Document LgaB1oKd8rMKXBv9bdZmxERvz

CHEMICALS INDUSTRIES TO Plant B Shift Supervisors and General Foremen DATE March 18, 1985 FROM J. A. Hart/S. L. White SUBJECT Environmental Incidents As a result of the recent enforcement action against PPG for the failure to report an environmental incident, we all must be keenly aware of the reporting procedures to be followed. Furthermore, as a result of the current political climate, we must greatly reduce the number of releases we have been experiencing. The following procedures will be followed by all in the event a release occurs on back shifts and weekends. ' 1. Any release (as defined below) will be verbally reported to the Shift Superintendent who will report it to the Environmental Department. Indi cate on the written report who in the Environmental Department the Shift Superintendent contacted. Critical Points: a. If the release occurs in an area covered by the VCM regulations, then the Environmental Department must notify the DEQ within three (3) hours. b. It is critical that all possible chemical components in the release be reported to the Environmental Department. c. It is very important that a good estimate of the quantity of each com ponent released be provided to the Environmental Department. d. If there is any question or doubt, call the Unit Foreman or duty man immediately. 2. The Environmental Department will make the decision on whether an incident is reportable to the regulatory agencies. Therefore, all release incidents that fit the definitions given below must be reported to the Environmental Department. 3. A written Environmental Incident Report will be prepared on all incidents that fit the definition of a release given below regardless of whether or not they are believed to be reportable to regulatory agencies. Procedure: Two copies of the report will be made and routed by the Shift Supervisor. Use the routing slip to assure that each copy follows correct route and can be easily identified. 1) One copy, labeled preliminary, is routed to the Production Superintendent, Operations Superintendent, and Plant Manager. It must be on the Plant Manager's desk by 12:00 noon on the day following an incident. 0&3&67 SL Plant B Shift Supervisors and General Foremen Procedures for Reporting Environmental Incidents March 18, 1985 Page 2 2) The second copy (which will be the final copy) should be delivered to the Unit General Foreman or duty man at 7:30 AM on the morning following an incident. 4. Finalization and verification of the components and quantities will begin by 7:30 AM on the morning following any incident that occurs after 4:00 PM any day of the week. The duty man should be contacted on weekends. He will come out and perform this task. Critical Point: If any error is found in the preliminary report, notify the Environmental Department immediately. 5. The final report must be prepared by the Unit Foreman and approved by the General Foreman. All follow-up information and calculations should be attached to the final report. The final report must be submitted to the Environmental Department by 4:00 PM on the 4th day following the incident. The following procedures will be followed by all in the event a release occurs on Monday-Friday days. 1. Any release (as identified below) will be verbally reported to the Environmental Department by the Unit Foreman involved. Critical Points: a. If the release occurs in an area covered by the VCM regulations, then the Environmental Department must notify the DEQ within three (3) hours. b. It is critical that all possible chemical components in the release be reported to the Environmental Department. c. It is very important that a good estimate of the quantity of each com ponent released be provided to the Environmental Department. 2. The Environmental Department will make the decision on whether an Incident is reportable to the regulatory agencies. Therefore, all release incidents that fit the definitions given below must be reported to the Environmental Department. 3. A written Environmental Incident Report will be prepared on all incidents that fit the definition of a release given below regardless of whether or not they are believed to be reportable to regulatory agencies. Procedure: Two copies of the report will be made and routed by the Unit Foreman. 1) One copy, labeled preliminary, is routed to the Production Superintendent, Operations Superintendent, and Plant Manager. It must be on the Plant Manager's desk by 4:00 PM on the day of the Incident. SL 043668 Plant B Shift Supervisors and General Foremen Procedures for Reporting Environmental Incidents March 18, 1985 Page 3 2) A second copy (which will be the final copy) should be prepared by the Unit Foreman and approved by the General Foreman. 3) Use the routing slip to assure that each copy follows correct route and can be easily identified. 4) The preliminary copy can be eliminated if the final copy can be prepared by the 4:00 PM deadline on the day of the incident. 4. If any errors are found during final report preparation, notify the Environmental Department immediately. 5. The final report must be prepared by the Unit Foreman and approved by the General Foreman. All follow-up Information and calculations should be attached to the final report. The final report must be submitted to the Environmental Department by 4:00 PM on the 4th day following the incident. Attached please find a new Environmental Incident Report form. Please destory all old forms and begin using this form immediately. Also, a new routing form for preliminary and final reports is attached. Please begin using this immediately. Also attached are: 1) Definition of a release including PPG internal reportable quantities. 2) Definition of units and SRV's covered by the Vinyl regulations. /bjm Attachments cc: J. E. Fike/E, J. Tullier Shift Superintendents W. J. Peard R. L. Jones 0436&9 si* THE FOLLOWING ARE DEFINED AS RELEASES WHICH MUST BE REPORTED TO THE ENVIRONMENTAL DEPARTMENT IF THE QUANTITY INVOLVED EXCEEDS THE AMOUNT GIVEN ON THE ATTACHED LIST. - A spill of any liquid organics or olL on the ground. - A spill of any liquid chemicals such as cooling tower treatment chemicals, Dowtherm, or still aids on the ground. It is not a reportable release if a dry solid (such as a catalyst) Is spilled on the ground, however, it must be cleaned up since rain could cause a reportable release. ________ _____________ __________________ _______ A spill of any liquid volatile organics even if to a contained concrete pad. In this case, volatile is defined as anything with a boiling point below Trichloroethane (TCE). It is not a reportable release if a non-volatile liquid is spilled to a con tained concrete pad such as those that drain to the lift stations and go to the WTU. - The bypassing or the anticipated bypassing of the primary environmental control device for more than four (4) hours for any organic, HC1 or CI2 gas or vent streams. The primary control device could be, for example, the incinerator, scrubber, or a refrigerated vent condenser. - The release of any organics, HC1 or CI2 from an SKV, a rupture disk, a leak (for example, due to corrosion or equipment failure) or Improper opening of a line, valve or vessel. - Any incident which results in visible and/or odorous emissions which could escape the Complex fenceline. IN ADDITION TO THE ABOVE, THE FOLLOWING ARE DEFINED AS RELEASES WHICH MUST BE REPORTED TO THE ENVIRONMENTAL DEPARTMENT FOR THOSE UNITS COVERED BY THE VCM REGULATIONS: - Non-incineration of the vents from any of the units covered by the VCM regula tions for greater than one hour. - Bypassing of the CSS or failure of the CSS to remove VCM to less than 10 ppm in the effluent. - Any release from an SRV in vinyl service. - The escape of VCM due to sudden piping or equipment failure (line or vessel rupture/failure as opposed to non-sudden failure, e.g., drips). SL 043670 REPORTABLE AMOUNTS A release of any amount into the environment of material containing any of the following components: 1. chlorine 2. 1,2 trans-dichloroethylene 3. 1,1-dichloroethane 4. ethyl chloride 5. hexachloroethane 6. methylene chloride 7. perchloroethylene 8. tetrachloroethane (sym and unsym) 9. 1,1,2-trichloroethane 10. 1,1,1-trichloroethane 11. vinyl chloride 12. freon 12 A release of > 100 lbs. into the environment of any other chemical. SL 0A3671 PREPARED BY___________________________________ ________ PLANT B ENVIRONMENTAL INCIDENT REPORT DATE & TIME OF INCIDENT SPECIFIC LOCATION_______ DESCRIPTION OF INCIDENT ENVIRONMENTAL UPSET CHEMICAL RELEASE WAS THERE A RELEASE? IF SO, WHAT COMPONENT? QUANTITY? AIR/GROUND/WAT IF VC RELEASE, WAS IT DETECTED BY MONITOR OR LEAK PATROL? _________________ _________________ ' LBS ___________________________ _____________ LBS __________________ ------------------------------------------------------ ------------ ;_________ _____________LBS ___________________ ______________ LBS ____________ TOTAL _________________ DESCRIPTION/SOURCE, CAUSE .& DURATION ______________ LBS __________________ WEATHER CONDITIONS(Circle One): Clear Partly Cloudy WIND SPEED & DIRECTION (if a gas release)mph_ IMMEDIATE ACTIONS TAKEN: Cloudy Rain NOTIFICATIONS (Who & When) Shift Superintendent (Name) Environmental_________ _____________________________________________ (Name) Other (Name) (Date & Time) (Date & Time) (Date & Time) 1. Attach action plans to prevent recurrence and/or follow-up plans to final copy, 2. Attach release calculations to final copy. FOR USE BY ENVIRONMENTAL DEPARTMENT ONLY NOTIFICATIONS MADE (Agency, Name, Time); REASON REPORTED/NOT REPORTED: OTHER COMMENTS: SL 043672 ROUTING PREPARED BY: fuel /mm ENVIRONMENTAL INCIDENT REPORT SHIFT SUPERINTENDENT CONTACTED ? EVE/NIGHTS/UKND-BY SHIFT SUPERVISOR DATE/TIAE/INIT. ENVIRONMENTAL CONTACTED ? _________ DAYS-BY FORMAN EVE/NIGHTS/UKND-BY SHIFT SUPT. DATE/TIAE/INIT. FINAL COPY BEING PREPARED ? ------ DATE/TIAE/INIT. SHIFT SUPERVISOR GIVE DATE/TIAE EOPY DELIVERED TO GEN.FORAAN (AUST BE BY ?:3B A.A. A0RNIN6 FOLLOUING INCIDENT-- CALL DUTY AAN ON UEEKENOS) UPON COAPLETION OF ABOVE QUESTIONS ATTACH REPORT AND DELIVER TO PRODUCTION SUPT.-PLACE IN SECRETARY'S ENVIR. INCIDENT BOX COPY TO ENVIRONMENTAL FORENANIBY SECRETARY)? DATE/TIAE/INIT. PRODUCTION SUPT. APPROVAL _ _ _ _ _ _ _ _ _ _ - OPERATIONS SUPT. APPROVAL COPY TO PLANT AANAGER BY H: ON DAYS COPY TO PLANT AANAGER BY 1B:B0 NOON ON DAY FOLLOUING IF AFTER 4:00PA OR IB:00 NOON ON AONDAY FOR UEEKENDS] COPY TO ENVIRONMENTAL DEPT. BY SECRETARY AFTER APPROVAL SL 043673 PREPARED BY: 4 ROUTING -- ENVIRONMENTAL INCIDENT REPORT FINAL COPY SHIFT SUPERINTENDENT CONTACTED ? EVE/NIGHTS/UKND-BY SHIFT SUPERVISOR DATE/TIAE/INIT. ENVIRONMENTAL CONTACTED ? DAYS-BY FORENAN EVE/NIGHTS/UKND-BY SHIFT SUPT.mte/TIK/INIT PRELIMINARY COPY TO PRODUCTION ' SUPT. ? DATE/TIAE/INIT. SHIFT SUPERVISOR:UPON EOAPLETION OF ABOVE QUESTIONS DELIVER TO UNIT FORENAN BY 7:3BAN ON HORNING FOLLOUING INCIDENT GENERAL FOREMAN APPROVAL PRODUCTION SUPT. APPROVAL OPERATIONS SUPT. APPROVAL PLANT MANAGER ENVIRONMENTAL ----------------------_______________ FINAL COPY RUST BE DELIVERED TO ENVIRONHENTAL DEPT. BYl I4-06 F.H. ON THE FOURTH DAY FOLLOUING THE INCIDENT. | SL 043674 UNITS COVERED BY VCM REGULATIONS I. ALL OF VCM-II (Including VC Unit, OHC Unit, Purification and VC Storage Area) II. CENTRAL STEAM STRIPPER III. T/E-II (from Inlet to Cracker to overhead of Vinyl Stripper) TRI-ETHANE II VINYL SERVICE SRV's Quench Tower Quench Liquor Tank (86-301) Quench Liquor Tank (86-329) VC-HC1 Still (86-302) VC-HC1 Still (86-328) VC-HC1 Reflux Drum (86-304) VC-HC1 Reflux Drum (86-309) VC-HC1 Reflux Dryer VC Stripper (86-320) VC Stripper (86-327) VC Stripper Reflux Drum (86-323) VC Stripper Reflux Drum (86-331) VC Stripper Reflux Dryer STORAGE AREA VINYL SERVICE SRV's VC Day Tank #1 VC Day Tank #2 VC Day Tank #3 VC Day Tank #4 VC Day Tank #5 VC Day Tank #6 VC Day Tank it 7 VC Day Tank #8 VC Sphere #3 NW VC Sphere it3 SW VC Sphere if3 SE VC Sphere if3 NE VC Sphere //I East VC Sphere it 1 West VC Sphere it2 East VC Sphere it2 West Vinyl Transfer Line VCM-II VINYL SERVICE SRV's HC1 Knockout Drum Quench Liquor Drum Stripper Product Still Feed Drum Product Still Reflux Drum Product Still Humidifier #1 Neutralizer #2 Neutralizer #3 Neutralizer Neutralizer Drain Drum Caustic Storage Vessel Waste Storage Drum VCM Bullet No. 1 VCM Bullet No. 2 VCM Bullet No. 3 VCM Bullet No. 4 VCM Bullet No. 5 VCM Compressor Suction Drum VCM High Pressure Condensate Receiver No. 1 Quench Dopp Kettle No. 2 Quench Dopp Kettle Quench Tower Absorber Low Temperature Storage Tank No. 1 Low Temperature Storage Tank No. 2 Vaporizer Deriming Dryer Dryer Water Drain VCM Condensate Tank Deriming Surge Drum VCM Product to Docks VCM Recirculation VCM from S-l, S-2 SL 043675