Document 93o59wQ0ooDGYx3wbE7daXen3

\^ Interoffice Communication To : Vinyl Shift Supervisors From Dote : J. E. Barton : April 10, 1979 Subject : EPA COMPLIANCE (REVISED) (conoco) The following items need to be done to assure EPA compliance reguarding VCM emissions. 1. The date must be stamped on the Honeywell recorder charts each morning at 7:00 a.m. When the Honeywell charts are replaced the number of the Honeywell unit is to be written on the bottom of the chart. All used charts are to be turned into me. 2. All recovered VCM receivers are not to be filled above 80%. 3. The high pressure alarms on the blowdown tank in each unit will be reset to 40 psig. 4. The Emergency Kill Procedure has been revised as follows: Emergency Shutdown The following parameters are to be the maximum limits on a runaway reaction. The reaction should be killed with AMS if either one of the parameters is exceeded. Resin Maximum Temperature Maximum Pressure 5385, 5425, 5465 142F 145 PSIG 5305 162F 175 PSIG A runaway reaction immediately after charge and heat-up indicates that the reactor condenser may be plugged, and that the reaction must be killed. If AMS will not kill the reaction, use the nitric oxide (N,0.) short stop system. CAUTION: N.O. is a highly poisonous orange-colored gas. A Scott Air Pack or a "Rocket Fuel" cannistcr mask must be worn while killing a reactor with the N.O. short stop system. The runaway reaction must be killed immediately if either one of the pressure or temperature limits listed above are exceeded. If the reaction is allowed to exceed these limits, it may not be controllable and result in a relief valve or rupture disc discharge to the atmosphere. DTH 000058558 EPA Compliance (Revised) April 10, 1979 Page 2 5. The emergency nitric oxide kill system for all the reactors has been pressure checked to assure integrity of the systems. These systems will be pressure checked each six months with nitrogen. 6. After every coarse batch produced the reactor condenser will be inspected to determine if it is plugged. If the condenser is found to be plugged, it will be cleaned prior to charging the next batch. If the condenser is not plugged, charge the next batch back with 1/2 gallon less catalyst. If this batch runs normal return to the original catalyst loading. 7. Copies of the procedures for the Old Unit, New Unit, and Dryers will be placed on the table between the Lead Operators' desks in the control room. There will also be copies in the Shift Supervisor's office and Operations Supervisor's office for your reference. Please conduct a formal review with your people on the seven items above and the attached Work Practice Controls for the OSHA VCM Standard. Write the review meeting up on the safety meeting form and return it to me. I would like to have all the meetings completed by 4/25/79. J. E. Barton cjt Attachment c: CLM, ELK, RAF, Shift Supervisors (5) DTH 000058559 WORK I'I'Xlllii YON HUM S OSIIA YUM SLANIURl' 1 ! I . Rf.ACTOR ARHA.S The purpose of the vinyl reactors is to convert \ i in l chloride monomer into polyvinyl chloride resin (i'Vh). Severnl of 1 he opernfor functions in the I a rye reucior area can result in YUM exposure. I lie following relates to those work practices which are affected hy potential YcM emissions. A. Opening Manhcad on 1 nipty Reactor 1. (.heck the external pressure gauge to imure that the reactor is not under pressim-. 2. Put on the continuous flow fresh air breathing mask. a. Unlatch the manhcad roll bar. 1. Radio panel operator to open evacuation ict to the reactor. This wi I I move air inward and disperse Yt'.ll vapors. a. Open manhcad completely, o. Inspect reactor. NO If.: The manhcad is not opened alter every reaction but only periodically t.o check the internal condition. B. Manual Reactor f.ntry 1. Open manhcad vising the procedure described in A, 2. hollow equipment entry procedure as described in Attachment ''A" of Safely and Health Manual. 3. (Hose the top manhcad. 1 . Hydrostatically test reactor for leakage. d. Reactor Recovery Unroacted YUM is removed from t he polymer i .'at ion reactor slurrv hy the recovery system. the recovery system consists of vacuum pumps, compressors and condensers which remove t lie YCI from the reactor, compress, and condense it. so that it can he recycled to the process. Operating personnel DTH 000058560 riavkir v; - coni iMil.u C. Reactor Recovery - Cunt i nurd arc revpiired in flic recovery area durinp sy-M cm start up and lot' periodic checks durinp the recovers. The recover}' area is monitored for \ t "I levels from the Con trol Room, The operator is alerted l'\' radio before entcrinp the area if the \ t. M level is above l.t) ppm. I). Rene tor iRnn]' i up bumpinp of the reactor slurry occurs at the end of the Vf.M stripping operation. 1 lie operator observin'; the dump dot's not need to wear a CITV1 'mder normal condition. This area is monitored from t lit' control roo;i and the operator is notified if the \C't level is above l.t) ppm. Abnormal conditions reipiiritp.; a i'll.VI are; 1. I'lopped reactor dump valve or I ino. 2. bumpinp a coarse batch. A. Clcaninp dump Sweco. 1. Inoperative Sweco exhauster. f. I liter Cleanin';, Removal and Rej'laeemeut I he foil ox in;; information applies to the; Recovered VY.M filters I rcsh VCM 1: i 11 e rs Seal Water filters (.Compressors I These fi Iters come in contact with Vt 11 and therefore are potential exposure sources. The filter pack is steam purped and recovered to the process. The recovery system pulls a vacuum on the filter pack prior to openinp. I he operator tlu'ii puts on a id 1AM, impervious ploves and an impervi mis suit. ) . t'.onden se r , Subcoo 1 e r , fine and Vessel Ma i n 1 enauee lhe f o 1 1 os. i up precautions are repuir'-d in provent Vf.M exposure while performiny, maintenance on lines, vessels, subeooler and condensers. DTH 000058561 ui.A'ii'm -\ki.\s l;. hoiHlenso r , Subcooler, Line ;iiiJ Vessel Mu i ii I enu ih ' e - beu t i nii'. vl 1. The cqui pmcnt must be bliiulcil ,it .ill inlets aiu1 out lets. 2. '1 lie unit is to bo i" 111sh' 11 or e\ iciiileil uni i 1 I ree oh \(! I a s detccLcu by the 1 INI I OVA insl ru'iienl . (I. The rtMclor operatin''. ;ire;t mikI lank t`. i rui are eu ut i 111IOIis | V nenitni'eh for hii;h VbM cone en 1 r.i t i nn s I > > the lie nevuell unit located in the reactor control room. DTH 000058562