Document EdzzrZ0vJwoOm8Jpr9waaQN1V

l R. E. Sourwine Juiy 3, 1973 Zeb G. flei:, Jr. 19 East Pauisboro Terminii Visit A review of the Pauisboro terminal VCM loading, handling and recovery systems was made on June 7 , 1973. This writer was accompanied by Mr. D. Dupre and yourself. The engineering design of the terminal has incorporated some of the latest available technology to contain oil spills and reduce VCM emissions to the atmosphere from normal operations that this writer has experienced. George Barton and Paul Parchinski were most helpful in our review of the terminal pollution control program. VCM Emission Sources The terminal has installed equipment to recover or contain VCM emission resulting from repetatlve operations such as tank, truck and tank car loadings. A provision to collect residual liquid VCM contained in the spool piece has been installed to return this VCM to the accumulator. When this system is properly oper ated there is no liquid losses that occur during truck and tank car "deadhead" loadings. VCM vapor losses occur when these ves els are "deadheaded", however VCM releases to the atmosphere can occur if these transport vehicles can not be filled because of impurities such as oxygen and nitrogen. This condition Is rare at the Pauisboro terminal. When impurities are above specifica tions (oxygen) VCM is purged to the diked area (fire hazard pro tection). VCM impurity checks are made on incoming (empty) trucks and loaded trucks leaving the terminal. This check is nmde to determine oxygen content. An oxygen analyzer is connected to a valve after the line has been "blown down". This procedure releases about 10 ml of VCM. The above checks are made outdoors and constitutes a potential exposure to the employee performing these tests. VCM is unloaded from the US Puerto Rican through a closed system. The liquid VCM is displaced in the ship with vapors from the shore unit accumulator. Again, there can be VCM losses from the spool piece between the flexible hose butterfly valve and the ship's dead end. This connection is about 18 inches long and 10 inches in diameter. The usual practice is to ~eave the ship's valve open and close the butterfly valve on the dock thus permitting the VCM in the spool piece to drain back to the ship or vaporize into the ship's compartment btt:re the connection SL 074137 r Mr. Sourvine Page 2 July 3, 1973 is broken et the dock. However, during cold weather there may be an occasion when this break is maue and VCM will not vaporize. In this instance, a bucket is normally placed under the spool piece valve to oatch che liquid VCM. The VCM is then permitted to flash off to the atmosphere. The dock is constructed of ell steel and haa double 6 inch curbing (one under the unloading linea and the other around the perimeter of the dock). Treps are loceted within the diked arees. These traps collect weste (prlmerlly oils) end drein towards shore wher an oil/water separator is looated. Mhste oil is oollacted and used for dust control on plant roada. The aqueous phase 1$ pumped to a pit. This system is ideal for oil spill containment and liquid VCM from reaching the water, however VCM lost to this system due to a spill will flash off Into the ataoaphere during warm weather. During cold weather liquid VCM spills should be contained by thla system. Periods of rainfall Impose a substantial load on che small water pit. J The laboratory hood in the mein office building was reviewed and | this Is adequate for tests procedure using VCM even with the slight^ modifications to the system, however, VCM frem sample collection "bombs" is released Inside these hoods. This constitutes another VCM loss to the atmosphere. The location of the fresh elr Intake for the air conditioner was discussed. This writer wet told that the air conditioner is on 100X recirculated elr. This aspect Is questioned since most air conditioning unite have some make-up air provisions. In summary the Peulsboro terminal haa many excellent design char acteristics for containment of spills and emission discharges of certain product lines. In view of information that VCM has been reported to be experimental oardnogen (demonstrated in rets), this author's review of the leases of VCM hae been extremely critical. The terminal has provisions for recovery of most all VCM that is not contaminated. The blow down of tank trucks and oars that hav been contaminated poses a problem should it become necessary to prevent theae vapor losses to the atmosphere. Some operational changes may hava to be made as to the method for checking impurities where "blow-down" of the sample line Is done before the test can be made. A smaller sample bomb may have to be uaed in the future to reduce vapor releases or the system revised so that VCM is captured in a closed system. Absorption of vapors on activated carbon, flrres, otc. may have to be considered when impure VCM purge streams are discharged directly to the diked area. The application of molecular sieves for separation of nitrogen conta minated streams should be reviewed so that VO! vapor recovery in the accumulator-refrigeration system might be accomplished. SL 074138 r Mr. Sourwlne Page 3 July 3, 1973 It would appear prudent to collect air samples in the area during unloading of VCM at the dock, truck and tank car loadings to establish area levels of VCM. Personal air monitoring is recommended for operations during unloading of the Puerto Rican and during truck and tank car load ings. Documentations of the exposures with data is important. A list of all employees who work with VCM and their hours worked at each job should be made a permanent record. Employees who arc assigned work with VCM should have medical surveillance. The type of medical program should be recommended by Dr. L. fl. Grant. Some additional information on madioal aurvmlllmnca oan be obtained from Dr. H. Lovejoy, our Lake Charles plant physican. Zeb G. Bell, Jr. ZGB:rmp cc: J. A. Clapperton F. T. Dewoody D. D. Dupre L. 3. Grant, M.D W. R. Harris W. P. Lawrsnce R. E. Widlng SL 7413g