Document XR2ZX1w080335R5OL6mXRmELJ

VCM GENERAL TRAINING GUIDE WHO: All employees who work In the VCM Regulated Area WHEN: At the employees' Initial training and annually thereafter I. Nature of Health and Safety Hazards A. Chronic Exposure Hazard 1. B.F. Goodrich, Firestone, and 6oodyear reported several deaths of VCM workers In the early 1970's from a rare liver cancer (angiosarcoma). 2. Tests with rats exposed to ^^lpj^VCl fhron1 cal 1/ did develop angiosarcoma. J 3. In 1975 OSHA established a permanent .standard/or VCM exposure of fl-0 ppm fpr an S-hour time lighted average. A celling exposure of 5 V ppm W, * ,, l5 minutes A was also established. B. Acute Exposure Hazard 4 1 fa 9h. concentretlonxjisSlM' anariesthetfc* and~3rSrs1 nesT"ind unconsciousness may.pccuiv. Remove the victim to uncontaminated atmosphere as soon as possible and obtain medical help. 2. liquid VCM on the rein can cauj^Tr^e b^rns and be"absorbed T ^J^?lLthe.s)c1n. Obtain medicalhelp. C. Safety Hazard 1. VCM Is highly flanmable with a flash point of -78C. Flanmablllty Halts are between 3.6X VCM to 33* VCM In air. To fight a fire, valve off source and allow to burn out. 2. VCM will totally vaporize at ambient temperatures. It exists at high pressure in lines and vessels. Foam can be used to decrease vaporization and water spray to disperse cloud. II. Applicable VCM Regulations A. OSHA 1910.1017 (Personnel protection) B. EPA National Emission Standard for Vinyl Chloride Subpart F 61.60 (Control emissions) C. Louisiana DEQ EmissionStandard for Vlityl Chloride 77.0 (Control emissions) Ff>c 000412 " -2- III. Personnel Protection A. To target the area where VCM exposure could be most likely. A VCM regulated area was established and access limited to authorized personnel with a need to enter the area. Map Is attached. Records must be kept of the time spent by each person In the regulated area. Safety Policy 125 established this area. B. Respiratory Protection 1. To afford protection against the cancer hazard due to chronic exposure, the following limits were set: (a) 0.5 ppm - action level above which engineering efforts must be made to decrease the emissions. (b) 1 ppm - 8-hour time weighted average (c) 5 ppm - 15 minute celling concentration 2. The following types of respiratory protection must be used: (a) 5 ppm or above - full face mask with VCM cannlster (b) 25 ppm or above - self contained breathing apparatus with supplied air (c) Note that the Comfo II respirator Is not approved for VCM exposure. See Safety Policy #16. C. Area and Personnel Monitoring 1. To check the effectiveness of emissions control and requirements for respiratory protection periodic personnel monitoring must be done. FPC does this by placing the little VCM specific tabs on ersonnel for eight hours. Anyone found to be over the 1 ppm rImlt triggers an Investigation as to the cause and a letter must be sent to the person and placed In Ms personnel file as to cause and correction. 2. To help control emissions, there Is a requlreaent for VCM specific area monitors. The VCM has two monitors with 10 points each. These points are located In area where VCM leaks may occur and at the perimeter of the regulated area to help locate leaks. The monitors print out In the VCM control room with alarms at 5 and 10 ppm. D. Medical Surveillance To monitor the health effects of VCM exposure, there Is a requirement for annual physical examination and blood test for personnel working with VCM less than 10 years and semiannual for 10 years and over. These records must be kept 20 years. Anyone found not suitable can be banned from VCM areas. FPC 000413 I 3 E. Specific nature of operations that could lead to VCM exposure 1. Doing maintenance on VCM containing vessel or line after the line or vessel has been vented or purged to the required 21 or less. 2. Drilling rebollers from the residue left In the tubes. 3. From the solids In the quench pump strainers etc. 4. From leaks. F. Emergency Procedures (See attached sheet) IV. Summary of VCM Emission Regulations A. Any vent stream containing over 10 ppm of VCM must be sent to a control device. B. Any vessel or line having a volume of 25 gallons or 3.34 ft* must be vented and purged to less than 21 VCM before opening to the atmosphere for any reason. C. There shall be no relief valve discharge except nature diasters and other reasons that cannot be avoided by taking preventive measures (electrical outages* operator error* valves leaking through* most equipment failure* etc. are not acceptable reasons). D. The vent from the Oxy .reactor Is limited to 0.02 LB. VCM/100 LB. of EDO produced In Oxy. E. There shall not be any manual venting of VCM. F. Pumps In VCM service must be seal>les$ or have double mechanical seals with the space between seals conducted to a control device. G. A weekly leak detection survey must be made. H. A VCM area monitoring system must be set up and dally span and calibration done. 9/3/87 FPC 000414 Otragtay ft Miller, Inc FPC 0 0 0 4 1 5 EMERGENCY PROCEDURE VCM RELEASE 1. Check wind direction. 2. Alert Patrol and trip warning system. a. If wind from southwest, west or northwest, have Patrol advise Cell Assembly, Caustic-Chlorine and Powerhouse North to extinguish all flames and spark producing devices. b. If wind 1$ from southeast or east and VCM Is drifting toward cracking furnaces or incinerator: 1) Nave Guard block off entry and exit roads using any material available - safety tape, empty drums, etc. 2) If danger of Ignition is Imminent, shut down and cool furnace with steam snuff and check for other ignition sources. 3) Trip Incinerator line and leave blower running. c. If a vapor cloud 1$ travelling toward Kaiser and exposure to a heavy cloud concentration Is Imminent, have Patrol notify them of danger and advise extinguishing all Ignition sources. d. If wind 1$ from north or northest, notify Docks to eliminate all Ignition sources, 3. NOTIFY ALL PERSONNEL NOT REQUIRED FOR CONTINUED PLANT OPERATION AND/OR CONTAINMENT OF LEAK TO EVACUATE AFFECTED AREA. 4 Put on respiratory protection according to following: Expected VCM Concentration (1) Not over 1.0 ppm (2) Not over 25 ppm (3) Greater than 25 ppm Required Apparatus Chemical cartridge respirator with organic vapor cartridge. Gas mask, full face piece with acid gas, organic vapor cannlster. Self-contained type air pack with full face piece. 5. Put on protective clothing If danger of liquid or heavy vapor contact to skin exists. Required Clothing: ft Rubber rainsult. (3) Rubber boots and gloves. 6. Make every effort, CONSISTENT NITH SAFETY, to shut off the source of the release. 7. Use water spray to help disperse heavy vapor clouds and melt accumulations of frozen VCM and water. 8. Notify VCM Superintendent. 9. When situation Is corrected, alert Patrol to give "All Clear.* Revised 6/23/86 Kefjy Serlo r FPC 000416