Document Vj4OOO5JbkEGbvnoV3mVpordw

(conoco) Interoffice Communication To From Date Subject OSHA-Engineering and Work Control Plan File J. Paul Warner April, 1980 UPDATE OF ENGINEERING AND WORK PRACTICE CONTROL PLAN Attached is an update of the Plant's engineering and work practice controls plan for complying with the 05HA VCM Exposure Standard. All work practice controls have been implemented and significant progress has been made on most of the engineering controls. The start-up of the EPA compliance equipment has significantly reduced VCM levels in the Plant. Completion of the projects to improve ventilation in the V-40 area should further reduce levels. However, we will have to rely on breathing air to limit VCM exposure from some exposure sources. J. PAUL WARNER Senior Process Engineer Conoco Chemicals Company Oklahoma City Chemical Plant Approved: RTfant Manager tonoco Chemicals Company Oklahoma City Chemical Plant JPW-spt Attachment CC: JF, AWS, WHN, RP, JBE, MLA, DWH, JDO, DMW, REB, DPB, OLE, JDG, DWT, GHF CCR 00001049X Exposure Source 1. Residual monomer in slurry and resin. ENGINEERING AND WORK PRACTICE CONTROL PLAN FOR COMPLIANCE WITH OSHA VCM EXPOSURE STANDARD CONOCO CHEMICALS OKLAHOMA CITY PVC PLANT APRIL, 1980 o)Work Practice Controls la. All batches are steam stripped to remove unreacted VCM from the slurry prior to dumping the slurry to the blend tanks. Tests show that the slurry contains less than 220 PPM VCM after steam stripping. Engineering Controls la. Preliminary design work is in progress to replace the existing dump system with an enclosed system. IN o o g o ^ o lb. After the slurry is dumped from the reactors to the blend tanks, the slurry is stripped with air to further reduce the VCM concentrations. Tests show that the VCM content of the dried resin is below 5 PPM when the combination of steam and air stripping is used. lb. A design for removing the blend tank vents from the process area has been developed and included in the 1980 Capital Budget. 2. Obtaining and handling samples. 2. Wear personnel protection equipment which meets OSHA standards when VCM samples or reactor samples are obtained. 2. A design fori a closed reactor system is being developed. VCM from the samples will be routed to a control system. 3. VCM railcar. 3. Wear personnel protection equipment which meets OSHA standards while connecting and disconnecting tank cars. 4. Chemical wash screen. 4. Steam stripping of all batches has 4. A new exhauster system has been reduced the possibility of exposure installed, greatly reducing the from this source. possibility of exposure from this source. Note (1): As part of the work practice controls, two Honeywell VCM monitors sample twenty locations in the process and tank farm areas to detect VCM leaks. Exposure Source 5. Reactor rinse after dump 6. Flexible hoses, pipe unions and flanges, valve stems and swivel joints in VCM service. ENGINEERING AND WORK PRACTICE CONTROL PLAN FOR COMPLIANCE WITH OSHA VCM EXPOSURE STANDARD CONOCO CHEMICALS OKLAHOMA CITY PVC PLANT APRIL, 1980 Work Practice Controls (i) 5. Transfer the effluent from the initial water rinse after reactor dump to the dump system. 6. At least once per month, flexible hoses, pipe unions and flanges, valve stems and swivel joints in VCM service are checked for leaks. Leaks are repaired on the spot if possible and are put on the maintenance schedule where they can not be repaired immediately. Engineering Controls m O' o o oo C o u 7. Opening and working on equipment or piping which may contain VCM. 7a. Before opening, VCM is removed from equipment or piping to the lowest practical level by flushing, purging and/or evacuation where possible. 7b. Wear personnel protection equipment which meets OSHA standards when open ing equipment or piping which may contain VCM. 7a. A project for installing a large exha/uster on the roof of the V40 building has been submitted as part of the 1980 capital budget. This will improve ventilation in the V40 area when equipment is being worked on. 7c. Before commencing repair work, measure the VCM concentration in or near the opened equipment or piping to determine what protective equipment is required and if further VCM removal is necessary. 8. Dump screener 8a. Wear personnel protection equipment which meets the OSHA standard if the VCM monitors detect VCM concentrations in the area around the dump Sweco. 8a. A project for installing a larger exhauster system is included in the 1980 Capital Budget. 9. V-20 seal water filters 9. Wear personnel protection equipment which 9a. meets the OSHA standard when working with the filters. Note (1): As part of the work practice controls, two Honeywell VCM monitors sample twenty locations in the process and tank farm areas to detect VCM leaks. A design to reduce exposure from this area is being developed. (conoco) Interoffice Communication to John Friend From K. L. Fogg Date November 26, 1979 subject OSHA COMPLIANCE PLAN REVIEW On November 25, 1979, Plant personnel performed an OSHA compliance plan review to identify areas where improvements are required to keep this facility in compliance with OSHA guidelines. Those areas are: 1. Fire Protection - Additional work is required to provide rescue capability, "via hose line method, in the V-40, V-20, and tank farm areas-. Expansion of the fire water loop in the tank farm area is- to be evaluated by Plant personnel. 2. Chemical Exposure Abatement - Work continues to identify VCM exposure sources and to reduce or eliminate them as required. A reassessment and redefinition of the regulated areas should be made to insure that these areas are correctly defined. The Plant will perform a toxicity risk assessment on any new chemicals introduced into this facility. 3. Safety Guidelines - A comprehensive safety manual will be published to provide employees a reference source for safety and health related information. 4. Emergency Training and Review - Emergency procedures are being reviewed and emergency training is being re-evaluated. 5. Maintenance Eguipment Inspection - A program for inspection of maintenance equipment is being developed. 6. Area Inspections - Walking/working surface inspections and accident potential surveys will be performed annually to identify potential hazards in the Plant. 7. Respiratory - The Plant will re-evaluate the respiratory protection program and make required changes to insure compliance with OSHA guide!ines. Should you require any additional information, please contact me. KEITH L. FOGG Safety and Health Director KLF-dh CCR 000010494