Document bBdE4ownnaJV7D483aRjQG1X1

. ABDD0228166 OSHA - ENGINEERING AND WORK PRACTICE CONTROL PLAN AUGUST 9, 1983 TABLE OF CONTENTS I. WORK PRACTICE CONTROLS A. Respiratory Protection Guidelines B. Exposure Protection Guidelines C. PVC and VCM Sample Handling Guidelines II. ENGINEERING CONTROLS A. Exposure Reduction Projects Tc Be Inscalied B. Completed Exposure Reduction Projects ABD00228167 A ENGINEERING AND WORK PRACTICE CONTROLS CSKA VCM STANDARD v:ORK PRACTICE CONTROLS A. Respiratory Protection Guidelines Although most of the planned engineering and work practice control programs for the plant have been implemented, some of the routine operational jobs require the use of respiratory protection. The OSHA Vinyl Chloride Standard states "Employees engaged in any opera tion, procedure or activity where a release of vinyl chloride liquid or gas might be expected as a consequence of the operation, which would result in an employee exposure in excess of the permissible limit, shall be provided and required to wear respiratory protec tion." Employees must use fresh air respirators, Scott air packs or Scott sling packs for the following operations, because the possibility of exposure to greater than the permissible limit exists. VCM cannister masks may be worn under some conditions, as noted in (h). It is anticipated that VCM cannister masks wili be phased cut by November 15, 1983. 1. General Plant a. 'Then entering a vessel or any confined area that contains more than 1 ppm vinyl chloride. b. tfhen opening any piece of equipment that has been in vinyl chloride service. c. Then performing work on any open piece of equipment that has been in vinyl chloride service, unless the equipment is blinded and a Supervisor verifies that the VCM concen tration in the work area is less than 1 ppm. d. 'Then repairing a VCM leak on any equipment that contains VCM, and the VCM concentration in the work area exceeds or is expected to exceed 1 ppm. % e. '.'hen using the portable vinyl chloride detector to pin point a vinyl chloride leak detected bv the continuous monitoring system, and the VCM concentration in the work area exceeds or is expected to exceed 1 ppm. ?. 'Then working in an area where the local VCM warning beacon is flashing, or the fixed point monitor indicates a VCM concentration of 3 ppm or more in the area. g. '.-'hen performing any other operation which has the possi bility or resulting in exposure greater than the permissible exposure !init. The permissible exposure limit is defined as: No employee may be exposed to vinyl, chloride at con centrations greater than l opm averaged over nnv .-hour ABJXQQ22316&______ A ENGINEERING AND WORK PRACTICE CONTROLS OSHA VCM STANDARD ii. No employee may be exposed to vinyl chloride at con centrations greater than 5 ppm averaged over any period not exceeding 15 minutes. iii. No employee may be exposed to vinyl chloride by direct contact with liquid vinyl chloride. h. VCM cannister masks may be used under the following conditions: i. Working in a contaminated area of less than 10 ppm for up to 10 hours. ii. Performing leak detection operations while Honeywell units are indicating between 1 and 10 ppm VCM. iii. Escape from an area of high VCM concentration to obtain a Scott Air Pak. 2. VCM Tank Farm Area a. When checking the sphere vapor space oxygen content. b. When working at the compressor station. c. When opening domes on railcars prior to connecting hoses. d. When connecting and disconnecting hoses to the railcar. e. When samoling VCM railcars or storage vessels. 3. Reactor Area * a. When opening a Lenape manway on a reactor without using steam jet evacuation on the reactor. b. When changing filters which have been contaminated by VCM. This includes but is not limited to fresh and recovered VCM filters, recovery seal water filters, recovery knockout tank scrubber water filters, etc. r. When on top of any hLend tanks which are regulated areas. .1. When v/orking on a pbiuam r When working r.c-ar ha t ch. Nni`:i . ' tv. :: v :. * < ABD00228169 ENGINEERING AND WORK PRACTICE CONTROLS OSHA VCM STANDARD g. When sampling reactors or VCM storage vessels. h. When on top of a blend tank that is being filled with water or slurry from the resin reclaim system. 4. Biooonds Area a. When working near the biodisc operation and the biodisc shaft covers are not being ventilated. b. When using compressed air to fluidize resin in Pond t. E. Exposure Protection Guidelines This section covers work practices which help to minimize employee exposure to VCM, regardless of whether or not respiratory protectic is used. In general, this includes VCM exposure caused by perfor nance of certain jobs, and VCM exposure caused by unknowingly beir. in an area which has a high VCM concentration. 1. Hazardous Job Posting Whenever any job is performed in which VCM will potentially t dispersed around the workplace, hazardous job signs must b posted around the site in order to warn passerbys. These sicr. read "DANGER - POTENTIAL VCM EXPOSURE AREA - RESPIRATOR REQUIRED." Personnel are not to enter marked oiif areas unless they are wearing respiratory protection, or they have obtained verification from a calibrated HNU that the area is safe to enter without a respirator. The following jobs are hazardous, and must be posted as such. a. VCM or VCM-contaminated filter changes. b. Vessel Opening and cleanout. c. Fiushout of VCM-contaminated material to grade or sewer. d. VCM leak repair. 2. Filter Cleaning, Removal and Replacement The following procedure must be used when changing filters vhic have been in contact with VCM. a. Steam nurge and recover the filter to the process until a vacuum .s reached. b. The (Operator must put on a fresh ai.r mask, Impervious glove and Impervious suit. ABD002281I0 EMGIKEERIKC AMD WORK PRACTICE CONTROLS QSHA VCM STANDARD c. Post hazardous job signs around the area of the filter. d. Change the filters. e. Dispose of the used filters in accordance with Section (I)(B)(7) of this manual. 3. Pump, Condenser, Subcooler, Line and Vessel Maintenance The following procedure must be used when performing maintenance on lines, vessels, subcoolers and condensers which have contained VCM. a. The equipment must be evacuated or flushed out until free cf VC'i as detected by the HNU portable hydrocarbon detector. b. Post hazardous job signs around the area of the equipment to be opened, if VCM is still present in the equipment. c. Open the equipment. d. Dispose of any VCM-contaminated waste material in accor dance with Section (I)(B)(7) of this manual, where applicable. e. When drilling a reactor condenser, perform work using an air mover on the Lenape manway for ventilation of the condenser. 4. Opening Manhead on Empty Reactor The following procedure must be used when opening the manhead on a reactor. a. Check the external pressure gauge to insure that the reactor is not i/nder pressure. % b. Unlatch the manhead roll bar, and crack the manway. c. Radio the panel operator to open the evacuation jet to the reactor. This will move air inward and disperse VCM vapors. d. Open manhead completely, after verifying that the evacuation jets are on. e. Inspect reactor. RQTF: The manhead la not ooened alter every reaction but only periodically to cheek the internal condition. ABD00228171 ENGINEERING AND WORK PRACTICE CONTROLS OSHA VCM STANDARD 5. Manual Reactor Entrv The following procedure must be used when entering a reactor. a. Open manhead using the procedure described in Section (B)(4). b. Follow equipment entry procedure as described in Attachment "A" of Safety and Health Manual. c. Perform work using a Lenape-mounted air mover for ventilation of the reactor. Entry without a respirator can be permitted if the supervisor has verified that the VCM concentration inside the reactor is less than 1 ppm. d. Close the top manhead. e. Hydrostatically test reactor for leakage. 6. VCM Leak Detection And Elimination VCM leaks which are detected by any of the following means, or by any other means, must be expeditiously isolated and repaired within a reasonable period of time. a. The continuous monitoring system data logging computer notifies the panel operator with a panel alarm whenever the monitor picks up three consecutive readings above 5 ppm on an individual stream. Following awareness of a leak condition, a reasonable effort must be made by the operating department to locate the leak and isolate it. b. A weekly VCM Leak Survey is conducted with an HNU. This survey checks a substantial number of potential VCM Leak sources in the plant. c. A more thorough VCM Leak' Survey then required in Section (T)(B)(6)(b) is conducted at least once per year, in which every flange, gasket and fitting on equipment in VCM service is checked with an HNU. Isolation Of VCM - Contaminated Wastes . waste material v'nic:: is contaminated with a significant quantitv - VCM, as determined with a calibrated HNU, must be moved nvav from : ' t aerations and personnel before being dumped in the plant's lo u Luposa.L bins. Suer, wastes nay be moved to che plant's waste usa] bins after taey have aerated long enough to strip out VCM. ' ri:ied by a calibrated HNU. Examples or candidate wastes are i titers, vessel clean-out debris, coarse resin, etc. ABD00228172 A ENGINEERING AND WORK PRACTICE CONTROLS OSHA VCM STANDARD \ C. ?VC And VCM Sample Panelling Guidelines 1. PVC Resin Analysis PVC resin, in small individual samples, is brought to the Laboratory for the performance of certain physical tests. The following work practices apply to handling of dry PVC resin. a. Samples fresh from the dryer department should not exceed 3 pounds. This will limit exposure to residuals of VCM in resin. b. Upon completion of testing, sample to be retained is stored on sample shelves. .Any spillage is immediately swept up and alone with samples not to be retained, discarded in a waste can and removed from the area to be placed in a waste box outside tie Laboratory. 2. VCM Analysis From time to time it will be necessary to perform chemical no..-: A . on samples of VCM. These samples are taken from various r the process stream in stainless steel pressure vessels. .k-- : ing work practices apply to the handling and testing of VCM in the Laboratory. a. When pressure vessels are brought to the lab fer ana lyn : >. must be placed in a fume hood for storage. b. Any transfer and testing of VCM shall take place in ::a vent heed. Technician will wear impervious gloves wr.er. ferring liquid VCM. ABD00228173 ENGINEERING AND WORK PRACTICE CONTROLS OSHA VCM STANDARD II. ENGINEERING CONTROLS A. Exposure Reduction Projects To Be Installed 1. Recovery System Improvements This project will inprove operation of the large recovery sys tems bv installing additional recovery system instrumentation. Problems with the recovery systems that are caused by reactor foaming will also be reduced by this project. Currently, employees are exposed to VCM when the recovery systems are opened in order to clear resin out of the equipment. Target Completion Date: 4/85 2. Elevation Of Reactor Evacuation Stacks This project will elevate the reactor evacuation stacks in order to improve atmospheric dispersion of the plumes. Currently, plumes from the reactor evacuation stacks impinge on the tops : the reactors when certain wind conditions prevail. Target Completion Date: 7/84 3. Recovery System Drain And Flush Revisions This project will install additional and improved high pressur-. service water connections and drains on several pieces or equip ment in the recovery areas. Installation of this project result in better recovery of VCM that must be removed from recovery systems when they are opened for maintenance. Target Completion Date: 10/84 4. Biodisc Exhausters This project will install fans on the biodisc shaft covers order to ventilate the biodisc unit. Currently, VCM stripped out of the wastewater in the bicdisc unit, and contaminated air disperses around the biodisc unit. :r Target Completion Date: 12/8? Improved Compliance With MPA VCM Standard This project will install additional high corner.: ` v pressure alarms on reactor:;, ami '..'ill collect ere from six small relief valves in the old module. Target Completion Date: 7/84 ENGINEERING AND WORK PRACTICE CONTROLS OSHA VCM STANDARD Completed Exposure Reduction Projects 1. General Plant a. Continuous Flow Fresh Air System fc. Fixed Point Monitor, Data Logging Computer and Warning Lights c. Emission Recovery System g. Process Vent Containment (sphere, bullets and reactors'; e. Relict Valve Leakage Reduction (rupture discs) f. Improved Rupture Disc Holders 2. VCM Tank Farm Area a. VCM Unloading Compressor Seals b. VCM Transfer Pumo Seals e. Railcar Unloading Arm Revisions g. General Compressor Revisions (process piping simplifica tions ) e. VCM Unloading Revisions (unloading line K.O. pot. sphere alarms) 3. Reactor Xrea a. Emergency aMS Rill System b. Steam Stripping c. Vent Gas Incineration System And Spare d. VCM Puma Seals e. Compressor-Vacuum Pump Sea Ls lat ch Water Su ipnine Pvstem Process Waste Water Conta Lament 'receivers and recover-.svstens) u Reactor i.'oubie .unnr.re Disc ,:o i acemont m V? ABD00228175k '-.i'.l #. W vtJ.t, .*1 n'wI i gfn'* rS^wvaV ENGINEERING AMD WORK PRACTICE CONTROLS OSHA VCM STANDARD i. Emergency Cooling For Reactors j. Receiver High Level Alarms Laboratory a. Laboratory Analysis Hood Revisions