Document VGXjE2GzRQxLMaYL2X1Z1vvOj

-Goodrich tt>o BfGooQ<Ch Compony CtTOrniCOl Group nr? i.Bo* 15 nor*?, Ml>rto>t 61507 30906^-20t1 i> Certified Mail No. P-ii.I4_.300 ?\Q___ January 17, 1986 ' Illinois Environmental Protection Aaency Division of Air Pollution Control 5415 North University Avenue Peoria, Illinois 61614 Attention: Mr. Richard Jennings, Reqional Manager Subject: Emergency Relief Valve Discharge - Paragraph 61.65 (a) of the National Emission Standard for Vinyl Chloride Dear Mr. Jennings: Pursuant to 40 CFR 61.65 (a) of the National Emission Standard for Vinyl Chloride, the BFGoodrich Company, at it`s facility in Henry, Illinois is reporting an emergency relief valve discharge. The discharge is detailed in the following letter. k At approximately 1700 hours on January 10, 1986 the Waste Water Stripper safety relief valve discharged approximately 22C pounds of vinyl chloride to the atmosphere (See Calculation Attachment). BFGoodrich has taken the following steps prior to the discharge to prevent such occurrences: 1. Rupture discs which are in place to protect safety relief valves, are replaced after a specific length of service to ensure their integrity. 2. Relief valves are removed and pressure checked as part of a preventative maintenance program. 3. The operators and area supervisors responsible for the operation of the equipment have been trained with respect to procedural steps for controlling releases and emergency conditions. The following is the chronology of events leading to the discharge: On January 10, 1986, the actuators to the shut off valves on the main cooling water line to the Polymerization Building were being retrofitted with new actuating mechanisms. The contractor performing the task positioned the valves in the half-open position required to install the new actuators. This did not affect operations. Upon completion of the installation the building personnel beqan to open the valves to the full open position. While opening the valves the personnel were informed that the coolinq water supply pressure was inadequate for the Polymerization Buildina. Realizing that the valves must have been closed, the personnel reversed the operation nf NGC 01609 2- - The loss of cooling water to the Polymerization building resulted in loss of control of the batches in reaction and resulted in an increase in the recovery system pressure. All Polymerizers were controlled following the standard emergency procedures. However, the increased pressure in the recovery system resulted in the overpressure of the waste water stripper causing the discharge. The area personnel responded to this condition and stopped all feeds and steam to the waste water stripper. This immediately stopped the overpressure condition. The Cause of the Discharge Upon review of the incident it was discovered that the existing shut off valves were not standard ANSI valves, in that their closure direction was reversed. Standard ANSI operators had been installed on the valves. The building personnel following the clearly labeled opening direction on the actuator inadvertently closed the valve causing the loss of cooling water. Corrective Action to Prevent the Recurrence 1. This incident has been reviewed with all engineering, operational, and contractor personnel involved. 2. This incident will be reviewed with all other personnel in the Polymerization area and all emergency steps involving cooling water failure will be reviewed. 3. The cooling water valve acuators will be modified to indicate the proper closure direction. If you have any questions concerning this report, please feel free to call me at (309) 364-2311. Sincerely, rdm cc: Chris Romaine/IEPA Kenneth J. Willings Sr. Environmental/Safety Engineer NGC 01610 *Vv. ' : a * yiIHQD_FOR_DeTERHiNINB_THe_AMOUNI_OF_yiNYL_CHUORiDg \ Facts: 1 2 Approximate duration'1 of the release -- 2 minutes The discharge was approximately 42X vinyl chloride Calculationc A _____V Z^V T /T 1-175 CKd P Kb (See attached Farris Safety Relief Valv calculation for vapors and gases.) V = A <1, 1J7p5)iCCKdJP &b /Gi/TTz V B Volume (SCFM) * 7 A " Orifice * 1.287 sq. in. G ** Specific Gravity * 1.304 of the Vapor in the column T = Temperature - 700R Z ** Compressibility ** 1.0 Factor C *= Gas Constant = 356 Kd Coefficient of " 0.953 Discharge P *= Relieving 08-7 psia Pressure Kb " Vapor Flow " 1 Correcti on Factor ClVfe87>_Cl. 175) <356> (.955) (8B.7M1I / (y 1.304 >< v'7000R )( 1.0 > - -1506" SCFM * * r * * \4 - *. * . f r -^\Q Quantity of VCt_ released , JQ`:V5b6 SCFM X 2 Minutes x #_MoJes x 62.5 x V, . V" Q ^220 lbs 359 SCF Mole ', > 4 (0.42) 'i ' * ,*: > - ;5. a*-. ' *.:. ' ;`.*_Vr \ S.'\ . ... * . - - + 'J, V / '.A " . ' * NGC 01611 Teledyne Farris Safety-Relief Valves Sizing O^mOlas Before imiMtinc Any c-tlcuMlioiii, it is necessary to establish the >e<icr,il CMC|;oiy ol Ihe pressure relief valve Imuir con Sxiered. Tins section covers conventional spring loaded types and Q.ilanScJl S|'<>C loaded types separately. Pilol opctAlcd types are coyereri m a separate catalog. Given Hie rate ol fluid flow to (>e ie'*eveJ. p<e usual proce dure is to calculate first tlie minimum area required m the valve orifice for the conditions contained in one ol the follow mg formulas, in the case of steam, air or water, tlte selection ol an orifice may Ue made ducctly from the capacity tables m Section A il so desired. In either case, the second step is to select the specific type of vatvc that meets the pressure ami temperature require ments as doscnlKd >n section S. Selection. General lormuMs are given first, to identify the basic terms winch correMic with ASMC. 1`icssurc Vessel Code. Section Vllt. Then, an alternate wing mrlliod >s given to provide modified lormnlas which reduce computation Since these formulas are conservative. >| is recommended that computations ol relieving loads avoid cascading of safety factors or multiple contingencies beyond the reasonable flow required to protect the pressure vessel. Conventional Valves -- conelanf bock presauro only ` -The convention*! valve may be used when the variation in backpressure does not exceed 10% of the set pressure, provided : the corresponding variation in set pressure is acceptable. T Orifice area calculations VAPORS or GASES... ----- Lbs./hr. ~ ... -. CONSTANT BACH PRESSURE. .CK^r^M Kb ClI vln ImI primiw l(hlwU%Wdi. aNwtar >wiww. VAPORS or GASES... -- S.C.F.M. --- ; a ;'7 v ^/c y/f^/~z : A r. 1.175 CK^P Kb CONSTANT BACK PRESSURE ft -- t >U< let WWWT f ^inn. STEAM . . / -- Lb*./hr. ; Vw, A,..;. 51.5 K*P Kb K CONSTANT BACK PRESSURE K4 e I ie<* r*Mfq 1^4-1 if |fea LIQUIDS... " ----- C.P.M.-- ' 1' i vLV^ . Z- M-.9 Kd yj 1-25 P!-P2 Kp Ku COHSTANTBACK . PRESSURE P2 r(,,1-.1*wfWilaa.rclp%Wirwaraltwml AIR . . . -- S.C.F. M. -- V, yff A " die KdP*b CONSTANT BACK PRESSURE (1 B rl,HUinht 'tW.ii%Kiuliml.. Nomenclature - 'A W W, V .0 u Raqulrwd orifice area In equaro Inches. Thl* value may fra compared w'll. tha effective discharge eras* published In thia catalog. ANSI Standard 0H6.1 and defined In ANSI Standard B9S.1. -- Raqulrad vapor capacity In pound* par hour. _ Required alaam capacity In pounds par hour. m Required |(i capacity In &.G.F.M. -- Required air capacity In S.C.F.M. w. Required liquid capacity In U. S. (ilhnt par minute. . Specific gravity of gas fair --1) ar epeclfic Gravity Of liquid (water -- 1) at actual discharge temperature. A apacitic (cavity al any lowar len-pare* rr* will obtain a u( vatva *lia. -- Average molecular eight of vapor. - .p > 'T _ - rx -P2 T r c pitllaia ^ ** m fr* a aviai j wSat prauwn at InlaL ptlg. Back pre**ire at outlet, pa>(. -- Intat lamparaluro *P. absolute (*F. ply* 460). -- Compressibility factor corresponding to T and P (If thl* factor la not avallaola. compressibility correction can too lilaly Ignored by ueing a valua of Z -- l-01. Cn or vapor flow constant. Salad fn* ubfr. pica J.04 using ratio of specific heat "V* of vapor or (as being comldarad. a -- Ratio Of apacillc haatm. Cp/Cu- tM* valua is constant'for an Idaal (aa. If this ratio Is not tno. IN* value k 1.001. C ~ IIS will raiutt In a sal* vatva u. IsenlroptC coefficient n may fra usad Instaad of h. *0 -- Liquid capacity corraction factor <r ovarprcssvraa tosser than IS% Irons curva on page 3.0/. Kfc .. Vapor Or gat flow correction factor far conlltnl back pcasturcs above cdtical praisura from curva on pifa J.06. Kv Kv h. Vapor or (a* flow factor tor variable back preaaurv* from curvu on page J.0i. Applta* to BalanSaal valvos only. ~LV)vM flow factor for variable back prasswras from curvo On paga 3.04. ApplU* to O atariSa at vatws only. Kui _ Sufrar Naat corrocdon (actor from tafrla on pa|a 3-07. K. Ke _ VHcoarty correction factor tiom curva on pa(a l.Ot. _ Coefficient o( dltcharga (OSS) for air.'itaam. vapor*, gaaas; 0.64 for liquids; for use in theio formufal). v -r . c'. ' #t "'r . a ... v< ' 1 ' NGC 01612 JANUARY IQ. 1966 WASTEWATER STRIPPING COLUMN 1. This incident has been reviewed with all engineering, operational, and contractor personnel involved. STATUS Complete 2. This incident will be reviewed with all other personnel in the Polymerization area and all emergency steps involving cooling water failure will be reviewed. Complete 3. The cooling water valve actuators will be modified to indicate the proper closure direction. Complete NGC 01613 I^Goodrich INTER-ORGANIZATION CORRESPONDENCE TO R. J. Grahek FROM D. L. Rys SUBJECT Fiao POINT OR DPT. & BLDG. NO. Henry FIELD POINT OR DEPT & BLDG. NO. Henry VINYL CHLORIDE RELEASE FROM BLOWDOWN TANK #1 DATE YOUR LETTER DA IE THIS LETTER 6/16/87 REDACTED SUMMARY OF INCIDENT On Saturday, June 6, 1987 at 2000 hours, the 3" rupture disc on Blowdown Tank #1 burst and vented Blending resin slurry and VCL gas to the atmosphere. Blowdown was stopped immediately and valving was changed to the secondary rupture disc system. Venting time was limited to approximately 2 minutes, resulting in 201 pounds of VCM released to the atmosphere. There was no equipment damage or personnel exposure to VCM. BOARD OF INQUIRY REPORT The Board of Inquiry was conducted on June 7, 1987 at 0700 hours wit.h the following personnel in attendance: Kevin Buiiinston Larry Loeboch Ron Moore Dave Rys B Shi ft Charge Operator B Shift Temporary Foreman D Shift Downstairs Recovery Operator D Shift Foreman Sr. !ocess Engineer D Shift Upstairs Recovery Operator Geon Resin Manager NARRATIVE '* Geon 213 Blending resin charge <*339 1 was initiated in PoLy #1 at 1400 hours on June 6, 1987 as per standard charging procedure. No abnormalities occurred. The reaction temperature was adjusted once to achieve specification limits. Five hours after reaching reliction temperature, the temperature and pressure began increasing. At this time, the cooling water flow to the reactor jacket and baffles was at maximum rate. The water rates on the quick fill and seal flush systems were adjusted to maximum. The temperature and pressure continued to increase. NGC Olf,j4 -2- At. 149 F. reactor temperature and 165 psig reactor pressure the operator notified the Foreman of the problem. After evaluating the situation, the decision was made to drain the charge to Blowdown Tank si for recovery of the unreacted VCM, without adding shortstop. The operator notified downstairs recovery to assure that the Bio*-down Tank was empty. Upon receiving confirmation, the charge was drained 5.75 hours after reaction temperature had been reached. Shortly thereafter, the 3" rupture disc on the Blowdown Tank ruptured. After ascertaining the source of the venting, the drain valve was closed and then the valve on the 3" vent line was closed. Over pressure protection of the Blowdown Tank was maintained by a second set of 4" rupture discs. After conditions had stabilized the charge was completely drained to the Blowdown Tank and recovered without further incident. Both sets of rupture discs were removed for inspection. Further charging was suspended until the Board of Inquiry was held. FACTS SURROUNDING THE INCIDENT 1. *2 chiller unit was shutdown on Friday, June 5, 1987 due to a freon leak in a newly installed stainless steel expansion joint.. Kith only one chiller operational, LoSope charge rates were decreased while maintaining Suspension and Blending charge rates. 2. Cooling wnt.er temperature had increased to 75F. Friday night but had decreased and stabilized at 60F. by 0700 hours on Saturday morning. At 1530 hours Saturday, the temperature increased to 68F. and continued to rise to 80F. at 1800 hours. The one chiller was operating satisfactorily but could not handle the Load. ' 3. When the temperature began to increase on Saturday, there viere II polys calling for cooling. Three 110X500 charges were recovered early. I. Standard operating procedure will call for the addition of BUI' at t.he initiation of a charge to control the reaction if t.he cocling water temperature is above 70 F. In this-; case, the water temperature at. that time was stable at 60 F. and no BUT was added. n. Normal reaction conditions for (icon 213 are as follows: Reactlon temperature React, i on pressure Ri *ac t i on t \ me I !; v.n'h u:n pressure 113+ 1 F. 115-150 psig i riours an ps-g NGC OV''5 -3- fc> The Blovalown Tank is equipped with 2 sets of ruptur-e discs. There is a dual set of 3" discs rated at 1*13 psig at 143 F. with a manual valve located between the tank and the discs. There is also a dual set of 4" discs rated at 172 psig at 165wF. without a valve. This design was installed as part of the `Blending resin expansion in 1983. 7. There is no scheduled replacement of the rupture discs on the BLowdown Tanks. The discs on Blowdown Tank *1 have not been changed since original installation in J983. The removed rupture discs were inspected for any abnormalities. The 3" discs were ruptured due to over pressure. The 4" discs were intact and showed no abnormalities. There was a good deal of rust above the top 4` disc. 8. The recovery rate on Blowdown Tank *1 is controlled to minimize the amount of carryover to the compressor system during Blending resin manufacture. 9. The Blowdown Tanks do not have full range pressure recorders or high pressure alarms. CONCLUSION'S The reaction rate on Blending resin charge *3391 could not be controlled due to the high coaling water temperature. The reaction rate at the time of draining to the Blowdown Tank was greater than the ability to recover the unreacted VCM. The temperature and pressure continued to increase until the burst pressure of the 3" rupture disc was reached. CORRECTIVE ACTION 1, The decision was made in the meeting to shortstop any abnormal Blending resin charge prior to transferring t.o the Blowdown Tank. Z. Update our procedures for handling all abnormal. PVC resin charges. To t>e reviewed in the Foremen's Meeting scheduled for 8/12/87. (JPG - 6/30/87) 3. Investigate the criteria tor BHT addition to Blending resin charges. (RDM - 6/30/871 4. Determine a frequency for replacing rupture discs on the Tanks. (Jlxi - 6/30/87 ) ! he IkjMoki ( disc Will tit- sent nut ar.d tested Tor hurst pressure :o determine !t' weakenin'! had. cx-cur- el , ! \J8 - 6/80/8/ ) NGC 01616 -4- 6. Determine the design criteria tor the rupture disc assemblies on Blowdown Tank #1. (DLP - 6/30/87) 7. Install full range pressure recorders and high pressure alarms on the Blowdown Tanks. (WHL - 8/30/87) 8. Review our philosophy on charging during abnormal conditions. Production priority must not come before safety, environmental concerns and quality. {Dili - 7/30/87) 9. Review this incident with ail personnel in the Shift Meetings. (Foremen - 7/30/87) DLR:bh attachments See Distribution Sheet D. L. Rys NGC 01617 BLOWDOWN TANK 1 VINYL RELEASE : ( Volume of BDT = 4,990 Gal. Slurry Level 9 time of Rupture Disk Failure = Temperature = 149 *F C 609 *R ) 63 X ,, Pressure on Reactor when charge dropped to BDT = 165 psig. { PI > Pressure on BDT when valve below Rupture Disk closed = 80 psig. < P2 > 4,990 Gal. x ( 1 - 0.63 ) = 1,846 Gal. 1,846 Gal. / 7.481 Gal./ cu.ft. = 246.8 cu.ft. (PI - P2) * V ------------------------------- = N RtT cu.ft.tpsi R = Gas Constant - 10.73 ------------------------- 1b.mol el0R ( 165 - 80 )psi x 246.8 cu.ft. ------------------------------------------------------------------------------- ( 10.73 ) x 609 aR = 3.21 lb.moles VCM 3.21 lb.moles VCN t 62.5 lb.VCh / lb.moles VCfl = 201 lbs. VCN NGC OH. 18 NC.C (I16i<; 1 ^\ L^ajs,^cp BF Good rich Goon Vinyl Division Spocislly Pofymor* l Chamlcsts Division R.R. 1. Bok IS Hanry. Illinois 61537 309364-2311 CERTIFIED MAIL NO, P 299 839 S33 ft.J. Grshak Plnt Miuigr June 16, 1987 Illinois Environmental Protection Agency Division of Air Pollution Control 5415 North University Peoria, IL 61614 Attention: Mr, Richard Jennings, Regional Manager SUBJECT: EMERGENCY RELIEF VALVE DISCHARGE REPORT Dear Mr. Jennings: In accordance with the requirements for 40 CFR 61.65 (a) of the National Emission Standard for vinyl chloride. The BFGoodrich Company is reporting an emergency relief valve discharge at its Henry, Illinois facility. Should you have any questions concerning this report, please contact Mr. Kenneth J. Willings, Manager Safety, Health, and the Environment* at (309) 364-2311, extension 214. Sincerely THE BFGOODRICH COMPANY Geon Vinyl Division rdm cc: Chris Romaine Robert J. Grahek Plant Manager NGC 01620 THE BFGOODRICH COMPANY ' HENRY. ILLINOIS VINYL CHLORIDE RELEASE REPORT (40 CFR 61.65 (a) ) Type of Release: Day/Time of Release: Vinyl Chloride Released: ource/Nature: Rupture Disc Saturday, June 6, 1987; 2000-2002 hours 201 lbs. (See attached calculations). Emergency relief of pressure in No. 1 blowdown tank. > <> NC.C 01621 Actions Taken Prior to Discharge to Prevent Recurrence: 1. New operators are given several weeks of on-the-job training wit experienced operators. 2. Written standard operating procedures are provided to the operators, * 3. Foreman supervision is provided. 4. Training sessions are held on the vinyl chloride standard (40 CFR Par 61, Subpart F) and Company standard operating procedures annually t> ensure compliance. 5. There is a scheduled maintenance and replacement program for rupturt discs. Emergency Discharge - Chronology of Events: 1. On Friday, June 5, 1987, the No. 2 Chiller unit serving the polymerization building was taken out of service for maintenance. 2. The cooling water temperature stabilized on Saturday, June 6, 1887 and was within the temperature range specified in the standard operating procedures. 3. A blending resin charge was initiated in polymerizer No. 1 at 1400 hours on Saturday, June 6, 1987. 4. At 1900 hours, the polymerizer temperature and pressure began to increase. Cooling water flow was Increased to the maximum. 5. The pressure continued to increase and the charge in the polymerizer No. 1 was equalized to the No. 1 blowdown tank at 1945 hours on Saturday, June 6, 1987, The No. 1 blowdown tank had been valved to the vinyl chloride recovery system prior to equalizing polymerizer No. 1 to the blowdown tank. This is standard operating procedure for controlling over pressure reaction of blending resins and has always been successful prior to this event. At 2000 hours on Saturday, June 6, 1987, the primary 3** dual rupture discs on blowdown tank No. 1 burst. Polymerlser No. 1 drain valve was closed to No. 1 blowdown tank. The valve under the 3** dual rupture disc assembly was closed to stop the venting, and the secondary 4" dual rupture disc assembly maintained the vessel pressure. Polymerizer No. 1 was completely drained to No. 1 blowdown tank once sonditionz stabilized and was recovered without further incident. NGC OU>22 Causa of PlarhAr^: 1. The reaction rate of the blending resin in polymeriser No. 1 could not be controlled with maximum cooling water flow thus requiring draining of the polymeriser to No. 1 blowdown tank for recovery. 2. The rate of unreacted vinyi chloride being transferred into the blowdown recovery 147 pslg reached. tank exceeded the system. Thus the burst pressure of recovery capacity of the vinyl chloride pressure continued to increase until the the primary 3" dual rupture discs was Corrective Action to Prevent .Recurrence*. 1- The incident will be reviewed with all operating personnel in the Polymerisation area. 2Standard operating procedures will be modified to require the addition of the reaction shortstop to any abnormal blending resin charge prior to draining to the blowdown tank for recovery. 3. The preventative maintenance program for rupture disc replacement will be reviewed and modified as necessary. o NGC 01623 BLOWDOWN TANK * I VINYL RELEASE * Volume oi DDT 4,990 Gal. Slurry Level D time of Rupture Disk Failure 63 X Temperature * 149 *F ( 609 *R ) Pressure on Reactor when charge dropped to BDT 165 psig. i PS > Pressure on BOT when valve below Rupture Disk closed *= 80 psig. C P2 > 4,990 Gal. x < I ~ 0.63 ) - 1,8*6 Gal. 1,8*6 Gal. / 7.481 Gal./ cu.ft. - 2*6.8 cu.ft. (Pi - P2> IV --------------------------------> N RtT cu.ft.tpsi R = Gas Constant 10.73-----------------------lb.molet*R < 165 - 80 )psi x 2*6.8 cu.ft. -------------------------------------------------------------------------------- < 10.73 ) x 609 *R c 3.21 lb.moles VCH 3.21 lb.moles VCH I 62.5 lb.VCH / lb-moles VCH = 201 lbs. VCH >Gt JUNE 6. 1987 ELOHECfrM TANK NO. 1 1. The incident will be reviewed with all operating personnel in the Polymerization area. 2. Standard Operating Procedure will be modified to require the addition of the reaction shortstop to any abnormal blending resin change prior to draining to the blowdown tank for recovery. 3. Preventative maintenance program for rupture disc replacement will be reviewed and modified as necessary. STATQS Complete Complete Complete NGC 01625 BFGoodrich Tr>e BfGoodrtch Ccxnpony Chomicol GfOvo 009-364.2311 CERTIFIED MAIL HO. p 299 839 575 November 25. 1987 Illinois Environmental Protection Division of Air Pollution Control 5415 North University Avenue Peoria. IL 61614 Agency Attention: Mr. Richard Jennings, Regional Manager Subject: Emergency Relief Valve Discharge - Paragraph 61.65 (a) of the National Emission Standard for Vinyl Chloride Dear Mr. Jennings: Pursuant to 40 Standard for Vinyl facility in Henry, valve discharge. letter. CFR 61.65 (a) of the National Emission Chloride, the BFGoodrich Company, at it's Illinois is reporting an emergency relief The discharge is detailed in the following At approximately 10:40 hours on November 20, 1987 the Waste Water Stripper, the Waste Water Hold Tank, and APRS "Burp" Tank safety relief devices discharged vinyl chloride to the atmosphere. The quantities released were: * Waste Water Stripper - 938 lbs (1) Waste Water Hold Tank - 1732 lbs U> APRS "Burp" Tank - 559 lbs. (1) (1) See Calculation Statement The following is a chronology of events leading to the discharge; On November 20, 1987 at approximately 10:00 hours the low pressure alarm for cooling water sounded. The operating personnel responded to the cooling water supply area and tried to determine the reason for the low pressure alarm. The loss of cooling water to the polymerization building resulted in an increase of the pressure on the recovery system and a loss of control of the batches in reactors. All polyraerizers were controlled following the emergency procedures in place. The increased recovery pressure resulted In the over pressure of the waste water stripper, the waste water hold tank, and the APRS "Burp'' Tank. NGC (11625 The area personnel responded to this condition and stopped all feeds and steam to the waste water stripper. They also switched the waste water hold tank safety relief device to the standby safety relief device. These actions Immediately stopped the release and over pressure conditions. Cause of Discharge: Upon review of the Incident it was discovered that the loss of cooling water to the Polymerizatlon Building was caused by the chilled water system failing and the area personnel were unable to switch to the cooling tower system due to the valve actuation not functioning properly. The failure of the cooling water system resulted in the high pressure on the recovery system. BFGoodrlch has taken the following ateps Prior to dlac-harga. to prevent occurrences: 1. Rupture discs which are in place to protect safety relief valves, are replaced after a specific length of service to protect their integrity. 2. Relief valves are removed and pressure checked as part of a preventative maintenance program. 3. The operator and area supervisors responsible for the operation of the equipment have been trained with respect to procedural steps for controlling releases and emergency conditions. 4. The actuators on the cooling water valves were modified to indicate open/closed position. Corr.&cJJLy.e Action to. -Brc^ent_tlie. ..Recurr&nggA 1. This incident will be reviewed with all operational personnel in the polymerization area and all emergency 3tep3 involving cooling water failure will be reviewed. 2. The steam supply to the waste water stripper system will be reviewed and modified to provide an automatic shutoff uhen a high pressure condition is determined in the 3tripper. 3. A review of the feed system to the waste water stripper holding tank and stripper is to be done, and modifications recommended from this review to prevent over pressuring the system will be implemented. NGC 01627 4. The cooling water supply system will be reviewed and modifications will be made to ensure that the back-up cooling water supply can be actuated. Sincerely, rdra/S280 Kenneth J. Hillings Sr. Safety/Environmental BFGoodrich Company Henry, Illinois Engineer > NGC 01628 VCL DISCHARGE FROM WASTE WATER STRIPPER SAFETY RELIEF VALVE METHOD FOR DETERMINING THE AMOUNT OF VINYL CHLORIDE FACTS: 1. Approximate duration of the release - 5 minutes 2. The discharge was approximately 84,3% vinyl chloride Calculation: A = _____-/Z 1. 175 CKa P Kb V = A f 1. 175) CKd P Kb /G SI fl (See attached Farris Safety Relief Valves calculation for vapors and gases.) V = Volume (SCFM) = ? A = Orifice = 1.287 sq, in. G = Specific Gravity = 1.92 of the Vapor in the column T = Temperature - 670R Z = Compressibility Factor = 1.0 C ~ Gas Constant = 356 Kd = Coefficient of Discharge =' 0.953 P - Relieving Pressure 89.7 psia Kb - Vapor Flow Correction Factor = 1 V = (1. 287 )(1. 17 5) (356M . 953 M89.7 ) f n ( ^1792 ) (^/~670^1u ( ^TTo ) = 1278 SCFM Q = Quantity of VCL released Q = 1278 SCFM x 5 minutes x ft Moles x 62.5ft x (0.843) 359 SCF ft MOLE Q = 938 lbs NGC 01629 VCL DISCHARGE FROM WHS HOLD TANK SAFETY RELIEF VALVE Bas is 1. Two inch schedule 40 pipe - 2.06 in ID 2. 100 psig tank pressure during discharge 3. Four minute discharge time 4. Sonic velocity at discharge due to high section of pipe. 5. Tank temperature = 150F 6. Ideal gas law assumed ziP/P' and short V 3 = 68.1 v/kp*'v where V 3 - sonic velocity ft/sec k - ratio of heat capacity Cp/Cv (1.3) P = Pressure is psia V = Specific Volume W = M2. 0.0509 V where W = flow in lb/hr V = velocity ft/sec d2 = pipe internal diameter in2 for VCL at 150*F V = (359 ft.3 \ (6IO0R) =7.12 fit*/lb (62.5 Ib/roole ) (492R ) Vs = 68. 1 /(1. 3) { 114. 7 ) (7 . 12 ) - 2219 ft/sec W= (2219)(2.Q621 (.0509)(7.122) = 25.976 lb/hr (4/60 hr)(25.976 lb/M) 1732 lb VCL METHOD FOR DETERMINING THE AMOUNT OF VINYL CHLORIDE BURP TANK RELIEF VALVE RELEASE Assumption - 30 second release - Vapor in 100% VCL Vapor temperature = 150F r 610R Calculation of vent stream flow: Z = Compressibility Factor - 1. 0 V = Volume scfm = ? A = Orifice = 4.34 sq. inch G = Specific Gravity = 2. 16 C = Gas Constant - 356 Kd = Coefficient of discharge = 0.953 P = Relieving Pressure = 134.7 psia Kb = Vapor flow correction factor = 1 V = LA) (1. 175)fC)(Kd) (P) (Kb) JG yT(oR) Jz Specific Gravity G = 62.5/29 - 2.16 V (4. 34) (1.JLI.5) L 356 ) f. 9531.1J.34. 7) (1) 6418 scfra , '2. 16 v/FTo /\ Q 559 lb VCL (2) (359) NGC 01631