Document YDkxKJ9zeaVn2BXNEa7wRmGRK

DOW CHEMICAL U.S.A. August 1, 1985 TEXAS OPERATIONS FREEPORT. TEXAS 77541 Mr. George Wirth Environmental Protection Agency 401 M St. S.W. Washington, D.C. 20460 RE: AIR TOXIC-SITE GUIDANCE MEETING, JULY 23, 1985 Dear Mr. Wirth: Attached is the proposed formula for determining the Relative Exposure Risk Potential Index for chemical containment systems I promised last week. As I understand, EPA is committed to providing community guidance in case of a large, acutely toxic chemical release by listing chemicals of concern. The dedication by you and the other EPA people to establish a very sound scienti fic basis for this guidance while insisting on simplicity is admirable. Toxicity alone is obviously not definitive enough. This proposed formula incorporates every factor you and the other EPA people brought up and dis cussed as being important considerations, and yet, is the simplest type formula mathematically possible. I would propose the EPA work with several chemical companies to determine an index on many of the chemicals proposed to be placed on the Site Review Guidance List. These indexes could be bracketed into Emergency Response Guidance catagories (i.e. 1 through 5) with a different level of response for each. A "1" might call for nothing more than general information on the chemical such as making available Material Safety Data Sheets, while a "S'* might recommend good communications, evacuation procedures, annual drills, vapor detectors with warning horns, etc. Certainly these different levels would be a positive basis for good rapport between industry and the community. After you formalize any proposal, it would be important to provide a response period for both public and industry to give you their comments. Hopefully, this type of index can identify those chemicals which can be of great concern to a community and also eliminate those which offer no threat. Probably 95% of chemicals handled in the industry would thus be eliminated from the list. Once again, I wouldlike to thank you for this opportunity to input during your strategy forming stage. The safety record of the Chemical Industry in the United States is one of the best of all industries and we certainly want to see this record continue. Sincerely, Gordon R. Miller Loss Prevention Engineering APB bj attachment AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY vvv 00001T521 Means More At Dow. CHEMICAL EXPOSURE RISK POTENTIAL INDEX Scope Provide a comparable index to measure the relative degree of risk to the public from loss of containment of any chemical. Introduction The impact on the public from loss of containment of any chemical is based on: (1) The acute toxicity of the compound, (2) The concentration that reaches the people, and (3) The length of time of exposure. Even though it is impossible to predict all of the factors that will control concentration and time of exposure (i.e. temperature, humidity, wind speed and direction), these two factors are equally as important as toxicity. The best one can do in determining the degree of risk from any chemical containment is to develop a simple, relative formula of those important parameters that can be measured and hold all other parameters constant. This will allow a Relative Risk Potential number to be generated which can be catagorized to determine a level of Emergency Response Preparedness needed. These catagories and proper responses will be developed later. Non-linear and logarithimic functions of gas dispersions have been ignored to maintain simplicity. Formul a R.V. X Q.F. X V.D.F. X P.P.F. - RISK POTENTIAL INDEX ------TOST"--X---- dt:----------------------------- Factor Identification 1. Tox = Toxicity - Select acute toxicity in ppm by preferred method. Suggest: IDLH = Immediately Dangerous to Life or Health in ppm; See NIOSH/OSHA Pocket Guide, 0 LC50 at 4 hour value. 2. R.V. = Relative Volatility - Vapor pressure of substance in mm of Hg at 25C divided by 760 mm. If above 760 mm, use 1.0. 3. Q.F. ** Quantity Factor - Amount of release in thousand lbs., i.e. 500 lbs. * 0.5, 1000 lbs. * 1.0, 10,000 lbs. = 10, etc. Do not use more than one decimal place. Use only amount that will become airborne in 15 minutes of a "worst" case release. 4. D. F. - Distance Factors - Determine distance from point of containment to point of public exposure concern in thousand foot increments; i.e. 500 ft. = 0.5, 1000 ft. = 1.0, 10,000 ft. * 10.0, etc. Do not use more than one decimal and round off to ^ne significant number. 5. V.D.F. - Vapor Dispersion Factor - The vapor density relative to air is proportional to dispersion, i.e. light density * rapid dispersion, heavy slow. Divide the molecular weight of the substance by 28.8 {molecular weight of air) and round to one decimal place, i.e. Ammonia * 17/28.8 = 0.6, Chlorine * 71/28.8 = 2.5, etc. 6. P.P.F. = Process Penalty Factors - Multiply by 2 for each factor: (1) contained above 10 psig; (2) thermally reactive with itself, water, air, or other common on site materials below 100C. (Includes loss nf inhibitors). yVV 0000l75 22 GRM/8-01-85 SKETCH PAD INFORMATION - FOR PLANNING ONLY Examples: * For a 2,000 lb. chlorine cylinder rupture at 1000 ft. distance: 1 x 2 x 2.5 x 2 = 10 = 0.4 2TT 1 2F For 50,000 lb. methyl isocyanate at 500 ft 0.5 x 50 x 2.3 x 2 = 115 = 11.5 20 x 0.5 lo For 5,000 'lb. ammonia spill at 5000 ft.: 1 x 5 x 0.6 x 2 - 6 - 0.0024 500 x 5 2OT GRM 8/01/85 00QO1T523 PRESENTATION TO THE VINYL CHLORIDE SAFETY ASSOCIATION BY ROBERT R. OUBRE - DOW CHEMICAL TAMPA, FLORIDA SEPTEMBER 13, 1985 VCM QUESTIONNAIRE SENT COPIES TO 37 COMPANIES US - 17 13 REPLIED NON US - 19 16 REPLIED RECEIVED 67 COMPLETED QUESTIONNAIRES B. F. GOODRICH ICI ENICHEM POLIMERI LIMBURQSE VINYL 12 10 7 5 SLIDE 1 wVV 00001^52^ QUESTIONNAIRE TOPICS STORAGE VESSELS - SIZE DISTANCE FROM POPULATED AREAS SAFETY FEATURES PROCEDURES - EMERGENCY PLAN INVOLVEMENT OF COMMUNITY PUMPS, LINES - SAFETY FEATURES LOCATION SLIDE 2 - U. S. COMPANY NON U.S. COMPANY VVV GOQ01T525 3. WHAT IS THE DISTANCE FROM TANK TO NEAREST RESIDENCE? WHAT IS THE DISTANCE TO NEAREST COMMUNITY? METERS <100 RESIDENCE COMMUNITY 2 0 101 201 501 1001 2001 200 500 1000 2000 5000 >5000 15 14 10 17 6 0 3 14 12 21 12 3 SLIDE 3 VVV 000017526 4. DOES THE PREVAILING WIND BLOW TOWARD A RESIDENTIAL AREA? YES -26 NO 39 OF THE 26 YESES - CLOSEST RESIDENCE = 150 M CLOSEST COMMUNITY = 150 M OF THE 26 YESES - AVER. DIST.TO RESIDENCE = 900 M AVER. DIST.TO COMMUNITY = 1300 M 5. HAVE YOU DONE ANY VAPOR CLOUD DISPERSION MODELING? YES - 23 NO - 42 35 % have done modeling OF THE 26 YESES IN "4" - 46 % HAVE DONE MODELING SLIDE 4 oV 00& 6 DOES YOUR PLANT HAVE AN EMERGENCY PLAN WHICH INCLUDES NOTIFICATION OR WARNING OF THE LOCAL COMMUNITY? YES 54 -----83% INCLUDE COMMUNITY IN THEIR PLAN NO 1 1 OF THE 26 PLANTS WITH PREVAILING WIND TOWARD COMMUNITY 88% INCLUDE COMMUNITY IN PLANS 7. HAVE YOU MADE ANY CHANGES IN YOUR OPERATION OR PROCEDURES SINCE THE BHOPAL INCIDENT? YES NO - 14 ___ ONLY 22% HAVE MADE CHANGES 63 SLIDE 5 vVV 000017528 8. TANK SAFETY FEATURES: A. IS TANK DIKED? B. IF SPILL OCCURS DOES VCM COLLECT UNDER TANK OR DOES IT DRAIN AWAY TO BASIN? YES - 54 _ 83% DIKED NO 1 1 UNDER - 40 AWAY - 23 C. WHAT SPECIAL FEATURES DOES DIKED AREA OR BASIN HAVE? HARD SURFACE COVERED PIT FOAM SYSTEM WATER SPRINKLER PUMP OUT PUMP STEAM CURTAINS 4 SIDES - 32% - 8% - 15% - 44% - 6% - 1 PLANT D. ARE YOUR TANKS SPRINKLED? SLIDE 6 YES NO 60 92% SPRINKLED 5 VVV 000011529 E . ARE FLAMMABLE VAPOR DETECTORS DETECTORS LOCATED WHERE SPILL COULD OCCUR? YES-39 60% HAVE DETECTORS NO-26 - F. ARE VCM AREA MONITORS LOCATED YES-42 - 65% HAVE AT TANKS (FOR MEASURING PPM)? PPM NO-23 - DETECTORS 86% HAVE EITHER FLAMMABLE VAPOR DETECTORS OR PPM DETECTORS OR BOTH 14% HAVE NEITHER G. DO LEVEL INSTRUMENTS HAVE REDUNDANCY (BACKUP)? YES-40 -- 62% ARE REDUNDANT NO-25 _ H. DO LEVELS ALARM AT A CONTROL BUILDING WHICH IS MANNED AROUND THE CLOCK? YES-52 _ 79% ARE AROUND NO-13 -- THE CLOCK I. DOES TANK(S) HAVE DUAL RELIEF VALVE? YES-51 -- 78% HAVE NO-14 DUALS 0. IS THERE A RUPTURE DISC UNDER THE RELIEF VALVE? YES-41 NO-24 63% HAVE RUPTURE DISCS OUTSIDE US PLANTS SLIDE 7 YES-22 50% NO-22 vw 000017530 K. HOW IS SPACE MONITORED BETWEEN THE RELIEF VALVE AND THE RUPTURE DISC? PRESSURE GAUGES - 61% PRESSURE SWITCH - 29% OPEN VALVES - 10% OTHERS 12% L. HAVE YOU ESTABLISHED A MAXIMUM FILL LEVEL FOR YOUR TANK? YES 100% RANGE 65% TO 98% AVERAGE 84.5% M. HAS TANK(S) BEEN INTERNALLY INSPECTED SINCE ORIGINAL INSTALLATION DATE? YES - 57 NO - 8 (1 NEW,2 DUE SOON) 88% TANK AGE <10 YRS 11 10-20 27 20-30 11 >30 2 34 1 ONE PLANT REPORTED EXTERNAL CORROSION TWO REPORTED INTERNAL PITTING (RECOVERED MONOMER) TWO REPORTED NEGLIGIBLE TO LIGHT CORROSION REMAINDER FAIR TO GOOD TO EXCELLENT CONDITION SLIDE 8 vvv OOOOl7531 N. ANY OTHER TANK SAFETY FEATURES? MANY REPORTED REMOTE OPERATED VALVES. TOTALIZING METER BACKS UP LEVEL. EXCESS FLOW CHECKS IN LIQUID LINES. 2 HLA'S SET AT 72% -85% - 95% (2 INST). HLS TRIPS PUMP, CLOSES VALVE. SAME FOR VAPOR ALARM. HLS OR HPS CLOSES FEED. LPS CLOSES PUMP SUCTION. INTERNAL BILLET VALVE. ALL VALVES CLOSE ON ABNORMAL CONDITION. AUTO CLOSE INLET WITH HLS. OVERPRESSURE OF TANK VENTED TO INCINERATOR. AUTO VALVE CLOSE WITH XS FLOW OR DELUGE TRIP OR HL. BOTTOM HALF OF SPHERE IN CONCRETE CUP. STEAM CURTAIN ON 4 SIDES. WATER INJECTION CAPABILITY FOR LEAK. VAPOR DETECTOR TRIPS SPRINKLER. REPEATERS ON LEVEL TRANSMITTER MAKE Dp CELL MORE RELIABLE BY ELIMINATING VCM FILLED LEG. SLIDE 9 oooo^Z 9 PUMPS AND AND LINES: A. ARE BOTTOM TANK VALVES EQUIPPED WITH REMOTE OPERATED VALVES? YE5 - 5^_ N 0 - 1 1__I 83% HAVE REMOTE VALVES B. DO PUMPS HAVE DOUBLE SEALS? NON-U.S C. ARE PUMPS SEALLESS? YES - 11 D. ARE PUMPS STEEL OR WROUGHT IRON CONSTRUCTION? SLIDE 10 YES -4^-, 81% HAVE DOUBLE SEALS NO -10--J YES -23NO -11 -- 68% HAVE DOUBLE SEALS NON U.S. -10 U.S, - 1 YES -6 0--, 92% HAVE STEEL OR WROUGHT IRON. NO - 5--I ooon*33 E. ARE PUMPS PROTECTED FROM DEAD HEADED CONDITION (RUNNING WITH DISCHARGE BLOCKED)? YES - 38-- 58% PROTECTED NO - 27_ PSV - 14 TS, FS, PS- 11 RECYCLE- 7 ELECT OVERLOAD- 1 OTHER - COMPUTER CONTROL PUMP START W/FLOW AND RECYCLE F. ARE PUMPS PROTECTED FROM BLOCKED IN CONDITION? YES NO - 27 -- 41% PROTECTED - 38 -- PSV -17 S- 3 G. ARE PIPELINES PROTECTED FROM LIQUID BLOCKED IN CONDITION? YES - 49 -- 75% ARE PROTECTED NO - 16 -- SLIDE 11 PSV -48 BY-PASS - 1 OQOOX H. ARE PIPELINES PROTECTED FROM HYDRAULIC SHOCK OF SUDDEN VALVE CLOSURE? YES 21 NO - 32% ARE PROTECTED I. WHAT TYPE GASKETS ARE USED IN PIPING? FLAT RING ASBESTOS - 56 RETAINED TYPE (FLEX ITALLIC) - 9 ONE PLANT USES- FLAT ASBESTOS ON 150 LB RETAINED ON 300 LB 10. TANK CAR LOADING/UNLOADING : 50 PLANTS A. IS THE T/C AREA PROTECTED BY SPRINKLER? YES -22 --. 44% PROTECTED NO - 28 -- B. ARE MONITOR NOZZLES INSTALLED? YES 34 70% HAD MONITORS NO 16 90% HAD EITHER SPRINKLERS OR MONITORS OR BOTH. SLIDE 12 Wy OOQ0ir535 C. ARE FLEXIBLE HOSES USED IN THE OPERATION? TEST PROGRAM USED? YES - 39 -- 78% USE HOSES NO - 11-- YES - 24 FREQUENCY - VARIES FROM EACH USE INITIALLY QUARTERLY YEARLY OTHER COMMENTS - ONE REQUIRED BY LAW TO TEST YEARLY AND WHENEVER DISCONNECTED TO 1.5 X MWP FOR 15 MIN. HOSE HAS TEST DATE TAG AND NUMBER. ONE HAS DOUBLE WALL HOSE WITH GAUGE ON OUTSIDE HOSE. ONE DOES ELONGATION TEST DURING PRESSURE TEST AND ELECTRICAL CONDUCTIVITY TEST. EVERY 6 MONTHS OR 1600 HOURS USE. MOST USE WATER PRESSURE TEST. D. HAVE YOU HAD A HOSE FAIL UNDER VCM PRESSURE? SLIDE 13 18% HAD FAILURES NO- 41--J 0000H53* E. HOW IS OVERFILLING OF T/C PREVENTED? THERE WERE 41 WHO LOAD T/C'S MAGNETIC FLOAT GAUGES - 15 TOTALIZING METER AUTO STOP (3 REPORTED TWIN METERS) - 10 COMBINATION OF LEVEL SWITCH AND DP CELL -9 LOAD SCALE -7 OUTAGE GAUGES -4 NON - U.S. PLANTS MAGNETIC GAUGE - 6 OF26 F. IS T/C AREA DIKED FOR SPILL CONTAINMENT? 11. DO YOU RECEIVE OR SHIP VCM BY T/T? YES - 18 NON U.S U.S YES - 7 -- 14% HAVE NO - 41-- 16 2 12. TOTAL RETURNS 65 SLIDE 14 NON U.S. - 44 U.S. - 21 V 0oO BFGOODRICH CHEMICAL GROUP SAFETY STANDARD SA-132 Revised: 10/29/84 Hazardous Material Storage Tank Standard Vinyl Chloride, Butadiene, Isobutylene Propane/Propylene/Butane, Ethylene, C-4 Vinyl Chloride Storage Tanks (Non-Process) Tank Valves and Nozzles I. All tank nozzles must have one of the following: 1. If Not In Use - Blank on the tank nozzle flange. 2. Vapor Service Nozzles - Ball valve mounted on tank nozzle flange. Valves in conjunction with relief valves will be covered in the relief valve section. 3 Liquid Service Nozzles (usually on bottom of tank, but would also include top entering dip pipes) - Remote air actuated ball valve mounted on tank nozzle flange. The following exceptions apply: (a) Tank nozzles with thermowells. Thermowells must be welded to the tank flange. (b) A manually operated ball valve that meets criteria in Appendix I, mounted between the tank nozzle flange and the air actuated ball valve is optional. (c) Fill lines into the VCM spheres at the VCM pi ants. These lines require a check valve that is ins pected annually and an air actuated valve that is ac tivated only by a remote air switch. Air actuators must include the following features: (a) Air to open, spring to close. (b) Contain section of burn-through tubing. (c) Valve, with air actuators mounted on them, bench tested for leaks before installed on tank and during vessel turnaround. wplO/155 Lq-1 VVV 000017538 VINYL CHLORIDE (CONTINUED) SA-132 Revised: 10/29/84 4. All tank nozzles must be a minimum of 1-1/2" pipe size. 5. No threaded connections should be attached to the tank. II. Valve requirements for Section I and a list of valves that meet these requirements are in Appendix I. III. Air actuated valves are required to have two local and one remote manual air switch. The two local air switches will 180 apart and located just outside the tank containment system. A LEL vapor detector, discussed later, will also operate these valves. be IV. It is required that all air actuated valves be cycled every two weeks. V. Excess flow valves may be used in conjunction with air actuated valves. Vapor Detectors I. LEL type vapor monitor with continuous sampling that alarms at a maximum of 25% and closes air valves and activates deluge system at 50% are required. II. Three LEL detectors will be located below tank and one at pump. It is not required that the LEL detector at the pump activate the deluge system. III. Vapor detectors should be tested and calibrated every four months. Fire Protection I. An automatic deluge fire water system is required for each tank. II. Vessel supports need either a deluge system or fire proofing with a 3 HR rating. Relief Valves I. One of the following two, (a) or (b), may be used for vessel pressure relieving systems: (a) A three-way valve with two relief valves. wpl0/1551q-2 VVV OOOOi7539 VINYL CHLORIDE (CONTINUED) SA-132 Revised: 10/17/84 (b) Two-way valves, multi-noz2le with "Castell" locking system. See Engineering Standard #ST-528 for relief valve design and installation requirements. II. Manual valves below relief valves must be mounted on tank nozzle flange. Valves for this service must meet the requirements in Appendix I. III. Each relief valve will be bench tested every three years. IV Rupture discs will continue to be used per the EPA Regulations. V Sizing of relief valves must adhere to BFG Policy ST-1317. Tank Internal Inspection I.Storage tanks will be inspected a minimum of once in five years; tanks in rework VCM service every two years. II. The minimum inspection requirements are: (a) Visually inspect for internal corrosion, especially around flange welds, thermowells, level indicators, etc. (b) U1trasonically test wall thickness in several representative locations. (c) Record results of each inspection and thickness measurement and compare with previous inspections. III. Connecting piping will be inspected at the same time tank is inspected. wp!0/1551q-3 VVV QOGOl7540 ADDENDUM HAZARDOUS MATERIALS STORAGE TANKS SAFETY STANDARD SA-132 To be used for existing installations and specific applications only. (1) Existing high performance butterfly valves, manufactured by Posi-Seal, may be used in vinyl chloride service at Calvert City in place of the ball valves required by the standard. When these valves are replaced, however, they must conform to the standard. (11/15/82) (2) Existing six inch pipe elbows may remain between the tank nozzle flange and the air actuated valve on the butadiene tanks at Port Neches. These elbows must be inspected every year, however. (11/15/82) (3) Existing "Tufline" plug valves may be used in vinyl chloride service at LaPorte. The valve bonnet bolts and nuts must be drilled and a wire seal attached in such a manner that the bonnet bolts cannot be inadvertently removed. When these valves are related, however, they must conform to the standard (11/21/83). wp!0/1551q-4 VVV 000017541 SA-L32 Revised: 10/17/84 Butadiene Storage Tanks (Non-Process) Tank Valves and Nozzles I. All tank nozzles must have one of the following: 1. If Not In Use - Blank on the tank nozzle flange, 2. Vapor Service Nozzles - Ball valve mounted on tank nozzle flange. Valves in conjunction with relief valves will be covered in the relief valve section. 3. Liouid Service Nozzles (usually on bottom of tank, but would also include top entering dip pipes) - Remote air actuated ball valve mounted on tank nozzle flange. The following exceptions apply: (a) Tank nozzles with thermowells. Thermowells must be welded to the tank flange. (b) A manually operated ball valve that meets criteria in Appendix I, mounted between the tank nozzle flange and the air actuated ball valve is optional. Air actuators must include the following features: (a) Air to open, spring to close. (b) Contain section of burn-through tubing. (c) Valve, with air actuators mounted on them, bench tested for leaks before installed on tank and during vessel turnaround. 4. All tank nozzles must be a minimum of 1-1/2" pipe size. 5. No threaded connections should be attached to the tank. II. Valve requirements for Section I and a list of valves that meet these requirements are in Appendix I. Ill. Air actuated valves are required to have two local and one remote manual ait switch. The two local air switches will 180 apart and located just outside the tank containment system. A LEL vapor detector, discussed later, will also operate these valves. be wpL0/1551q-5 VVV 000017542 BUTADIENE (CONTINUED) SA-132 Revised: 10/17/34 IV. V. it is required that all air actuated valves be cycled weekly. Excess flow valves may be used in conjunction with air actuated valves. Vapor Detectors I.LEL type vapor monitor with continuous sampling that alarms at a maximum of 25% and closes air valves and activates deluge system at 50% are required. II. Three LEL detectors will be located below tank and one at pump. It is not required that the LEL detector at the pump activate the deluge system. III. Vapor detectors should be tested and calibrated every four months. Fire Protection I A monitor fire water system is required for hori zontal tank installations. A deluge system is required for spherical tank installations. II Vessel supports need either a deluge system or f ire proofing with a 3 HR rating. Relief Valves I. One of the following two, (a) or (b), may be used for vessel pressure relieving systems: (a) A three-way valve with two relief valves. (b) Two-way valves, multi-nozzle with "Castell" locking system. See Engineering Standard #ST-528 for relief valve design and installation requirements. II. Manual valves below relief valves must be mounted on tank nozzle flange. Valves for this service must meet the requirements in Appendix I. III. Each relief valve will be bench tested every three years. wp!0/1551q-6 WV 000017543 BUTADIENE (CONTINUED) SA-132________ _ Revised: 10/17/84 IV. Rupture discs will continue to be used per the EPA Regulations. V. sizing of relief valves must adhere to BFG Policy ST-1317. Tank Internal Inspection I. Storage tanks will be inspected a minimum of once in three years; tanks in recycle service every year. II. The minimum inspection requirements are: (a) Visually inspect for internal corrosion, especially around flange welds, thermowells, level indicators, etc. (b) Ultrasonically test wall thickness in several representative locations. (c) Record results of each inspection and thickness measurement and compare with previous inspections. III. Connecting piping will be inspected at the same time tank is inspected. wp!0/1551q-7 VVV 000017544 SA-132 Revised: 10/17/84 Isobutylene Storage Tanks (Non-Process) Tank Valves and Nozzles I. All tank nozzles must have one of the following: 1. If Not In Use - Blank on the tank nozzle flange. 2. Vapor Service Nozzles - Ball valve mounted on tank nozzle flange. Valves in conjunction with relief valves will be covered in the relief valve section. 3. Liquid Service Nozzles (usually on bottom of tank, but would also include top entering dip pipes) - Remote air actuated ball valve mounted on tank nozzle flange. The following exceptions apply: (a) Tank nozzles with thermowells. Thermowells must be welded to the tank flange. (b) A manually operated ball valve that meets criteria in Appendix I, mounted between the tank nozzle flange and the air actuated ball valve is optional. Air actuators must include the following features: (a) Air to open, spring to close. (b) Contain section of burn-through tubing. (c) Valve, with air actuators mounted on them, bench tested for leaks before installed on tank and during vessel turnaround. 4 All tank nozzles must be a minimum of 1-1/2" pipe size. 5 No threaded connections should be attached to the tank. II. Valve requirements for Section I and a list of valves that meet these requirements are in Appendix I. III. Air actuated valves are required to have two local and one remote manual air switch. The two local air switches will 180 apart and located just outside the tank containment system. A LEL vapor detector, discussed later, will also operate these valves. be wpl0/lS51q-8 VVV 000017545 ISOBUTYLENE (CONTINUED) SA-132 Revised: 10/17/84 IV. It is required that all air actuated valves be cycled weekly. V. Excess flow valves may be used in conjunction with air actuated valves. Vapor Detectors I. LEL type vapor monitor with continuous sampling that alarms at a maximum of 25% and closes air valves and activates deluge system at 50% are required. II. Three LEL detectors will be located below tank and one at pump. It is not required that the LEL detector at the pump activate the deluge system. III. Vapor detectors should be tested and calibrated every four months. Fire Protection I. A monitor fire water system is required for horizontal tank installations. A deluge system is required for spherical tank installations. II. Vessel supports need either a deluge system or fire proofing with a 3 HR rating. Relief Valves I. One of the following two, (a) or (b), may be used for vessel pressure relieving systems: (a) A three-way valve with two relief valves. (b) Two-way valves, multi-nozzle with "Castell" locking system. See Engineering Standard #ST-528 for relief valve design and installation requirements. II. Manual valves below relief valves must be mounted on tank nozzle flange. Valves for this service must meet the requirements in Appendix I. III. Each relief valve will be bench tested every three years. vpl0/1551q-9 VVV 0000175^6 ISOBUTYLENE (CONTINUED) SA-132 Revised: 10/17/84 IV. Rupture discs will continue to be used per the EPA Regulations. V. Sizing of relief valves must adhere to BPG Policy ST-1317. Tank Internal Inspection I. Storage tanks will be inspected a minimum of once in three years: tanks in recycle service every year. II. The minimum inspection requirements are: (a) Visually inspect for internal corrosion, especially around flange welds, thermowells, level indicators, etc. (b) Ultrasonically test wall thickness in several representative locations. (c) Record results of each inspection and thickness measurement and compare with previous inspections. Ill Connecting piping will be inspected at the same time tank is inspected. wplO/1551q-10 vVV 0000175AT SA-132 Revised: 10/29/84 Propane/Propylene/Butane Storage Tanks (Non-Process) Tank Valves and Noz2les I. All tank nozzles must have one of the following: 1. If Not In Use - Blank on the tank nozzle flange. 2. Vapor Service Nozzles - A ball valve mounted on tank nozzle flange. Valves in conjunction with relief valves will be covered in the relief valve section. The following exception apply: (a) The 1-1/2", 150 pound "Varec," soft seated pinch valves for the Varec level indicators may be used provided that a separate deluge firewater sprinkler be installed and directed at the valve and that the drain valve at the bottom of the level indicator complies with Appendix I. 3. Liquid Service Nozzles - Remote air actuated ball valve mounted on tank nozzle flange. The following exceptions apply: (a) Tank nozzles with thermowells. (b) A manually operated ball valve that meets criteria in Appendix I, mounted between the tank nozzle flange and the air actuated ball valve is optional. (c) The screwed piping between the 1", 6,000 pound tank coupling and the level alarm valve must be a 1/4" maximum opening on the present propane/propylene/ butane storage tanks at Calvert City. Air actuators must include the following features: (a) Air to open, spring to close. (b) Contain section of burn-through tubing. (c) Valve, with air actuators mounted on them, bench tested for leaks before installed on tank and during vessel turnaround. vpl0/1551q-ll 001754a PROPANE/PROPYLENE/BUTANE (CONTINUED) SA-132 Revised: 10/29/84 II. Valve requirements for Section I and a list of valves that meet these requirements are in Appendix I. III. Air actuated valves are required to have two local and one remote manual air switch. The two local air switches shall be located a sufficient distance away from the vessel(s) to allow operation in the event of an emergency and shall be a minimum of 90 apart. IV. It is required that all air actuated valves be cycled every two weeks. V.Excess flow valves may be used in conjunction with air actuated valves. Vapor Detectors I. LEL type vapor monitor with continuous sampling that alarms at a maximum of 25% and activates deluge system at 50% are required. IT. There will be four LEL detectors located such that the tankage area periphery is covered in four directions 90 apart. III. Vapor detectors should be tested and calibrated every four months. Fire Protection I.An automatic deluge fire water system is required for each tank. II. Vessel supports need either a deluge system or fire proofing with a 3 HR rating. Relief Valves I. One of the following three, (a), (b) or (c), may be used for vessel pressure relieving systems: (a) A three-way valve with two relief valves. <b) Two-way valves, multi-noasle with "Castell" locking system. (c) A relief valve with no block valve between it and the vessel. wp!0/1551q-12 VVV 0000175^9 PROPANE/PROPYLENE/BUTANE (CONTINUED) SA-132 Revised: 10/29/84 See Appendix I foe recommended three-way valves and relief valves. See Engineering Standard #ST-528 for relief valve design and installation requirements. Block valve mounted on first flange. II. Each relief valve will be bench tested every four years. III. sizing of relief valves must adhere to BFG Policy ST-1317. Tank Internal Inspection I. Storage tanks will be inspected internally a minimum of once in 12 years. II. The minimum inspection requirements are: (a) Visually inspect for internal corrosion, especially around flange welds, thermowells, level indicators. etc. (b) Ultrasonically test wall thickness in several representative locations. (c) Record results of each inspection and thickness measurement and compare with previous inspections. III. A visual external inspection of storage tanks shall be performed yearly to detect external corrosion. Specifically, all vapor nozzles and structural attachments shall be closely examined. IV. Connect! ng piping will be inspected at the same time tank is external ly inspected. wpl0/1551q-13 ooovl $5 SA-132 Revised: 10/29/84 Ethylene Storage Tanks (Non-Process) Tank Valves and Nozzles I All tank nozzles must have one of the following: 1. If Not In Use - Blank on the tank nozzle flange. 2. Vapor Service Nozzles - Ball valve mounted on tank nozzle flange. Valves in conjunction with relief valves will be covered in the relief valve section. 3 Liquid Service Nozzles - Remote air actuated ball valve mounted on tank nozzle flange. The following exceptions apply: (a) Tank nozzles with thermowells welded to the tank flange. Thermowells must be (b) A manually operated ball valve that meets criteria in Appendix I, mounted between the tank nozzle flange and the air actuated ball valve is optional. Air actuators must include the following features: (a) Air to open, spring to close. (b) Contain section of burn-through tubing. (c) Valve, with air actuators mounted on them, bench tested for leaks before installed on tank and during vessel turnaround. 4 All tank nozzles must be a minimum of 1" pipe size. 5. No threaded connections should be attached to the tank. II. Valve requirements for Section I and a list of valves that meet these requirements are in Appendix I. For ethylene service, only stainless valves will be used. III. Air actuated valves are required to have two local and one remote manual air switch. The two local air switches shall be located a sufficient distance away from the vessel(s) to allow operation in the event of an emergency and shall be a minimum of 90 apart. wplO/155lq-14 000017551 VVV ETHYLENE (CONTINUED) SA-132 Revised: 10/29/84 IV. It is required that all air actuated valves be cycled every two weeks. V. Excess flow valves may be used in conjunction with air actuated valves. Vapor Detectors I. LEL type vapor monitor with continuous sampling that alerts at a maximum of 25% and alarms at 50% LEL. II. There will be four LEL detectors located such that the tankage area periphery is covered in four directions 90 apart. III. Vapor detectors should be tested and calibrated every four months. Fire Protection I. An automatic deluge fire water system or a fire water monitor system is required for each tank. II. Vessel supports need either a deluge system or fire proofing with a 3 HR rating. Relief Valves I. One of the following two, (a) or (b), may be used for vessel pressure relieving systems: (a) A three-way valve with two relief valves. (b) Two-way valves, multi-nozzle with "Castell" locking system. See Engineering Standard #ST-528 for relief valve design and installation requirements. II. Manual valves below relief valves must be mounted on tank nozzle flange. Valves for this service must meet the requirements in Appendix I. III. Each relief valve will be bench tested every four years. IV. Sizing of relief valves must adhere to BFG Policy ST-1317. wpl0/155iq-15 V,VV 000017552 ETHYLENE (CONTINUED) SA-132 Revised: 10/29/84 Tank Internal Inspection I. Storage tanks will be inspected internally each time the vessel is taken out of service and completely emptied and prepared for vessel entry. II. The minimum internal inspection requirements are: (a) Visually inspect for internal corrosion, especially around flange welds, thermowells, level indicators, etc. (b) Ultrasonically test wall thickness in several representative locations. (c) Record results of each inspection and thickness measurement and compare with previous inspections. Ill. A visual external inspection of storage tanks shall be performed yearly to detect loose or separated insulation, and to spot external corrosion at those locations. Specifically, all vapor nozzles and structural attachments shall be closely examined. IV. Connecting piping will be inspected at the same time tank is externally inspected. wp!0/1551q-16 VVV 000017553 SA-132 Revised: 10/29/84 C-4 Storage Tanks (Non-Process) Tank Valves and Nozzles I All tank nozzles must have one of the following: 1. If Not In Use - Blank on the tank nozzle flange. 2. Vapor Service No22les - A ball valve mounted on tank nozzle flange. Valves in conjunction with relief valves will be covered in the relief valve section. The following exceptions apply: (a) The 1-1/2**, 150 pound MVarec,M soft seated pinch valves for the Varec level indicators may be used provided that a separate deluge firewater sprinkler be installed and directed at the valve and that the drain valve at the bottom of the level indicator complies with Appendix I. 3 Liquid Service Nozzles - Remote air actuated ball valve mounted on tank nozzle flange. The following exceptions apply: (a) Tank nozzles with thermowells. Thermowells must be welded to the tank flange. (b) A manually operated ball valve that meets criteria in Appendix I, mounted between the tank nozzle flange and the air actuated ball valve is optional. Air actuators must include the following features: (a) Air to open, spring to close. (b) Contain section of burn-through tubing. (c) Valve, with air actuators mounted on them, bench tested for leaks before installed on tank and during vessel turnaround. 4 All tank nozzles must be a minimum of 1" pipe size. 5. No threaded connections should be attached to the tank. wplO/155lq-17 vvv 00001^554 C-4 (CONTINUED) SA-132 Revised: 10/29/84 II. Valve requirements for Section I and a list of valves that meet these requirements are in Appendix I. III. Air actuated valves are required to have two local and one remote manual air switch. The two local air switches shall be located a sufficient distance away from the vessel(s) to allow operation in the event of an emergency and shall be a minimum of 90 apart. IV. It is required that all air actuated valves be cycled every two weeks. V. Excess flow valves may be used in conjunction with air actuated valves. Vapor Detectors I. LEL type vapor monitor with continuous sampling that alarms at a maximum of 25* and activates deluge system at 50* are required. TT. There will be four LEL detectors located such that the tankage area periphery is covered in four directions 90 apart. III. Vapor detectors should be tested and calibrated every four months. Fire Protection I. An automatic deluge fire water system is required for each tank. II. Vessel supports need either a deluge system or fire proofing with a 3 HR rating. Relief Valves I. One of the following three, (a), (b) or (c), may be used for vessel pressure relieving systems: (a) A three-way valve with two relief valves. (b) Two-way valves, multi-nozzle with "Castell" locking system. (c) A relief valve with no block valve between it and the vessel. wpl0/1551q-18 VVV 000017555 C-4 (CONTINUED) SA-132 Revised: 10/29/04 See Appendix I for recommended three-way valves and relief valves. See Engineering Standard #ST-52S for relief valve design and installation requirements. II. Each relief valve will be bench tested every four years. III. Sizing of relief valves must adhere to BFG Policy ST-1317. Tank Internal Inspection I. Storage tanks will be inspected internally a minimum of once in 12 years. II. The minimum inspection requirements are: (a) Visually inspect for internal corrosion, especially around flange welds, thermowells, level indicators, etc. (b) Ultrasonically test wall thickness in several representative locations. (c) Record results of each inspection and thickness measurement and compare with previous inspections. III. A visual external inspection of storage tanks shall be performed yearly to detect external corrosion. Specifically, all vapor nozzles and structural attachments shall be closely examined. III. Connecting piping will be inspected at the same time tank is externally inspected. wpl0/1551q-19 WV 00Q017556 APPENDIX I RECOMMEND VALVES FOR STORAGE SPHERES AND BULLETS SPECIFICATION: Ball Valves - Split Body 150 Pound Flanged, Fire Test, Blowout Proof Stem Grounded Ball Manufacturer and Model Number KITZ K-150-UTBM-FS K-150-SCTB-FS KT OMNI EO13 2-3 2GT-15L E08 3 2-3 2GT-15L E0162-32GT-15L EOS 6 2-3 2GT-15L JAMESBURY 6150-31-3600 6150-31-2236 5150-31-3600 5150-31-2236 WATTS SF-2000-150 CF-1800-150 COOPER FIG 415 KAMYR PC PC Port Size Full Full Full Std. Full Std. Full Full Std . Std. Full Full Full Full Full Available Material* SS CS Available Sizes 1/2"-10" l/2"-10" Actuator Mounting Pad Prov Yes Yes SS 1/2"-S" Yes SS 3"-10" Yes CS 1/2"-8" Yes CS 3"-10H Yes SS 2"-20" Yes CS 2"-20" Yes SS 6"-20" Yes CS 6"-20" Yes SS 1-1/2"-6" Yes CS l-l/2"-6" Yes Alloys Only l/2"-12" Yes CS l-l/2"-24" Yes SS l-l/2"-24" Yes Stainless steel must be used for ethylene service. wplO/1551q-20 VVV 000017557 APPENDIX I RECOMMEND VALVES FOR STORAGE SPHERES AND BULLETS SPECIFICATION: Ball Valves - End Entering 150 Pound Flanged, Fire Test, Blowout Proof Stem - Grounded Ball Manufacturer and Model Number Port Size Available Material* Available Sizes Actuator Mounting Pad Prov. MARPAC SS-C470-RF CS-470-RF Std. Std. SS cs l-l/2*,-4'* l/2"-4" Yes Yes WORCESTER AF51-66 AF51-46 AF-55-66 AF-55-4 6 Std. Std. Full Full SS CS SS CS l/2"-8" 1/2"-8 " 1/2"-8* l/2H-8" Yes Yes Yes JAMESBURY 5150-31-3600 5150-31-2236 6150-31-3600 6150-31-2236 Std. Std. Full Full SS CS SS cs 1/2"-4" 1/2"-4" l/2"-l-l/2" 1/2"-1-1/2" Yes Yes Yes Yes HILLS MCCANNA McCannaflo F151 McCannaflo F151cs Std. Std. SS cs 1/2"-12" l/2"-12" Yes Yes MARWIN 5233R 5333R 5233F 5333F Std. Std. Full Full cs ss cs ss 1/2--12" l/2"-12" 1/2H-12" 1/2"-12" Yes Yes Yes Yes WKM 310C-B136-CS-Q2-S1 310C-B13 6-S1-02-S1 310C-B138-CS-02-S1 310C-B13 8-S1-0 2-SI Std. Std. Full Full cs ss cs ss 1/2"-4" 1/2"-4 H l/4"-4" l/4'*-4'* Yes Yes Yes Yes Stainless steel must be used for ethylene service. wplO/155Ig-21 VVV COOOl7558 APPENDIX I RECOMMEND VALVES FOR STORAGE SPHERES AND BULLETS __________UNDER RELIEF VALVES ONLY___________________ SPECIFICATION: Three-way - 150 Pound Flanged Valves Full Port Manufacturer and Model Number COOPER f BALL) 3 Piece T Port KAMYR {BALL)<y> Y2 Y2 KTM (BALL 1 E03132-3 2GT-1SL EO 31-62-3 2-15-GFS Port Size Full Full Full Full Full Available Material* Available Sizes Alloys Only 1/2"-12" CS 3"-12" SS 3 " -12 " SS 3 " -8 " CS 3 " -8 " Actuator Mounting Pad Prov Stainless steel must be used for ethylene service. wplO/1551q-22 VVV 000017559