Document e1MY88KKXdVr3M3JvzoREEGOy

Interoffice Communication To : Vinyl Shift Supervisors From : J. E. Barton Date ; March 20, 1979 Subject : EPA COMPLIANCE (conoco) / 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 Maximum Temperature Maximum Pressure 5385, 5425, 5465 142F 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.O.) short stop system. CAUTION: N.Q. 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. DTH 000086970 EPA Compliance March 20, 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. 7. Copies of the procedures for the Old Unit, New Unit, and Dryers will be placed on the table between the Lead Operators' desks in the control room. There will also be copies in the Shift Supervisor's 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 would like to have all the meetings completed by 4/8/79. c: CLM, ELK, RAF, Shift Supervisors (5) UJH 00008697: WORK f'f\U OS!!A Vi U )N I KOI i TANDARU II. m.ACIOR ARIVAS Tii o purpose of the v i ny 1 react or s i s t o coin ert v 1 n y 1 eh I or i di monomer into po 1 yv i in 1 eh I c r ido re s i n (l'\ 0 ) . Several ol: the ope rat or fm et ions in the largo reactor aroi can result in ACM exposure . The fn 1 low i ng re I at es to those work practices kIi i ch are a! I'ee t cd by pr t ent i a 1 VOM emissions. A. Opening Manhead on bmp: y Rene tor 1. dheek the ex t e rna 1 p i e s s ure gauge t o insure that the re a e. t or i s no' mnl r pi m sure . 2 . Put on the cunt i minis Hue I'resh air 1 > r r: a t h i ng mask. a. Unlatch the manhead roll bar. 4. Radio panel operator to open rva ai.i t i en ict t o the reactor. I h 1 will more air1 inward and d i spersi Uhl vapors. h . Open manhead completely. (i. Inspect: reactor. NO II.: 1 lie manhead is not opened aider eve rv react i on hut only periodiea 11y t o cheek the intern il condition. 11. Manua 1 Reactor lint ry 1. Open manhead us i ng t he procedure described in A. 2. hollow equipment ent ry procedure as described in Attachment ''A" ot' Safety and Health Manual. 3 . (Hose the top man lead . 4. 11 vd ros t a t i c a 1 1 y test reactoi' for 1 oak a go . 0 . React or Recovery Unroaet ed V( M is row vrd f rom the po 1 \ nier i: a l ion react oi slurry by the recovery systcm. 4 he recovery system cons i s t s of vacuum pi imp s , coni] rcssors and condense rs which remove the YtIM from the realtor, compress, and condense it: so that it can be rccy led tc the process. Ope rating per:sonne1 DTH 000086972 \C SOU ARIAS - QV, i I Sill.H Reactor Recover)' - Continued are required in tin' rev :>ve rv a rea during system st art up and for periodic checks during the recove rv. The recove ry area is iwm i to red for VC! I I eve 1 s from the Cont ml Room. The operator i a alerted hv i ad i o before entering the area if the \ CM love 1 is above 1.0 ppm. Reactor 1 U_inip i ng humping of the react or slnrrv occurs at the end of the V(I stripping epe rat: i or . I lie operator obse rv i ii't the dump does not need to near a (if RAM under norna 1 condition. Tins a veil is monitored from the emit i nl room and the operator i s not i f i 'd i f t he VCM level i s a hove' 1.0 ppm. Ahnormal coiul i t i mis requiring a ('ll \M are: 1 . I' lugged rractor dump valve nr line. 2. Humping a coarse hatch. 7>. Cleaning bump Swec >. d. Inoperative Swcco ' \ 11; n i : -1er. filter Cleaning, Removal and Re]' 1 act iieut 111 C following information ape 1 i rs to t he Reel' vei'ed VC?-' hilt e rs l: resli VCM F i 11 e r-' Seal Water i: i Iters (Compressors I liese filters come in com act with VCM and t here fore arc pot cutia 1 exposure sources . The filter pad: is st < am purged and recovered to the process. 1 lie recover) syst em pul Is a vacuum on the filter pack 'prior to opening. 'flu; operator then put on a Clh'AM, impervious gloves and an i mpe rv i ous sin t . F . Condenser . Snhcooler, Fine and Vessel Ma i n t dinner llie folloning precautions are required to prevent VCM exposure while perfotii ing maintenance on lines, vessels, snhcooler and condensers. DTH 000086973 riR \i;i.\s - coNiiNin.it ( omleiiser , Kubcoo lor, I,i ne ami \ ess" I M;i i n t enance (iont i iuksI 1 . The equipment must I r lilt mleil at all inlets ami outlets. . The unit is to he lliishnl or uvaenut ml until I' ree of VC'I as ile t ce toil by the HNU OVA instrument, 1 he reactor opera' i nr. a rc;i rani i ant. farm are rout i noons 1 v non i to red for hiyli VOM amrnit r.it ions by the lloneywe 1 1 unit loe.ateil in the reactor aunt rel room. DTH 000086974