Document bBJO6jG4bORajLbZY8nXVYnE6

(conoco) Interoffice Communication to OSHA-Engineering and Work Control Plan File From M. G. Jakel Date April 14, 1983 Subject UPDATE OF ENGINEERING AND WORK PRACTICE CONTROL PLAN Attached is an update of the Plant's engineering and work practice control plan for complying with the OSHA VCM Exposure Standard. All work practice controls have been implemented and significant progress has been made on most of the engineering controls. The startup of the larger Dump Screener exhauster has significantly reduced VCM levels in the V-40 area. Completion of other projects to improve ventilation and simplify cleaning of the recovery filters in the V-40 area should further reduce levels. However, we will have to rely on breathing air to limit VCM exposure from some exposure sources. A Class "4" design has been completed to improve and simplify cleaning of the V-4C recovery filters. This project was included in the 1983 Capital Budget and will be AFE'd in the near future. MARK G. JAKEL Process Engineer Conoco Chemicals Company Oklahoma City Chemical Plant Approved: R. A. CONRAD Plant Manager Conoco Chemicals Company Oklahoma City Chemical Plant MGJ-dh Attachment cc: RAC, AWS RDF, RP, CWT, JPW, JDO, RVG, REB, DPB, RJK, JBB, GHF, JDG File - OSHA Engineering and Work Practice Controls CCR 000010469 Exposure Source 1. Residual Monomer in slurry and resin. ENGINEERING AND WORK PRACTICE CONTROL PLAN FOR COMPLIANCE WITH OSHA VCM EXPOSURE STANDARD CONOCO CHEMICALS OKLAHOMA CITY PVC PLANT APRIL, 1983 ____________Work Practice Controls^ la. All batches are steam stripped to remove unreacted VCM from the slurry prior to dumping the slurry to the blend tanks. Tests show that the slurry contains less than 220 PPM VCM after steam stripping. Engineering Controls In Progress TiT A project was developed irT 1980 which provides a system to reduce VCM contamination of stripped reactor slurries caused by leaking reactor valves. This should further reduce the VCM concentration of stripped slurries. Mechanical design work is complete. Completion is scheduled for the third quarter of 1983. lb. After the slurry is dumped from the lb. A project for removing the blend reactors to the blend tanks, the slurry tank vents from the process area is stripped with air to further reduce was developed and approved in the the VCM concentrations. Tests show that 1980 Capital Budget. Mechanical the VCM content of the dried resin is work is in progress. Completion below 5 PPM when the combination of is scheduled for the 3rd quarter of ( steam and air stripping is used. 1983. 2. Obtaining and handling samples. 2a. Wear personnel protection equipment which meets OSHA standards when sampling can result in VCM exposure. 2b. All reactor samples are obtained via the closed sampling system. 3. VCM railcar. 3. Wear personnel protection equipment which meets OSHA standards while connecting and disconnecting tank cars. CCR 0 0 0 0 1 0 4 7 0 4. Chemical wash screen. 4. Steam stripping of all batches has greatly reduced the possibility of exposure from this source. Note (1): As part of the work practice controls, two Honeywell VCM monitors sample twenty locations in the process and tank farm areas to detect VCM leaks. Exposure Source 5. Reactor rinse after dump. ENGINEERING AND WORK PRACTICE CONTROL PLAN FOR COMPLIANCE WITH OSHA VCM EXPOSURE STANDARD CONOCO CHEMICALS OKLAHOMA CITY PVC PLANT APRIL, 1983 Work Practice Controls^ ^_________________ ^ The effluent from the initial water rinse after reactor dump is transferred to the dump system. Engineering Controls in Progress CCR 0 0 0 0 1 0 4 7 1 6. Flexible hoses, pipe unions and flanges, valve stems and swivel joints in VCM service. 6. At least once per month, flexible hoses, pipe unions and flanges, valve stems and swivel joints in VCM service are checked for leaks. Leaks are repaired on the spot if possible and are put on the maintenance schedule where they cannot be repaired immediately. 7. Opening and working on equipment or piping which may contain VCM. 7a. Before opening, VCM is removed from equipment or piping to the lowest practical level by flushing, purging and/or evacuation where possible. j 7b. Wear personnel protection equipment which meets OSHA standards when opening equipment or piping which may contain VCM. 7c. Before commencing repair work, measure the VCM concentration in or near the opened equipment or piping to determine what protective equipment is required and if further VCM removal is necessary. 8. Dump screener 8. Wear personnel protection equipment which 8. A larger exhauster system has meets OSHA standards if the VCM monitors been installed and is operational. detect VCM concentrations in the area Discharge piping remains to be around the dump Sweco. completed. Note (1): As part of the work practice controls, two Honeywell VCM monitors sample twenty locations in the process and tank farm areas to detect VCM leaks. Exposure Source 9. Filters 9a. V-20 seal water. 9b. V-40 seal water. 9c. V-40 K.O. circulation water. 10. Mechanical seals on 6-101 and G-105 VCM transfer pumps. ENGINEERING ANT WORK PRACTICE CONTROL PLAN FOR COMPLIANCE WITH OSHA VCM EXPOSURE STANDARD CONOCO CHEMICALS OKLAHOMA CITY PVC PLANT APRIL, 1983 Work Practice Controls^ 9. Wear personnel protection equipment which meets the OSHA standard when working with the filters. 10. Wear personnel protection equipment which meets the OSHA standard when the fixed point monitors indicate a leak. Engineering Controls In Progress fM oHOt O g at. u o 9a. The existing filters have been replaced with units which require less maintenance. 9b. A Class A design for improving and simplifying cleaning procedures has been completed. This project will be AFE'd during the second quarter of 1983. 9c. A Class A design ffor improving and simplifying cleaning procedures has been completed. This project will be AFE'd during the second quarter of 1983. Note (1): As part of the work practice controls, two Honeywell VCM monitors sample twenty locations in the process and tank farm areas to detect VCM leaks.