Document NEDbeJvOyDmMVeEdd939nKEdQ

AFE Request Consent Decree - Compliance Plan Projects Project Descriptions Twelve capital projects are included in the Lake Charles VCM Plant Compliance Plan. A listing of these projects and individual project descriptions are as follows: 1) Combustion Air Control $ 95.OM This project provides for the installation of an improved combustion air control system to minimize incinerator bypasses due to flameouts. The existing combustion air control system will be revised to include: 1) vent header feedforward, 2) liquid byproduct flow feedforward; 3) natural gas flow feedforward; 4) firebox oxygen- concentration feedback; and 5) feedback control of flame or firebox temperature. These modifications will improve the control of excess oxygen and incinerator firebox temperature to ensure complete combustion and thereby minimize incinerator bypasses due to flameouts. 2) Standby Blower Autostart $ 39.5M This project provides for -the installation of automatic controls to start a standby incinerator combustion air blower when the on-line blower approaches maximum capacity. The proposed system will;, minimize incinerator bypasses due to flameouts that result from incomplete combustion .associated with combustion air supply limitations. 3) 'Incinerator Burner Modifications $158.OM This project provides for the installation of new burner assemblies in Incinerators 1-901 and I-901B. The new burner assemblies will improve mixing of combustion air, fuel gas, "and vent streams and thereby minimize incinerator bypasses which result from incomplete combustion due to insufficient mixing. * CUM 00001146? 4) Oxygen Analyzers $ 17.9M This project provides for the installation of a new in-situ oxygen analyzer in each of the Incinerators to improve the control of excess oxygen requirements for complete combustion. Installation of the new in-situ oxygen analyzers will provide for quicker response of the combustion air blower to changes in the incinerator load and thereby minimize incinerator bypasses due to flameouts. 5) Flame Arrestor Level Control $ 9 . OM This project provides for the installation of instrumentation to prevent incinerator bypasses due to low liquid seal flame arrestor level. The proposed system..provides .for. a. board mounted alarm to indicate a malfunction of the emergency make-up water valve. Installation of these position alarms will allow for quicker operator response and thereby minimize incinerator bypasses due . to low liquid seal flame arrestor level condition. 6) Auto Tie Breaker $ 27.5m This project will provide for the installation of an automatic tie breaker system at the Stauffco Substation.-- .The..new auto tie breaker provides for a programmable controller system to sequentially detect- a...-.loss of ..-.voltage on an incoming line, check for ground faultsoh the secondary side of the substation-, open' the switch on the-feed.-.which lost power, and close the tie breaker. Installation of this auto tie breaker will minimize incinerator bypasses due to electrical power- failures.- 7) Wet Vent and D.C. Vent Flow Alarms $ 6.1M This project ... provides,, for the installation of operator adjustable flow alarms for the wet vent and direct chlorination vent to alert the incinerator operators of changing conditions which could impact the incinerator. Installation of the adjustable flow alarms will provide for quicker operator response to changes in the incinerator load and thereby minimize incinerator bypasses due to high vent flows. CWH 00001.1470 8) S-207 A&B Restriction Orifice $ 0.2M This project provides for the replacement of the existing restriction orifice in the vent line from the Flake Caustic Dryers, S-207 A and B. The new restriction orifice will limit the maximum vent flow and minimize incinerator bypasses due to high vent flow from the Flake Caustic Dryers. 9) HC1 Column Control $142,014 This project provides for the installation of new HCl Column instrumentation to improve the control of the " column ' 'overhead and bottom product compositions. The proposed system will prevent excessive HCl concentrations in the tower bottoms and the resulting carryover to the .VCM Column. The Improved control., system^ will reduce , the need, to vent the * vinyl column condensers - and thereby minimize incinerator bypasses due to high vent flow from the vinyl column condensers. 10) Direct Chlorinator Feed Restriction $ 4.1M This project provides for the installation of new 'instrumentation'to prevent incinerator bypasses resulting from impurities in the chlorine and ethylene feedstock to the Direct Chlorinator. -The proposed system, will provide two... high vent flow alarms to alert operators such that the necessary corrective., action -.-pan - be made to prevent incinerator'bypasses which result from high/vent flows associated-.with-- feedstock impurities.. cr 11) S.-102 Flow Indicator- Alarm -- - -$ 4.6M This project provides for the installation of a flow indication for the vent from the Light Ends Column Accumulator (S-102). The flow indication and alarm wi'ir~aid 'in"manual'venting management as well as alerting main plant operators to. changing conditions which could impact the incinerator. 12) Tank Farm Vent Eductor $58.0M This project provides for the installation of a backup system for the Tank Farm Vent Blowers, BL-412A and B to prevent incinerator bypasses due to blower failure. The proposed system provides for a Kynar eductor using nitrogen as the motive fluid to compress the tank vents. The backup system is activated automatically when the operating blower trips out. C'UH 000011471 March/ 1985 March 18 (10 min) Flame failure high vents from oxy and R-101 S/U. March 26 (3 min) DC header due to low/low S-911B level - instrument problem. April/ 1985 April 16 (90 min) Power interruption to BL-902 controls - loss of air. Ignitor head to be replaced also. Mav, 1985 May 7 (20 min) Low combustion air flow. BL-902 trip out. Julv. 1985 July 21 (50 min) Plantwide 4160 power failure. July 26 (15 min) DC high vent flow - Pascal ship lined compressor to us. Auaustz 1985 August 17 (2) Related to C-203 startup activities, malfunction of a hand valve on condensers caused too much flow. October r 1985 October 26 DC R/D blew for 9 hours. t November, 1985 November 4 (45 min) High amp S/D on BL-901A. November 7 (12 min) Loss of natural gas - LCCP closed valve. November 28 High ethane LCCP S/U overamped blower. Februarv, 1986 February 3 (2) a. Upset in EDC wash system put liquid in vent header. b. High vent - undetermined source. CUH 0000.U47 February 7 April, 1986 April 20 April 21 May, 1986 May 25 BL-902 trip out. BL-412 down due to T-450 steaming, later found line plugged on discharge. BL-902 tripped. Wet vent valve tripped on - air line broke, maintenance. Wet vent bypass, ship loading with DC vents split to both - wash system upset. CWH 000011473