Document MJ71Qg9qm0Zxm3XxYGdv7b2Xy

ISSUE NO./DATE 1/May, 1978 OPERATING PROCEDURES SECTION-PAGE XX-79 EPA COMPLIANCE FUGITIVE EMISSIONS General Information The EPA requires the concentration of vinyl chloride in in-process waste water Istreams and vents to the atmosphere has to be less than 10 ppm. The EPA systems serve as a central collection point for all of the contaminated streams. How ever, the operators need to be aware of various operating procedures which do not pertain to the EPA systems but are required to meet EPA compliance of the VCM Standard under fugitive emission sources. The following will serve as guidelines (check the appropriate section in the Plant's Operating Procedures 1 Manual for step-to-step details). j 1. The sample tap (slip gauge) and liquid header bleed cannot be used to detect | bia^*icL I the presence of VCM in the railcars. !A .' I 2. The vapor and liquid headers' pressure for therailcar platform must be | pulled down to less than 5 psig before the hoses canbe disconnected at I the railcars. i| j 3. The reactors cannot be vented to the atmosphere unless there is an emergency. 4. Do not open up any piece of equipment or section of line in vinyl chloride I service unless it has been purged with water to the EPA systems (water 1 \, ! strippers). DTH 00008288 ISSUE NO./DATE 1/May, 1978 1 CUNUCO CHEMICALS OKLAHOMA CITY OPERATING PROCEDURES SECTION-PAGE XX-80 EPA COMPLIANCE FUGITIVE EMISSIONS (Continued) ' 5. Manual venting of VCM to the atmosphere is not allowed. Any venting of VCM needs to be ducted to the EPA purge header. 6. Any unused portions of samples containing at least 10 percent by weight vinyl chloride must be returned to the process. 7. 1 i 8. Whenever a leak is detected from the gas chromatographs, the leak must be located and eliminated. Any leaks detected during a routine patrol or the leak monitoring program are to be recorded in the log book in the shift supervisor's office. m'-m DTH 000082883 mm