Document MJ97z4y4ZwVzOMN0147kR12Yy

. ........ . * VAB.00010 Distribution from: Me: F. G* Jumon November 24 1985 EQUIPMENT OPENING PROCEDURES Attached are the equipment opening preparation procaduree for equipment that nay contain VCM. A review meeting for these procedures was held on September 26, 1985* Conmnta from this review meeting have been Incorporated Into these procedures* Frank G. Jeanson Process Engineer r 8P * c:JF,JW,DWH,CRS,OT,MLN,AHS4&JLHtVEM,VLT A 4 VAB.0001094894 , %. A uimnrr opekirg procedures tnwnita CHEMICAL PUT Introduction 4 Prior to opening any vassal or placa of equipment tha quantity of VCM it contains nust ba no niora than 2.01 by volume at standard temperature and prassura or 25 gallons of VCM vapor at standard temperature and prassura (vblchavar Is graatar). To Insura compliance with this requirement tha following procedures hava baan provldad. Thasa procaduras will ba usad whanavar equipment that nay ' contain VCM Is balng praparad for opening to atmosphere. Thasa procaduras are broken down Into tha following categories. A. Vassals larger than 1250 gallons B. Vassals smaller than 1250 gallons C. Pumps* compressors* filter packs* and piping Procaduras for sampling and measuring tha concentration of VCM In vessels of graatar than or equal to 1250 gallons volume prior to opening are provldad In Appendices B* C* and D. Procaduras Tha following procaduras are to ba usad for preparing vassals that may contain VCM and are graatar than 1250 gallons in capacity for opening to atmosphere. Tha vinyl reactors are not included In thasa procedures since their openings are governed by more stringent amission standards* Thera are two acceptable methods of preparing vassals greater than 1250 gallons for opening to atmosphere. These are given below. A. LARGE VESSEL PREPARATION BY DISPLACEMENT WITH WATER 1. Isolate the vessel from the rest of the process. * ( 2* Fill tha vassal up with water to displace tha vapor space. Tha displaced vapor volume and water overflow should ba lined up to go from tha top of tha vassal to tha blowdown tank or tha batch water strippers. m 3. After tha vassal has baan completely filled* Isolate tha Inlet and outlet and sample tha witer in tha vassal for VCM concentration par thes. sampling procedure In Appendix B. a. If the VCM concentration Is less than 53 PPM in the water sample* than tha VCM concentration in tha vapor space VAB.0001094895 PROCEDURES ABERDEEN CHEMICAL PLANT II. Largs Tciitl Opening Preparation Procedurea - Continued after dump will be within acceptable limits. If the VCM concentration in water is below 10 PPM it can be drained directly to the sewer; if it is above 10 PPM the water must be drained to the batch water strippers and stripped per normal procedures b. If the VCM concentration is less than 150 PPM, but above 53 PPM, then drain the water to the batch water strippers or the blowdown tank. After draining, the vessel vapor space should be sampled for VCM concentration using the sample method In Appendix C. c. If the VCM concentration Is greater than 150 PPM, the vessel should be closed off at the top and partially drained to the4 batch water strippers or the blowdown tank. Refill the vessel while pulling a vacuum on the top through the batch water strippers or the blowdown tank. After refilling, resample and follow steps a, b, and c until a concentration below at least 150 PPM is reached. B. LARGE VESSEL PREPARATION BY STEAM STRIPPING 1. Isolate the vessel from the rest of the process. 2. Partially fill the vessel with water and steam strip while recovering until the one of che temperature/ pressure limits given Appendix D is reached. 3. After the vessel has been stripped and Isolated from recovery, the water in the vessel should be sampled per the sampling procedure in Appendix B. If th VCM con centration is less than 10 PPM, the water can be drained to the sewer; otherwise, drain the water to the blowdown tank or the batch water strippers. If preferred, sampling can be omitted and the vessel drained to the blowdown tank or batch water strippers. A VAB.0001094896 A UIFMENT OPENING PROCEDURES ABERDEEN CHEMICAL PUNT II, Large Vessel Opening Preparation Procedure - Continued 4. For the blowdown tank and the batch water strippers opening preparation strip following nornal procedures to one of the tenperature/pressure Units given In Appendix D* then drain the water to the sewer or centrate tank* 5* After the vessel Is drained* It can be opened to atnosphere* Appendix A lists and gives the volunes for all the vessels In VCM service of 1250 gallons capacity or greater* III Snell Vessel The following procedures are to be used for preparing vessels that nay contain VCM and that are snaller than 1250 gallons In capacity for opening to atnosphere* This Includes piping runs of nore than 25 gallons In volune between Isolation valves* Nornal procedures are as follows: a 1* Isolate the vessel fron the rest of the process* 2* Fill the vessel one-third to one-half full with water and steam strip until the recovery line gets hot and then strip for at least 15 ninutes* After the tine Unit* cut off the stesn* 3* Finish filling the vessel up with water to displace the vapor space* 4. Close the recovery outlet and drain the vessel to the batch water strippers or the blowdown tank* 5* The vessel can be opened to atnosphere. Sanpllng of vessels of less than 1250 gallons capacity is not required* IV The following general procedures are to be used for the recovery systens or preparing pumps, compressors, filter packs* piping and other miscellaneous snail equlpnent of less than 25 gallons of volune that nay contain VCM for opening to atnosphere* VAB.0001094897 UIPMENT OPENING PROCEDURES ABERDEEN CHEMICAL PLANT Puaa, Compressors, Filter Peeke, end Piping That May Contain VCM A After Isolating equipment, use the following procedure: * 1. Connect a steam hose and a recovery hose to the piece of equipment (If there Is not hard piping to the batch water stripper or the blowdown tank) and strip until the pressure in the piece of equipment Is below atmospheric pressure. 2. Strip the unit for at least 15 minutes. 3. The equipment can be opened to atmosphere. For small pieces of equipment (25 gallons volume or less) that do not have the facilities to do the above procedure use the following procedure 1. Connect a recovery hose to the piece of equipment and recover the unit until a vacuum can be held on the piece of equipment with the recovery shut off. 2. The piece of equipment can be opened to atmosphere. V. Safety To eliminate the risk of overexposure to VCM, a fresh air mask should be worn when opening equipment that may have contained VCM, even after equipment opening procedures have been followed. + VAB.0001094898 APPENDIX A Vassals largar than or aqual to 1250 gallons that nay contain VCM name volume,gal VCM Sphara 640600 VCM Bullats (2) 61000 aa. Naw Unit Frash VCM Racalvar * 9275 Naw Unit Racovarad VCM Racalvara(2) 7390 (f) Old Unit Frash Racalvar 7390 Old Unit Racovarad Racalvars(2) 7390 aa. Naw Unit Blowdown Tank Batch Watar Strlppars(2) Naw Unit K. 0. Pots (2) 5922' * 17380 aa. v 1541 aa. VAB.0001094899 A equipment opening procedures ABERDEEN CHEMICAL PLANT APPENDIX B Watsg Saaplifj Ptroc*dure The following sap1Inf anthod is to bs ussd whsn sampling s vassal In VCM ssrvles thst has bssn cosplstsly fIliad with water to displacs VCM vapors. Tha sampling Is dona prior to opaninf tha vassal to tha atmosphere. This sampling asthod is basad on Tast Mathod 107 of tha Padaral VCM Emissions Ragu1stions. 1. Obtain froa tha lab a 50 al. glass vial* aluainua cap* taflon saaling disc, and cap criapars. 2. Fill tha 50 al. vial with tha water saapla to ovarfloving so that a convaz aanlscus forms at tha top. Tha excess vatar is dlsplacad as tha saaling disc is carsfully placad, with tha Taflon sida down* on tha opaning of tha vial. 3. Placa tha aluainua saal over tha disc and tha neck of tha vial* and crlap into placa. 4. Attach an ldantlfylng label with tha data* tias* and saapla Identification to tha vial. 5. Taka tha saapla to tha G C lab for analysis and log it .into tha special saapla log book. Include tha data* tlas* saapla identification, and that it is to be tasted for VCM concentration. a 6. Placa tha saapla in tha bench top refrigerator near tha door to the development lab. Tha saapla must be refrigerated until analyzed. 7. Analysis of saaples must be run within 24 hours of whan tha saapla was taken. VAB.0001094900 A UIPMENT OPENING PROCEDURES ABERDEEN CHEMICAL PLANT i APPENDIX C Vtattl Vapor Spic Saaplinx Mithod The follovisg iMplifii attbod Is to bo used to saaple the vapor apace of the vassals listed in Appendix A when the concentration of VCM in the displacing water is between 53 and 150 PPM* The sanpllng will be done with a TLV hydrocarbon detector and sanples will be taken at the top* niddle* and botton of the vessel as described in 61*67(g)(5)(1)(A) of the EPA Regulations on National Bnlsslon Standards for Hazardous Air Pollutants* 4 1* The two TLV portable hydrocarbon detectors in the plant will be used to detenlne the concentration of VCM vapor in a vessel that has been drained of the displacing water if the VCM concentration in that water was between 53 and 150 PPM* A TLV* detector will be used rather than a HNU detector because the TLV will be sble to read up to the 2*0 volX concentration Unit* One TLV should be kept by the vinyl departnent and one by the safety departaent* 2* After draining the vessel* saaple the vessel at three locations with the TLV detector* One aeasureaent will be aade within 6 Inches of the vessel botton* one near the vessel center and one near the vessel top* . *s 3* Measurements are to be aade at each location until the reading is 8tablized* All hydrocarbons measured are to be assumed to be vinyl chloride VAB.0001094901 A APPENDIX D Vessel Steen Strl erature/Pressure Limits Given below is s tsble of tenperature/pressure limits that asst be reached when steam stripping a vessel in preparation for opening to the atmosphere. The calculation of these limits is based on the equations in part 2 of this appendix. Part 1: Table of T rature/Pressure Limits For St Strl Select the temperature to which the vessel Is being stripped under the temperature column. The vessel vapor space pressure must be equal to or less than the pressure given for that temperature for the VCM concentration to be less than 2Z by volume at standard temperature and pressure. Stripping Temperature Required Pressure 215 *F 1.0 PSIG 210 *F 1.0 in HgVac 205 F 3.0 in HgVac 200 *F 6.0 in HgVac 195 F 190 #F 8.0 in HgVac 10.5 in HgVac 185 F 12.0 in HgVac 180 #F 14.0 in HgVac VAB.0001094902 EQUIPMENT OPENING PBOCEPURES ABERDEEN CHEMICAL PLANT A Part 2: Vapor Swct VCM Concentration Calculation*! Method If th vassal has baan itau purgad tha VCM aalaslons can ba calculatad from the partial pressure of VCM In tha vassal vapor spaca as follows: A. Tha partial praasura (asHg) of vinyl chlorlda In tha vassal vapor spaca will ba datarslna froa: PPVC - 760 - W - VPV PPVC * partial praasura of vinyl chlorlda In uaHg. 760 atmospheric praasura at 0*C, In iBSlIg * W absoluta value of vassal vacuus In asHg. r VPV * vapor praasura of watar In ssfig at tha vassal tasparatura 3 B. Tha vassal vapor spaca volusa (s ) will ba datarslnad from dIsonsIons of tha vassal. C. Tha vassal opening loss VCM amission (kg) will ba datarslnad by tha following aquation: VOL - (PPVC) (VSV) (1.002) (273 +VT) Whara: PPVC Partial praasura of vinyl chlorlda In mm Hg. VSV Vassal vapor volusa In m^. 1.002 Idasl gas constant for vinyl chlorlda VOL Kg of VCM raloosed. VT Vassal Tasparatura In C. VAB.0001094903