Document jB2gyXeGO15zR50N2kaQB42Bp

(conoco) Interoffice Communication to OSHA-Engineering andWork ControlPlan File From 0. Paul Warner Date April, 1979 Subject UPDATE OF ENGINEERING AND WORKPRACTICE CONTROL PLAN Attached is an update of the Plant's engineering and work practice controls 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 start-up of the EPA compliance equipment has significantly reduced VCM levels in the Plant. Currently, however, we are having to rely on breathing air to limit the VCM exposure from some exposure sources. J. J. PAUL WARNER Process Engineer CONOCO Chemicals Company Oklahoma City Chemical Plant Approved: OpHlTCFRieND Hant Manager CONOCO Chemicals Company Oklahoma City Chemical Plant JPW-spt Attachment CC: JF, AWS, KLF, JWW, WHN, RP, LAH, JBE, REB, DPB CCR 000010498 Exposure Source 1. Residual monomer in slurry and resin. 2. Obtaining and handling samples. 3. VCM railcar. 4. Chemical wash screen. ENGINEERING AND WORK PRACTICE CONTROL PLAN FOR COMPLIANCE WITH OSHA VCM EXPOSURE STANDARD CONOCO CHEMICALS OKLAHOMA CITY PVC PLANT April, 1979 Work Practice Controls (D gineering 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 400 PPM VCM after steam stripping. lb. After the slurry is dumped from the reactors to the blend tanks, the slurry is stripped with air to further reduce the VCM concentration. Tests show that the VCM content of the dried resin is below 5 PPM when the combination of steam and air stripping is used. 2. Wear personnel protection equipment which meets OSHA standards when VCM samples or reactor samples are obtained. 1 a. Preliminary design work is in progress to replace the existing dump system with an enclosed system. 1 A design for removing the blend tank vents from the process area is being developed. 2 A design for a closed reactor system is being developed. VCM from the samples will*be routed to a control system. 3. Wear personnel protection equipment which meets OSHA standards while connecting and disconnecting tank cars. 4. Steam stripping of all batches has reduced the possibility of exposure from this source. 4 A class "A" design for improving the screener ventilation has been prepared and equipment is being placed on order. CCR 000010 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. i-li. . Exposure Source ENGINEERING AND WORK PRACTICE CONTROL PLAN FOR COMPLIANCE WITH OSHA VCM EXPOSURE STANDARD CONOCO CHEMICALS OKLAHOMA CITY PVC PLANT April, 1979 (Continued) o)Work Practice Controls Engineering Controls 5. Reactor rinse after dump. 6. Flexible hoses, pipe unions and flanges, valve stems and swivel joints in VCM service. 7. Opening and working on equipment or piping which may contain VCM. o o jo 5. Transfer the effluent from the initial water rinse after reactor dump to the dump system. 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 can not be repaired immediately. 7a. Before opening, VCM is removed from equipment or piping to the lowest practical level by flushing, purging and/or evacuation where possible. 7b. Wear personnel protection equipment which meets OSHA standards when open ing 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. 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. 000010500