater at Tri-Ethane II accounts for 56% of the total wastewater spilled in 1989. Figure 7 illustrates a breakdown by unit of 1988 and 1989 releases along with the number of incomplete corrective actions associated with these releases. Attachment II is a listing by incident of all incomplete corrective action items from 1/88 through 12/89. Special attention should be given to those releases with an asterisk by them. These signify reportable releases and also a corrective action which was reported to an agency as PPG's plan to prevent reoccurrence of that release. These items in particular should be given the priority they deserve to assure they are completed in a timely manner. With an increased Environmental awareness by all employees in addition to the programs now in place and those planned for 1990, it is expected that the Lake Charles spill/release record will continue to improve during the upcoming year. 1890ESL/vc Distribution: T. G. Brown S. L. White H. C. Hank W. J. Peard J. M. Porter G. K. Jordan J. E. Meadows cc: R. J. Samelson (G.O. J. E. Wyche R. L. Holliday W. G. Wallace B. P. Bourgeois R. P. Byars C. R. Parnell Area Supervisors Shift Superintendent J. C. Lafleur R. W. LeBlanc E. S. Liggio A. P. Plauche' M. W. Wood W. E. Cleary/D. T. R File #1111.4.03 File #1103.3.07 File #1109.8 SL 08853! DATE HATERIAL/AMOUNT 01/05/09 CIHC/WATER L Thu 5.3/6530.7 tbs. REPORTED TO INTERNAL 01/11/89 NATURAL GAS G Med 3000 lbs. INTERNAL 01/17/89 VDCH G Tue 1030 lbs. INTERNAL 01/24/89 CIHC t Tue 1423 tbs. INTERNAL 01/25/89 CHLORINE G Ued 465.4 tbs. DEQ/NRC CHLORINE 465.4 lbs. 01/30/89 CIHC/UATER G Hon 0.1/1141.3 lbs. INTERNAL ATTAC! t: N T J PLANT B/ UIU AREA CA/ POWERHOUSE 6/ EOC B/ VC -11 CA/ Hg CELL B/ WTU LLS AND RELEASES AT LAKE CHARLES DESCRIPTION SANDBLASTERS PUT A HOLE IN B-1 LIFT STATION HEADER WHILE ATTEHPIING TO BLAST A RUST SPOT ON PIPERACK BENEATH IT. HATERIAL FROM HEADER DRAINED TO THE GROUND. CORRECTIVE MEASURES REVIEW POLICY AND PROCEDURES OF SAND BLASTERS NEAR FIBERGLASS LINES WITH FIELD ENGINEERS BY 1-18-89. (PE) (DONE) RIVERSIDE POWERHOUSE LOST A TURBINE BLADE. WHILE IN PROCESS OF UNlFORK]LT TAKING TURBINE OFF-LINE, GAS PRESSURE INCREASED IN SYSTEH CAUSING SRV AT CONOCO LOW PRESSURE STA. TO RELIEVE. DISCUSSED INCIDENT WITH SUPERVISION AT POWERHOUSE "C". (OP) EXTERNAL CORROSION IN THE REWORK HEADER WAS RECOGNIZED BEFORE THE SPILL. BEFORE LINE COULD BE REPAIRED, IT WAS USED TO TRANSFER VDCH. COHHUNICATIONS REGARDING LINE CONDITION WERE POOR. AREA FOREMAN AND OPERATORS WERE COUNSELLED TO IMPROVE COMMUNICATIONS. PIPE WILL BE REPLACED. (PE) REACTOR LIQUOR LEAKED OUT OF A DRUHHING HOSE FROH THE DOPP KETTLE. OPERATOR DID HOT NOTICE A BLOCK VALVE ON THE HOSE WAS PARTIALLY OPEN. OPERATOR AND LEAD OPERATOR WERE ASKED 10 PREPARE SOP FOR PEOPLE AT VC-II TO USE WHEN EQUIPMENT IS PLACED IN SERVICE. OTHER ACTION HAY BE TAKEN. (PE)(OPS WERE GIVEN MINOR REPRIMANDS AND SOP WRITTEN) SANDBLASTER PUT A HOLE IN INSTALMENT SIGNAL TUBING TO NEUTRALIZER GAS EX HAUSTERS. THIS RESULTED IN LOSS OF NEUTRALIZER INLET VACUUH AND DIVERSION TO RIVERSIDE PWRHSE STACK. PH EXHAUSTER SUCTION VALVE ACTUATORS. (ONE COMPLETE). REVISE ACTION OF THE VALVES TO FAIL OPEN UPON LOSS OF SIGNAL OR AIR SUPPLY. MODIFY DIVERSION SYSTEM(PE) RUPTURE DISC ON #1 CSS FEED TANK BLEU. SUSPECT PHEHATURE FAILURE AS NO INDICA TIONS OF EXCESSIVE TEHPERATURE OR PRESSURE IN THE TANK WERE OBSERVED. REVIEW SOP'S REGARDING REMOVAL OF PHASE ORGANICS FROH FEED TANKS(DONE). REVIEW CONTRACT W/ OHC TO M1N1MZE PHASE ORGANIC ENTERING FD TKS{IN PROGRESS). DEV. CONTR W/ VDCH TO COOL BTMS. (COOLER INSTALLED) DATE MATER IAL/AMOUNT 02/02/69 HCl G Thu 15.6 lbs. REPORTED TO INTERNAL 02/03/89 NaOH L Fri 200 lbs. INTERNAL 02/03/89 CIHC L Fri 30 lbs. 02/06/69 CHLORINE G Hon 2.8 lbs. DEQ/NRC PER/HCBD 1.7 / 1.3 lbs. INTERNAL 02/07/89 CHLORINE G Toe 8 lbs. INTERNAL SPILLS AND RELEASES AT LAKE CHARLES PLANT B/ UTU AREA DESCRIPTION #1 PER/TRI STEAM STRIPPER RUPTURE DISC BLEU PREMATURELY. BLEW AT 3.5 PSIG WHICH UAS ONLY 1 PSI ABOVE NORMAL OPERATING PRESSURE. CORRECTIVE MEASURES PROPER RUPTURE DISC INSTALLATION PROCEDURES WERE REVIEWED WITH MAINTENANCE. (HP) CA/ PELS STG. BIN #1, PLUGGED WITH UET PRILLED CAUSTIC, UAS BEING WASHED TO PELS SUMP. BREAKTHROUGH OF A PLUG AT THE BOTTOM DISCHARGE RELEASED A SURGE OF CAUSTIC WATER THAT OVERFLOWED CONTAINMENT. PROC. FOR HASHING OUT A PLUGGED SIN TO BE REVIEWED HITH PACKERS. (HP) EVALUATE DETECTION DEVICES TO ALRM UHEN HET MATE ENTERS BUCKET ELEVATOR. QAT TO DEFINE CHANGES TO PREVENT UET MATE ENTERING. 8/ PER/TRI AS APPOLLO KNOCKOUT POT WAS BEING LIFTED OFF ITS FOUNDATION, LIQUID SPILLED TO THE GROUND. APPARENTLY, A PLUG IN THE NOZZLE CAM LOOSE RELEASING LIQUIDS. INSTALL A CONCRETE PAD LARGE ENOUGH TO COVER AREA UNDER THIS PROCESS VESSEL. (PE) -COUNSELED EMPLOYEE. INSTALLED FURAN PAD UNDER THIS VESSEL. CA/ Hg CELL CHLORINATED CONDENSATE DRAIN LINES PLUGGED CAUSING CHLORINE HEADER PRESSURE TO SUING. CHLORINE BLOWER TRIPPED CAUSING PRIMARY SEAL TO BLOW AND A SHALL RELEASE FROM NEUTRALIZER. DRAIN LINES HAVE BEEN TAKEN APART AND CLEANED. A WARNING LIGHT FOR LOW CHLORINE BLOWER AND CENTRIFUGAL SPEEDS WILL BE INSTALLED.(OP) DONE - LOW STM DRAW ALRMS BLUR TRIP & RPM ALRKS CENTRF. TRIP CA/ A ELECTRO. IMPULSE LINE TO CIRCUIT 16 CHLORINE PRESSURE TRANSMITTER FROZE. PCV CLOSED CAUSING CHLORINE TO BLOW THROUGH SEALS ON TWO PUMP TANKS. LINE UAS TEMPORARILY INSULATED AND HEAT TRACED. WORK ORDER WRITTEN TO DO PERMANENT JOB BEFORE NEXT WINTER. (IP) (IN PROGRESS) 02/07/89 CHLORINE G Tue 500 lbs. DEQ/NRC CHLORINE 500 lbs. CA/ A ELECTRO. IMPULSE LINE TO CIRCUIT 16 CHLORINE PRESSURE TRANSMITTER FROZE CAUSING LOSS OF CONTROL ON CIRCUIT. WHILE TRYING TO FIND PROBLEM, NEUTRALIZER UAS DEPLET ED OF CAUSTIC RELEASING CHLORINE. ELECTRICAL HEAT TRACING AND INSULATION WILL BE INSTALLED ON ALL CHLORINE PRESSURE IMPULSE LINES, NOZZLES, AND TRANSMITTERS. (IP) (IN PROGRESS) cn tr1 o CO 00 (J1 GJ to DATE HATER1AL/AM0UNT Q2/0//89 NaOH L Toe 3780 lbs. REPORTED TO DEQ/NRC NaOH 3780 lbs. 02/10/89 HCI G Fri 11.4 lbs. INTERNAL 02/10/89 HCI L Fri 47.6 lbs. INTERNAL 02/10/89 ETHYL CHLORIDE G Fri 5.8 lbs. DEQ ETHYL CHLORIDE 5.8 lbs. 02/11/89 CHLORINE G Sat 5.6 lbs. INTERNAL 02/16/89 NaOH L Thu 225 lbs. 02/17/89 ClHC L Fri 1075 lbs. CO tT1 O 00 00 cn bd 0J INTERNAL INTERNAL SPILLS AND RELEASES AT LAKE CHARLES PLANT AREA SH/ SHIPPING A DESCRIPTION EXPANSION JOINT BLEU OUT AT FLANGE BETWEEN TANK HG-1 SUCTION AND HC-50 TRUCK LOADING PUMP. CORRECTIVE MEASURES REPAIRS TO HG PUMP PAD AND PIPING SYSTEM ARE IN PROGRESS. UHEN COMPLETED, THERE UILL BE NO EXPANSION JOINT IN THE SYSTEM. (OP) (DONE) 8/ WTU #2 PER/TRI STEAM STRIPPER RUPTURE DISC FAILED PREHATURELY, OPERATOR INPUT WRONG SET-POINT ON STEAM TCV CAUSING SURGE OF STEAM TO HIT STRIPPER. COMPUTER WILL BE PROGRAMMED TO PREVENT A SET-POINT OF GREATER THAN 245 BEING ENTERED FOR THE TCV ON BOTH STRIPPERS. PREMATURE RUPTURE DISC FAILURES ARE ALSO BEING INVESTIGATED. (PE) -DONE- B/ UTU #2 PER/TRI STEAM STRIPPER RUPTURE DISC FAILED PREHATURELY AGAIN. PREMATURE RUPTURE DISC FAILURES ARE BEING INVESTIGATED UITH THE SUPPLIER. (HP) -DONE- B/ EC/HCl INTERNAL CORROSION TO THE SRV NOZZLE ON THE EC REWORK DRYER CAUSED A PINHOLE LEAK OF ETHYL CHLORIDE. SRV NOZZLE WAS REPLACED. OTHER NOZZLES ON THE DRYER UILL BE INSPECTED AND CHECKED FOR METAL THICKNESS. (1C) (DONE) CA/ L1QUIFACTION A LINE ON EXPANSION BOTTLE AT TANK 20 DEVELOPED A LEAK IN THE THREADED CONNECTION. CONNECTIONS ARE BEING CHANGED TO ALL WELDED CONNECTIONS EXCEPT FOR CONNECTION TO A BLOCK VLVE. THIS IS BEING DONE THRU ATTRITiON(EC). 28 OF 60 SETS OF BOTTLES/ PIPING HAVE BEEN UPGRADED(AS OF 1/3/90) SH/ DOCKS WHILE DRAINING CAUSTIC TRANSFER LINE AT "C" DOCK, SUMP FILLED FASTER THAN SUMP PUMP COULD HANDLE. HIGH LEVEL ALARM DID NOT SOUND. NONE PROVIDED. (IP) B/ UTU OPEN VALVES ALLOWED CONTINUOUS FEED INTO DH STILL UNTIL IT WAS COMPLETELY FULL BLOWING RUPTURE DISC. SPILL WAS CONTAINED ON THE PAD. REROUTE SAMPLE PURGE LINE INTO DH PROCCT TK(CAN NOT BE DONE). INSTRUCT OPERATORS TO PURGE FOR 5 MINUTES PRIOR TO SAMPLING AND KEEP VALVE CLOSED AT ALL OTHER TIMES. (PE) DONE DATE KATERiAL/AHOUNT 02/26/89 HCl G Sun 75 tbs. REPORTED TO INTERNAL 03/50/89 ClHC G Fri 16.5 lbs. 03/14/89 PERCHLOR L lue 6632 lbs. 03/14/89 VDCM G Tue 2034 lbs. DEQ ETHYL CHLORIDE 7 lbs. DEQ/NRC PERCHLOR 8632 tbs. INTERNAL 03/17/89 CHLORINE G Fri 6 lbs. INTERNAL 03/18/89 HCl G Sat 12.9 lbs. INTERNAL SPILLS AND RELEASES AT LAKE CHARLES PLANT B/ WTO AREA DESCRIPTION SPLIT FLANGE HOLDING A BLIND FLANGE ON THE OLD OHC VENT HEADER UAS SEVERELY CORRODED AND STARTED LEAKING. CORRECTIVE MEASURES VENT HEADER HAS BEEN INSPECTED AND PARTS REPLACED U/ DEREKANE AND/OR FURAN.(DONE) EVALUATION AS TO POTENTIAL TROUBLE AREAS WILL BE DONE. (EC HREPLACING OLD HEADER PIPING-SHOULD BE COMPLETE 7/15). 8/ UTU RUPTURE DISC ON UTU VENT COMPRESSOR KNOCK OUT POT BLEU. NO APPARENT REASON FOR DISC TO BLOU. PERHAPS PREMATURE FAILURE. RUPTURE DISC INSTALLATION WILL BE REVIEWED. (OP) B/ PER/TRI AS A RESULT OF POOR COMMUNICATIONS, THE PER STABILIZER POT OVERFILLED ALLOWING PERCHLOR TO SPILL TO THE GROUND. INVEST. INSTALLING SPRING LOADED VALVES. REROUTE STABILIZER SUMP OVERFLOW DRAIN. COUNSEL OPERATOR.(DONE) WRITE SOP TO STATE AN AUK. OPR MUST STAY IN BLDNG UHILE STABILlZING.(PE) (DONE) SH/ SHIPPING B CA/ Hg CELL A T/C UAS CONNECTED FOR LOADING BY CONNECTING LIQUID LINE TO VENT VALVE OF CAR AND INCIN. VENT HOSE TO LIQUID VALVE OF CAR. VENT SYSTEM RUPTURE DISC BLEU UHEN LOADING BEGAN. INST LIQ SENSOR AND CONTROL VLV IN VDCM INCIN. VENT LINE AT T/C LOADNG STATIONS TIE TOGETHER SENSORS, CONTROL VLVS, AND PUMP SWITCHES 10 STOP FLOW IF LIQUID IS SENSED. (PEKIN ENGR ). - INST END OF 8/89. NEW LEAD OPERATOR CONFUSED SEOUENCE OF STARTUP ACTIONS. LOAD UAS RAISED BEFORE PRODUCTION UAS IN LIQUIFACTION SYSTEM. RESULTING SYSTEM BACKPRESSURE CAUSED A RELEASE FROM THE CELL ROOM. INCIDENT UAS REVIEWED WITH OPERATOR. HE IS TO WRITE A PROCEDURE FOR SOP. SOP TO BE FINALIZED BY 4-14-89. (PE) B/ UTU OPERATOR SWITCHED STEAM FCV ON #1 P/T STEAM STRIPPER TO AUTO AND VALVE WENT 100X OPEN. OPERATOR PUT FCV ON MANUAL AGAIN, BUT VALVE REMAINED OPEN, RE SULTING IN RUPTURE DISC TO BLOU. SOFTWARE UPGRADE INSTALLATION IS COMPLETED. ALL TUNING PARAMETER DEFAULT VALUES WERE CHANGED TO THEIR SETTINGS DURING PROPER OPERATION. (IP) DATE MATER[AL/AMOUNT 03/21/89 CHLORINE G Tue 9 lbs. REPORTED TO INTERNAL 03/22/89 VOCM G Wed 838 l bs. INTERNAL 03/23/89 MEIHYLCHLOROFORM L INTERNAL Thu 218 lbs. 03/25/89 HCL G Sat 12 lbs. INTERNAL 03/30/89 CIHC G Thu T.4 lbs. DEQ/EPA ------'9 CIHC L 1067 lbs. CO tr1 o oo 00 Ur OJ ui DEQ/NRC VC/EC/PER 6.2/1.2/2.7 tbs SPILLS AND RELEASES AI LAKE CHARLES PLANT AREA CA/ A ELECIROL. DESCRIPTION LOSS OF 400# STEAM TO LIQUIFACTION CAUSED LACK OF COMPRESSION. RESULTING CHLORINE BACKPRESSURE ON CIRCUITS CAUSED RELEASE OF CHLORINE FROM VACUUM SEAL OVERFLOW SIPHON BREAKS. CORRECTIVE MEASURES WORKORDER HAS BEEN WRITTEN TO IENGIHEN OVERFLOW SEAL LOOPS FROM THE VACUUM SEALS ON EACH CIRCUIT. (HP) (DONE) B/ EDC VDC REACTOR RUPTURE DISC BLEW SINCE TOO MUCH STEAM WAS ON REACTOR WHEN REFLUX WAS INTRODUCED. EXISTING PRESSURE ALARM HAD BEEN PULLED AND NOT REPLACED. OPERATORS WERE COUNSELED. WOW TO PROVIDE PRESSURE INDICATION AND ALARM ON VDC RX RATHER THAN ON THE VENT VALVE. TEMPORARY ALARMS WERE INSTALLED UNTIL A PERMANENT SYSTEM CAN BE INSTALLED.{PE) B/ TE-Il A 1/2 INCH VALVE WAS LEFT OPEN ON A TANK. WHILE UNLOADING AN HC T/T TO THE TANK, LIQUID SPILLED FROM THE VALVE ONTO CONTAINMENT AND THE GROUND. OPERATORS WILL BE TALKED TO BY J. ROCK RE-INSPECTION OF BLEEDS AND VENTS PRIOR TO TRANSFERRING MATERIAL. ALL BLEEDS AND VENTS IN OLD TANK FARM TO BE INSPECTED FOR PLUGS. (PE) (DONE BY 3/30/89) S/ TE-1I TE-1I VENT HEADER DEVELOPED A LEAK AT A JOINT. APPARENTLY THE PIPE SUPPORT SLIPPED OFF THE RACK AND THE WEIGHT OF THE PIPE SPLIT THE JOINT. TEMPORARY REPAIR IS BEING OVERLAYED WITH DERAKANE. (DONE 3/26/89). PIPERACK INFECTION WILL 1NCLUOE VENT HEADER, SPECIFICALLY STATUS OF SUPPORT SHOES. (MP) (COMPLETED INSP. 5/89). B/ PER/TRI PINHLOE LEAK NEAR THE WELD IN THE INLET THROAT OF THE #3 PER/TRI REACTOR CYCLONE. SUSPECT INTERNAL EROSION. ORIGINALLY THOUGHT TO BE REPORTABLE. CYCLONE WILL BE SWAPPED AND INSPECTED. IMPLEMENT DESIGN AND PROCEDURE CHANGES AS OUTLINED IN MEMO OF 4/10/89. (DP) (DONE- OTHER CYOLONES BEING HOOIF1ED AS SWAPPED OUT). B/ WTU LIQUIDS CONDENSED INTO VC-Ii VENT HEADER AS THE VENT HEADER KNOCK OUT POT FILLED ITS 10# RUPTURE DISC BLEU, APPARENTLY PREMATURELY. ADJACENT PRESSURE TRANS. SET AT 3.5#, DID NOT ALARM. RUPTURE DISC WAS REPLACED WITH ONE RAIED AT 25#. KNOCK OUT POT WILL BE CHECKED EVERY 4 HOURS ON ROUNDS AND WILL BE DRAINED OF LIQUIDS AS NECESSARY. (OP) (APPEARED TO BE INSTALLATION PROBLEM) DATE HATER1AL/AMOUNT 04/04/89 CIHC/Water G Tue 41.7 lbs/3700 lbs REPORTED TO NRC/OEQ VC 14.9 lbs 04/13/89 CIHC/Water L Thu <1 tb/180 lbs NRC/DEO ICR substance 180 lbs 04/19/89 HCL/Water L Wed 1071 lbs/2498 lbs INTERNAL PLANT B/WTU 8/UTU SPILLS AND RELEASES AT LAKE CHARLES AREA DESCRIPTION Rupture disc bleu on CSS Feed Tanks due TO RISING TEMPERATURE AND LEVEL DURING a rate change on the VDCH Reactor. CORRECTIVE MEASURES i. INSTALL A COOLER ON VDCH RX BIHS BY 4/30/89. (DONE) 2. Divert VDCM Rx btms stream out of CSS SYSTEH(ENGR. WOW). LINING OF VALVE FAILED AND PROCESS WASTE water leaked onto the groundtph = 0.5). Valve was replaced. B/UTU White removing a piece of piping from the piperack, this piping struck an acid line breaking a nipple causing the spilt Review the incident >n the next maint* GANGBOX SAEETY MEETIWG(4/26/8V). DOME 04/27/89 CIHC L Thu 2244 lbs 04/28/89 VC G Fn 47.5 lbs 04/28/89 EDC L Fri 891 lbs 05/02/89 EDC L Tue 36 lbs. INTERNAL B/Per/Tri LASP/DEQ/NRC/LEPC VC 47.5 lbs 8/VCH II INTERNAL B/VCM li B/VCH 11 The hose connected to the scrubber came loose while filling the vaporizer; Faulty level indications on the vaporiz er did not allow the level to be known. i.. REV RX VAPORIZER S/UP PROC.(DONE) 2.. RPL. BAD VALVE ON VENT LINE.(DONE) 3 . REPLACE BAD HOSE FITTING. (DONE) 4.. HAVE INSTR. DEPT. CHECK ALL AIR SUPP. ARE REOPENED WHEN COHPL W/ JOB.(DONE) *1 SRV ON VC PRODUCT STILL REFLUX DRUM LIFTED DURING START-UP. - 1.. MOO S/UP SOP(COHPLET BY 6/15MDONE) 2.. Form OAT to finalize Start-up SOP for GOING ON RECYCLE(COMPLETE BY OCT.) 3.. CALL AN ORC MEETING TO DISCUSS 02 SRV on Primary Lean Oil Cooler lifted during unit start-up. 1. MOO S/UP SOP(COMPLETE BY 6/15).(DONE) 2..Form QAT to finalize start-up SOP for going on recycletComplete by Oct.). 02 DOPP KETTLE AT VCH II WAS OVERFILLED WITH SEAL FLUSH DUE TO IMPROPER ISOLATIONOCETTLE WAS OUT OF SERVICE). THE KETTLE OVERPRESSURIZED AND EDC WAS RELEASED THROUGH THE SRV STACK. 1.. MOO 1 FT SOP TO LIST EVERY ISOLATION VALVE. (DONE) 2.. REPAIR HIGH PRESSURE SWITCH. (DONE) 3., TAG OPEN SRV DISC STACK BLD VLV.(DONE 4.. COUNSEL THE OPERATOR 1NVOLVED.(OONE) DATE HATER IAL/AMOUNT 05/02/89 D002 L Toe 6535 lbs. REPORTED TO NRC, DEO D002 6555 lbs. 05/03/89 EC G Wed 92.5 lbs. DEQ EC 92.5 tbs. 05/07/89 orgamcs/water L Sun 103 lbs/334 lbs. 05/08/89 HCl L Hon 171 lbs. 05/10/89 CL2 G Wed 3 lbs. 05/12/89 VDC G Fri 409 tbs. PLANT 8/WTU SPILLS AND RELEASES AT LAKE CHARLES AREA DESCRIPTION A FLANGE LEAK DEVELOPED ON THE B1 LIFT STATION HEADER. WHEN AN ATTEMPT WAS HADE TO TIGHTEN THE BOLTS, ONE OF THE BOLTS BROKE, CAUSING THE LEAK. CORRECTIVE MEASURES 1. THE BOLTS ON THIS HEADER WERE REPLACED U/ TEFLON COATED BOLTS(DONE) 2. THIS WILL BE A SPECIFIC ITEM ON THE PIPELINE INSPECT 1ONS.(BEING DONE) B/EC B/VCM II A LEAK OF EC OCCURRED DUE TO EXTERNAL CORROSION ON A 2" LOADING LINE. A LEAK DEVELOPED ON A FRAK TANK TEMPORARILY LOCATED AT WTU DURING THE VCH [I OUTAGE. THE MATERIAL SPILLED INTO THE 010 SEWER. 1. THE LEAKING SECTION OF LINE WAS REPLACED. 2. THE REMAINDER OF THE LINE WILL BE 1. THE FRAK TANK WILL BE CLEANED 5/11 AND REMOVED. (DONE) B/UTU A/Liquefaction B/VDC A FLANGE LEAK DEVELOPED ON THE STRONG ACID HEADER AT THE NW CORNER OF THE BINS PLANT. 1 . IMPLEMENT CLOSER INSPECTION OF PIPELINES. 2. CHANGE FREQUENCY OF INSPECTIONS IF REQUIRED. DURING LEAK TESTING OF A NEWLY INSTALLED PUMP, CL2 ESCAPED FROM A TAPPED HOLE USED TO HYDROTEST THE PUMP. PPG PERSONNEL WERE UNAWARE OF THIS TAPPED HOLE. 1. MORE THOROUGH INSPECTION OF NEW EQUIPMENT UPON ARRIVAL. (BEING DONE) 2. VENDOR WAS CONTACTED TO DISCONTINUE INSTALLING THIS TAP. (DONE) 3. REV PRESSURE CHECKNG PROCEDURE.(DONE) DURING STARTIN' OF THE VDC RX, A SUDDEN PRESSURE INCREASE CAUSED THE R/D TO BLOW HIGH PRESSURE ALARMS SOUNDED BUT WERE AT THE SAME TIME AS THE R/D BLEU. POSS IBLE PLUGGING OF TRAYS IS SUSPECTED. 1. REACTOR WAS SHUTDOUN;ALL INSTRUMENTA TION WAS CHECKED AND WORKING. 2. AN INTERNAL INSPECTION OF THE RX WILL BE HADE AND REPAIRED AS NECESSARY. 3. REV. SOP FOR EXTENDED RX OUTAGES. DATE MATERIAL/AMOUNT 05/12/89 CL2 G Fri 86 lbs. REPORTED TO NRC, DEQ C12 86 lbs. 05/15/89 NaOH L Mon 191 lbs. 05/17/89 C12 G Wed <8 lbs. 05/17/89 NaOCl L Wed 394 lbs. 05/21/89 F024 L Sun 171 lbs. 05/26/89 HCt L Fri 55 tbs. NRC/DEQ NaOCl 394 lbs. NRC/DEQ F024 171 lbs. SPILLS AND RELEASES AT LAKE CHARLES PLANT AREA A/Hg Cell DESCRIPTION AN UPSET OCCURRED IN CELL FD PH WHEN AN ACID BYPASS VLV WAS LEFT OPEN. HIGH TEMP RESULTED CAUSING THE CL2 COMPRESSOR AT LIQUEF. TO BE TRIPPED. THIS CAUSED THE NEUTRALIZER TO BE OVERLOADED. CORRECTIVE MEASURES 1. AN ORC HTG. MAS HELD TO DISCUSS PROPOSED CHANGES. (DONE) 2. RPL. ACID BYPASS VLV W/ SMALLR (DONE) 3. INST ADD[TONAL INSTRUMENTATION. A. COMPLETE STUOY ON CAPACITY OK NEUTR. C/Caustic A CRACK IN A WELD DEVELOPED ON THE DRAIN LINE OF THE 50X TRANSFER HEADER.(THE CRACK HAY HAVE BEEN CAUSED BY HIGH VIBRATION DUE TO PROBLEMS WITH THE EAST TRANSFER PUMP. 1. REPAIR THE EAST TRANSFER PUMP.(DONE) A/LIQUEFACTION THE CL2 SNIFF BOOSTER PUMP LOST ITS PUMPING CAPACITY.THE AUTOMATIC DISCHARGE VALVE FAILED TO CLOSE WHEN THE MOTOR CONTINUED RUNNING.CL2 FLOWED BACKWARD ANO LEAKED OUT THE PACKING GLANDS. 1. INST BALL CHECK DOWNSTREAM OF BOOSTER SEPARATOR TO LIMIT RELEASE.-DONE-7/13 2. REVISE PROCEDURE FOR DETERMINING TO REPLACE SNIFF PUMPS. (DONE) B/UTU A GASKET BLEW OUT ON THE TRANSFER LINE FROM HG CELL UNIT TO SOOIUH FORMATE. 1. REVIEW PIPELINE INSP PROGRAM.(THIS LINE WAS HISSED ON EARLIER 1NSPECTN) 2. CHECK THAT GASKET TYPE IS PROPER FOR B/WTU INCINERATOR FEED LINE DEVELOPED A HOLE CAUSING A SPILL TO THE GROUND. 1. INSTALL INCINERATOR FEED LINES IN TRENCHES IN 1990. 2. INSTALLED REINFORCEMENT PADS TO B/EC A CRACK DEVELOPED IN A FURAN WEAK ACID LINE AFTER THE PIPERACK WAS ACCIDENTALLY HIT BY HEAVY EQUIPMENT. 1. REPLACE THE FURAN SECTION OF THIS LINE WITH LINED PIPE. (LINE REPAIRED 5/26; WOW TO RPL LINE WITH OERAKANE PIPE. -DONE- cn tr1 o 00 oo cn OJ 00 DAIE MATER 1AL/AMOUNT 06/OS/89 HCl/CLHC G Mon 189 LBS./20 LBS. REPORTED TO DEQ HCl 189 LBS. 06/06/89 NaOH L Tue 125 LBS. 06/14/89 EC G Wed 92 LBS. 06/16/89 NaOH L Fri 820 LBS. DEQ EC 92 LBS. 06/24/89 HCL L Sat 62 LBS. 06/26/89 CL2 G Hon 5 LBS. CO tr< o 00 CO cn Co LO SPILLS AND RELEASES AT LAKE CHARLES PLANT AREA PER/TRI DESCRIPTION THE RUPTURE DISC OH THE NORTH DH FEED TANK AT PER/TRI FAILED PREMATURELY. TANK HAD BEEN OUT OF SERVICE AND WAS BEING READIED FOR SERVICE. CORRECTIVE MEASURES 1. THE 3 DH FEED TANKS AT PER/TRI WILL BE PRESSURIZEDC10#) PRIOR TO USE AFTER MAINTENANCE WORK. 2. CHECK GASKETS FOR PROPER ONES USED. 3. CHECK BOLT TORQUEING AND REEMPHASIZE. CA/PELS SHIPPING WASH PAN DRAIN DEVELOPED A PLUG IN LINE CAUSING MATERIAL TO BACK UP AND ESCAPE THE WASH PAN, CAUSING A VIOLATION. 1. HYDROBLASTED SEWER LINE CLEAR. 2. COMMUNICATION MTG. TO BE HEID WITH PELS PACKERS TO REEMPHASIZE JMPOR TANCE OF PROMPT REPORTING OF SPILLS. B/EC A LEAK DEVELOPED IN A BLEED PLUG ON A FLOW TRANSMITTER DUE TO EXTERNAL CORROSION. 1. INSTRUMENT MECHANIC TO CHECK ALL TRANSMITTERS IN EC PLANT FOR SIMILAR PROBLEM AND CORRECT AS NECESSARY BY 7/14/89. CA/ pH CONTROL CELL LIQUOR WAS SPILLED TO THE GROUND WHEN THE CELL LIQUOR LINE FROM TANK #6 WAS BEING CLEARED FOR MAINTENANCE. THE LINE WAS IMPROPERLY ISOLATED AND TAGGED. 1. UPDATE AND DISTRIBUTE A FLOW DIAGRAM OF THE CELL LIQUOR COLLECTION AND DISTRIBUTION SYSTEM. B/WTU A HOLE DEVELOPED IN THE WEAK ACID TANK ALLOWING ACID TO LEAK ONTO THE GROUND AND INTO THE SEWER (INTERNAL CORROSION). 1. INSPECTION DEPT. WILL INSPECT TANK ON 6/27. PENDING RESULTS OF THIS INSPECTION, ROUTINE INTERNAL INSPECTT10N OF THIS TANK WILL CONTINUE. CA/HG CELL DURING AH EMERGENCY OUTAGE, CL2 WAS SENT TO THE NEUTRALIZER. THE ORP PROBE MAL FUNCTIONED ALLOWING CL2 TO BE VENTED TO THE ATMOSPHERE. THE PROBE FAILURE WAS DUE TO DIRTY PROBE AND LOW SAMPLE FLOW. 1. A POLICY HAS BEEN ADOPTED TO CHECK THE ORP PROBE WEEKLY TO INSURE A CLEAN PROBE AND ADEQUATE SAMPLE FLOW. DATE MATERIAL/AMOUNT 06/27/69 CL2 G Tue 1.5 LBS. REPORTEDTO 06/28/89 OIL L Wed 12 GALL 06/29/89 CL2 G Thu 9 LBS. 07/02/89 PER/HVS L Sun 43346LBS./2282/LBS 07/03/89 HCL G Hon 17 LBS. 07/03/89 CLHC SLUOGE Ho" '.00 LBS. GO f O 03 CO LIT O SPILLS AMD RELEASES AT LAKE CHARLES PLANT AREA CA/ HG CELL DESCRIPTION THE DEPLETED BRINE TANKS OVERFLOWED CHLORINATED BRINE AS A RESULT OF A PUMP BEING SHUT DOWN FOR A GROUND SEARCH AND NOT RESTARTING. CORRECTIVE MEASURES 1. WOU TO INST LOWER HIGH LEVEL ALARM ON DEPLETED BRINE TANKS. 2. DEVELOP SOP FOR DETECTING ELECTRICAL GROUNDS. SOP WILL HIGHLIGHT EQU1PMEN1 TO HAVE SPARE RUNNING PRIOR TO S/D. COMPLEX A FUEL TRUCK WAS BEING BACKED UP TO REFUEL A PORTABLE GENERATOR WHEN IT PUNCTURED A S3 GALLON DRUM OF TRANSFORM ER OIL. 1. SHIFT REPAIRMEN WERE COUNSELED. CA/'C' CL2 B/ PER/TRI B/ WTU CX/S.I.DRUH STG. DURING STARTUP OF A CIRCUIT, CL2 WAS DIVERTED TO THE NEUTRALIZER PER SOP. AT THAT TIME A SMALL AMOUNT OF CL2 BROKE THROUGH DUE TO A CAUSTIC NOZZLE FALLING OFF THE FEED DISTRIBUTION HEADER. 1. INVESTIGATE METHOO TO PREVENT THE CAUSIC NOZZLES FROM FALLING OFF AND INSTALL DURING NEXT INTERNAL INSPEC TION SCHEDULED FOR 10/89. THE SIGHTGLASS ON #4 AUK TANK FAILED AND CONTENTS OF TANK DRAINED TO A CONCRETED SUMP AREA. INSPECTION OF THE SIGHTGLASS SHOWED IT TO BE PLASTIC AND CAUSE OF THE FAILURE WAS CHEMICAL ATTACK. 1. INSPECTED ALL SIGHTGLASSES- NONE FOUND TO BE PLASTIC. 2. NEW POLICY INSTITUTED FOR BLOCKING IN BOTTOMS SIGHTGLASSES. THE RUPTURE DISC ON #3 WASTE STORAGE TANK BLEW PREMATURELY!<5 LBS.). 1. CONT. EMPHASIS W/ KAINT. ON PROPER INSTALLATION OF GRAPHITE DISCS(SPIER) 2. RPL SOLENOID ON VENT VALVE(DONE) 3. CHECK ALL PI'S ON WST FOR PROPER OPR. A. INST DRAINS ON R/D STACKS(DONE) SEVERAL DRUMS OF NORTH CLASSIFIER SLUOGE FELL OVER WHEN THE BOTTOMS DRUMS THEY WERE STACKED ON COLLAPSED. THE LID OPENED ON ONE OF THE DRUMS THAT FELL OVER ALLOWING THE CONTENTS TO SPILL. WILL HAVE TRICIL GO THROUGH DRUMS TO SEPARATE PARTIALLY FILLED DRUMS.PART IAL FILLED DRUMS WILL BE STACKED ON TOP. ONLY COMPLETELY FULL DRUMS TO BE PLACED ON FLOOR-COMPLETE- 7-14-89 DATE HATERIAL/AHOUNT 07/05/89 CLHC-CONI. DIRT Wed 60 LBS. REPORTED TO SPILLS AND RELEASES AT LAKE CHARLES PLANT AREA CX/S.T. DRUM STG DESCRIPTION TWO DRUHS Of CLHC-CONTAMINATED DIRT FELL OVER WHEN THE DRUMS THEY WERE STACKED ON COLLAPSED. ONE DRUM LID OPENED SPILLING CONTAMINATED DIRT ONTO THE PAD. CORRECTIVE MEASURES SAME AS FOR SPILL ON 7/3/89 07/24/89 NAOH L Hon 2560 LBS. 07/29/89 PER L Sat >0.5 LBS. 08/01/89 SOOIUH HYPOCHLOR1T Toe 817 LBS. NRC, DEO SOOIUH HYPOCHLO 817 LBS. 08/03/89 CL2 G Thu 2 LBS. 08/20/89 HG L Sun 2 LBS. NRC, DEQ HG 2 LBS. C/A /'A' CAUSTIC B/ PER-TRI B/VCMII C/A / HG CELL CA / HG CELL A GASKET FAILED ON THE PLANT 'C' TRANSFER HEADER WHILE TRANSFERRING CAUSTIC TO THE TANK FARM. APPROXIMATELY SOX OF THE SPILL WAS INTO A CONTAINMENT AREA. NONE PERCHLOR SPILLED TO THE PAD WHEN THE RECYCLE HEADER ON THE PER/TRI STILL LINE BEGAN LEAKING DUE TO CORROSION. 1. LINE WAS CLAMPED TO STOP LEAK. THIS LINE HAD ALREADY BEEN IDENTIFIED FOR REPLACEMENT(DONE). 2. PER/TR! ENV. DAT TO DEVELOP AN ACTION PLAN. DISCHARGE TUBING LEADING FROM C/I BLEACH STORAGE TANK FD PUMP TO THE C/T CRACKED RELEASING BLEACH TO THE GROUND. CAUSE OF CRACK IN TUBING APPEARS TO BE EMBRITTLE MENT. 1. THE INLET AND DISCHARGE TUBING ON THE COOLING TOWER BLEACH FEED PUMP WILL BE REPLACED WITH TEFLON TUBING BY 8/7/89. THE RECIRCULATION VALVE ON HG CENTR. COMPRESSOR WENT TO MAX REC., INSTRUMENT WOULD NOT CONTROL. BACK PRESSURE DEVELOPED ON THE SYSTEM CAUSING CL2 GAS TO ESCAPE INTO THE CELL ROOM. 1. RPLCO THE MOO 30 CONTROLLER AT S L1Q. 2. CLEANED DEBRIS IN AIR TUBING/ACTUATOR WHICH PREVENTED SUCT VLV ON EAST NEUT FROM OPERATING PROPERLY. 3. WKLY SWITCHING OF EXH WILL CONTINUE. CELL *3 DEVELOPED A FLANGE LEAK ON HG INLET LINE. DESPITE HAVING A FLANGE GUARD, HG WAS BLOWN OUT PAST CONCRETE PAD BARRIER AND ONTO THE SHELLED AREA SOUTH OF THE CELL BUILDING. 1. A NEW TYPE OF FLANGE GUARD HAS BEEN INSTALLED. 2. EXTENSION OF CURBED CONTAINMENT IS ONE PHASE OF IMPROVEMENTS TO CELL RM AND RCRA SITE.(COMPLETE BY 6/90). DATE MATERIAL/AMOUNT 08/31/89 EDC L Thu 105 LBS. REPORTED TO 09/11/89 HaOH L Mon 250 LBS. 09/15/89 CLHC/HCL G Fri 67 LBS./ 71 LBS. DEQ/NRC PERCHLOR/HCBD 39.2LBS/1.1 LBS SPILLS AND RELEASES AT LAKE CHARLES PLANT AREA B / EDC DESCRIPTION STARTED THE REFLX PUMP TO #1 STRIPPER, MATERIAL WENT FORWARD TO THE STRIPPER & ALSO FLOWED BACKWARD THRU A CHECK VALVE & OUT A PARTIALLY OPEN BED VLV AT #4 REC PHP. MAIL SPRAYED FROM NT PLT TO GROUND. CORRECTIVE MEASURES 1. RPL BAD CHECK VLV DURING NEXT OUTAGE. (BY 11/30/89) 2. SURVEY BLEED VALVES IN AREA.(10/30) 3. PLUG ALL BLD VLVS HOT OVER COHIA1NMHT 4. BLD VLVS OVER CONT. WILL POINT DOWN. C/A / C CAUSTIC DURING 601 LOUT, THE BOILOUT TK 0/FLOWED INTO A PROCESS SEWER BOX. WATER SPLASHED OUT OF BOX ONTO GROUND. TANK HI LVL ALRH DID NOT WORK/ OPS ATTENTION WAS DIVERTED DUE TO STEAM SYSTEM PRESSURE PROBLEMS. 1. RPR fl/O INK HI LVL ALRH BY 9/15.DONE 2. ADD 8/0 WATER AND STG TNK TO SIX MNIH CRITICAL ALARM PROOFTEST LIST.DONE 3. CONSIDER EXTRA OP. COVERAGE FOR MAJOR B01LOUTS.DONE PER T. SMITH 10/19. B/ PER/TRI DUR1NG START-UP OF #1 PER/TRI RX, BOTH RUPTURE DISCS ON THE RX BLEW DUE TO A FAULTY PRESSURE TRANSMITTER. 1. AN ORC MEETING WILL BE HELD TO DISCUSS THIS INCIDENT.(DONE) 2. A REVISED STARTUP PROCEDURE HAS BEEN WRITTEN AND IS IN EFFECT. 09/18/89 HCL L Hon 167 LBS. 10/02/89 N2/VC G Hon 0.95LBS/0.02LBS. 10/03/89 CL2 G Tue 3 LBS. B/ VCM11 B/ EDC- EC/HCL SHIPPING A A LEAK DEVELOPED ON THE #4 INC. PRIMARY SCRUBBER EFFLUENT TO WTU. AQUEOUS HATE FLOWED ONTO THE GROUND UNTIL BLOCK VLVES WERE CLOSED AT VCHII AND LINE WAS ABLE TO BLEED DOWN TO ENABLE REPAIRS. 1. AN IMMEDIATE VISUAL INSPECTION OF THE LINE WILL BE MADE TO ENSURE ITS SOUNDNESS. 2. LOSS PREVENTION INSPECTORS WILL EXA MINE THE LINE FOR POTENTIAL PROBLEMS. VENTS TRIPPED OUT OF #1 INC. SAT. 9/30. VENTS WERE ROUTED TO *2 INC. VCI VENT HEADER ISOLATION VALVE WAS NOT OPENED. SHIPPING CLEARED HOSES INTO THE VENT HDR AFTER THIS TIME. R/D FOUND LEAKING 10/2. 1. INST LOW PRESSURE ALRM FOR HDR. 2. CHECK PRESSURE RECORDER. 3. PROOFTEST HIGH PRESSURE TRIPS. 4. COUNSEL L.O. AND INC. OPERATORS. A SURGE OF CL2 GAS OF UNKNOWN ORIGIN ACCUMULATED IN SNIFF LINES AND BACKED OUT THROUGH A LOOSE FITTING INTO TANK CAR LOADING LINES. 1. COUNSELED LOADER TO TIGHTEN ALL FITTINGS MORE THAN JUST HAND TIGHT. 2. ALL LOADERS AND HELPERS WERE INFORMED OF THIS INCIDENT AT COMMUNICATIONS MEETINGS. DATE HATER IAL/AHOUNT 10/03/89 HCL G Tue <100 LBS. REPORTED TO 10/03/89 CLHC G Tue 180 LBS. 10/04/89 PER L Ued 2.3 LBS. DEQ/NRC PER/TCE/UN/SYH 4/24.5/11.2/4 10/04/89 PER L Wed 40 TONS 10/08/89 NAOH L Sun 433 LBS. 10/12/89 HCL G Thu 44 LBS. SPILLS AND RELEASES AT LAKE CHARLES PLANT AREA 8/ PER/TRI DESCRIPTION THE EXPANSION JOINT ON #4 RX PULLED OUT OF STEEL FLANGE WHILE MAINTENANCE WAS ATTEMPTING TO REPAIR A MINOR LEAK. CORRECTIVE MEASURES 1. THIS EXP. JOINT WILL BE EXAMINED ON EACH RX TO VERIFY THAT EACH HAS STAY BOLTS OR IS RPL WITH ONE THAT DOES. 2. REVIEW WITH MAINT PERSONNEL 3. RPR THE HCL FLOW CONTROL VALVE. B/ U1U THE LEVEL INDICATOR FLOAT CHAMBER FLOAT FAILED CAUSING THE LCV TO NOT SEE A LVL IN THE DH STILL. THE STILL WAS OVERFED, RESULTING IN A RELEASE THROUGH THE RUPTURE DISC. 1. RPL AND MORE THOROUGHLY CHECK ALARM SYSTEM LIGHTING. 2. RPR LEVEL FLOAT AND FLOAT CHAMBER 3. INV. USING DP SYSTEM AS A REDUNDANT LEVEL ALARM-MAY TIE IN TO SDS. B/ PER/TRI SHALL PINHOLE LEAK DEVELOPED ON THE BOTTOM SIGHTGLASS NOZ2LE ON THE CLEAN UP STILL REFLUX DRUM. PERCHLOR SPRAYED ONTO THE CONTAINMENT PAD. 1. VESSEL WAS CLEARED FOR ENTRY/INSPTN. 2. RPL LEAKING NOZZLE AND MAKE ANY OTHER REPAIRS AS RECOMMENDED BY LOSS PREV. 3. TAKE THICKNESS READINGS ON NOZZLE IN EFFORT TO DETERMINE CAUSE OF FAILURE. SHIPPING/ DOCKS CSCC BARGE 202 WAS LOADED WITH PERCHLOR. LEAD LOADER FOUND A LEAK FROM A CARGO TANK INTO DRY COMPARTMENT OF BARGE. 1. BARGE WAS SENT TO SHIPYARD FOR INSPECTION. A/ A GENERAL A LEAK DEVELOPED ON CELL LIQUOR LINE RUNNING THROUGH THE HG CELL AREA. APPROX 1/2 GPH FELL ON A CONCRETE PADDED AREA WHICH DRAINS TO THE BRINE SPILL SUNP WHICH IS TREATED PRIOR TO DISCHARGE. 1. THE BAD SECTION OF LINE WAS REPLACED. 2. LINE INSPECTIONS WILL CONTINUE. 3. GEM PAINTERS HAVE COMPLETED WORK ON THIS LINE AND NO OTHER PROBLEMS HAVE BEEN NOTED. B/ TE II THE TR1-ETHANE FURNACE DEVELOPED A TUBE LEAK ALLOWING EDC TO ESCAPE INSIDE THE FURNACE. ONLY HCL ESCAPED TO THE ATMOSPHERE. 1. TUBES ARE TO BE REPLACED IN DECEMBER '69. THE FABRICATION IS NOW IN PROGRESS. cn c* o CO 00 cn UJ DATE MATER 1AL/AMOUNT 10/19/89 EDC L Thu 14 LBS. REPORTED TO 10/28/89 CLHC L Sat 78 LBS. DEQ PER/ICE 12/2 10/31/89 UHC/HCL L Tue 24 LBS. 11/02/89 CEHC/HCL G Thu 4.42 LBS DEO PERCHLOR 2.3 11/09/89 CLHC G Thu 51377 LBS. 11/10/89 PER L Fri 709 LBS. SPILLS AND RELEASES A1 LAKE CHARLES PLANT AREA 8/ TE tl DESCRIPTION SLOCK VALVE ON #4 OHC REACTOR PRIMART VENT MLS BYPASS DEVELOPED A LEAK AT THE STEM. CORRECTIVE MEASURES 1. THE VALVE WILL BE REPLACED WITH A NONOIAPHRAH TYPE TEFLON LINED VALE DURING THE NEXT OHC II REACTOR OVERHAUL. B/ UTU B VCM 11 B/ PER/TRI B/ TRI II B/ PER/TRI WHILE TRANSFERRING MATERIAL FROM A VACUUM TRUCK INTO THE TOP OF A RENTAL FRACK TANK LOCATED ON N. CLASSIFIER PAD, THE HOSE BEING USED BLEU OUT OF THE TANK SPRAYING MATERIAL ONTO THE GROUND. 1. IRSPECT RENTAL TANKS TO ENSURE AN UNLQADNG FITTING IS IN PLACE BEFORE USE 2. REVIEW INCIDENT W/ SERVICE PERSONNEL AND AT NEXT ENV. QAT MEETING. 3. SLDGE HGHT TO IMCL EL1M. OF TEMP. TKS A WELD UPSTREAM OF THROTTLING VLV ON #2 VC DOPP KETTLE FEED LINE DEVELOPED A PIN HOLE LEAK SPRAYING APPROX. 2.5 GALLONS OF DOPP KETTLE FEED ONTO THE PAD AND GROUND. 1. RPL SECTION OF FEED LINE TO #2 VC DOPP KETTLE UIIH SCHEDULE 80 PIPE RATHER THAN SCHEDULE 40 AS UAS THE ORIGINAL PIPE. A LEAK DEVELOPED ON A PER/TRI REACTOR CATALYST CATCH POT RUPTURE DISC NOZZLE. OPERATORS BEGAN S/D OF RX BUT COULD NOT EST. FLUSH WATER FLOW TO COND. LK UAS CLAMPED UNTIL LINE COULD BE ISOLATED(EC) 1. REVISED PIP ING-REVIEU OTHERS AS WELL. 2. RETURN STM TRACING TO SERVICE. 3. EST N2 PURGES ON #4 RX CATCH POT, AS OTHERS. 4. VISUAL INSP OF ALL POTS. 5.1NCL CATCH POTS ON VtDS PROGRAM 6. REWORK FLUSH CV. THE CLEARING LINE ON THE DfE RX CATALYST POT UAS LEFT OPEN WHEN THE,SYSTEM UAS PUT BACK INTO SERVICE. THE RELIEF OPERA TOR FOUND THE VLV OPEN AND<BLOCKED IT. ALL MATERIAL UAS CONTAINED IN SUMP.{OP) 1. OEPRATOR UAS COUNSELLED. A LEAK DEVELOPED ON THE DISCHARGE OF THE P/T HVS STILL REFLUX PUMP AT PER STILL FEED NOZZLE UELD. THE LEAK UAS CLAMPED ALL PERCHLOR UAS CONTAINED ON THE CONCRETE PAD. (1C) 1. LOSS PREVENTION TO TAKE UV READINGS OF PIPING SURROUNDING UELD -DONE- 2. WOW TO RPL PER FEED NOZZLE ON THIS LN 3. P/T ENV. QAT ADDRESSING THIS LOCATION AS A POTENTIAL PROBlEH AREA. DATE HATER[AL/AMOUNT 11/10/89 PER, TRi G Eri <10 LBS. REPORTED TO DEQ PERCHLOR 62 11/14/89 CL2 G Toe <5 LBS NRC, LSP CL2 45 11/15/89 PER, TRI L Wed 13 LBS 11/15/89 HCL G Wed 35 LBS 11/16/89 PER L Thu 26 LBS 11/21/89 CLHC G Tue 1.4 LBS Xfl O CD CD LD Ol SPILLS AND RELEASES AT LAKE CHARLES PLANT AREA B/ PER/TRI DESCRIPTION THE PER/TRi STILL FEED LINE DEVELOPED A LEAK. DUE TO THE TEMPERATURE OF THE HATER 1AL{210 F), VAPORIZATION TO THE AIR OCCURRED. (1C) CORRECTIVE MEASURES 1. TEMPORARY CLAMP INSTALLED DONE2. WOW TO REPLACE THIS SECTION OF PIPE. 3. MOISTURE RIG WAS CHECKED TO VERIFY THE MATERIAL WAS DRY -DONE4. P/T ENV QAT STUDYING [NT CQRR PROBLEM C/A / HG CELL AS THE HG CELL UNIT WAS SHUT DOWN, THE LIQUOR IN THE NEUIR. HTPO TANK BECAME SATURATED U/ CL2 AND DID NOT HANDLE THE ENTIRE CL2 STREAM BEING SENT TO IT. PPG WAS NOTIFIED OF PROBLEM BY TETRA. (OP) 1. AN SOP WILL BE WRITTEN OUTLINING PROPER CAUSTIC ENRICHMENT OF THE HYPO RECIRCULATING SYSTEM PRIOR TO HIGH CL2 FLOWS TO THE NEUTRALIZER. B/ PER/TRI A LEAK DEVELOPED IN THE SIDE OF A BALL VALVE DOWNSTREAM OF THE #2 DH STILL LCV ON A DEAD-ENDED SECTION OF PIPING. ALL MATERIAL RELEASED WAS CONTAINED ON THE PAD. (1C) 1. THE BLOCK VALVE WAS REPLACED. 2. THIS AREA HAS BEEN IDENTIFIED BY THE P/T ENV QAT AS AN AREA OF POTENTIAL INTERNAL CORROSION PROBLEMS. THE QAT WILL MAKE RECOMMENDATIONS. B/ EDC - EC/HCL A LEAK DEVELOPED ON THE OLD HCL HEADER DUE TO EXTERNAL CORROSION. (EC) 1. WOW TO REPLACE THIS SECTION OF PIPING 2. CONTINUE TO MAKE QUARTERLY PIPELINE INSPECTIONS. B/ PER/TRI B/ WTU A LEAK DEVELOPED IN WELD OF PER STILL FEED NOZZLE ON THE DISCHARGE OF THE HVS STILL REFLUX PUMPtSEE M/10 SPILL). ALL MATERIAL WAS CONTAINED ON THE PAD. (1C) 1. P/T ENV QAT CURRENTLY ADDRESSING THIS LOCATION AS A POTENTIAL FOR INI CORR. 2. NOZZLE WAS REPLACED -REFLUX HEADER METAL LOOKED GOOD. OPERATOR DISCOVERED A BLOWN RUPTURE DISC ON #1 WTU PHASE SEPARATOR. INVESTIGATION REVEALED A HIGH ORGANIC LEVEL IN THE PHASE SEPARATOR. (OP) 1. START SLUDGE KETTLE SYSTEM TO REDUCE VOLUME OF SLUDGE AND CL2 CONCENTRA TION BEING SENT TO WASTE TECH. Z. SLUDGE MGMT MUST INCLUOE A MEANS OF SLUDGE REMOVAL FROM CRITICAL SYSTEMS. DATE MATERIAL/AMOUNT 11/22/09 EC G Wed 58 LBS REPORTED DEQ EC 47 TO 11/25/89 CLHC, HCL C Sat 123 LBS. NRC/DEQ VC/PER 1.5/5 11/29/89 OIL L Wed NRC OIL 12/06/89 CLHC G Wed 9 LBS. 12/06/89 NAOH L Wed 1216 LBS. DEQ VC 0.21 12/12/89 CLHC/WASTEWATER L NRC/DEQ Tue 9098 LBS. TCE/WASIEWATER 1.7/9098 SPILLS AND RELEASES AT LAKE CHARLES PLANT AREA B/ EDC - EC/HCL DESCRIPTION A GASKET FAILED IN THE 2 INCH VENT CONDENSATE LINE. THIS FAILURE WAS BETWEEN THE PUMP DISCHARGE AND THE PRIMARY STRIPPER fEED TANK. (HP) CORRECTIVE MEASURES 1. THE GASKET WILL BE REPLACED IMMEDIATELY. 2. A TEST SECTION OF PIPE IS TO BE PUT INTO SERVICE AND INSPECTED AFTER 3G-45 DAYS OF EXPOSURE. B/ WIU B/ 'B' GENERAL B/ WIU C/A / A CAUSTIC NO. 2 INC. TRIPPED AND PLANT VENTS (EXC. VCM X E/CSS) EQUALIZED BACK INTO THE VCM Il/CSS VENT HEADER. A FAULTY R/D IS SUSPECTED SINCE PRESSURE >3# WAS NEVER RECORDEDOO# R/D). (MP) 1. CONT. TO ENSURE PROPER R/D & GASKET IS USED-NOT SUSPECTED AS PROBIEM HERE 2. CHECK THAT EACH R/0 STACK HAS DRAIN HOLE AND IT IS UNPLUGGED. 3. REVIEW VI VLV SWITCHING PROC W/ OP. AN OIL SHEEN WAS SPOTTED PAST PPG BOOH IN THE CANAL. AN OIL LAYER WAS DISCOVERED ON THE WUT FEED TANK INVESTIGATION COULD NOT PINPOINT A SINGLE SOURCE NOR IDENTIFY THE OIL.(OP) 1. SCC TO ADDRESS AND OEVEOP ACTION PI AN EMERGERNCY SPILL RESPONSE TASK FORCE 2. MEMO TO BE ISSUED TO DERIVATIVES OPN PERSONNEL ON IMPACI OF QU IN SEWERS. NO. 1 CENTRAL STEAH STRIPPER FEED TANK WAS OVERFILLED CAUSING THE RUPTURE DISC TO BLOW. (OP) 1 . OPERATOR INVOLVED WILL BE COUNSELED POSSIBLE DISCIPLINARY ACTION 2. SOP TO BE WRITTEN TO ADDRESS HIGH ORGANICS IN SF FEED BY 12/31/89. 3. REVIEW INCIDENT WITH L.O.S BY 12/31. AUTOMATIC FEED VALVE ON #7 FILTER LEAKED BY. DRAIN TO COLLECTION SYSTEM WAS PLUGGED ALLOWING CAUSTIC TO GO TO THE 30" PROCESS SEWER. THIS RESULTED IN A PH EXCURSION FOR 45 MINUTES. (HP) 1. UNPLUG LINE FROM #7 FILTER TO COLLECTION SYSTEM. (DONE-12/6/89) 2. REV. SOP FOR THE MANUAL BLOCK VLV ON THE FD HEADR TO BE CLOSED WHEN A NAOH FILTER IS TAKEN OUT OF SERV1CE(12/13) B/ TE II THE PROCESS SUMP OVERFLOWED TO THE STORM SEWER AMD THE STORM SEWER BACKED OUT OF THE CATCH BASINS AND ONTO THE SHELL AT 11 LOCATIONS IN TE II. (OP) 1. CLEAN UP CONTAMINATED SHELL. 2. DEVELOP A BLOCK/LOGIC DIAGRAM AND SOP TO PREVENT O/FLOW OF BAT AND PROCESS SUMPS INTO THE STORM WATER SYSTEM. 3. REVIEW ABOVE PROCEDURES) WITH OP. DATE HATER IAL/AMOUNI 12/14/89 PER L Thu 3 LBS. REPORTED TO 12/17/89 CL2 G Sun <5 LBS. 12/20/89 CL2 G Ued A LBS. 12/22/89 tiCL L Fri 52 LBS. 12/23/89 VC G Sat 15 LBS. 12/23/89 NAOH L Sat 14917 LBS NRC, DEO VC 15 INTERNAL SPILLS AND RELEASES AT LAKE CHARLES PLANT AREA B / PER/TRI DESCRIPTION A SMALL PINHOLE LEAK DEVELOPED IN A STRAINER LID GASKET ON TOP OF A PER 208 DRYER. APPROXIMATELY 3 LBS. OF PERCHLOR LEAKED TO CONTAINMENT. CMP) CORRECTIVE MEASURES 1. GASKET REPLACED ON SCREEN 12/14. PRESSURE CHECK SHOWED IT STILL LEAKNG 2. WILL CHECK SEALING SURFACE/RET IGHTEN LIO/ETC THE WEEK OF 12/18. C/A / 'A' CL2 A FROZEN IMPULSE LINE TO CKI. 15 CL2 HEADER PRESSURE CONTROLLER FORCED CL2 INTO THE NEUTRALIZER. A VAPOR CLOUO WAS SEEN LEAVING THE NEUTRALIZER. CL2 HAS DETECTED AT HG CELL CONTROL ROOM (IP) 1. WOUREPL EXISING IMPULSE LINES W/ FRP MANIFOLD SYSTEM OF LARGER DIAMETER TO MIN. POTENTIAL OF ICE PLUGGING LINES. 2. TEMP HEAT LAMPS TO BE PROVIDED AT CRITICAL POINTS AND XTRA 1NSLN ADDED. SH/ A SHIPPING UHILE PRESSURE TESTING A NEW CL2 LOADING LINE PRIOR TO RETURNING IT TO SERVICE, A DEFECTIVE ANGLE VALVE UAS FOUND NOT FULLY CLOSED. CL2 FROM EQUALIZER SYSTEM USED TO TEST THHE LINE ESCAPED THRU VLVE 1. SOP 10 BE CHANGED TO DOUBLE CHECK ALL VALVES PRIOR TO TESTING. B/ VCH 11 TUBULAR GLASS S/G ON ATM. SCRUBBER FROZE AND BROKE, SPILLING HCL TO GROUND. SPILL DRAINED TO DITCH FLOWING TO OUTFALL 401. DUE TO FLOW OF FREEZE PREC. WATER, SPILL REACHED 401 BEFORE IT COULD BE DAMMED. 1. IMMEDIATELY INITIATE A POLICY TO KEEP SIGHT GLASS ISOLATED EXCEPT WHEN CONFIRMING A LEVEL. 2. INSTALL CONTAINMENT PAD AROUND BASE OF SCRUBBER (BY 4/89) SHIPPING/ DOCKS UHILE LOADING VINYL ONTO A BARGE, THE BLEED ON THE LOADING LINE CRACKED RELEASING VINYL. FREEZING WEATHER IS SUSPECTED TO HAVE CONTRIBUTED TO THIS FAILURE. 1. PERFORM MORE THOROUGH VISUAL INSPECTION OF ALL VALVES AND CONNECTIONS PRIOR TO LOADING. C/A /'A' CAUSTIC CLEAR LINE FROZE DUE TO COLD WEATHER. RECIRC. PUMP TRIPPED CAUSING TK TO O/F. NAOH TITRATOR FROZE. NO ALARM UAS RECEIVED IN CONTROL ROOM. PH VIOLATION OCCURRED. (HP) 1. CLEAR AND CLOUOY TANKS O/F LINES TO BE LINE MOLED. 2. INSTALL HIGH LEVEL ALARMS ON #7 CLEAN AND CLOUOY TANKS. DATE HATER IAL/AMOUNT 12/27/89 NAOH l Wed 577 LBS. REPORTED TO 12/29/89 CL2 G Fri 3 LBS. SP1LIS AND RELEASES AT LAKE CHARLES PLANT AREA C/A/ 'A' CAUSTIC DESCRIPTION THE UNDERGROUND CELL LIQUOR TRANSFER HDR FROM 'A' CAUSTIC TO PLANT B TAILED.SPILL CAHE TO SURFACE AND INTO STORHUATER RUN OFF SEUER EXITING AT 004 CUTFALL. FREEZE DAHAGE DID NOT ALLOU PH HEUTR. TO WORK. CORRECTIVE MEASURES 1. DET FAILURE MECHANISM OF CELL LIQUOR TRANSFER HEADER. DEVELOP ACTION PLAN TO PREVENT FUTURE SPILLS FROM LINE. 2. INST MANUAL ACID BYPASS VAtV AT 004. 3. CHECK OPERATION OF AUTO VLVS 1/SHIFT. C/A / HG CELL THE HG CELL CIRCUIT UAS ENERGIZED TO UARH UP PRIOR TO STARTUP. NEUTRALIZER IMS HANDLING CL2 BEING SENT TO IT, UNTIL A SUING IN THE CONTROLLER OCCURRED. A SHALL CLOUO UAS EMITTED FROM THE STACK. 1. AN SOP WILL BE IMPLEMENTED TO PRESTRENGTHEN THE CAUSTIC CONTENT OF THE RECIRCULATED HYPO IN THE NEUTRALIZER. cn 088548 LAKE CHARLES COMPLEX 1989 SPILL/RELEASE RECORD 16 14 SL 088549 1908 JAN FEB MAR APR MAY JUNE JUIY AUG SEPT OCT NOV DEC 1909 AVG/MTH AVG/MTH TOTAL REPORTABLE FIGURE 1 LAKE CHARLES COMPLEX SPILL/RELEASE RECORD 1985-1989 106 S S 8 qq 1985 1986 1987 1988 CO tr1 HI Total Total Releases - 27% Redaction (trom 1988) Reportable Releases - 29% Redaction (trom 1988) Reportable FIGURE 2 1989 LAKE CHARLES COMPLEX CHLOR/ALKALI RELEASES, 1989 Number of Releases Total Reportable LAKE CHARLES COMPLEX DERIVATIVES RELEASES, 1989 Number of Releases 14 !.... ........ .............. . '88 Ju Feb Mar Apr May June Jul Aug Sept Oct Nov Dec 89 Avg/Mo Avg/Mo Total NXXX Reportable FIGURE 3 sl 88551 LAKE CHARLES COMPLEX TOTAL RELEASES 1988 DERIVATIVES 54% dhlor/alkau 28% % COMPLEX 1% SILICAS 3% SHIPPING 14% LAKE CHARLES COMPLEX TOTAL RELEASES 1989 FIGURE 4 SL 088552 LAKE CHARLES COMPLEX CAUSES FOR TOTAL RELEASES 1988 MECH. PHOB. 28% LAKE CHARLES COMPLEX CAUSES FOR TOTAL RELEASES 1989 PEOPLE ERRORS 33.* OPERATIONS 83.* MAINTENANCE 20 * SHIPPING 8.5.* CONSTRUCTION 8.5.* FIGURE 5 SL 088553 LAKE CHARLES COMPLEX CHEMICALS RELEASED TO THE ENVIRONMENT (thousand ponndi) 300 --------------------- LAKE CHARLES COMPLEX CHEMICALS RELEASED TO THE ENVIRONMENT Thousand Pounds 16 iso Cl 2 1/90 NaOH C1HC KC1 1988 KS3 1989 FIGURE 6 PROCESS WATER SL 088554 LAKE CHARLES COMPLEX SPILLS/RELEASES BY UNIT Total Releasea/Outstanding CA* Items 16 ---------------- ---- -------- "-- 14i 13 Hg 'A* "C' `A' "C* Pals Brina Liquaf. "A" Complex Call ChlorlnsChlorlna Cauatlc Cauatlc Power Qanarai as Raiaaaaa !' . .1 BS Raiaaaaa [XXX] Outatanaing itama V/A Outstanding Itama Corrective Action Itama i/eo LAKE CHARLES COMPLEX SPILLS/RELEASES BY UNIT Total Releases/Outstanding CA* Items 30------------------------------------------------------------------------- TEN VCII Par EDC WTU 'B' *A' 'B' Oook Bllloas Trl General Shlppingatiipplng '88 Raiaaaaa '89 Raiaaaaa k\\\l Outstanding Itama V/A Outstanding Itama Correotlva Aotion Itama n G II R E 7 SL 088555 DATE HATER IAL/AMOUNT 01/14/88 EDC C 198 Tbs. PLAN! / AREA 6/ WTU 03/24/88 CHLORINE G ^ 6 lbs. B/ EDC 05/06/88 CIHC L 34 tbs. B/ VC-11 05/09/88 CHLORINE G 338 lbs. CA/ Hg CELL 05/18/88 MERCURY L 3 lbs. CA/ Hg CELL 06/01/88 TR1CHLOR 216 lbs. cn tr* o CO CO Ln LSI CTi B/ PER/TRI ATTAc M I- N T II QUARTERLY UPDATE SPILLS/RELEASES CORRECTIVE ACTION ITEMS DESCRIPTION OF RELEASE A SLUG OF ORGANICS WAS FED TO #2 CSS CAUSING RUPTURE DISC TO BLOW FOR ABOUT 1 MIN. NO UNUSUAL INCIDENTS IN THE OHC UNITS APPEAR TO BE PRECURSORS. CORRECTIVE MEASURES IN PROGRESS DISCUSSIONS ARE BEING HELD WITH VCHJI AND TE-li ON THIS MATTER. RESULTS AND PLANS WILL BE WRITTEN AND PRESENTED TO THE COMMITTEE WHEN COMPLETE. INVESTIGATE PROVIDING PHASE-OFF CAPABILITY AT CSS. WHILE HEATING UP *3 RX, VENT WENT TO SCRUBBER INSTEAD OF INCINERATOR HEADER. CHLORINE WAS RELEASED FROM SCRUBBER FOR ABOUT 2 MINUTES UNTIL VENT WAS SWITCHED TO INCINERATOR HEADER. REVISE PROCEDURES TO PUT VENTS TO INCINERATORS BEFORE CHLORINE ADDITION. REVIEW WITH OPERATORS. PRESSURE GAUGE DOWNSTREAM OF EDC SIDEARM COOLER BLEU OFF SPRAYING EDC REACTOR LIQUOR. THE CAUSE WAS INTERNAL CORROSION ON GAUGE THREADS. SPILL WAS CONTAINED ON ON CONCRETE PAD. MAINTENANCE WAS AGAIN INFORMED OF THE NEED TO USE STA1NIESS STEEL FITTINGS IN THIS AREA RATHER THAN CARBON STEEL. WILL TRY TO ARRIVE AT A VISUAL METHOD OF REMINDING PEOPLE OF THIS.(COLOR COOING) TAIL GAS WAS DIVERTED FROM Hg CELL NEUTRALIZING TOWER TO POWERHOUSE STACK. HYPO CIRCULATING PUMP TRIPPED THREE TIMES CAUSING DIVERSION. A BACKUP SYSTEM FOR PREVENTING EXCURSIONS TO THE POWERHOUSE STACK HAS BEEN ENGINEERED. PIPING AND VALVING WILL TIE DIVERSION SYSTEM INTO ONE OF PLT. A'S NEUTRALIZING TOWERS. LEAK DUE TO A BLOWN GASKET ON THE BOTTOM FLANGE OF CELL 15 MERCURY INLET VALVE. ALTHOUGH A FLANGE GUARD WAS PRESENT, SPLATTERING AS MERCURY HIT THE FLOOR CAUSED SOW TO CONTACT GROUND. ROOT CAUSE ANAL.-IDENT . CAUSE OF LEAKS. (DONE) FLANGE GUARDS ARE BEING INST. TO PREVENT SPRAY (DONE). TEST PROGRAM TO IDENTIFY A BETTER GASKET MATL.(IN USE) SOME CONIMNT. AREAS TO BE WIDENED.(1990) IRi SHIPPING TANK OVERFLOWED. DISCREPANCIES IN LEVEL INDICATORS RESULTED IN THE OVERFLOW SITUATION. ENGR. WOW TO INST. HIGH HIGH LEVEL ALARM REVISE LOGSHEET TO RECORD VAREC & BOARD INDICATION ON ALL AREA PROO/SHIPPING TKS INSTALL VARECS ON HVS STILL & P/T STILL FEED TANKS.-1ST QRTR 1990 COHPLETION- DATE HATER IAL/AMOUNT 06/05/88 HCl G 29 lbs. PLANT / AREA B/ EDC 06/09/88 CHLORINE G 8 lbs. CA/ Hg CELL 06/14/88 CLHC G 49.3 lbs. B/ PER/TRI 06/18/88 CLHC L 54 lbs. ^ 8/ WTU 07/10/88 CHLORINE G * CA/ C ELECTRO 125 lbs. 07/10/88 PERCHLOR G 11.2 lbs. B/ PER/TRI QUARTERLY UPDATE SPILLS/RELEASES CORRECTIVE ACTION l DESCRIPTION OF RELEASE RUPTURE DISC ON VC-1 INCINERATOR HEADER BLEW. DISC HAY HAVE BEEN FAULTY OR DETERIORATED AS PRESSURE WAS BELOW RUPTURE POINT. CORRECTIVE MEASURES IN PROGRESS HAVE A GROUP LOOKING AT PREMATURE GRAPHITE RD FAILURES. LOAD SHED INITIATED BY A CIRCUIT START UP AT A CHLORINE CAUSED A SUDDEN DROP IN CIRCUIT LOAD. Hg CELL COMPRESSOR COULD MOT SLOW DOWN FAST ENOUGH CAUSING BACK PRESS. RESULTING IN BLOWN SEALS. WORK ORDER WAS WRITTEN TO INSTALL NEW FASTER RESPONSE INSTRUMENTATION ON THE Hg CELL COMPRESSOR SYSTEM. ALSO CHANGES WERE HADE IN THE LOAD SHED PRIORITY SEQUENCE. #1 DH STILL RUPTURE DISC BLEW. LOU DH FEED TANK LEVEL ALLOWED LIGHT ORGANICS AND/OR HIGH MOISTURE TO BE FED TO STILL CREATING PRESSURE PROBLEMS. COUNSELLED OPERATORS TO MONITOR LEVELS MORE OFTEN. ENGR WOW TO FIND RELIABLE LVL 1ND. FOR DH FEEO TK ORGANIC LEVELS AND INSTALL LOW LEVEL ALARM.(IN ENGR). EXAMINE PIPING FOR COLLAPSED LINER. A HOLE IN INCINERATOR FEED LINE AT A WELD DOWNSTREAM OF THE LIQUID FEED FCV CAUSED A LEAK. LINE HAS BEEN REPLACED. RE INF.PADS USED TO REDUCE LEAK POTENTIAL WOW TO RUN INCINERATOR FEEO PIPING IN A CONCRETE TRENCH.(TO BE DONE IN 1990). PLANT POWER FAILURE CAUSED CHLORINE COMPRESSORS TO SURGE RELEASING CI2 AT ACID TOWER PRESSURE SEALS. POWER SURGE TRIPPED OFF NEUTRALIZER BLOWER WITH CL2 ESCAPING THRU DILUTION AIR STACKS LEVEL III STUDY HAS BEEN PERFORMED. RECOMMENDATIONS FOR THE NEUTRALIZER PROTECTION SYSTEM ARE BEING IMPLEMENTED. PLANT POWER FAILURE CAUSED LOSS OF PUMP CONTROL, INSTRUMENTS, ETC. EHERG. SHUT DOWN OF REACTOR PROBABLY CONTRIBUTED TO INCREASED HEADER PRESSURE RESULTING IN BURSTING LOWER RD ON #2 DH STILL. INVESTIGATED REROUTING OF RD VENT FROM BOTTOM OF STILL TO SOMEWHERE ELSE.(NOT POSSIBLE PER INDUSTRIAL ENGINEERING.) ENGR. WOW TO RPL THE DH STILL AND [NCR. PRESSURE RATING.(IN ENGINEERING) DATE HATERiAL/AMOUNT 07/10/88 VDC G 764 tbs. PLANT / AREA B/ EOC 07/14/88 MERCURY L ^ CA/ Hg CELL 3 lbs. 07/27/88 TRICOLOR G 1552 lbs. B/ PER/TRI 08/11/88 CHLORINE G "fa 13.2 ibs. 8/ EOC 08/23/88 CHLORINE G 2 lbs. CA/ Hg CELL 09/02/88 HCl G 76.6 lbs. B/ EDC (fi r1 o 00 00 U1 cn co QUARTERLY UPDATE SPILLS/RELEASES CORRECTIVE ACTION ITEMS DESCRIPTION OF RELEASE PLANT POWER FAILURE. VDC REACTOR STEAM VALVE FAILED TO SEAT OFF COMPLETELY ALLOWING REACTOR TO OVERPRESSURIZE AND SLOW RUPTURE DISC. CORRECTIVE MEASURES IN PROGRESS CHECK VDC REACTOR STEAM FCV AND REPAIR/ REPLACE. CAMPAIGN FOR AUK1LLARY OPERATOR TO ADD ADDITIONAL PAIR OF HANDS DURING EMERGENCY SITUATIONS. COHl p I & LEAK DEVELOPED ON THE TOP FLANGE OF CELL 34 MERCURY INLET VALVE SPILLING MERCURY TO FLOOR. SPLATTERING OR SPRAYING FROM GASKET FAILURE CAUSED SOME MERCURY TO SPILL OUTSIDE OF CURSED AREA. INSTALLED FLANGE GUARDS ON ALL MERCURY PIPING FLANGES WITH LEAK POTENTIAL TO GROUND. CURBING WILL BE EXTENDED TO CONTAIN ALL POTENTIAL SPILLS. (TO BE DONE IN 1990). RUPTURE DISC OH TRI TOPPING STILL BURST. REFLUX DRUM LEVEL TRANSMITTER WAS FOUND TO HAVE A PINHOLE IN DIAPHRAM. SUSPECT THIS CONDITION ALLOWED A HIGHER LEVEL TO OCCUR THAN WAS INDICATED. INSTALL A PRESSURE TRANSMITTER FOR THE TOPPING STILL. (ENGR. WOW) WILL BEGIN DAILY CROSS-CHECKING OF SIGHT GLASS/FIELD LEVEL INDICATORS VS LEVEL TRANSM1ITERS/BOARD 1NDI CAT IONS.(DONE) MODICOM SHUTDOWN SYSTEM FOR #1 EDC REACTOR TRIPPED CAUSING LIQUID CHLORINE PRESSURE TO INCREASE. AS A RESULT, CHLORINE VAPORIZER SRV LIFTED BRIEFLY. CHECK MOO ICOM SYSTEM TO SEE WHY IT TRIPPED *1 EDC REACTOR AND REPAIR AS NEEDED. INSTALL AN EMERGENCY SHUTOFF VALVE AT LIQUEFACTION CONTROL ROOM ON LIQUID LINE COMING TO EDC. CHLORINE WAS RELEASED AT THE ATMOSPHERIC VENT VALVE DUE TO INSUFFICIENT VACUUM ON INLET TO NEUTRALIZER. OPERATORS DID NOT OBSERVE RISE IN PRESSURE AND ACT TO LOWER IT. ALARM RESET TO 2.75" WATER VACUUM.(DONE) A NEW ATMOSPHERIC VENT VALVE ACTUATOR WILL BE INSTALLED. INITIATE WO/PROJECT TO REVISE INTAKE OF ATMOSPHERIC AIR TO STOP CL2 ESCAPE AT THIS LOCATION. A 1/2 INCH NICKEL NIPPLE BLEW OFF THE #1 EOC REACTOR VENT LINE DOWNSTREAM OF THE VENT CONDENSER. NIPPLE WAS CORROOED FROM THE INSIDE. INSPECT OTHER NOZZLES ON THIS LINE TO TRY TO DETECT ANY OTHER INTERNAL CORROSION ON NIPPLES IN SAME SERVICE AND REPLACE. DATE HATER 1AL/AMOUNT 09/15/88 CHLORINE G 5 lbs. 11/22/88 NaOH L 300 tbs. 12/13/88 CIHC G 152.2 lbs. 12/20/88 CHLORINE G 3 tbs. PLANT / AREA B/ EDC SHIPPING/ DOCKS B/ WTU CA/ Hg CELL QUARTERLY UPDATE SPiLLS/RELEASES CORRECTIVE ACTION [ DESCRIPTION OF RELEASE WHILE HEATING #3 EDC REACTOR FOR START OP Hg CELL CUT IN/OUT CELLS CAUSING AN UPSET IN CHLORINE PURITY. CHLORINE BROKE THROUGH REACTOR TO SCRUBBER AND SOME ESCAPED THE SCRUBBER. CORRECTIVE MEASURES IN PROGRESS A QAT WILL BE COMMISSIONED BY K. E2ELLE TO OEAL WITH THE CONDITIONS WHICH CAN CAUSE A RELEASE OF THIS TYPE. WHILE FILLING ET-50 CAUSTIC LINE FOR BARGE LOADING, CAUSTIC OVERFLOWED THE C" DOCK SUMP BECAUSE OF A DRAIN VALVE BEING LEFT OPEN. A WORK ORDER HAS BEEN WRITTEN TO REPLACE THE DRAIN LINE VALVES WITH BUTTERFLY TYPE VALVES.-COMPLETE 1/89.THE SUMP COULD BE RELOCATED AND DIKED. -UNDER STUOY- DUE TO A FAILED TEMPERATURE PROBE, ORGANICS WERE SENT TO THE CSS FEED TANKS BY VDCM. CONTENTS OF FEED TANKS WERE HOT ORGANICS CAUSED TANK TO OVERPRESSUR ES AND RUPTURE DISC BLEU. RPRD TI AND ALRM 12/K/88. SOP TO BE REV TO INSURE ORG GO TO L/S HDR DURNG UPSET INSTEAD OF CSS. COOLER HAS BEEN INSTLLED AT VDCM. ENGR INVEST. STRIPPER AT VDCM. INST MORE RELIABLE TRANSMITTER. CHLORINATED BRINE OVERFLOWED FROM THE DEPLETED BRINE TANKS DUE TO A PUMP NOT OPERATING PROPERLY. OVERHAUL PUMP AND RESET CLEARANCES TO CORRECT CAPACITY PROBLEMS. (DONE) INST A SECOND ALARM TO GIVE EARLIER WARNING ON TANK LEVEL.(WOW) QUARTERLY UPDATE SPILLS/RELEASES CORRECTIVE ACTION TENS DATE HATERIAL/AMOUNT 01/25/89 CHLORINE C 465.4 lbs. PLANT / AREA CA/ Hg CEU DESCRIPTION OF RELEASE SANDBLASTER PUT A HOLE IN INSTRUMENT SIGNAL TUBING TO NEUTRALIZER GAS EX HAUSTERS. THIS RESULTED IN LOSS OF NEUTRALIZER INLET VACUUM AND DIVERSION TO RIVERSIDE PURHSE STACK. CORRECTIVE MEASURES IN PROGRESS PM EXHAUSTER SUCTION VALVE ACTUATORS. (ONE COMPLETE). REVISE ACTION OF THE VALVES TO FAIL OPEN UPON LOSS OF SIGNAL OR AIR SUPPLY. MODIFY DIVERSION SYSTEH(PE) 01/30/89 CIHC/WAIES G 0.1/1145.3 lbs. B/ WTU RUPTURE DISC ON #1 CSS FEED TANK BLEU. SUSPECT PREMATURE FAILURE AS NO INDICA TIONS OF EXCESSIVE TEMPERATURE OR PRESSURE IN THE TANK MERE OBSERVED. REVIEW SOP'S REGARDING REMOVAL OF PHASE ORGANICS FROM FEED TANKS(DONE). REVIEW CONTRACT W/ OHC TO MINIMZE PHASE ORGANIC ENTERING FD TKS(IN PROGRESS). DEV. CONIR W/ VDCM TO COOL BTHS. (COOLER INSTALLED) 02/03/69 NaOH L 200 Lbs. CA/ PELS STG. BIN #1, PLUGGED WITH WET PRILLED CAUSTIC, WAS BEING WASHED TO PELS SUMP BREAKTHROUGH OF A PLUG AT 1 HE BOTTOM DISCHARGE RELEASED A SURGE OF CAUSTIC WATER THAT OVERFLOUED CONTAINMENT. PROC. FOR WASHING OUT A PLUGGED BIN TO BE REVIEWED WITH PACKERS. (HP) EVALUATE DETECTION DEVICES TO ALRH WHEN WET MAIL ENTERS BUCKET ELEVATOR. OAT TO DEFINE CHANGES TO PREVENT WET MAIL ENTERING. 02/11/89 CHLORINE G 5.8 Lbs. CA/ LIQUIFACT ION A LINE ON EXPANSION BOTTLE AT TANK 20 DEVELOPED A LEAK IN THE THREADED CONNECTION. CONNECTIONS ARE BEING CHANGED TO ALL WELDED CONNECTIONS EXCEPT FOR CONNECTION TO A BLOCK VLVE. THIS IS BEING DONE THRU ATIRITION(EC). 28 OF 60 SETS OF BOTTLES/ PIPING HAVE BEEN UPGRADED(AS OF 1/3/90) 02/26/89 HCl G 75 lbs. B/ UTU SPLIT FLANGE HOLDING A BLIND FLANGE ON THE OLD OHC VENT HEADER WAS SEVERELY CORRODED AND STARTED LEAKING. VENT HEADER HAS BEEN INSPECTED AND PARTS REPLACED U/ DEREKANE AND/OR FURAN.(DONE) EVALUATION AS TO POTENTIAL TROUBLE AREAS WILL BE DONE. (EC)(REPLACING OLD HEADER PIPING-SHOULD BE COMPLETE 7/15). 03/14/89 PERCHLOR L T^C B/ PER/TRl 8632 lbs. AS A RESULT OF POOR COMMUNICATIONS, THE PER STABILIZER POT OVERFILLED ALLOWING PERCHLOR TO SPILL TO THE GROUND. INVEST. INSTALLING SPRING-LOADED VALVES. REROUTE STABILIZER SUMP OVERFLOW DRAIN. COUNSEL OPERATOR.(DONE) WRITE SOP TO STATE AH AUX. OPR MUST STAY IN BLDNG WHILE STABILIZ1NG.(PE) (DONE) DATE MATER IAL/AMOUNT 03/14/89 VOCH G 2034 lbs. PLANT / AREA SH/ SHIPPING B 03/17/89 CHLORINE G 6 lbs. CA/ Hg CELL 04/04/89 CIHC/Uater G 41.7 lbs/3700 lbs B/WTU 04/28/89 VC G 47.5 lbs B/VCM 11 05/08/89 HCl L 171 tbs. B/UTU 05/12/89 CL2 G 86 tbs. A/Hg Cell QUARTERLY UPDATE SPILLS/RELEASES CORRECTIVE ACTION H DESCRIPTION OF RELEASE A T/C UAS CONNECTED FOR LOADING BY CONNECTING LIQUID LINE TO VENT VALVE OF CAR AND INCIN. VENT HOSE TO LIQUID VALVE OF CAR. VENT SYSTEM RUPTURE DISC BLEU WHEN LOADING BEGAN. CORRECTIVE MEASURES IN PROGRESS INST LIQ SENSOR AND CONTROL VLV IN VDCM INCIN. VENT LINE AT T/C LOADNG STATIONS TIE TOGETHER SENSORS, CONTROL VLVS, AND PUMP SUITCHES TO STOP FLOU IF LIQUID IS SENSED. (PEHIN ENGR).-1NST END OF 8/89. NEU LEAD OPERATOR CONFUSED SEQUENCE OF STARTUP ACTIONS. LOAD UAS RAISED BEFORE PRODUCTION UAS IN L1QU1 FACTION SYSTEM. RESULTING SYSTEM BACKPRESSURE CAUSED A RELEASE FROM THE CELL ROOM. INCIDENT UAS REVIEWED WITH OPERATOR. HE IS TO WRITE A PROCEDURE FOR SOP. SOP TO BE FINALIZED BY 4-14-89. (PE) Rupture disc bleu on CSS Feed Tanks due TO RISING TEMPERATURE AND LEVEL DURING a rate change on the VDCM Reactor. 1. INSTALL A COOLER ON VDCM RX BTMS BY 4/30/89. (DONE) 2. Divert VDCM Rx btms stream out of CSS SYSIEMCENGR. UOU>. *1 SRV ON VC PRODUCT STILL REFLUX DRUM LIFTED DURING START-UP. 1. MOO S/UP SOP(COMPLETE BY 6/15XOONE) 2. For* QAT to finalite Start-up SOP for GOING ON RECYCLE(COMPLETE BY OCT.) 3. CALL AH ORC MEETING TO DISCUSS A FLANGE LEAK DEVELOPED ON THE STRONG ACID HEADER AT THE NU CORNER OF THE BTMS PLANT. 1. IMPLEMENT CLOSER INSPECTION OF PIPELINES. 2. CHANGE FREQUENCY OF INSPECTIONS IF REQUIRED. AN UPSET OCCURRED IN CELL FD PH WHEN AN ACID BYPASS VLV UAS LEFT OPEN. HIGH TEMP RESULTED CAUSING THE CL2 COMPRESSOR AT L1QUEF. TO BE TRIPPED. THIS CAUSED THE NEUTRALIZER TO BE OVERLOADED. 1. AN ORC HTG. UAS HELD TO DISCUSS PROPOSED CHANGES. (DONE) 2. RPL. ACID BYPASS VLV U/ SMALLR (DONE) 3. INST ADD I TONAL INSTRUMENTATION. 4. COMPLETE STUDY ON CAPACITY OF NEUTR. DATE MATERIAL/AMOUNT 05/17/09 NaOCt L 394 Lbs. 05/21/69 F024 L 171 Lbs. 06/06/89 NaOH L 125 LBS. QUARTERLY UPDATE SPILLS/RELEASES CORRECTIVE ACTION I PLANT / AREA B/UTU DESCRIPTION OF RELEASE A GASKET BLEU OUT ON THE TRANSFER LINE FROM HG CELL UNIT TO SODIUM FORMATE. CORRECTIVE MEASURES IN PROGRESS 1. REVIEU PIPELINE 1NSP PROGRAM.(THIS LINE UAS MISSED ON EARLIER INSPECTN) 2. CHECK THAT GASKET TYPE IS PROPER FOR B/UTU INCINERATOR FEED LINE DEVELOPED A HOLE CAUSING A SPILL TO THE GROUND. 1. INSTALL INCINERATOR FEED LINES IN TRENCHES IN 1990. 2. INSTALLED REINFORCEMENT PADS TO CA/PELS SHIPPING WASH RAN DRAIN DEVELOPED A PLUG IN LINE CAUSING MATERIAL TO BACK UP AND ESCAPE THE WASH PAN, CAUSING A VIOLATION. 1. HYDROBLASTED SEUER LINE CLEAR. 2. COMMUNICATION MTG. TO BE HELD U1IH PELS PACKERS TO RE-EMPHASIZE IMPOR TANCE OF PROMPT REPORTING OF SPILLS. 06/16/89 NaOH L 820 LBS. CA/ pH CONTROL CELL LIQUOR UAS SPILLED TO THE GROUND WHEN THE CELL LIQUOR LINE FROM TANK #6 UAS BEING CLEARED FOR MAINTENANCE. THE LINE UAS IMPROPERLY ISOLATED AND TAGGED. 1. UPDATE AND DISTRIBUTE A FLOW DIAGRAM OF THE CELL LIQUOR COLLECTION AND DISTRIBUTION SYSTEM. 06/24/89 HCL L 62 LBS B/UTU A HOLE DEVELOPED IN THE UEAK ACID TANK ALLOWING ACID TO LEAK ONTO THE GROUND AND INTO THE SEUER (INTERNAL CORROSION). 1. INSPECTION DEPT. WILL INSPECT TANK ON 6/27. PENDING RESULTS OF THIS INSPECTION, ROUTINE INTERNAL INSPEC TION OF THIS TANK UILL CONTINUE. 06/27/89 CL2 G 1.5 LBS. 06/29/89 CL2 G 9 LBS. CA/ HG CELL CA/'C' CL2 THE DEPLETED BRINE TANKS OVERFLOWED CHLORINATED BRINE AS A RESULT OF A PUMP BEING SHUT DOWN FOR A GROUND SEARCH AND NOT RESTARTING. 1. UOW TO INST LOWER HIGH LEVEL ALARM ON DEPLETED BRINE TANKS. 2. DEVELOP SOP FOR DETECTING ELECTRICAL GROUNDS. SOP UILL HIGHLIGHT EQUIPMENT TO HAVE SPARE RUNNING PRIOR TO S/D. DURING STARTUP OF A CIRCUIT, CL2 UAS DIVERTED TO THE NEUTRALIZER PER SOP. AT THAT TIME A SHALL AMOUNT OF CL2 BROKE THROUGH DUE TO A CAUSTIC NOZZLE FALLING OFF THE FEED DISTRIBUTION HEADER. 1. INVESTIGATE METHOO TO PREVENT THE CAUS1C NOZZLES FROM FALLING OFF AND INSTALL DURING NEXT INTERNAL INSPEC TION SCHEDULED FOR 10/89. DATE HATERIAL/AHOUN7 07/03/89 HCL G 17 LBS. PLANT / AREA B/ WTU 07/29/89 PER L >0.5 LBS. B/ PER-TRI 08/20/89 HG L 2 LBS. CA / HG CELL 08/31/89 EDC L 105 LBS. B / EDC 10/02/89 N2/VC G 0.95LBS/0.02LBS. B/ EDC- EC/HCL 10/03/89 HCL G <100 LBS. CO (r< o 00 00 Oin', Ui 8/ PER/TRI QUARTERLY UPDATE SPILLS/RELEASES CORRECTIVE ACTION 1 DESCRIPTION OF RELEASE THE RUPTURE DISC ON #3 WASTE STORAGE TANK BLEU PREKATURELY(<5 LBS.). CORRECTIVE MEASURES IN PROGRESS 1. CONT. EMPHASIS U/ MAI NT. ON PROPER INSTALLATION OF GRAPHITE DISCS(SPIER) 2. RPL SOLENOID ON VENT VALVE(OONE) 3. CHECK ALL PI'S ON UST FOR PROPER OPR. A. INST DRAINS ON R/D STACKS(DONE) PERCHLOR SPILLED TO THE PAD WHEN THE RECYCLE HEADER ON THE PER/TRI STILL LINE BEGAN LEAKING DOE TO CORROSION. 1. LINE UAS CLAMPED TO STOP LEAK. THIS LINE HAD ALREADY BEEN IDENTIFIED FOR REPLACEMENT(DONE). 2. PER/TRI ENV. OAT TO DEVELOP AN ACTION PLAN. CELL *3 DEVELOPED A FLANGE LEAK ON HG INLET LINE. DESPITE HAVING A FLANGE GUARD, HG UAS BLOWN OUT PAST CONCRETE PAD BARRIER AND ONTO THE SHELLED AREA SOUTH OF THE CELL BUILDING. 1. A NEW TYPE OF FLANGE GUARD HAS BEEN INSTALLED. 2. EXTENSION OF CURBED CONTAINMENT IS ONE PHASE OF IMPROVEMENTS TO CELL RH AND RCRA SI IE.(COMPLETE BY 6/90). STARTED THE REFLX PUMP TO #1 STRIPPER, MATERIAL WENT FORUARD TO THE STRIPPER K ALSO FLOWED BACKWARD THRU A CHECK VALVE OUT A PARTIALLY OPEN BLD VLV AT *4 REC PHP. HATL SPRAYED FROM *1 PLT TO GROUND. 1. RPL BAD CHECK VLV DURING NEXT OUTAGE. (BY 11/30/89) 2. SURVEY BLEED VALVES IN AREA.(10/30) 3. PLUG ALL BLD VLVS NOT OVER CONTAINMNT A. BLD VLVS OVER CONT. UILL POINT DOWN. VENTS TRIPPED OUT OF #1 INC. SAT. 9/30. VENTS WERE ROUTED TO #2 INC. VCI VENT HEADER ISOLATION VALVE UAS NOT OPENED. SHIPPING CLEARED HOSES INTO THE VENT HDR AFTER THIS TINE. R/D FOUND LEAKING 10/2. 1. INST LOU PRESSURE ALRM FOR HDR. 2. CHECK PRESSURE RECORDER. 3. PROOFTEST HIGH PRESSURE TRIPS. A. COUNSEL L.O. AND INC. OPERATORS. THE EXPANSION JOINT ON #4 RX PULLED OUT OF STEEL FLANGE WHILE MAINTENANCE UAS ATTEMPTING TO REPAIR A MINOR LEAK. 1. THIS EXP. JOINT WILL BE EXAMINED ON EACH RX TO VERIFY THAT EACH HAS STAY BOLTS OR IS RPL WITH ONE THAT DOES. 2. REVIEW WITH MAI NT PERSONNEL 3. RPR THE HCL FLOU CONTROL VALVE. DATE MATER1AL/AHOUNT 1G/03/B9 CLHC G 180 LBS. 10/04/89 PER L 2.3 LBS. 10/04/89 PER L 40 TONS 10/12/89 HCL G 44 LBS. PLANT / AREA B/ WTU B/ PER/TRI SHIPPING/ DOCKS B/ T II QUARTERLY UPDATE SPILLS/RELEASES CORRECTIVE ACTION ITEMS DESCRIPTION OF RELEASE THE LEVEL INDICATOR FLOAT CHAMBER FLOAT FAILED CAUSING THE LCV TO NOT SEE A LVL IN THE DH STILL. THE STILL WAS OVERFED, RESULTING IN A RELEASE THROUGH THE RUPTURE DISC. CORRECTIVE MEASURES IN PROGRESS 1. RPL AND MORE THOROUGHLY CHECK ALARM SYSTEM LIGHTING. 2. RPR LEVEL FLOAT AND FLOAT CHAMBER 3. INV. USING DP SYSTEM AS A REDUNDANT LEVEL ALARM-HAY TIE IN TO SDS. SMALL PINHOLE LEAK DEVELOPED ON THE BOTTOM SIGHTGLASS NOZZLE ON THE CLEAN UP STILL REFLUX DRUM. PERCHLOR SPRAYED ONTO THE CONTAINMENT PAD. 1. VESSEL WAS CLEARED FOR ENTRY/]NSPTN, 2. RPL LEAKING NOZZLE AND MAKE ANY OTHER REPAIRS AS RECOMMENDED BY LOSS PREV. 3. TAKE THICKNESS READINGS ON NOZZLE IN EFFORT TO DETERMINE CAUSE OF FAILURE. CSCC BARGE 202 WAS LOADED WITH PERCHLOR. LEAD LOADER FOUND A LEAK FROM A CARGO TANK INTO DRY COMPARTMENT OF BARGE. 1. BARGE WAS SENT TO SHIPYARD FOR INSPECTION. THE IR1-ETHANE FURNACE DEVELOPED A TUBE LEAK ALLOWING EDC TO ESCAPE INSIDE THE FURNACE. ONLY HCL ESCAPED TO THE ATMOSPHERE. 1. TUBES ARE TO BE REPLACED IN DECEMBER '69. THE FABRICATION IS NOW IN PROGRESS. 10/19/89 EDC L 14 LBS. B/ TE 11 BLOCK VALVE ON #4 OHC REACTOR PRIMARY VENT MLS BYPASS DEVELOPED A LEAK AT THE STEM. 1. THE VALVE WILL BE REPLACED WITH A NON-D1APHRAM TYPE TEFLON LINED VALE DURING THE NEXT OHC II REACTOR OVERHAUL. 10/28/89 CLHC L 78 LBS. * 8/ WTU WHILE TRANSFERRING MATERIAL FROM A VACUUM TRUCK INTO THE TOP OF A RENTAL FRACK TANK LOCATED ON N. CLASSIFIER PAD, THE HOSE BEING USED BLEU OUT OF THE TANK SPRAYING MATERIAL ONTO THE GROUND. 1. INSPECT RENTAL TANKS TO ENSURE AN UNLQADMG FITTING IS IN PLACE BEFORE USE 2. REVIEW INCIDENT W/ SERVICE PERSONNEL ANO AT NEXT ENV. DAT MEETING. 3. SLDGE MGHT TO INCL EUM. OF TEMP. TKS CO f1 o 00 CO in or DATE HATER!AL/AHOUNT 10/31/89 CLHC/HCL L 4 LBS. PLANT / AREA B VCM 11 11/02/89 CLHC/HCL 6 'Jf B/ PER/TR) 4.42 LBS 11/10/89 PER L 709 LBS. B/ PER/TR1 11/10/89 PER, TRI G 410 LBS. B/ PER/TRI 11/14/89 CL2 G 45 LBS C/A / HG CELL 11/15/89 PER, TRI L 13 LBS CO f' O CO 0O Ur CTi UT B/ PER/TRI QUARTERLY UPDATE SPILLS/RELEASES CORRECTIVE ACTION 11 DESCRIPTION OF RELEASE A WELD UPSTREAM OF THROTTLING VLV ON #2 VC DOPP KETTLE FEED LINE DEVELOPED A PIN HOLE LEAK SPRAYING APPROX. 2.5 GALLONS OF DOPP KETTLE FEED ONTO THE PAD AND GROUND. CORRECTIVE MEASURES IN PROGRESS 1. RPL SECTION OF FEED LINE TO #2 VC DOPP KETTLE UITH SCHEDULE 80 PIPE RATHER THAN SCHEDULE 40 AS UAS THE ORIGINAL PIPE. A LEAK DEVELOPED ON A PER/TR1 REACTOR CATALYST CATCH POT RUPTURE DISC NOZZLE. OPERATORS BEGAN S/D OF RX BUT COULD NOT EST. FLUSH UATER FLOW TO CONO. LK WAS CLAMPED UNTIL LINE COULD BE ISOLATED(EC) 1. REVISED PIP1NG-REVIEU OTHERS AS UELL. 2. RETURN STM TRACING TO SERVICE. 3. EST M2 PURGES ON #4 RX CATCH POT, AS OTHERS. 4. VISUAL I MSP OF ALL POTS. 5.JNCL CATCH POTS ON VIDS PROGRAM 6. REWORK FLUSH CV. A LEAK DEVELOPED ON THE DISCHARGE OF THE P/T HUS STILL REFLUX PUHP AT PER STILL FEED NOZZLE WELD. THE LEAK UAS CLAMPED ALL PERCHLOR UAS CONTAINED ON THE CONCRETE PAD. (1C) 1. LOSS PREVENTION TO TAKE UV READINGS OF PIPING SURROUNDING UELD -DONE- 2. UOU TO RPL PER FEED NOZZLE ON THIS LN 3. P/T ENV. QAT ADDRESSING THIS LOCATION AS A POTENTIAL PROBLEM AREA. THE PER/TRI STILL FEED LINE DEVELOPED A LEAK. DUE TO THE TEMPERATURE OF THE HATERIAL<210 F), VAPORIZATION TO THE AIR OCCURRED. (IC) 1. TEMPORARY CLAMP INSTALLED -DONE2. UOU TO REPLACE THIS SECTION OF PIPE. 3. MOISTURE RIG UAS CHECKED TO VERIFY THE MATERIAL UAS DRY -DONE4. P/T ENV QAT STUDYING 1NT CORR PROBLEH AS THE HG CELL UNIT UAS SHUT DOWN, THE LIQUOR IN THE NEUTR. HYPO TANK BECAME SATURATED U/ CL2 AND DID NOT HANDLE THE ENTIRE CL2 STREAM BEING SENT TO IT. PPG UAS NOTIFIED OF PROBLEH BY TEIRA. (OP) 1. AN SOP UELL BE URITTEN OUTLINING PROPER CAUSTIC ENRICHMENT OF THE HYPO RECIRCULATING SYSTEM PRIOR TO HIGH CL2 FLOWS TO THE NEUTRALIZER. A LEAK DEVELOPED IN THE SIDE OF A BALL VALVE DOUHSTREAH OF THE #2 DH STILL LCV ON A DEAD-ENDED SECTION OF PIPING. ALL MATERIAL RELEASED UAS CONTAINED ON THE PAD. <1C> 1. THE BLOCK VALVE UAS REPLACED. 2. THIS AREA HAS BEEN IDENTIFIED BY THE P/T ENV QAT AS AN AREA OF POTENTIAL INTERNAL CORROSION PROBLEMS. THE QAT WILL MAKE RECOMMENDATIONS. DATE MATERIAL/AMOUNT 11/15/89 HCL G 35 LBS PLANT / AREA 6/ EDC - EC/HCL QUARTERLY UPDATE SPILLS/RELEASES CORRECTIVE ACTION DESCRIPTION OF RELEASE A LEAK DEVELOPED OH THE OLD HCL HEADER DOE TO EXTERNAL CORROSION. (EC) CORRECTIVE MEASURES IN PROGRESS 1. WOW TO REPLACE THIS SECTION OF PIPING 2. CONTINUE TO HAKE QUARTERLY PIPELINE INSPECTIONS. 11/16/89 PER L 26 LBS 11/21/89 CLHC G 1.4 LBS 11/22/89 EC G 58 LBS 11/29/89 OIL L 12/06/89 CLHC G > LBS. GQ It1 o CO 00 Ul a\ CTl B/ PER/TRI B/ WTU 'A' B/ EDC - EC/HCL B/ `B* GEHERAL B/ WTU A LEAK DEVELOPED IN WELD OF PER STILL FEED NOZZLE ON THE DISCHARGE OF THE HVS STILL REFLUX PUMPtSEE 11/10 SPILL). ALL MATERIAL WAS CONTAINED ON THE PAD. (IC) 1. P/T ENV QAT CURRENTLY ADDRESSING THIS LOCATION AS A POTENTIAL FOR INT CORR. 2. NOZZLE WAS REPLACED -REFLUX HEADER HETAL LOOKED GOOO. OPERATOR DISCOVERED A BLOWN RUPTURE DISC ON #1 WTU PHASE SEPARATOR. INVESTIGATION REVEALED A HIGH ORGANIC LEVEL IN THE PHASE SEPARATOR. (OP) 1. START SLUDGE KETTLE SYSTEM TO REDUCE VOLUME OF SLUDGE AND CL2 CONCENTRA TION BEING SENT TO WASTE TECH. 2. SLUDGE MGMT MUST INCLUDE A MEANS OF SLUDGE REMOVAL FROM CRITICAL SYSTEMS. A GASKET FAILED IN THE 2 IHCH VENT CONDENSATE LIME. THIS FAILURE WAS BETWEEN THE PUMP DISCHARGE AHD THE PRIMARY STRIPPER FEED TAHK. (HP) 1. THE GASKET WILL BE REPLACED IMMEDIATELY. 2. A TEST SECTION OF PIPE IS TO BE PUT INTO SERVICE AND INSPECTED AFTER 30-45 DAYS OF EXPOSURE. AN OIL SHEEN WAS SPOTTED PAST PPG BOOM IN THE CANAL. AN OJL LAYER WAS DISCOVERED ON THE WUT FEED TANK INVESTIGATION COULD NOT PINPOINT A SINGLE SOURCE NOR IDENTIFY THE OIL.(OP) 1. SCC TO ADDRESS AND DEVEOP ACTION PLAN EMERGERNCY SPILL RESPONSE TASK FORCE 2. MEMO TO BE ISSUED TO DERIVATIVES OPN PERSONNEL ON IMPACT OF OIL IN SEWERS. HO. 1 CENTRAL STEAM STRIPPER FEED TANK WAS OVERFILLED CAUSING THE RUPTURE DISC TO BLOW. ({OP) 1. OPERATOR INVOLVED WILL BE COUNSELEDPOSSIBLE DISCIPLINARY ACTION 2. SOP TO BE WRITTEN TO ADDRESS HIGH ORGANICS IN SF FEED BY 12/31/09. 3. REVIEW INCIDENT WITH L.O.S BY 12/31. DATE HATER IAL/AMOUNT 12/12/89 CLHC/UASTEUATER^t 9096 LBS. PLANT / AREA B/ IE II 12/17/89 CL2 G <5 LBS. C/A / 'A' CL2 12/20/89 CL2 G 4 LBS. SH/ A SHIPPING 12/22/89 HCL L 52 LBS. B/ VCM II 12/23/89 VC G 15 LBS. "jAT SHIPPING/ DOCKS 12/23/89 NAOH L 14917 LBS CO t-< O 03 OO in <T\ <1 C/A /'A'CAUSTIC QUARTERLY UPDATE SPILLS/RELEASES CORRECTIVE ACTION I DESCRIPTION Of RELEASE THE PROCESS SUHP OVERFLOWED TO THE STORH SEUER AND THE STORH SEUER BACKED OUT OF THE CATCH BASINS AND ONTO THE SHELL AT 11 LOCATIONS IN TE [1. (OP) CORRECTIVE MEASURES IN PROGRESS 1. CLEAN UP CONTAMINATED SHELL. 2. DEVELOP A BLOCK/LOGIC DIAGRAM AND SOP TO PREVENT O/FLOW OF BAT AND PROCESS SUMPS INTO THE STORH WATER SYSTEM. 3. REVIEW ABOVE PROCEDURE(#2) WITH OP. A FROZEN IMPULSE LINE TO CKT. 15 CL2 HEADER PRESSURE CONTROLLER FORCED CL2 INTO THE NEUTRALIZER. A VAPOR CLOUD UAS SEEN LEAVING THE NEUTRALIZER. CL2 UAS DETECTED AT HG CELL CONTROL ROOM (IP) 1. UOU-REPL EX]SING IMPULSE LINES U/ FRP MAN I FOLD SYSTEM OF LARGER DIAMETER TO MIN. POTENTIAL OF ICE PLUGGING LINES. 2. TEMP HEAT LAMPS TO BE PROVIDED AT CRITICAL POINTS AND XTRA INSLN ADDED. WHILE PRESSURE TESTING A NEW CL2 LOADING LINE PRIOR TO RETURNING IT TO SERVICE, A DEFECTIVE ANGLE VALVE UAS FOUND NOT FULLY CLOSED. CL2 FROM EQUALIZER SYSTEM USED TO TEST THHE LINE ESCAPED THRU VLVE 1. SOP TO BE CHANGED TO DOUBLE CHECK ALL VALVES PRIOR TO TESTING. TUBULAR GLASS S/G ON ATM. SCRUBBER FROZE AM) BROKE, SPILLING HCL TO GROUND. SPILL DRAINED TO DITCH FLOWING TO OUTFALL 401. DUE TO FLOW OF FREEZE PREC. WATER, SPILL REACHED 401 BEFORE IT COULD BE DAMMED. 1. IMMEDIATELY INITIATE A POLICY TO KEEP SIGHT GLASS ISOLATED EXCEPT WHEN CONFIRMING A LEVEL. 2. INSTALL CONTAINMENT PAD AROUND BASE OF SCRUBBER (BY 4/69) WHILE LOADING VINYL ONTO A BARGE, THE BLEED ON THE LOADING LINE CRACKED RELEASING VINYL. FREEZING WEATHER IS SUSPECTED TO HAVE CONTRIBUTED TO THIS FAILURE. 1. PERFORM MORE THOROUGH VISUAL INSPECTION OF ALL VALVES AND CONNECTIONS PRIOR TO LOADING. CLEAR LINE FROZE DUE TO COLD WEATHER. REC1RC. PUMP TRIPPED CAUSING TK TO 0/F. NAOH THRATOR FROZE. NO ALARM UAS RECEIVED IN CONTROL ROOM. PH VIOLATION OCCURRED. ( MP ) 1. CLEAR AND CLOUDY TANKS 0/F LINES TO BE LINE MOLED. 2. INSTALL HIGH LEVEL ALARMS ON #7 CLEAR AND CLOUDY TANKS. DATE MATERIAL/AMOUNT 12/27/89 NAOH L 577 LBS. 12/29/89 CL2 G 3 L8S. PLANT / AREA C/A/ 'A' CAUSTIC C/A / HG CELL QUARTERLY UPDATE SPILLS/RELEASES CORRECTIVE ACTION 1 TENS DESCRIPTION Of RELEASE THE UNDERGROUND CELL LIQUOR TRANSFER HDR FROM 'A' CAUSTIC TO PLANT B FAILED.SPILL CAME TO SURFACE AND INTO STORMWATER RUN OFF SEWER EXITING AT 004 OUTFALL. FREEZE DAMAGE DID HOI ALLOW PH NEUTR. TO WORK. CORRECTIVE MEASURES IN PROGRESS 1. DET FAILURE MECHANISM OF CELL LIQUOR TRANSFER HEADER. DEVELOP ACTION PLAN TO PREVENT FUTURE SPILLS FROM LINE. 2. INST MANUAL ACID BYPASS VALVE AT 004 3. CHECK OPERATION OF AUTO VLVS VSH1FT THE HG CELL CIRCUIT WAS ENERGIZED TO WARM UP PRIOR TO STARTUP. NEUTRALIZER IMS HANDLING CL2 BEING SENT TO IT, UNTIL A SWING IN THE CONTROLLER OCCURRED. A SHALL CLOUD WAS EMITTED FROM THE STACK. 1. AN SOP WILL BE IMPLEMENTED TO PRESTRENGTHEN THE CAUSTIC CONTENT OF THE RECIRCULATED HYPO IN THE NEUTRALIZER.