Document YrzZ6KGNr941VwyGdJ3nENbQO

1. S US PENSION / NON-SOLVENT /VINYL REFRIGERATION UNIT VCM ACTION PLAN FOR COMPLL.NCE Emission Source Project Description for Compliance Status as of 3/14/75 Non-Solvent H. P. vent Modify No. 1 VCM rec. system to allow recovery of contained vinyl chloride {3,000 lbs VCl/day! in the H. P. vent by scrubbing in Solvent Vinyls acetone stripping system. Complete Suspension H. P. vent Modify #2 VCM rec. system to send H. P. vent s tream (2 , 500 lbs /day VCMIto the #1 Powerhouse for burning in boilers as fuel. Complete Off-gas H. P. vent Modify Off-gas rec. system to send H. P. vent (5Z8 lbs VCM/day) to the #1 Powerhouse for burning in boilers as fuel. Complete Suspension VC1 Solvent scrubbing system Recover contained VCl in NonSolvent, Suspension, & Off-Gas HP vents by scrubbing in MEK stripping s ys tem. Engineering design calculations are complete. Engineering/Pro* duction team to expedite system installation by Oct. 1975 has been assigned. Operation by Nov. 1. Accountability: Leroy Dampman/D. Walthal, A. A. Peterson Nos. 3 & 4 Stripping Tank effluent , Recirculate #4 st. tk. effluent and increase temperature of #3 st. Ik. to minimize atmospheric releases of V CM (400 lbs /day). Steam addition system was in stalled on #3 st, tk. on 11/26. Presently repairing recirculation pump for use by 3/31. Account ability: R. P. Keefe Off-Gas Recovery System Install spare vacuum pump to improve vacuum stripping of slurry. Capital budget request has been prepared. Delivery expected by 5/1/75, Accountability: R.Q. Payne, A. A. Peterson. Esti mated cost: $100 M UCC 091236 Suspension/Non-Solvent/Vinyl Ref. Unit VCM Action Plan For Compliance 2. Emission Source Project Description For Compliance Status as of 3/14/75 Decant Tanks 14107, 14108, 14111 & 14112 (Non-Solvent) Eliminate decanting of Non-Solvent rec. monomer tks, to the atmosphere, (144 lbs VCM/day). Piping modifications to allow decanting of rec. monomer tks. to a closed vessel instead of the sewer were completed on 10/3. Instrumentation for automatic decanting will be completed by 4/15. Accountability: G. Pyle Boil-off sampling Eliminate operator exposure during boil-off sampling. Complete Decant Tanks C-10, C-ll (Suspension) Eliminate decanting of Suspension Complete rec. monomer tks. to the atmosphere. (100 lbs VCM/day) Autoclave rupture dis cs Replace autoclave rupture disc type PLDV w/more reliable type RB-90. Complete BDT/VST rupture dis cs Eliminate BDT/VST rupture discs ruptures by installing DMV's on blowdown tank feed headers to avoid autoclave blowdowns during vacuum stripping. A DMV was installed in the feed header to the #1 BDT on 11/4 w/ a dramatic decrease in number of blown rupture discs, Five remaining BD tk. feed headers will be modified by July 1975. Accountability: A. A. Peterson Autoc Laves -high reaction pressure Eliminate atmospheric releases Issued new SOP. of VCM during high reaction pressures. Suspension surge tks, dryer exhausts Batch vacuum strip resin to minimize atmospheric releases of VCM and reduce VCM content of resin. Batch stripping with #5 BDT was started 3/5 with impressive re duction in residual VCM. Other BDT's are being checked by T&I before revising. Account ability: A. Peterson Non-Solvent surge Continuous strip resin to minimize tanks, dryer exhausts atmospheric releases of VCM. Complete VC l filters Install piping to vent VCl filters to the #3 st. tk. prior to opening for maintenance. Complete UCC 091237 Suspension/Non-Solvent Vinyl Ref. Unit VCM Action Plan For Compliance 3. Emission Source Proiect Description For Compliance Status as of 3/14/75 Priming VCM pumps Evaluate several means of priming VCl pumps to eliminate atmospheric releases of VCl during priming. Complete and new procedure implemented C-auLoolave agitator Test several packing designs to packing failures minimize packing failure frequency. Autoclave resin sampling Maint. food prep aration & eating facilities Redesign autoclave resin sampling equipment to minimize operator expos ures. Install a temporary bldg, to re locate maintenance food preparation and eating facilities. Discovered & corrected quality control problem w/vendor of existing packing. Also evaluat ing new packing design for this service. New seal design com plete h ready to run. Autoclave w/H20 & Nz pressure to be tried before production. Account ability: R. H. May Have installed samplers on all lines. Accountability: R.P. Keefe, F. L. Johnson Complete Fresh/rec. VCM feed pump seal replacement Eliminate VCl packing leaks from fresh & rec. VCl feed pumps. InstalL 20-point VFA s quentialVCl analyzer in B-120 control room Provide additional monitoring capability in the Suspension/NonSolvent department. Replace packing w/mechanical seals by 5/75. Accountability: R. P. Keefe Delivery - April, 1975 Install "data-logger" for VFA sequential VCl analyzer Improve VCM exposure data analyses and reporting capability in the Sus pension/Non-Solvent department. Delivery - April, 1975 Surge tanks atmos pheric vents Purchase & install compressor to transfer atmospheric surge tank vents to the #2 VCM rec. system. No action to date Bird Effluent re covery system Re-use Bird effluent water rather than dump to the sewer. Mechanical portion of project is complete. Electrical drawings to be issued March 21 - SOP being written. UCC 091238 Suspension/Non -Solvent Vinyl Ref. Unit VCM Action Plan For Compliance 4. Emission Source VC1 underground barrel pump seals VCM loss in MEK Nash-Hytor seal water Nash compressor seal replacement VCM compressors packing vents Pilot Plant VCM emissions Project Description For Compliance Install double-seal arrangement on underground VCM pump seals to minimize seal leakage. Status as of 3/14/75 Double-seals have been received Engineering is presently design ing seal lube system. Plan to have on seal in service 4/15. Reduce MEK washings & hence, VCM loss by installing direct steam injection system on each D-autoclave Direct-steam injection tests on D-3 autoclave since 2nd Qtr 74 indicate the usefulness of this technique. An OIP for convert ing all D-autoclaves has been written. Eng. to begin on 3/1/75. Accountability: A. Peterson/J. T. Tannos Recover VC1 & VAc contained in seal water Complete Eliminate VCM packing leaks from Nash compressor. Complete Install exhaust fan on compressor room to minimize personnel exp. Comple te Recover VCM emissions from the Pilot Plant Operating procedures revised to send VCM emissions to the #2 Rec. System. UCC 09t9