Document bB7JnBMrnnM55NO6bM0xwbjnk

A Interoffice Communication To : Vinyl Shift Supervisors From Date : J. E. Barton : April 10, 1979 Subject : EPA COMPLIANCE (REVISED) The following items need to be done to assure EPA compliance reguarding VCM emissions. 1. The date must be stamped on the Honeywell recorder charts each morning at 7:00 a.m. When the Honeywell charts are replaced the number of the Honeywell unit is to be written on the bottom of the chart. All used charts are to be turned into me. 2. All recovered VCM receivers are not to be filled above 80%. 3. The high pressure alarms on the blowdown tank in each unit will be reset to 40 psig. 4. The Emergency Kill Procedure has been revised as follows: Emergency Shutdown The following parameters are to be the maximum limits on a runaway reaction. The reaction should be killed with AMS if either one of the parameters is exceeded. Resin '' _ 5385, 5425, 5465 Maximum Temperature -*' 1 11 ** I 142F Maximum Pressure i * 145 PSIG 5305 162F 175 PSIG A runaway reaction immediately after charge and heat-up indicates that the reactor condenser may be plugged, and that the reaction must be killed. If AMS will not kill the reaction, use the nitric oxide (N,0.) short stop system. CAUTION: N.O. is a highly poisonous orange-colored gas. A Scott Air Pack or a ''Rocket Fuel" cannister mask must be worn while killing a reactor with the N.O. short stop system. ~ The runaway reaction must be killed immediately if either one of the pressure or temperature limits listed above are exceeded. If the reaction is allowed to exceed these limits, it may not be controllable and result in a relief valve or rupture disc discharge to the atmosphere. VAB.0001148571 EPA Compliance (Revised) April 10, 1979 Page 2 5. The emergency nitric oxide kill system for all the reactors has been pressure checked to assure integrity of the systems. These systems will be pressure checked each six months with nitrogen. * 6. After every coarse batch produced the reactor condenser will be inspected to determine if it is plugged. If the condenser is found to be plugged, it will be cleaned prior to charging the next batch. If the condenser is not plugged, charge the next batch back with 1/2 gallon less catalyst. If this batch runs normal return to the original catalyst loading. 7. Copies of the procedures for the Old Unit, New Unit, and Dryers will be placed on the table between the Lead OperatorsT desks in the control room. There will also be copies in the Shift Supervisors office and Operations Supervisor's office for your reference. Please conduct a formal review with your people on the seven items above and the attached Work Practice Controls for the OSHA VCM Standard. Write the review meeting up on the safety meeting form and return it to me.I I would like to have all the meetings completed by 4/25/79. J. E. Barton cjt Attachment c: CLM, ELK, RAF, Shift Supervisors (5) WORK RR.UMlfi tonikui .I^' OSIIA VTM S IAN DAI'I' RkACTOR AURAS Ino purpose of the vinyl rone tors is to v`'inert, vinvl chloride monomer, into polyvinyl chloride resi (RVC). Several of the operator functions in : largo reactor urea can result in ACM exposure. The following relates tn those work practices which are affected by potential ATM emissions. A. Opening Nonhead on kmpty Reactor r 1. Check t lie external pressure gauge to insure that t ho reactor is not uiuler pressure. i ^t- on the continuous t low fresh air breathin'1 mask. a. Unlatch the manhead roll bar. 1. Radio panel operator to open evaeuat ion jet to the 4 reactor.' this wi I 1 move ai r inward and disperse VTM vapors. a . Open manhead completely. n. Inspect reactor. NO Ik. 1 he man hen d i s not opened a l l er eve in' react ion hut only periodically to check the internal condition. B. Manual Reactor lintrv 1. Open manhead using the procedure 'described in A, 2. follow equipment entry procedure as described in Attachment "A" of Safety and Health Manual. a. Tlose the top manhead. I. Hydrostatically test reactor for leakage. 0. Reactor Recovery Unreacted ATM is removed from the polymerization reactor slurry by the recovery system. The recovery system consists ol vacuum pumps, compressors and condensers which remove the VTM from the reactor, compress, and condense it so tit.it it can he recycled to the process. Opcral ing personm Ar mil Aui;\s .lie_'K~ t i' y t j nucii arc required in the recovery aro;i during svstem Martl,p a,Kl tor p03i`,tn,ic c,u'^'s during Hie recoverv ||u, recovery area is monitored lor VCM levels iVom'the Con 1 l.loom* ,lu' operator is alerted hv radio before L'utcrmy the area i f the VCM level is above 1.0 ppm. Hone tor Dump ini* lljimpin- of _ the reactor slnrrv occurs ;.l t Ik- <-ii.| of t lie , 1 st.ri''l,,n>' l'cr;,`>on. Il.o ,Tcn,|,,,- observin', the To,Ins does .iio.i not need to we;;i r n CITAM 'indrr non,,:, is monitored I'rom the control n,v, :MU| -,nl i , |K. t In operator is ipni. Abnoi notified, if tin ^ * I 1 eve inn 1 conditions requiring n I i ^ alnn e ill A'I a ie 1.0 1 . lugged reactor dump valve or line. Dumping a coarse hatch. a. Cleaning dump Sweco. I. Inoperative Sweco exhauster. -1 -LLLAJLJ.-J. rile tollowing oyayv-H^ j uul Kcjvt;ie emeit w " ' - ^ _ information applies to ihe: Kccovered VCM filters fresh VcM hi Iters iSc.iI hater kilters (Compressors I fl,esc filters come in contort with VCM nml therefore ire potential exposure sources. c ,u 1 I lie filter pack is steam purged and recovered to the process. I he pack prior to recovery opening. system pulls a vacuum on the fi11 e 1 he operator then puts on a CflAM, an impervi mis suit. impervious gloves- and Condenser. Suheoo I er.fine Vessel M.i, n Ico.ince 1 lie iol lowing precautions are required to prevent VC.M exposure wh i 1c performing suhcoo 1 er and condensers. maintenance on lines, vesse1s, mi. ui;,v.:i'iii Aiii:\s - m\n\i;i;n l:. Condenser, Subcooler, bine and Vessel Mainti mo; - ('.out i nued 4 1. The equipment must be blinded at all inlets and outlets. The unit is to be flushed or evacuated until free of WM as detected bv the IINU OVA instrument. r,. I'he react or operating, area and tank far a re cont i nuouslv monitored tor h iqh VCM concent rat ions b\ the llonovwe located in the reactor control room. un l A VAB.0001148575 * >*' t- ^ .1- T+' i