Document GKK10dro3v35On0Xwwm8ZQRkY

CHEMICALS --?*/-*- y^^^>JLjl X^ dr-d 'UrLc^~s-/s2-0^l ^S-IWoOfFIFICE / LAKE c-?1 CHARLES TO FROM J - E. Wyche A. P. Plauche^ DATE SUBJECT May 28, 1980 In-Plant Vinyl Chloride Emissions Survey On May 5-8, 1980, C. A. Burns and I visited the VCM Unit, the Tri-Ethan II Unit, and the Plant B Shipping Department to survey PPG's readiness (with regard to VC emissions) for an upcoming EPA inspection. The overall picture looked good, except-for monitoring in the Shipping Department. Attached is a summary of the conditions found to exist in these areas and the improvements needed to bring us into compliance. /ap Attachment cc: W. Caillouet R. Holliday G. Jordan J. LaFleur/H. Hank C. Muery W. Peard/C. Bums 043971 Sb Regulation 6).65 (a) Relief valve discharge 61 .*65 (b) Fugitive emission sources 1-Loading & unloading lines VCM {Bill Sonnier) None in the past six months - they would be reported to Env. Dept,jf. occurs.- tn fulTcompliance; no further action needed. Tri-Ethane II (Clark Graybill) Same as VCM fVA 2-Slip gauges 3-Leakage from pumps, com pressors, & agitators 4-Leokage from relief valves N/A pumps - double mechanical seals (leak returned to process) compressors - none in VC service agitators - double mechanical seals (leak returned to process) In full compliance; no further action needed. There is a rupture disc between VC equipment and relief valves. In full compliance; no further action needed. IVA Same as VCM Same as VCM Page 1 Plant B Shipping (Winston Caillouet) Same as VCM All gas resulting from the cleaning of lines is sent to the incinerators. Die concentration is not checked by the Lab. It is determined by "experience" as to how long a line should be cleared. Ibis line ts plugged when cleaning is completed. IF the incinerator were to "shut down", ioading/unlocding operations would halt. This is not presently in SOP. The volume of the vinyl remaining in the line (offer cleaning) should be determined by Lob analyses and documented. Analyses of 3 or 4 cleared lines should give us a good basis lo determine how many times a line should be purged to the incinerator. Analysis should be performed each quarter to assure ourselves and EPA that this procedure is still accomplishing its purpose. This procedure, along with shutdown procedures, should be included in SOP. Discharge sent to incinerator. This is in SOP. In full compliance; no further action needed. Pumps - double mechanical seals Compressors - none in VC service Agitators - none in VC service Some as VCM ^ t") O tn The only relief valves in the area are on the tank cars. This would be covered by DOT, not EPA (no rupture discs). Same as VCM It 1 t Regulation / 5-Manual venting of gases >` 6-Opening of equipment 7-Samples 8*Leak detection; (i) permanent monitor (ii) portable detector \ t < VCM All gases manually vented are sent to the incinerator. In SOP. In full compliance; no further action needed. Tri-Ethane II Same as VCM All vinyl removed from equipment is sent to the Incinerator. The Lab (M. Wood) samples gases from the equipment until the : 'concentration it below 2%. Some of these reports are kept in the unit. The Lab retains files of all of these reports. SOP. A-Cftpy--. of all lob analyses reports should.be kept in ibe Individual units. Otherwise, no further action needed. Same as VCM All samples are purged in a closed process system and returned to process. SOP. In full compliance; no further action needed. Same as VCM Thore are 9 permanent sample points in the area. Samples are taken continuously and in sequence with analysis showing on a computer print-out in the control room. All sample points are in operation and checked at least three times per week. The calibration gas cylinders are properly labled. SOP. The action taken to correct a detected leak should be noted on the computer print-out. Some as VCM except; (a) 11 sample points (b) action taken is written on print-out In full compliance; no.further action needed. A portable detector Is shared with the Shipping Dept. Patrols are made weekly with monthly checks being more point specific. The instrument is calibrated and maintained as needed (almost every time it is used - unreliable). The "time" of the patrol was not being recorded, but will be In the future. A monitor should be purchased so that VCM would then have it own instrument. This would enable personnel to make the patrols on a more routine basis. Also, the presently used monitor could be used as a backup. The time of the patrols should be noted on the report. Patrols are mode^wice/rnonth^ The "action token" and "time" will be.recorded in the future (not being done inthe past). The portable monitor is calibrated and checked ori request. Plant B Shipping Same as VCM Same as VCM Page 2 H/A There is no permanent sampling Instrumentation In this area. Permanent sampling Instrument ation should be installed ASAP and the schedule for maintenance on the inslrumentatic properly tabled calibration gas mixture, a plar of action to correct leaks when detected, and the definition oF a leak be followed. No patrols were made since July 30, 1979 due to Unreliability of portable monitor sliared with VCM. A monitor should be purchased to enable personnel to make "routine" patrols in the area. SL 043973 I (MI) semi-portable HNU 9-lnprocess waste water N(/A IF under 10 ppm, sent to segregated sewer and then to API. If over 10 ppm, kept until a level under 10 ppm is reached (under Nj purge to incinerator). In Full compliance; no Further action needed. n/a None In VC service Pogo 3 Used For ship loading but not for barges. This monitor should be used for barge loading as well as ship loading. N/A The integrity of the sample lines in Tri-Ethane II and VCM are checked twice per year using a standard VC sample which Is introduced Into each sample line. Included in SOP are the procedures to be Followed in the event that the incinerator sould be shut down which would prevent any vent gas burning. 043974 s-T CO >/ > I* /