Document B5Nb317NkyxqgJr667YwKVBqk

Information For Meeting With ICI Page 2 Item 1 2 3 4 5 6 7 Type 8-hr TWA operator position 8-hr TWA assigned maintenance 15-minute avg. specific tasks 8-hr TWA perimeter (fence line) 8-hr TWA perimeter (outside reg. area) 8-hr TWA distribution opr. 8-hr TWA Bldg. 133 lab analysts Frequency Weekly Weekly Weekly Monthly Monthly Quarterly Quarterly Number 20 5 9 6 12 3 1 The 8-hour TWA results on personnel are communicated in writing to the individual within ten days of the test. 1.3 Specific Points 1-3.1 Area monitoring - The VFA sample points are located at spots in the regulated area where personnel are likely to be working. They are positioned at approximately head-high levels. The monitor scans the area every 40 minutes - 2 minute per point. The microcomputer can average the data in a number of ways including a simulation of 8-hr TWA's. A listing of the type of data the computer print-out will show is attached (Attachment B) with a copy of the "Data Presentation" (Attachment C). The VFA can be set to alarm at any fraction of full scale. It is currently set at 90% of 25 ppm = 22.5 ppm. The alarm is a buzzer-type and must be manually switched off in the control room. 1-3.2 Personal monitoring accuracy The carbon tube method has recently been evaluated and found to be well within the limits required by the permanent standard: UCC 091385 Information For Meeting With ICI Page 3 OSHA Regulation Range (ppm) Accuracy 0.25 to 0.5 + 50% over 0.5 to 1.0 + 30% over 1.0 + 25% UCC Evaluation Level (ppm) Accuracy 0.5 6.7% 1.0 7.1% 5.0 1.5% Precision 9.6% 5.5% 4.6% 1.3.3 Areas Not Scanned by VFA - Discuss II. MONITORING RESULTS 2.1 VFA Area monitoring Attached Table I shows the average number of points per dayexceeding certain levels for the period since the VFA was installed in June 1974 through March 1975. Installation of the computer will allow much more extensive data averages to be obtained. 2.2 Personal Personal monitoring results are shown in attached Table II for the period from January 3 to April 30, 1975 when the major part of the 8-hr TWA data was taken. A calculation of 8-hr TWA exposure from VFA data was made in January for each operating position - Table III attached. The values varied from 2-6 ppm - average of 2.9 for all operators which compares with the 1.89 ppm determined for the operators by carbon tube in February-March period Table II. III. INTERPRETATION OF RESULTS No write-up - Discussion UCC 091386 Information For Meeting With ICI Page 4 IV. WORK PRACTICES TO REDUCE VCM RELEASE TO ATMOSPHERE Changes to equipment Suspension high pressure vent Off-gas high pressure vent Non-solvent high press, vent Decanting 07,08,11 & 12 tanks Decant tanks C-10 & C-ll Boil-off sampling Autoclave resin sampling Suspension surge tanks^dryer exhausts Non-Solvent surge tank and dryer exhausts Sent to No. 1 Powerhouse for incineration. Will be sent to MEK recovery system at future date. Sent to Solvent Vinyls strip ping system Decant to No. 3 stripping tank to eliminate atmospheric losse Suspension feed tank decanted to closed vessel to eliminate atmospheric losses Use lab resin analysis as a guide and eliminated need for operators to boil off VC1 in feed samples Autoclave resin sampler was installed to minimize operator exposure when checking autoc. No. 5 BDT has been revised to batch strip w/steam in jection. Revisions to No. 1 BDT in progress, to be com pleted May 20. Remaining BDT's have been inspected and will be done as time allows. Residual monomer & VCM in dryer and surge tank exhausts have been reduced significant! Continuous stripping of the non-solvent resin has reduced residual monomer, dryer ex hausts and surge tank losses. UCC 091387 Information For Meeting With ICI Page 5 Vinyl chloride filters Priming VC1 pumps Vinyl chloride pumps Nash Compressor Nash Hytor seal water C-autoclave agitator packing failures MttK recovery system Piping installed to vent filters to No.3 stripping tank before opening. Piping installed to allow venting of pumps to No. 3 stripping tank instead of to atmosphere. Double mechanical seals are to be installed on all VC1 pumps. VC1 packing leaks were eliminated by installing double mechanical seal on Nash compressor. Seal water sent to No. 3 stripping tank to recover VC1 and vinyl acetate. Corrected quality control prob lem w/vendor. Also new seal arrangement designed and in stalled for trial run. An MEK scrubber is to be in operation by Dec. 1975 to re cover the high pressure vent streams from the area. Reactor purge, opening, cleaning, ventilation and VCM unloading procedures to be discussed by M . Peterson. UCC 091388 Information For Meeting With ICI Page 6 IV. A TRAINING This item not on agenda but slide-tape presentation being given to personnel as training program relating to OSHA regulation may be of interest at this point since it pertains to personnel protection. V. OPERATOR PROTECTION Respiratory Equipment Three types of equipment are available: 1. MSA full face canister mask - type VCM-SS for use below 25 ppm. 2. MSA full face mask plus regulator for hookup to fresh air supply (bottle) - mask No. 4522, regulator No. BM.19B-42 for use in 0-100 ppm range. 3. Fresh air pack, self contained full face mask with regulator MSA Model 401 - for use in 0-100 ppm range. Equipment to modify (2) and (3) to pressure demand type are on order to upgrade these to the required 3600 ppm or above. Protective Clothing Cotton "coveralls", gloves, and face shield are required for entry into vessels containing residual PVC, Showering, Eating Facilities, etc. There are no requirements for showering although shower facilities are available in the plant for personnel wishing to use them. The eating facilities for the maintenance group has been moved to a location outside the regulated area. Operating personnel are allowed to eat in facilities in the control rooms. These rooms are air conditioned and pressurized to give a positive displacement of air. TJCC 091389 Information For Meeting With ICI Page 7 VI. ENVIRONMENTAL Mr. Eisenhour will discuss. VII. VCM IN FINISHED PRODUCT Removal of VCM has been most effectively accomplished by batch stripping at elevated temperatures under vacuum. This technique was begun in March and only two products have been done to date: Product type QSAP QSAN QSAL QSAH QSQH QSQF VSJE VSKK Continuous 100 100 175 800 1200 1200 165 600 Batch 90C - - - - 120 200 - - All of the above represent levels from the dryer decrease as the products are transferred to storage bins and shipping containers to customers. Recent work has shown appreciable decrease with storage, particularly in paper bags. Copy available. UCC 091390 TABLE I VFA ANALYSIS FOR VC1 AVERAGE/DAY(l) June 22 - July 21 August 19 - September 5 September October November ^ December January February March __________ Exceeding 50 19 11 8 5 Number of Points Exceeding 25 12 18 18 16 12 6(3) Exceeding 10 74 64 (1) Out of 720/day, until Oct. 5 when it changed to 684/day. (2) Changed sensitivity of VFA on Nov. 4 from 100 to 25 ppm, full scale. (3) For the period March 1 - March 23 when the unit was operating. ucc 091391 U C C 091392 TABLE II PERSONAL MONITORING RESULTS (8-HOUR TWA - PPM) Period Jan. 3 to Feb. 19 Operators No. High Low Avg. 11 8.81 0.03 0.92 Maintenance No. High Low Avg, Combined No. High Low Avg. 11 8.81 0.03 0.92 Feb. 24 to Mar. 22 21 10.06 0.06 1.89 17 15.04 0.06 3.65 38 10.06 0.06 2.68 Mar. 23 to April 30* 8 0.34 0.02 0.11 28 5.31 0.01 0.49 36 5.31 0.01 0.41 * Unit was down during this period. Page In fo rm a tio n F o r M eeting W ith IC I oo Information For Meeting With ICI ATTACHMENT B COMPUTER PRINT-OUT Page 9 By Shift (8 hours) 1. Reading of each point (20) every 40 minutes. 2. 8-hour averages of each point. 3. Number of times exceeding 5 ppm (total shift). By Day (24 hours) 1. Average of each point for day. 2. Number of times exce-ding 5 ppm (each point). By Month 1. Average of each point for month. 2. Standard deviation of average. 3. Number of times exceeding 5 ppm (each point). 4. Average number of times/day exceeding 5 ppm (each point). ucc 091393 REACTOR PURGE, OPENING, CLEANING , VENTILATION, AND VCM UNLOADING PROCEDURES Vessels are opened for inspection,-cleaning and maintenance work. Those vessels which have contained VCI or are suspected Lo have contained VC1 require the following procedures: 1) The vessel is water washed to another vessel which will not be entered ( such as washing an autoclve to a blowdown tank ). 2) A vacuum is pulled on the vessel using a Nash Hytor vacuum pump, which discharges to the VCM recovery system. 3) If the vessel to be opened contains resin or chunks of resin, it is steamed for several hours to the atmospL here. > 4) The vessel is' then either completely disconnected or slipblinded and all agitators are locked out. 5) The vessel is then tested with our Vapor Fraction Analyzer (VFA) for the presence of VCM. If the test indicates that the level is below the TLV, further steaming and evacuation is not required. During autoclave manual cleaning, the VFA continues to monitor the vessel atmosphere. rfC i5> Cvv/ed 4 Currently, VCM unloading is performed in the following manner: 1) The tank car hose and piping are stripped down to a pressure of 5 psig using the unloading compressor. 2) The hoses are then vented to the atmosphere and purged with nitrogen. Hose Connecting: 1) ALL hoses and piping are purged with nitrogen to eliminate oxygen. In both the connecting and disconnecting procedures, the operator is required to wear fresh air equipment. Proposed unloading facilities will have a purge system will will vent to the production monomer recovery system. Hopefully, this will eliminate the use of fresh air equipment. Currently, UCC uses a solvent washing system for the autoclaves and manual cleaning of the autoclaves in not required unless an agglomerated batch or severe plugging of the autoclave dump valve occurs. Our current rate of manual cleaning is now about once every other month or six autoclves per year. Most problems occur during the reaction of VAC copolymer resins. UCC 091394 TA-SleT \ TEXAS CITY SUSPENSION/NON -SOLVENT UNIT CALCULATION OF 8-HR TWA VINYL CHLORIDE EXPOSURE FROM VFA DATA Operating Position 1. Non-Solvent autoclaves Bldg. 174 control room (6 hrs. ) Outside (2 hrs. ) 2. Off-Gas Recovery- Bldg. 174 Control Room (6 hrs.) Outside (2 hrs. ) 3. Suspension Utility- Bldg. 174 Control Room (2 hrs. ) Outside (6 hrs. ) 4. Suspension, North line autoclaves Bldg. 174 Control Room (6 hrs. ) Outside (2 hrs. ) 5. Suspension, South line Autoclaves Bldg. 174 Control Room (6 hrs. ) Outside (2 hrs.) 6. Suspension, East line Autoclaves Bldg. 174, Control Room (5. 6 hrs.) Outside (2.4 hrs.) 7. Dryer, Inside Bldg. 120, Control Room (6.4 hrs.) Outside (1.6 hrs.) 8. Dryer, Outside Bldg. 120, Control Room (2. 4 hrs.) Outside (5, 6 hrs. ) 9. Refrigeration & VCl Unloading Bldg. 113 Control Room (6.5 hrs.) Outside (1.5 hrs. ) 10. Chief Operator Control Room - 174 & 120 (4. 8 hrs. ) Outside (3.2 hrs.) Area (ppm) 1 5 1 10 1 8 1 6 1 6 1 7 0. 5 6 0. 5 6 0. 5 7 1 5 8-Hour TWA (ppm) 2 3 6 2 2 3 2 4 2 3 To prevent operator exposure to over 50 ppm VCM currently requires two operators to wear respiratory equipment 5% of the time. This is equivalent to one percent of the total operator time. UCC 091395 January 10, 1975 UCC 091396 (Dl^K " i*^L, / ij. d&rtf VW.:l.*V '' uc , , 11 ", INTERNAL CORRESPONDENCE 4^ ssM *a*c*i : ` '*** ' -` CHEMICALS AND PLASTICS .y TO (NAi^ftr/|K. E. Ross^ company Mr.VR. L. Frantz l_ OCA T10H . , ` TEXAS CITY PLANT copvt^^^5. W. Sealer, 515 ^ v' ' X Ifc.TJ. B. Leverton, 515 Mr.tG. F. Tacquard, 515 Hockersmith, 515 ' "Mr.fR. N. Wheeler, 514 4 v... :/y j*..* 1 ,, ...W.K'.'tJfc ;'-tir4 p. o. BOXX 471, -y^AS CITY. TEXAS 77590 date Hay 27, 1975 i*:: SUBJECT OSHA ! -4 . ' ` A^ ji1i-=Jr.L7J- iNick Wheeler called to pass on that in his conversations with OSHA, it became apparent that their compliance officers will check to see ftjat fchqffi is ft respirator available for each employee in a regulated area. Their thinking is that an employee may change his mind at any time and request a respirator so it must be available to him. The respirators should be located so that they are readily accessible, and the employees should know of their whereabouts and availability. Apparently a proposed standard for MEK and MIBK has recently published in the Federal Register. The National Cancer Institute has published an early warning (before all data is in) on trichloroethylene. John Leverton, could you please have someone check the Federal Register for the MEK and MIBK standards? MEE/ebm V--^-- M. E. Eisenhour ^V~ vVitcl A.VjO'J \ * `/V'iQV A. -V.'\ ,AV/\ Kh/i. V\QVa> Wm, A oooOi .0 25 i', ' t i \Vd WaViA 'ArV \A\Tty(Ay_t . Aai "oJtmJL V r "a \l\ wy A'.*y \ ioor . i4. ;Wn\ U L- L J )r ; *> t V- '-.l . V \5 i \\W'J V VS\AC^i wv \ ,\\' !,y. j cuu) 5C5 iVi * /Ac :/>vvVi 'A'.. v)v1-'v0A;Il v'.XijJ tt sV/V V.f< ,,\.'V t. UCC 091397 iTTM TTT3 RECD. r' internal correspondence CHEMICALS AND PLASTICS CATION Mr. E. Bell - B.B. Mr. R. N. Wheeler - 514 P l-Alfc May 30, 1975 c i' PLAM7 I '3RS. FILES Mr. A. E. Donaldson - B.B Mr. R. L. Frantz - 515 Dr. W. R. Manning - 511 Mr. R. W. Martin - 511 Mr. R. W. Sesler - 515J Dr. A. B. Steele - NYO, 28th Floor Mr. K. L. Topham - 515 T VCM Tank Car Unloading The attached from Keith Topham outlines a scheme that should permit the unloading and removal of VCM tank cars for maintenance without planned loss of VCM to the atmosphere. With Drs. Manning and Steele's permission we will proceed with the preparation of a work, order request. Our thanks to Keith for evolving a scheme for solving a rather difficult knotty problem. Sincerely MEE:lw Attachment M. E. Eisenhour UCC 091398 DESIGN CHANGES TO MEET O.S.H.A. STANDARDS EQUIPMENT AND PIPING MATERIAL LIST Vinyl Chloride Vaporizer Installation Vaporizer - Design pressure tube side 75 psig - steam, 608 pc, 96" long tubes 3/4" O.D. 16 BWG - 330 sq. ft. Design pressure tube side - 100 psig Vinyl chloride liquid and vapor 27" O.D. x 15'10" long. Overall length including steam jacket 18' Insulated for 70 psig steam/steel shell and tubes Piping 300' - 3" l-B-2- design pressure 150 psig from vaporizer to Bldg. 120 Operating pressure 70 psig - steam - insulated 5 pc. 3" 150 psig steam valves GA-5 20' 4" 1-C-l design pressure 150 psig from vaporizer to VC1 compressors discharge Operating pressure 70 psig VC1 vapors 7 pc. 4" 150. psig VC1 vapor vaives GA-59 Operating pressure to 70 ps'Tg'^ 35' 1" 1-C-l design pressure 150 psig Operating pressure to 150 psig VC1 liquid feed piping 5 pc. li" 150 psig VC1 liquid valves GA-1148 operating pressure to 150 psig 60' 3" VC1 vapor safety valve piping 1-C-l discharge to VC1 vent and to air 2 pc. 3" 150 psig VC1 vapor valves under safety valves GA-1148 4 pc. i" 150 psig steam and VC1 press, gauge and vent valves - l-B-2 and 1-C-l 300 1" l-B-2 design press. 150 psig steam condensate return 1 pc 3/4" l-B-2 steam condensate trap with valves Instrumentation 1 pc 3" steam motor valve with press, controller operating press. 0-70 psig - normal press. 40 psig l-B-2 1 pc 0-100 psig press, gauge for steam service tube side 1 pc 1" vinyl chloride liquid feed motor valve with liquid level controller 1-C-l UCC 091399 Equipment and Piping Material List Page 2 Instrumentation (continued) 1 pc 4" VC1 vapor feed motor valve with two-way cross-over to existing suspension and solvent accumulator liquid level controller 1 pc 0-100 psig press, gauge for VC1 shell service 2 pc 3" safety valves 1-C-l VC1 vapors oper. press. 75 psig 8c 85 ps: 1 pc 3' safety valves l-B-2 steam service oper. press. 85 psig VC1 Brine Cooler Inert Gas Vent 720' 14" 1-C-1A design press. 150 psig VC1-N2 vent from condenser shell to Bldg. 119 - oper. press. 7 psia to 70 psig 4 pc. 14" 150 psig VC1 and N2 vapor vent valves GA-1148, oper. pressure 7 psia to 70 psig 1 pc 4" vacuum to 100 psig press, gauge VC1 Tank Car Hose Purge Connections and Piping 110' 1" 1-C-l-A design 150 psig VC1 8c N2 vent piping to 14" brine condenser vent header - oper. press. 7 psia to 90 psia 18 pc 4" N,, purge valves G-1191 (ball valves) 12 pc 4" VC1 & N2 vent valves G-1191 (ball valves) 2 pc 1" 150 psig'TCl & N2 vent valves to 14" VC1 & N2 vent header Oper. press. 7 psia to^90 psig GA-1148 2 pc 4" vacuum to 100 psig press, gauge VC1 & Ng service VC1 Tank Car Maintenance Preparation Location from old VC1 8c acid tank car racks to Bldg. 119 900' 14" 1-C-l-A design pressure 150 psig VC1-N2 vent line from tank cars to Bldg. 119 * 5 pc 14" 150 psig VC1 8c N9 vent valves oper. press 7 psia to 100 psi GA-1148 * 1 pc 12" Dia. x 4' long liquid separator pot 1-C-l-A 2 pc 1" 150 psig VC1 8c N,, safety valve shutoff and drain valves GA-1148 * 1 pc 1" safety valve for pot oper. press 100 psig K. L. Topham May 12, 1975 TJCC 091400