Document YDnDzxvXoQ2303n99dK6mJE4y

ALLIED CHEMICAL CORPORATION MEMORANDUM RECEIVED BY MAY u 1974 J. M. QUINN May R, 197 M Mr. J. M- Quinn Attached is R. J. Curtis' memo to file covering our recent visit from the EPA group as listed. PBC:ef cc: Mr. E. E. James 4^-4'* P. B. Cornell, Manager Baton Rouge North Works environmental SERVICES INFO ACTION JMQ JMD C WFS --- -- GK - --. - ---------- "lmp " " J------- -- ;WCK 1 -- ---------- "CMM . -- -- i. *~SK I ' RJ>J F WORKS I product L T.'CKLE ' J E 1 RET. TO AS I 00001893G MEMORANDUM DATE: May 7s 1974 subject: EPA VISIT TO BRNW - MAY 1, 1974 TO; FILE 1) EPA visitors included: Paul Fahrenthold - Enforcement Division, Dallas, Texas Oscar Ramirez, Jr. - Surveillance & Analysis Division 1600 Patterson St., Dallas, Texas (Phone - 214-749/1121) B. J. Pritchard - Surveillance & Analysis Division Box 885, Slidell, La. Thomas F. Beckers - Surveillance & Analysis Division Box 885, Slidell, La. 2) Purpose of Visit As a result of VOI angiosarcoma emphasis the EPA Surveillance and Analysis Group were visiting Louisiana vinyl producers to become more familiar with the operations, to review environmental contamination by VCM, and to review analytical procedures for detection of VCM in air and water effluents. For clarification, the visitors were reviewing environmental exposure. Employee or personnel exposure is being followed by OSHA Division of DOL. 3) Following a meeting and review of EPA request for permit data in plant manager's office with P. B. Cornell and R. J. Curtis, the visitors toured the VCM and loading operating with R. J. Curtis. Areas reviewed were: a. Neutralization pond. b. Tank car vents (we were drying a car recently returned from the shop with a nitrogen purge. Discussed and proposed system). c. Tank car loading hose. Advised them of our plan to vent back into operation. d. Tank car level gauge. e. Oxychlor system vents. f. Lights column atmosphere vent. g- Decoking procedure h. Caustic scrubber recharging procedure C-639 (6^9) (F) AS I 00001 8937 -2- i. Pump design for minimum release. j. Heads column condensate recovery. k. Vacuum column bottoms l. EDC open ditch and sump system m. Discussed proposed recovery system Mr. Ramirez asked how we analyzed for VCM in the vacuum column bottoms and EDC sump. He was told that we do not routinely analyze for VGM in either stream. We analyze for EDC and trichloroethane. We have analyzed for VCM in the air immediately above the EDC sumo by taking a bomb sample and analyzing in a Bendix flame--ionization gas chromatograph. No VCM was found present. He asked for our analytical procedure since he was a chemist. Attached is ICD procedure for "Determination of Impurities in Crude Stream". The visitors left on an apparent tight time schedule for Dow in Placuemine at 12:00 P.M. RJC:ef Attach. cc: Mr. J. M. Quinn R. J. Curtis AS! 000018938 INDUSTRIAL CHEMICALS DIVISION ALLIED C) Di li CAL CORPORATION Page 1 of 2 ED-1.5-4 Ethylene D.ichloride Specific Procedure Impurities Gas Chromatographic DETERM1NATION OF IMPURITIES TH CRUDE STREAMS APPLICATION This procedure is designed to test for impurities in organic or crude streams of ethylene dichloride. The instrument is set up in such a manner to allow manual step attenuation or automatic peak area readouts on an Infotronic Model CRS 100 integrator. PRINCIPLE A sample is injected into a Perkin Elmer gas chromatograph and the peak areas are compared to known standards to determine the impurity level. SPECIAL PRECAUTION'S Avoid excessive contact of ethylene dichloride with the skin. Wash contacted areas with large amounts of water. Avoid inhalation of ethylene dichloride fumes. APPARATUS " ........................ 1. Perkin Elmer Model 154D gas chromatograph. 2. 1/4" x 18' copper columns packed with 5% carbowax 20M on Chromosorb W 60/80 mesh. 3. Precision Sampling Corp. No. 304101-C liquid syringe or equivalent. 4. 0-1 MV Recorder 5. Paragon K&E 56-3280 ruler or equivalent. 6. Infotronic Model CRS 100 Digital Readout System (optional). REAGENTS None. PROCEDURE 1. The following conditions should exist, prior to starting the analysis: a) Column temperature - 100C b) Injection port and block temperature - 100C c) Bridge current - 8 volts d) Helium flow - 45 cc/min ASI 000018 939 Pago 2 of 2 ED-1.5-4- 2. A stable baseline should exist before injection of samples. 3. Plush the syringe with several portions of sample being certain to dispose of the flushings outs ide of the sample container. 4. Take the required 10 microliter sample and inject through the liquid injection port into the column. 5. Hark your injection or starting point on the recorder chart. If integrating, push the start button at the same time you inject the sample. 6. Attenuate all peaks as necessary to prevent them from going off scale. If using the Infotronic integrator, set the scale on the position used for standardization. 7. After the last component (trichloroethane) has eluted, return to standard conditions before injecting the next sample. Total integrated areas after the analysis is completed. CALCULATIONS Hand Attenuation Peak Height x 1/2 peak width x attenuation setting x factor = ppm component Integrator Area x factor - ppm component Approximate Elution Times: Component 1. Ethyl chloride 2. Carbon tetrachloride 1,1 diohlorocthane 3. Benzene 4. Trichloroethylene 5. Chloroform 6. Tetraohloroethvlene 7. Ethylene Dichloride 8. Trichloroethane 1.9 minutes 3.3 4.3 5.0 5.5 5.9 6.6 18.1 INTERFERENCES None. Op ]/pcao&\ fiorTo^i r . rmcHitnt 00001894 AS I