Document jB5qmVL3NoE5Nk8E6rRwGd2py

PLANT "A" ENVIRONMENTAL SURVEY PART III SHIPPING DEPARTMENT M-9223 A/ // d ' sv- Authors: Cliff Beadle Rick Gros Carey Hardaway Darrell Moore Andy Plauche' Barney Tyson Shipping Shipping Process Engineering Shipping (Chairman) Environmental Operations Distribution: T. G. Brown (abstract only) A. J. Kubicek (abstract only) J. M. Porter R. 0. Whitaker/J. W. Hutchins/C. A. Muery Jr LaFleur D. Fontenot j. Taylor R. Ogea Shi ft Superintendent Shi pping Shift Foreman D. L. Moore C. J, Hardaway A. Plauche' B. Tyson SL 087204 ABSTRACT A task force was assigned to conduct an environmental survey of Plant A Shipping areas. The task force members were comprised of personnel from Plant A Shipping, Operations and Technical Departments and the Environmental Department. The survey was conducted February 26 - March 1, 1985. The task force reviewed environmental regulations and past environmental upsets pertaining to the Plant A Shipping operation. During the survey, the environmental condition of each shipping area was evaluated, loading procedures were examined, and hourly and supervisory Shipping personnel were interviewed. Two major problem areas were identified: 1) Outfall 021 receives process water from the chlorine tank car and ton cylinder test areas. This outfall is permitted only for storm run-off and once through, non-contaminated cooling water; 2) Proper material handling and the containment of spills is inadequate for organic products which have a one pound minimum reportable release quantity. These products are: ethyl chloride, vinyl chloride, trichloroethane and perch!oroethylene. Other problems found during the survey for the most part were minor in nature. Recommendations for rectification of these problems are given. Some recommendations may involve engineering and construction. They include the elevation of dock loading lines, construction of organic sumps at the dock areas and the relocation of test facility drains to the 30" process sewer. The relocation of test facility drains to the 30" process sewer is part of engineering project P-1031, which is awaiting approval from the General Office at this writing. SL 087205 -2 INTRODUCTION The purpose of this report is to present the findings of the Plant A Shipping Department environmental survey. The survey was conducted to identify environmental problem areas and recommend corrective action as needed. The task force organized to conduct the survey was made up of the following people: Darrell Moore Carey Hardaway Andy Plauche' Cliff Beadle Rick Gros Barney Tyson Shipping (Chairman) Process Engineering Environmental Shipping Shipping Operations The survey was conducted from February 26 to March 1, 1985 and completes the review of Plant A from an environmental point of view. Two other surveys conducted in 1984 identified problems in all Plant A operating areas. The findings of these surveys are contained in two reports, "Plant A Environmental Survey, Part I - North Half" and "Plant A Environmental Survey, Part II - South Half". PROCEDURE This section will outline the basic steps that the task force took to conduct the Shipping environmental survey. I. Review of Shipping Related Environmental Upsets The task force obtained a list of reported environmental upsets which had occurred over the last 2i years. These upsets were reviewed before any actual surveying was done. Each upset was discussed with recognition given to the cause and possible prevention. The problems identified were given close attention during the actual survey. The environmental reports for each upset reviewed is included in the appendix of this report. II. Survey of All Plant A Shipping Areas Plant A Shipping was divided into the following major areas: 1) Chlorine tank car prep and loading stations, including the valve repair and test areas. 2) Chlorine tank car test area, including the caustic car used for a vent scrubber. 3) Heavy chlorine tank car unloading, patio (chlorine valve manifold area for tank car loading), and sniff tank. 4) Ton cylinder building. 5) Tank car repair shop area. 6) Caustic truck loading facility. 7) Caustic tank car loading area. 8) Barge and ship loading docks (A B C D & E), 9) Organics storage tank area. 10) Sulfuric acid unloading at Liquefaction and Mercury Cell. -2.1- SL 087206 The task force surveyed each of the areas. Upon arrival in each area, the products and potential wastes that were being handled were pointed out as well as which outfall or part of the environment would be affected should a spill occur. Procedures for handling the product/potential waste were explained and sometimes demonstrated. The condition of the equipment and overall area was evaluated for how it could effect the environment. Past environmental problems (not necessarily reported) were discussed. Questions and comments were directed to personnel working in the area. Notes were taken by all members of the task force. III. Wrap-up Session for Each Area At the end of each day, the task force would discuss the major items found in each area. Risk analysis and recommendations for improvements were determined. Questions on specific items were prepared for the interview with the foremen and supervisors of the area. IV. Interview With Foremen and Supervisors of Each Area The interviews presented the information found during the survey to the foremen and supervisors in the Plant A Shipping Department. Questions were answered and recommendations for improvements were discussed. ENVIRONMENTAL REGULATIONS This section will describe the environmental regulations that pertain to the Plant A Shipping area. The regulations deal with limiting the number of accidental chemical spills to the environment and quality of all the plant's effluent streams. The regulations discussed in this report will be in the four following areas: I. Non-containable and Non-treatable Spills and Vapor Releases of Chemicals Found in the Plant A Shipping Area II. Plant A Shipping Effluent Outfalls - Regulations and Monitoring III. Regulations for Plant A Shipping Dock Facilities IV. Other Environmental Considerations I. Non-containable and Non-treatable Spills and Vapor Releases of Chemicals Found in the Plant A Shipping Area' When a chemical is released to the environment where it cannot be contained and recovered or treated at a permitted location, the amount of the release must be determined and promptly reported to the appropriate Plant A Shipping supervisor. If the amount exceeds the minimum reportable quantity listed below, the chemical release must be reported to the proper environmental agency (done by PPG's Environmental Control Department). -3- SL 087207 Minimum Reportable Quantities for Chemicals in Plant A Shipping Chemical Minimum Reportable Quantity Chlorine Ethyl Chloride Ethylene Dichloride Perchloroethylene Sodium Hydroxide (Ab) Sulfuric Acid Trichloroethane (1,1,1) Trichloroethylene Vinyl Chloride 10 lbs 1 lb 5.000 lbs 1 lb 1.000 lbs 1,000 lbs 1 lb 1,000 lbs 1 lb Oil - the minimum reportable quantity of an oil spill is any amount that creates a sheen in the effluent or outfall. Due to safety factors and the many other environmental considerations, it must always be stressed that al1 chemical spills be promptly reported to supervision whether the minimum reportable quantity was exceeded or not. Plant A Shipping Effluent Outfalls - Regulations and Monitoring Nearly all liquids which flow out of the process and shipping areas of the plant are routed through outfalls. Outfalls throughout the plant are distinguished by their location and are permitted by the National Pollutant Discharge Elimination Systems (NPDES) for type of effluent, type of monitoring and limitations placed on them. General information about Plant A Shipping outfalls are listed below. Drawings and outfall permits are contained in the appendix. A. Outfall 014, 001 Outfall 014 is presently an internal monitoring station which collects process effluents from Mercury Cell (outfalls Oil and 111), Plant A Electrolyzer Chlorine process waste water and once-through cooling water, and process streams from the north half of Plant A. Outfall 014 is commonly referred to as the 30" process sewer. Some drainage from the caustic car loading area is collected and sent to the 30" sewer. Outfall 014 discharges into the PPG canal which flows through outfall 001. Outfall 001 is the final monitoring point for PPG's process waste water. It is monitored for flow, temperature, pH, mercury, and organics. The pH is recorded in the Shift Superintendent's office. The acceptable pH range is 6 to 9. Any pH value which is outside of the range of 4 to 11 is a reportable violation. Any pH outside the range of 6 to 9 is known as an excursion. Excursions which exceed one hour become reportable violations. -4- SL 087208 The 30" process sewer is monitored for pH at the southwest corner of the rectifier building. This pH is indicated in the Plant A Electrolyzer Chlorine control room, Plant A Caustic control room and the Shift Superintendent's office. This pH monitoring is used to identify pH upsets before the flow reaches outfall 001. Outfall 014 has a chlorine and pH monitor which is indicated in the Shift Superintendent's office. A high chlorine alarm is in the guard office. A grab sample is caught once per shift by the Electrolyzer operator. The sample point is located at the 30" process sewer pH monitoring probe. The sample is analyzed for pH and chlorine. B. Outfall 021 Outfall 021 discharges north of the 50% caustic storage tanks 108, 109 and 110 into Bayou Verdine (01 in Ditch). The north and south 54" and north 72" sewers combine to form outfall 021. In the Plant A Shipping area these sewers primarily collect surface drainage from the caustic car and truck loading, car repair shop and chlorine car loading areas. Elsewhere outfall 021 collects the surface runoff from the Pels area tank farm, north and south liquefaction, brine treatment and sulfur chloride areas. Areas with once-through uncontaminated cooling water are the Plant A Caustic B set weak pan condenser, anhydrous concentrator condensers, and the Pels coolers. Outfall 021 is currently permitted to discharge only surface runoff and once-through uncontaminated cooling water. There are no other limitations established in the permit. The outfall is monitored continuously for flow, pH and temperature. The results are recorded in the Pels control room. High and low pH alarms are set for 9 and 6 respectively. Strip charts and log sheets are saved and sent to the Records Department. C. Outfall 024 Outfall 024 discharges into the Calcasieu River. It collects storm runoff from Powerhouse A, overflows from the rainwater collection tank and sump and the surface drainage from the caustic and chlorinated hydrocarbon dock storage areas. Outfall 024 is permitted for surface drainage and must maintain a pH level between 6 and 11. The pH is monitored via 5 grab samples per week (when flowing). D. Outfall 005 Outfall 005 discharges into the PPG barge slip and collects oncethrough cooling water from Plant A Electrolyzer Chlorine, treated sanitary waste water from Plant A, storm runoff from Powerhouse A, and surface drainage from the caustic and chlorinated hydrocarbon dock storage areas. The permit limits the pH from this outfall to be between 6 and 9. The pH is monitored 3 times a week via grab samples. -5- SL 087209 III. Regulations for Plant A Shipping Dock Facilities The environmental regulations for loading products on barges and ships fall under the jurisdiction of the U.S. Coast Guard. A detailed description of these regulations would be beyond the scope of this report. Copies of the regulations can be obtained from the Plant A Shipping Department. Extensive training in these regulations is required for all licensed tankermen. Currently the shipping lead tankermen are licensed. In addition to the U.S. Coast Guard regulations, the EPA regulations are also in effect while loading ships and barges unless the Coast Guard regulations specifically state otherwise. IV. Other Environmental Considerations Many more environmental regulations exists than have been covered in this section of the report. In order to assure the compliance of all environmental regulations, it must always be stressed that all spills and environmental upsets be reported to supervision. Prompt action in reporting gas releases and spills is also necessary. A chlorine gas release could involve coordination between PPG supervision and the State Police to safely secure sections of highways. A chemical spill on the ground that doesn't even reach an outfall ditch could involve the immediate excavation and proper disposal of the area that collected the spill. The Environmental Control department has the responsibility of identifying and defining the environmental regulations and reporting environmental upsets to the proper authorities. But, it is the responsibility of each employee to report any and all environmental upsets. SURVEY REPORT This section contains an area-by-area outline of the task force findings during the Plant A Shipping environmental survey. Descriptions of existing or potential problems are given along with an analysis of the risk involved. The risk analysis for the major sources of environmental upsets ranges from High to Rare. These are used to give some indication of the overall probability of the upset occurring as well as the frequency and quantity of pollutant. The risk is assigned based on the analysis of the survey task force, and may differ from that of the General Foreman or Environmental Department. However, the risk can be used as a guideline by which area priorities can be arranged. The risk assigned to each item is on the basis of the environmental impact it has and not on the safety aspect. High Risk: pollutant. outfalls. Occurs frequently or results in large amounts of the listed These items appear frequently in historical records of the Moderate Risk: Occurs often enough to be an area of concern, but rarely results in violations. Low Risk: These upsets are uncommon. Rare: These items are mostly potentials only, where an actual upset is not expected and in most cases have never occurred. Major cause of these upsets would be human error or extremely unlikely conditions. -6- SL 087210 The comments in this section pertain only to the environmental condition of the area when it was surveyed. Recommendations are given in a latter section of this report. I. Area: Chlorine Tank Car Loading Rack A) Description: Chlorine leaks in valves, fittings and hose connections while loading or preparing a chlorine car. Pollutant: Chlorine in the air Risk: Low Comments: 1) Leaks are infrequent on valves and flanges and are promptly repaired. Leaks are readily detected with ammonia water. 2) Hose leaks are due to the hose becoming old and worn. Some hoses get worn spots due to the way they are bent while in the process of connecting and disconnecting them. 3) During chlorine loading, hose and fitting leaks are sometimes checked by pressurizing with liquid chlorine. If a leak should occur, the line must be isolated, cleared and broken at the leaking fitting for repair. The use of liquid chlorine for leak testing along with improper line clearing increases the chance of chlorine release. 4) Proper clearing of chlorine through the sniff system takes longer with the ton cylinder valve and 3/8" copper tubing connection than it previously did with a 1" valve and 1" piping connection. However, the "old" 1" sniff valve required constant maintenance to reduce leakage, whereas the ton valves require little maintenance. A search for a better valve is being made. 5) A small amount of chlorine is released when a vapor sample is collected from the car. The method used is to purge the burette to the air with the chlorine sample before catching the sample. 6) The installation of 3" globe valves to replace 3" ball valves has helped in reducing chlorine leaks from idle prep stations. Required plugging of the idle hose connections has also helped. Some hoses were found not to be plugged. 7) Installation of automatic block valves on the chlorine lines at the loading stations provide a safe and fast way to block the flow of chlorine should a leak occur. B) Description: Grease and triethane' ' spills at the valve repair and test area. ,R, Pollutant: Oil sheen and triethane'K' spill to outfall 021. Risk: Rare /Rv Comments: 1) Handling triethane^ is critical because there is a one pound minimum reportable quantity should a s&vM occur. 2) Possible spillage of triethane'K' could be caused from a) improper disposal, b) carrying triethane in buckets c) overflowing the collection basin or collection drum downstairs. Triethanei^ is disposed of via drums which are supplied to catch used triethane' '. 3) Steam cleaning is used at the 1" angle valve repair area for removing grease from chlorine tank car valves. The steam cleaning drain discharges to outfall 021 via surface drainage sewers and creates a potential for an oil sheen at outfall 021. This discharge is considered to be a process stream and out, all 021 is not permitted for process streams. -7- SL 087211 C) Description: Chlorine release at powerhouse stack while blowing down cars or barges. Pollutant: Chlorine in the air Risk: Low Comments: 1) When waste chlorine in the 8, 6 and 4 inch lines is being neutralized at Mercury Cell, a large blowdown of a car or barge could cause a sudden buildup of pressure in the absorber or neutralizer. If the high pressure trip limit is reached in the absorber or neutralizer, the automatic valves on the 8 and 6 inch lines will divert the flow of chlorine from Mercury Cell to the powerhouse stack. The 4 inch shipping blowdown automatic valve will shut off the blowdown flow. 2) Shipping personnel are instructed to call Mercury Cell prior to blowing down a car or barge. 3) Mercury Cell personnel are instructed to manually trip the 4 inch blowdown header should the blowdown cause the pressure in the absorber or neutralizer to approach the trip limit. Area: Chlorine Tank Car Test Rack A) Description: Chlorine leaks from hose connections and piping while bTowing down. Pollutant: Chlorine in the air Risk: Low Comments: 1) Leaks are infrequent on valves and flanges and are promptly repaired. Leaks are readily detected with ammonia water. 2) Hose leaks are due to the hose becoming old and worn. Some hoses get worn spots due to the way they are bent while in the process of connecting and disconnecting them. 3) Proper clearing of chlorine through the sniff system takes longer with the ton cylinder valve and 3/8" copper tubing connection than it previously did with a 1" valve and 1" piping connection. However, the "old" 1" sniff valve required constant maintenance to reduce leakage, whereas the ton valves require little maintenance. A search for a better valve is being made. B) Description: Chlorine release at powerhouse stack while blowdown down car. Pollutant: Chlorine in the air Risk: Low Comments: 1) When the 8, 6 and 4 inch waste chlorine lines are being neutralized at Mercury Cell, a large blowdown of a car or barge could cause a sudden buildup of pressure in the absorber or neutralizer. If the high pressure trip limit is reached in the absorber or neutralizer, the automatic valves on the 8 and 6 inch lines will divert the flow of chlorine from Mercury Cell to the powerhouse stack. The 4 inch shipping blowdown automatic valve will shut off the blowdown flow. 2) Shipping personnel are instructed to call Mercury Cell prior to blowing down a car or barge. 3) Mercury Cell personnel are instructed to manually trip the 4 inch blowdown header should the blowdown cause the pressure in the absorber or neutralizer to approach the trip limit. -8- SL 087212 C) Description: Chlorine release or caustic spill while filling car with water. Pollutant: Chlorine in the air and/or Caustic spillage in outfall 021 ftislT: Low Comments: 1) While filling a test car with water, vapors are vented to a caustic car where chlorine can be neutralized. The caustic car is located at the sulfuric acid unloading station. 2) A chlorine release could be caused from a) rupture in the PVC vent line, b) improper vent line hook-up to the caustic car, c) low liquid level in the caustic car and d) insufficient caustic concentration in the caustic car. 3) A caustic spill to outfall 021 could occur if the vapor/liquid check valve on the vent line fails (often does) and water flows through the vent line overflowing the caustic car. 4) The caustic car is replenished with caustic at the caustic tank car loading rack. When the caustic car gets too full, a vacuum truck removes some of the weak caustic and either puts it into the Shift Superintendent's outfall 001 caustic tank or the Plant B Waste Treatment Unit bleach storage tank, depending on the hypochlorite concentration. 5) Whenever a sulfuric acid car is unloaded all venting from the test car rack is stopped. The "absences" of the caustic car is logged in the log book. D) Description: Draining hydrostatic test water to outfall 021. Pollutant: Process water to a non-permitted sewer, pH upsets in outfall Wl Risk: High Comments: Outfall 021 is not permitted for any process streams. Only surface drainage and uncontaminated once-through cooling water are permissible. III. Area: Heavy Tank Car Unloading, Patio and Sniff Tank A) Description: Chlorine leaks in valves, fittings and hose connections while unloading heavy tank cars. Pol 1utants: Chlorine in the air Risk: Low Comments: 1) Leaks are infrequent on valves and flanges and are promptly repaired. Leaks are readily detected with ammonia water. 2) Hose leaks are due to the hose becoming old and worn. Some hoses get worn spots due to the way they are bent while in the process of connecting and disconnecting them. B) Description: Vacuum loss is sniff system while sampling a heavy chlorine car. Pollutant: Chlorine in the air Risk: Rare Comments: Liquid chlorine is purged to the sniff system while sampling a heavy chlorine car. Having liquid chlorine in the sniff system piping presents the risk of lossing the sniff system vacuum and possibly causing chlorine to leak at another location where the sniff system is in use. There was -o indication that this has ever been a problem before. -9SL 087213 C) Description: Undesired movement of railroad car while unloading Pol 1utantT~ Chlorine in the air Riskl Rare Comments: 1) This risk potential applies for all stations that service rai1 road cars whether it is for chlorine, caustic or acid.It is mentioned in this section because of one such occurrence while unloading a heavy chlorine car. 2) To prevent future occurrences, much attention has been given to stress the required use of brakes and chocks on the car being serviced as well as the proper use of derails and blue flags. D) Description: Chlorine leaks in valves and expansion bottles on the patio Pollutant: Chlorine in the air Risk: Low Comments: 1) Newer types of valves and packing has reduced the potential for valve leaks. Other types of valves are being tested. 2) The expansion bottles have not been within plant specifications. This can cause problems at weak points in the system such as valves and flanges because adequate expansion was not supplied. Presently work is being done to meet the specifications. This will reduce the possibility of a chlorine release due to lack of expansion space. E) Description: Draining the sniff tank to outfall 021 Pollutant: Process water to a non-permitted sewer, low pH upsets in outfall 021 Risk: Rare Comments: Work has already been planned to adapt the sniff tank drain 1ine for vacuum trucks. Area: Ton Cylinder Building A) Description: Chlorine leaks while loading cylinders Pollutant: Chlorine in the air Risk: Low Comments: 1) Minor leaks can be easily corrected. 2) There is a potential for the copper tubing filling line to break and release liquid chlorine. Breaks can occur from high pressure "blowing out" weak points or personnel tripping over the tubing. B) Description: Chlorine venting to atmosphere at the ton cylinder test area Pollutant: Chlorine in the air Risk: High Comments: Chlorine ton cylinders being tested are vented to the atmosphere (just outside ton cylinder building) while steaming or filling with hydrostatic test water. C) Description: Draining hydrostatic test water from ton cylinder to outfall 021 Pollutant: Process water to a non-permitted sewer Ri sk: Higi. Comments: Outfall 021 is not permitted for any process streams. -10- SL 087214 V. Area: Tank Car Repair Shop A) Description: Draining excess material left in cars to outfall 021 PollutantT" The material which was last loaded into the car. Risk: Rare Comments: Outfall 021 is not permitted for any process streams. B) Description: Oil spills creating oil sheens at outfall 021 PollutantT- Oil sheen at outfall 021 Risk: Rare Comments: Lubrication oil from car wheel systems that have not been converted to roller bearings is stored in a drum and is picked up for disposal by the oiler. This hazard will be eliminated as wheel systems are converted to roller bearings. VI. Area: Caustic Truck Loading A) Description: Spillage not contained by the truck loading sump. Pollutant!" Caustic spill. High pH in outfall 021. Risk: Rare Comments: 1) The truck loading sump is pumped to the 50% area overflow sump. I valve on the east boundary of the truck loading platform can be opened to allow the truck loading sump to overflow to the 50% area sump. 2) Spillage not contained by the truck loading sump can occur because, a) truck dump valve is open when filling is initiated b) truck loading sump overflow valve is closed and sump pump is not running, c) caustic overfills and runs over the truck due to scale or automatic valve malfunction. VII. Area: Caustic Tank Car Loading A) Description: Caustic spills to outfall 021 Pollutant: Caustic spill. High pH upset at outfall 021. Risk: Cow Comments: 1) Spills to the ground that occur in the vicinity of the north tracks will be washed to outfall 021 via rainfall. 2) Overfilling a car has occurred due to inattention of the tankerman. Car levels are manually gauged while filling. 3) Belly pans are used to collect drainage of tank car washings. These pans can be bent by passing tank cars, tearing the pan away from its drain pipe. If this condition goes unnoticed, material can leak under the pan to the ground. In addition, splash screens used while draining wash water can become worn, losing their effectiveness in preventing splashing outside of the pans. 4) When unloading caustic from a car, splashing is avoided by using a 10" pipe designed to be placed under the nozzle allowing the liquid to drain out of holes located on the bottom. This apparatus could not be located at the time of the survey. 5) Automatic shut-off switches for the E-50 and MC-50 loading pumps are located on the loading platform. In addition to safety, these switches can help minimize spills due to pipe leaks and overflows. There were no switches for the 70% caustic loading pumps that were perational during the survey. Work orders have been written for the installation of switches and flange guards. -11- SL 087215 6) Steam that is used for clearing out the caustic tank car loading arms sometimes leaks into a loading arm when not in use. This causes caustic contaminated condensate to overflow from the raised end of the idle loading hose to the ground. B) Description: Caustic spills to 30" sewer PollutantT" Caustic causing possible high pH upset at outfall 001 Risk: Cow Comments: 1) Spills on the ground that occur in the vicinity of the south tracks will be washed to the 30" sewer. All caustic loading pump pads south of the tracks also drain to the 30" sewer. 2) All comments in Section VII, A apply. 3) Spills on the caustic loading pump pads can be caused as a result of packing leaks and improper drainage of caustic piping when caustic from the storage tank drains out of the pump suction bleed. I.Area: Barge and Ship Loading Docks, A, 8, C, D & E A) Description: Insufficient drainage of loading lines causing product to spirt into the river Pollutant: Ethyl chloride, vinyl chloride, trichloroethane and perchloroethylene will probably result in a reportable violation since the minimum reportable quantity is one pound. All the other products will also be addressed since it is desired to have nothing unnecessarily spilled into the river. Risk: High Comments: 1) Adequate provisions for the draining of loading lines and hoses downstream of the block valves did not exist except for the following: a) caustic at 'C' dock could be drained to the caustic sump b) vinyl chloride and ethyl chloride at 1D1 dock and 'A' dock would be cleared back to the Plant B incinerator (however other problems exist in clearing vinyl chloride lines at 'A' dock). 2) Instances were found where a nitrogen hose was used to drain the dock piping and loading hose to the river after attempts had been made to blow the piping through to the barge. 3) With regards to loading vinyl chloride at 'A' dock, some ships have an expansion spool piece which joins the loading hose to the block valve on the ship. There is usually no practical or timely way of draining the residual vinyl chloride left in the spool' piece. Instances were found where vinyl chloride spills resulted while disconnecting loading hoses from such spool pieces. B) Description: Spills caused by leaks in piping, hoses and fittings while loading product on a barge or ship Pollutant: Potential for spillage of all products into the river Risk: Moderate Comments: 1) Automatic shutdown switches for all the products at all of the docks exists and are periodically checked. Inadequate labeling was found on some switches. 2) Engineering is being done to relocate all product lines at 'C' dock in a pipe rack over the dock. This will eliminate undetected leaks. -12- 087216 SL 3) There was no means for spill containment on any dock should a hose or fitting leak develop. 'C', 'D', and *E1 docks have concrete surfaces suitable for curbing to contain spills. 4) Hoses are inspected yearly and are providing 3-5 years of service. 5) Flange leaks can occur due to the bad condition of customer barges. Description: Spills caused by pumping or draining material from barges. PollutantT~ Potential for any contaminant to enter the river R i sic: Low Comments: 1) Pumping water from the dry compartments of barges is necessary before loading the barge. This water is pumped via steam siphon to the river. Contamination of this water can be a result of leaks in the product storage compartments. There is no sampling routine established for determining if contamination of the water exists. Description: Chlorine leaks at 'B' dock Pollutant: Chlorine in the air Risk: Low Comments: 1) Leaks are infrequent on valves and flanges and are promptly repaired. Leaks are readily detected with ammonia water. 2) Crane valves in use at the supply manifold appear to be inferior to the Stockham valves which are in use at the chlorine tank car loading rack. Description: Diesel spillage around dock areas Pollutant: Diesel can cause an oil sheen at outfall 024 or on the river Risk: Low Comments: 1) Diesel storage tanks are located near 'D' dock and 'C' dock". These tanks are diked. The dikes are constructed of clay and shell and show wear in places where people step over them. 2) Po-tentialfor diesel spillage exist when filling the diesel tank on a barge. Any spill will go directly into the river. Tanks on barges aren't equipped with enclosed dikes. 3) Sufficient room must be left in the diesel tank after filling for expansion of the diesel when the temperature increases. 4) At 'C' dock, a bucket is used to collect diesel drips from the disconnected filling hose nozzle. Description: Hydraulic oil spill from dock loading cranes Pollutant: Oil sheen on river Risk: Rare Comments: 1) An oil sheen on the river can be caused from the rupture of a hydraulic oil line on one of the dock loading cranes. There are no provisions to contain such a spill. Description: Spills resulting in overflow of the caustic sump at 'C' dock Pollutant: Caustic spill at river Risk: High Comments: 1) Maintenance attention is required for sump pump to maintain full pumping capacity. Sump level is hard to maintain when pump problems develop. -13- SL 087217 2) The sump has a high level alarm which is located at 'C' dock. Instances were found where the personnel did not know what the alarm was for, which resulted in sump overflows. Area: Organics Storage Tanks A) Description: Spills resulting in leaks around pumps and transfer lines to the docks Pollutant: Spills of all products to river and outfalls 005, 021 & 024 Risk: Rare Comments: Pipe clamps have been used to repair leaks in transfer lines because of instances where the line could not be properly cleared in a timely manner. B) Description: Leaks in the trichloroethane storage tank, pump and filter area Pollutant: Trichloroethane spill to outfall 024 Risk: High Comments: 1) No containment for spills from triethane'K' tanks, pumps or filter exist. One dike wall which doesn't encircle anything has recently been formed to prevent leaks around the pumps and filters from flowing directly into the surface drainage ditch supplying outfall 024. 2) The triethanew filter has been a source of numerous leaks. The Shipping and Operation Departments are not certain of who has responsibility of the filter. ,R, 3) Spills and leaks of triethane'K' usually result in excavation and disposal of the area where the spill occurred. Area: Sulfuric Acid Unloading at Liquefaction & Mercury Cells A) Description: Acid spills resulting from hose and transfer line leaks PollutantT- Sulfuric acid spill to outfall 021 or the Powerhouse ditch. Low pH-upsets. Risk: Rare Comments: 1) Leaks in hoses and piping are rare and are promptly repaired. 2) A new unloading procedure has been written with respect to acid unloading at Mercury Cell. 3) There are no emergency air shut-off valves with bleeds to quickly depressurize the acid car should a leak occur. Such a device could reduce the amount of acid spilled. B) Description: Acid spills resulting in the overflow of a storage tank Pollutant!- Sulfuric acid spill to outfall 021 or the Powerhouse ditch. Low pH upsets. Risk: Rare Comments: 1) The storage tank level is monitored by the Shipping Department personnel while the car is being unloaded. Overflows can result from inattention to level monitoring or faulty gauges. 2) Sulfuric acid is being supplied in larger capacity tank cars. This increases the chance of overflowing a storage tank. -14- SL 087218 XI. Area: General Conclusions & Comments A) Description: Inspection of hazardous waste trucks leaving PPG boundary 1imits. Comments: The Shipping Shift Foreman inspects all hazardous waste trucks which leave the Lake Charles PPG complex. The waste container must be sealed in a manner to keep the contaminant from escaping. B) Description: Knowledge and competency of Shipping personnel in loading . procedures. Comments: 1) Several spills and environmental upsets in the past have been a direct result of errors committed by the personnel involved with the loading. However, there was no lack of knowledge or competency demonstrated by the people interviewed and observed during the survey. 2) Written loading and unloading procedures were not readily obtainable. Most procedures that were written require updating. C) Description: Environmental awareness of Shipping personnel Comments: Most Shipping personnel interviewed lacked knowledge in the environmental regulations concerning spills and outfall monitoring conditions. Few were aware that a one pound release of trichloroethane, perchloroethylene or vinyl chloride would be a reportable violation. 2) The overall environmental concern and awareness for Shipping personnel was very positive. Everyone interviewed has been aware of the changes in policies and procedures regarding the environment over the past years. Many of the older employees see the impact that these changes have had on improving the quality of the river and surrounding areas of the plant and community. RECOMMENDATIONS I. Chlorine Tank Car Loading Rack A) Improve hose connecting/disconnecting procedure to minimize hose bending that creates weak spots. B) Change the procedure for testing hose connections for leaks to use 250 psig air instead of liquid chlorine. C) Revise sampling procedure for chlorine vapor in tank cars so chlorine will not bleed to the atmosphere. D) Install additional valve activation switches for chlorine loading automatic valves in different locations. E) Install drainage piping for the trichloroethane collection basin. F) Reroute valve repair steam cleaning drain to 30" process sewer. II. Chlorine Tank Car Test Rack A) Establish specific procedures for monitoring the strength and level in the caustic car. -15- SL 087219 B) Use a NOTICE or DO NOT OPERATE tag on the test rack vent line supply valve whenever the caustic car is out of service. C) Reroute the drain for the hydrostatic test water to the 30" process sewer. Incorporate with the new test rack facility if approved. III. Heavy Tank Car Unloading, Patio and Sniff Tank Dispose of sniff tank drainage by use of a vacuum truck. IV. Ton Cylinder Building A) Provide a means of neutralization of the ton cylinder vapors that are vented during the testing procedures. B) Reroute the drain for the hydrostatic test water to the 30" process sewer. V. Tank Car Repair Shop Should a car that is to be serviced have some residual product remaining inside, send the car back to the proper production area where the product can be removed. VI. Caustic Truck Loading - no recommendations VII. Caustic Tank Car Loading A) Fabricate some drain pipe devices used to prevent splashing when unloading caustic from a tank car. B) Install additional pump kill switches in different locations on the loading rack for all caustic loading pumps. VIII. Barge and Ship Loading Docks A, B, C, D & E A) Install an adequate system for drainage of all product lines and hoses on all docks. This system should involve the elevation of most of the loading lines and the possible construction of organic sumps. B) Eliminate vinyl chloride loading at 'O' dock. C) Stress that it is the ship's responsibility to provide a means of clearing all product lines and hoses before disconnecting. Be sure this is communicated to the person who is responsible on the ship before any loading takes place. D) Replace any defective labeling for pump motor switches at the docks and pumps. E) Evaluate the installation of curbing for 'C, 'D' and 'E' docks. F) Refuse to load customer barges that are in bad condition and have the potential to cause leaks. -16- SL 087220 G) Establish a sampling procedure for determining the proper disposal of barge dry compartment water. H) Discontinue use of Crane valves at the 'B1 dock chlorine supply manifold. Use Stockham valves or experiment with other types. I) Improve diking around diesel tanks. J) Install a means of containing hydraulic oil leaks from loading cranes. Use catch pans where dock curbing cannot be provided. Keep an adequate supply of Hi-Dri and diapers at each dock. K) Implement measures to prevent overflows of the caustic sump such as the installation of signs, firming up training,lowering the high level alarm set point and frequent checks to the level indication and alarm. Install an automatic reset on the sump alarm acknowledge button. L) Initiate use of radios at the dock area to help eliminate environmental problems during upsets by allowingaudio contact between the tankerman at the dock and the helper at the loading pumps beside the storage tanks. IX. Organics Storage Area A) Have a system to clear transfer lines from Plant B to the shipping docks. Install pig traps to clear lines in a timely manner to make permanent pipe repairs. Avoid the use of pipe clamps. B) Provide adequate means for the containment of trichloroethane spills such as pump pads and additional diking. C) Improve the reliability of the trichloroethane filter. Assign operational responsibility. X. Sulfuric Acid Unloading at Liquefaction & Mercury Cells A) Implement the new unloading procedures for the Mercury Cell sulfuric acid tank car station. Procedure is in appendix. B) Install emergency air cut off and bleed valves for fast depressurization of the sulfuric acid tank car. The location for the emergency valves should be removed from potential sources of acid leaks. C) Investigate a central sulfuric acid unloading station and tank for all Plant A sulfuric acid users. XI. General Conclusions & Comments A) Shipping Shift Foremen need to be trained in federal regulations governing the transportation of hazardous waste containers. B) Update and revise all loading procedures as necessary. Organize and distribute the procedures so they are readily accessible to all Shipping personnel. -17- <c>v C) Conduct periodic environmental training for all Shipping personnel. The training should provide an update of all environmental regulations which pertain to Shipping and promote environmental awareness. -18- Sh 08T222 APPENDIX -19- 087223 Sk Memo, February 7, 1985 from Porter SL 087224 CHEMICALS INTEROFFICE / LAKE CHARLES TO FROM A. J. Kubic J. M. Porte DATE February 7, 1985 SUBJECT Shipping Environmental Survey In order to identify environmental problems associated with loading/ shipping activities in Plant A, a Task Force is being established to survey the situation and reconmend corrective action as needed. The Task Force will be expected to review past history of environmental upsets associated with shipping, review the previous Plant A environmental surveys, and include all products loaded in Plant A in the survey. Tile Task Force will be made up of the following people: ? Darrell Moore Carey Hardaway Andy Plauche' Cliff Beadle Rick Gros Barney Tyson Shipping (Chairman) Process Engineering Environmental Shipping Shipping Operations The survey is scheduled to be conducted during the week of February 25, and the survey report should be submitted by the end of March. With the completion of this survey, we will have reviewed all of Plant A from an environmental standpoint. dt cc: Task Force Members R. P. Byars/L. C. Comeaux J. C. Lafleur lJ. Peard R. J. Whitaker/B. J. Green 087225 Outfall Permits 9^ A-l EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning effective date and Luting through expiration date Jthe permittee is authorized to discharge from outfall(s) serial number(s) 001 Final moni toring polnt / Such discharges shall limited and monitored by the permittee as specified below: Effluent Characteristic Discharge Limitations kg/day (Ibs/day) OtKer UniU (Specify) Flow--m3/Day (MGD) Temperature, *F Daily Avg N/A Daily Max N/A Daily Avg N/A Daily Max N/A Monitoring Requirements Measurement Frequency Continuous Continuous Sample Type Record Record *tm ii n . LA0000761 i LZZL20 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard uniU and shall be monitored continuously and recorded. There shall be no discharge of floating solids or visible foam in other than trace amounts. Samples taken in compliance with the monitoring requirements specified above shall be taken at the following tocation(s): 001 Final monitoring point. Mobile Bridge No. 1 and Mobile Bridge No. 2. I 1 v 5,^ t c A-2 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning effective date and lasting through expiration date. {the permittee is authorized to discharge from outfall(s) serial number(s) 005, surface runoff Such discharges shall be lin)M||nil monitored by the permittee as specified below: Effluent Characteristic Discharge Limitations kg/day (Ibs/day) Other Units (Specify) Daily Avg . Daily Max Daily Avg Daily Max Flow~m3/Day (MGD) Temperature, F N/A N/A N/A N/A Monitoring Requirements Measurement Frequency 3/week 3/week Sample Type Grab Grab Permit No. LA0000761 SL 0 8 7 2 2 8 The pH shall not be less than 6,0 standard units nor greater than 9.0 standard units and shall be monitored 3/week via grab sample. There shall be no discharge of floating solids or visible foam in other than trace amounts. Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s): 005, East 24" Sewer to Turning Basin of.Calcasieu Ship Channel. 1 f r",-t -- i A-11 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS / During the period bgin|d|^fftffeetive date and lasting through expiration date the permittee is authorii3i|p||charge from outfall(i) aerial numbcr() 021, once-through uncontaminated cooling Such discharges shall be limited and monitored by the permittee as specified below: Eftluent Characteristic Discharge Limitations kg/day (Ibe/day) Other Units (Specify) Flow--m3/Day (MGD) Temperature, F pH Daily Avg -- N/A N/A Daily Max -- N/A N/A Daily Avg -- M/A N/A Daily Max -- N/A N/A Monitoring Requirements Measurement Frequency Sample Type Continuous Continuous Continuous Record Record Record 5L 087229 The pH shall not be less than N/A standard units nor greater than N/A Standard units and shall be monitored There shall be no discharge of floating solids or visible foam in other than tract amounts, I Samples taken in compliance with the monitoring requirements spedOpd fbove shall be Uken at the following location(s): 021 (Combined 002 , 003 & 004 - See PPG Dwg. 20A-1577-P^&#**** 13, 14 and 15) discharge to Olin Ditch, to Calcasieu Ship Channel. ' A-l 2 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginnjMtattffeCtive date end lasting through expiration date the permittee is authori||JJ(fi|fccharEe from outfaJl(s) serial numbcr(s) 024 Surface drainage from product Stora Such discharges shall be limited and monitored by the permittee as specified below: Etlluent Characteristic Discharge Limitations kg/day (lU/dayj Other Units (Specify) Daily Avg Daily Max Daily Avg Daily Max Flow--m^/Day (MGD) Monitoring Requirements Measurement Frequency Sample Type 5/week* Indicate *When flowing. tiff 13 at 23 Pt.mn No. LA00007S1 qE ^ 80 in c1 The pH shall not be less than 6.0 standmd unit* npc greater than ]1,0 standard units and shall be monitored 5/week via grab sample. There shall be no discharge of floating solids or visibfe foam in other trace Samples taken in compliance with the montl-oring requiinpmt* ** above shall be taken at the following location(s): 024 strom drainage from product storage area to Calturning basin. Outfall Drawings SL 087231 { t * * ft. I. ** Si, 0s^s &?|T| _____________ ^s, INDUSTRIAL CHEMICAL DIVISION ijJLt OuUS. IA'Iim rvrr^rrr-rtri&^rz:x--r 0>iir **_ S At-L _____ -*__ L"j.O'C^. KtoJ -- -j Cottar* i*_________ - *** _ , _ to-?------ 1 ww>7 ~i- un , >* ------------------$ ...`iaD.-'WSAaGs..sir-.' irrt^^g^aw__g_a_a_c_s_rJfca V -X 1983 SPILL/RELEASE SUMMARY Date 1/1-3 1/3 1/10 1/12 1/13 1/16 Source Tetra Pit. A Caustic Ok Tetra TE-li TE-II 1/17 1/17 1/17 1/17 1/18 1/18 1/19 1/19 1/18-20 1/20 1/21 1/28 2/4 2/4 2/10 2/14 2/21 ?hippin$ TTTT TE-II Pit. C LP-EDC VDCM Tetra Tetra LP-EDC LP-EDC Pit. A Power A VCM-II VCM-II LP-EDC Pit. A VCM-II 2/25 TE-II 2/25 3/3 3/5 3/6 3/11 OHC-I Pit. C cShippmco lp-eDc VCM-I 3/18 3/25 Hg Cell Liq. 3/28 3/29 TE-II TE-II 4/3 VC-I 4/5 Tetra 4/6 Pit. C 4/7 TE-II 4/14 Pit. C Pollutant HCL Oil NaOH CIHC VCM/ VCM clitv HCI KOH CIHC CIHC CIHC CIHC CIHC CIHC NaOH Oil CIHC EDC ClClp CIHC CIHC CIHC Cl2 MC CIHC a?<L Cl. C,2 vc HCI VC' CIHC Brine VC ' HCI Cause Quantity Vent Compressor Maint. 14,890 lb. Diesel Spill Unknown Overfilled Dock Sump Unknown Vent Compressor Maint. 44 lbs. Pipe Corrosion 200 lbs. Corrosion to Stripper 11 lbs. Condenser 2 lbs. Catalyst Spill 10 lbs. DCE Stg. Tk. Vent Overfilled Storage Tk. Unknown 8,880 utfr. Non-Incineration of Vents 300 lbs. Non-Incineration of VEnts 800 lbs. Vent Compressor Maint. Unknown Vent Compressor Maint. 2,436 lbs. Non-Incineration of Vents 879 lbs. Non-Incineration of Vents 2,800 lbs. Valve Open During Transfer 400 lbs. Compressor Leak 2 gals. OHC Rx Rupture Disc Blew 2,556 lbs. Quench Tower Rupture Disc Unknown Cl, Vaporizer SRV Lifted 50 lbs. Power Loss at Absorber 75 lbs OHC-III Rx Rupture Disc 2,885 lbs. Blew Leak on Catalyst Catch 385 lbs. Pot Leaks in OHC-I Vent Header 2 lbs. Power Failure, Seals Blew 1 lb. Shipping Tank Overfilled 500 gals. Vent Line Leaked Leak on Cl? Cylinder 370 lbs. 2,000 lbs. No. 8 Well Absorber Pump Shutdown 10 lbs. Lost Two Refrigeration 270 lbs. Units Non-Incineration of Vents Unknown Gasket Leak on H.P. 169 lbs. Accumulator Vent Header Rupture Disc Unknown Blew Tetra Rx Rupture Disc 97 lbs. Blew Corrosion on Storage Tk. 3,000 gals. Leak on VC Stripper 4 lbs. Feed Pump Block Valve Leaked by on 5,810 lbs. Storage Tank Agency Contracted DNR CG/DNR NO NO NRC/DNR NO NO NO NO NO DNR DNR NO DNR DNR NO NO NO DNR NO DNR DNR/NRC DNR NO NO DNR/NRC NO DNR DNR NO DNR/NRC EPA NO EPA NO NO DNR/NRC/CC NO 08l^38 w Date 4/18 Source ' Per/T ri 4/20 Pit. C 4/25 VC-I 4/25-27 4/27 4/28 Liq. TE-ll VC-I 4/29 VC-I 5/8 5/10 5/12 5/13 Pit. C Pit. A LP-EDC Liq. 5/16 VC-ll 5/16 5/18 5/18 VC-II Per/T ri LP-EDC 5/20 5/22 5/23 VC-ll VC-I LP-EDC 5/23 VC-I 5/23 5/24 Hg VDCM 5/28 6/2 6/2 LP-EDC TE-ll Pit. A 6/11 6/16 Pit. A tSnrpgino? 6/20 6/22 Hg LP-EDC 6/23 Liq. 6/25 LP-EDC 6/28 6/28 6/29 7/7 TE-ll TE-ll VCM-II Bottoms Pit. Pollutant CIHC HCI VC Oil Oil VC ' VC NaOH Clp Cl? a ?C VC VC Nt-U CIHC CIHC vc CIHC VC NaOH CIHC Cb cil HCI HCI Cl- Hg EDC Oil EDC HCI HCI CuCI*/ CIHCT Cause Vent Header Rupture Disc Blew Tank Overflow at Regeneration Unit Vent Header Rupture Disc Blew Leaking Equipment Hydraulic Hose Ruptured Gasket Leak on Transfer Line Vent Header Rupture Disc Blew Cell Liquor Tk. Collapsed Tail Gas Diversion Liquid Clp Line Leak Ruptured^Hose on Sniff Line Pump Broke in VC Sphere Area SRV Release Valve Leak on Lewis Unit No. 1 Plant Refrigeration Unit Down OHC Rx Rupture Disc Blew Leak in VC Vent Header No. 1 Plant Refrigeration Unit Down SRV Release During Transfer Maint. Open Manway on E. Day Tank Blown Rupture Disc on Vent Header Clp Vaporizer SRV Cl| Vaporizer SRV Blown Gasket on Weak Acid Line Weak Acid Line Leak Bowndown too Fast Caused Absorber Trip Fume Blower Down Spill at EDC Dryers (South Terminal) Seal Leak on Diaphragm Centrifugal EDC Dump Tank Rupture Disc Water Off Emerg. Scrubber HCI Preheater Leak Catalyst washed to ditch Vent header ruptured Quantity 3,000 lbs. 620 lbs. Unknown 100 gals. 4 gals. Unknown Unknown 240 gals. 10 lbs. 400 lbs. 237 lbs. 4,022 lbs. 2,800 lbs. 500 lbs. 190 lbs. 861 lbs. 1 lb. 190 itnr 3,899 lbs. 4,400 lbs. 106 lbs. 10 lbs. 895 lbs. 2,000 gals. Unknown 10 lbs. 2,300 grs. 16,000 lbs. 2 lbs. 100 lbs. 2,260 lbs. 1,606 lbs. 20 lbs. 500 lbs. Agency Contracted DNR NO EPA NO NO NO NO NO NO DNR/NRC DNR/NRC DNR/NRC EPA DNR/NRC DNR DNR NO DNR DNR/EPA NO NO NO DNR/NRC NO NO NO DNR DNR/NRC NO NO NO NO NO NO 2 SL 087239 Date im 7/14 7/15 7/15 7/18 7/21 7/24 7/27 8/6 8/8 8/8 8/18 8/24 8/24 8/24 8/25 8/31 9/8 9/24 10/3 10/5 10/5 10/11 10/25 11/1 11/8 11/12 11/8 11/21 11/23. 12/11 12/15 12/16 12/16 12/22 12/23 12/26 12/26 Source Pollutant NaOH <*" ~ShiDDina> EC TE-II Cl- Liq. ci, Per/Tri CIRC Pit. A NaOH Silica Silica EC Bottoms Pit Pit. B (Cl- loading? Bottoms pH NaOH HCI HCI EC CIHC CIHC CI&C Per/T ri Pit. A Pit. A Power A OHC-I VCNI-II Per/Trl HCL TE-II CIHC Brine Brine Oil CIHC CL, HCt HCL VCM Cause Dumped condensate tank EC loading line SRV SRV on Cl- Surge drum Scale tks Teal pot leak Lost Lewis unit (burnt motor) Overfilled No. 5 Stg. Tk. 1" valve Bonnet failed Opened manway on stg. tk #4 Day Tank SRV Sight glass broken Spill to Outfall 010 Cl, Loading Line Leak Blown rupture disc on DH Tank Hole in vent line DH still Spill to Outfall 021 Spill to Outfall 021 Leak in equipment Diversion to scrubber SRV on CL, Vaporizer SRV on P/T DH Still Leak on impulse line Non-incineration of OHC VCM-II EDC R. D. on OHC Rx Power A Plant C TE-ll PH. C Hg Cell LP-EDC s2cl2 CgjjTppin^ Liq. VDCM Pit. A Silica VC-II VC-II VC-II Oil CL, HCt CLTherminol CIHC s^cl2/ Unknown Total Plant Shutdown Partial power failure Operator error at Neut. Valve left open No. 2 LP-EDC vented 5 hrs. 23 min. Leak on equipment at CL, HQmME CLc, S.O? v'cm- CL, CLi T^nk^Truck spill (valve open) Maintenance Rupture disc blew Absorber shutdown causing diversion to Powerhouse Tank developed a leak Valve left open between R. D. & SRV SRV on vaporizer blew SRV on vaporizer blew Quantity 430 000 gal. 1140 lbs. 909 lbs. 40 lbs. 900 lbs. Agency Contracted EPA NO DNR/NRC DNR/NRC DNR 35 tons 578 lbs. 400 lbs. 150 lbs. 200 lbs. Unknown 210 lbs. 200 lbs. NO NO NO NO NO NO NO NO 300 lbs. DNR Unknown NO Unknown NO 4 gal. NRC < 10 lbs. NO 820 lbs. DNR/NF 25 lbs. NO 27 lbs. DNR 18 lbs. DNR '720QJbs. (cat) 2685 lbs. (EDC) DNR 1300 lbs. (HCL) 5 gal. NRC 760 lbs. NRC/DI 1600 lbs. NO 21 lbs. NO 40 gal. NO 500 lbs. DNR 10,000 lbs. DNR/NF 600 lbs. < 10 lbs. 1750 lbs. 250 lbs. NO NO NO DNR/N 3400 lbs. 400 lbs. EPA DNR 45 lbs. 45 lbs. NO NO SL 087240 3 SL 087241 DATE HATERIAL/ANOUNT 1/1 Oil (l> 1 gallon 1/3-6 EC(g) 500 lbs. 1/6 EDC (t) 100 lbs. 1/12 HCl ID 950 lbs. 1/22 NaOH (D 3600 lbs. 1/24 HCl <g) 10 lbs. 1/25 NaOH <l) 300 tbs. 1/31 HCl (1) 100 lbs. 2/5 EC (g) TOO lbs. 2/6 VCN (9) 5.2 tons 2/6 HCl (D 5400 lbs. REPORTED TO PLANT - LOCATION C - Powerhouse MRC/QEQ B - EC B - OHC-1 C - Silicas NRC/DEQ A - Caustic B - VCH-I Qt- Shipping^/ B - VCH-I B - EC DEO B - VCN-II NRC/DEQ/CG A - Powerhouse A DESCRIPTION CORRECTIVE MEASURES Operator forgot to close off Operators counselled supply line. Cooler plugged in the nonaal Cooler will be routinely cleaned EC vent systca. tiienever the EC unit is shutdown Corroded box Box replaced Expansion joint burst Joint replaced frozen NaOH plug not found until line was put into use Ditch flow beneath line being changed (9/B4) and daa was built to collect future leaks Failure of packing in valve Tightened up packing gland Relief valve not closed off after loading Loaders counselled Steaa hamaer ruptured line Cheatite line being replaced with different pipe Lost both vent compressors (spare included) Both compressors have been repaired Refrigeration probleas at VCN-1 allowed VCN to enter HCl distribution systca Procedures at VC-1 changed to prevent VCN froa entering HCl aystea Overflowed tank due to a combination of failed high-level alarm and operator inattentiveness Alans repaired and operator procedures for tank filling were changed DATE MATERIAL/AHOUHT 2/7 VCH (g) K00 tbs. REPOSTED TO PLANT - LOCATION DEQ 8 - VC-II 2/8 MCI (l) 200 lbs. 2/9 VCH (8) 2800 lbs. 2/11 NaOH (!) 5 tons 2/21 NaOH <t) Unknown 2/22 NaOH (t) 2100 lbs. 2/27 Organics (g) 42 lbs. 2/28 Organics (g) 63 tbs. 2/28 EOC (t) 300 lbs. 2/28 Oil (t) 2 gallons O CD A - Machine Shop DEO B VC-II A - Caustic <r Shipping NRC/DEO/CG B - Per/Tri B Per/Tri B - EOC COMPLEX DESCRIPTION CORRECTIVE MEASURES Equalizing line mistakenly opened by loader Loader counselled; tag installation now togged into a Book; double block/bleed to be installed (5/84) in current equalizing line to #2 VCH Sphere Contracted acid vat had cracked weld Contractor told to inspect equipment before use Storage tank overfilled due to faulty level transmitter An additional alternate wans of measuring VCH level is in use Transfer line clearing added Operator counselled; Tank #5 too auch product to tank roof drain to be repaired (6/84) Blown gasket in transfer line Gasket repaired Loading unattended while Barge loading procedures have Loaders checked on Barge tilt, been rewritten overfilled Barge Maintenance done on Per/Tri Still Line Scrubber Started repair of leaking flange Maintenance done on Per/Tri Still Line Scrubber Finished repair of leaking flangt Sightgtass/valve leak Equipawnt repaired oiain not tied to oil weir box Drain was connected to weir box SL 087243 DAIE MATERIAL/AMOUNT 2/29 Triethane (l) IMS lbs. REPORTED TO PLANT LOCATION NRC/DEO 3/6 C12 (g) AS lbs. 3/6 HCi (g) 16 tbs. 3/2 VDCH (g) 1200 lbs. 3/2 EDC (g)/B10 lbs. HCI <g>/940 lbs. Catalyst (s)/2.2 tons 3/7 C12 (g) 40 lbs. NRC/DEQ 3/7 Ethylene (g) 57 lbs. 3/13 Cl2 <g) 5 lbs. 3/14 Ethylene (g> 341 lbs. 3/19 HaON (l) 340 lbs. B - VCH-I1 B - TE-ll EDC VCH-II B - EDC B - VC-1l C^-ShippingT^ B - VC-11 C - Caustic DESCRIPTION CORRECTIVE MEASURES Misinforamtion from contractor Loaders counselled to check on capacity oi tank truck strapping and loading to be dona on containment pad (under construction) LP-EOC startup problems Recalibrated steam control valve Valve teak by Piping/valves to be replaced (5/80 Complex power failure, steam to VDC reactor not closed off quickly enough Reviewed the procedures for steam blocked-off during power failure with operators Premature failing of rupture disc Supervision interacted with Maintenance on the careful installation of rupture discs Complex power failure caused autoamtic valve closure/timing problems No operational changes planned Plant power failure Car was insufficiently "sniffed off" when opened PCV leaked by Operator counselled Plugged drain line Operating procedures changed; Work Orders initiated for area reliability study and continuous Monitor in runoff to 025 (both in 7/84) SL 087244 DATE MATERIAL/AMOUNT 3/22 EC (g) 3635 lbs. 3/23 NaOH (l> 6 1/2 tons 3/26 Douthem (l) A90 tbs. 3/27 Cl2 (g) 10 lbs. 3/29 NaOH (l> 5750 lbs. REPORTED TO PLANT - LOCATION Shippirg^ NRC/DEQ/C6 A- Mercury Cell A - Pels NRC/DEQ C^A ~ Shipping^ A - Caustic A/05 EC (g> 530 lbs. A/05 Trichlor (l) 61 lbs. A/05 EC (g) 10 lbs. A/11 Chlorine (g) 9 lbs. A/11 NaOH (I) A tons A.B MRC/OEQ NRC/DEQ A - Caustic DESCRIPTION Overfilled tankcar CORRECTIVE MEASURES Loaders counselled Coxaaurticat ions problaa resulted in inadvertent draining Operations/Supervision corrected the coaexjni cat ions problaa Maintenance on unit, gunk plug, rodded out which released pent-up anterial Different type of bleed valve (not liable to plug) to be installed in April Header not sufficiently "sniffed** prior to opening to repair leak Shift Foroaen told to allow longer "sniff** tine on tine before future repairs High level elans broken and coauunicat ions problaa resulted in puep not being turned on Operator counselled; alanae to be repaired (April); ptap to be put on automatic (7/8A) Material (EC 7) found in stack. No apparent source Not applicable No cause deterained Overfilled tank car Set up pew logbook end new procedure Leak developed on EC tank truck. (See 5/8 EC Spilt) Heterial offloaded to a tank. Custoner contaminated truck. Electrical breaker Mistakenly Tie-in to Sulfur Chloride owned. S/D blower, etc. (9/8A) will prevent in future Chlorate destruction test, NaOH NS exceeded expected aaount Rerouted condensate tine to cell liquor tanks Si^ 8 0 DATE MATERIAL/AMOUNT 4/17 EC (g) 150 lbs. 4/24 S2C14 (g) 6 lbs. 4/26 Chlorine (g) 6 lbs. 4/Z7 VCH (g) 4 lbs. 5/02 Chlorine (g) 35 lbs. 5/02 Douthera (g) 200 lbs. 5/03 NaOH (l) 2 tons A.B. 5/05 VCH <g> 273 lbs. 5/06 NCI (l) 4300 lbs. A.B. 5/0? NaOH (l) 44 tons A.B. 5/08 EC (g) 400 lbs. 5/09 EDC (1) ZOO lbs. REPORTED TO NRC/DEQ PLANT - LOCATION (L Shipping"^ A - Sulfur Chloride A - liquefaction DEO B - VC-11 NRC/DEQ DEQ NRC/DEQ NRC/DEQ A - Powerhouse A B - Per/Tri C - Caustic B - TE-ll A - Powerhouse A A - Mercury Cell /l - Shipping^ B - VC-I DESCRIPTION CORRECTIVE MEASURES Puap on tank truck corroded and leaked See 5/8 EC Spill Gasket on filter basket bleu Gasket surface has been/uilt out during pressure check be Modified for all filters Barge transfer line overpres Maintenance notified sured. No gasket after R/D SRV relieved, autoaatic valve did not reopen prior to VCH transfer Checked instruaents. Meu procedure for starting transfer Construction sandblasted hole Requested construction to notify in chlorine header Operations in advance of work Unexpected reaction in RX New procedure - will not circulate during startup - SRV relieved Dowthens with vent blocked Incorrect valve aligraent. Operators counselled Unintentionally drained filter Scrubber valve leaked by Repaired valve. Instructed Operators how to detect S/G retainer ring blew out. New procedure for Operators to Urong valve position indicated onitor valve position Expansion joint on discharge of caustic ptap failed hpse ruptured on tank truck. Cfestoawr contanirated truck Tanporary puap reMoved. Engineering Work Order written to curb and pad area Cuetaawr agreed to revise procedures for unloading EC Super valve leaked in into furnace. 25k of EDC leaked off pad Super valve replaced. EDC was quickly rcoved fron ditch SL 087246 DATE MATERIAL/AH0UHT REPORTED TO PLANT - LOCATION 5/10 HaOH (1) 171 tbs. B VC-11 5/10 HaOH (1) 500 lbs. A.B. 5/14 EC (g) .7 lbs. A - Powerhouse A B - EC 5/16 Chlorine (g) 9 lbs. 5/18 VCH (g) 3100 lbs. DEO A - Electrolyzers a - VC-ll 5/23 PCD Cant. Oil Cl> 10 gal. 5/24 EC (g) 1201 tbs. 5/26 HCL <(> 1500 lbs. A.B. 5/27 VCH/DCE/HCL (g) 10 lbs. Total 6/01 EDC <l> 30 tbs. 6/03 CIHCs t HCl <g) 300 tbs. HRC/DEQ A - Mercury Cell cr - Shipping A - Powerhouse A B - IE-II B - EOC B - IE-11 DESCRIPTION CORRECTIVE MEASURES PCV did not seat off; line overpressured and lifted SRV Overhauled PCV; Engineering Work Order written to upgrade pipe Gasket failure on transfer l irve Replaced gasket Valve inadvertently opened. SRV relieved due to thermal expansion Changed R/D. Advised Operators and Shipping to check this line Hole developed in acid tower Replaced cover, iaproved liner cover. Leaked during startup has been/will be used on cover SRV relieved. Sphere overpressured - inadequate vent purging Operators reprimanded. Engineering Work Order to replace switch with transmitter Bushing broke off transfonaer Gasket will be broken loose before because of stuck gasket lift next time Overfilled tank car. Level guage stuck Loader counselled. Atare procedure put into operation Automatic valve broke. Acid New procedure for Operators to bypassed to sewer monitor valve position Leak developed on vinyl Repaired pipe stripper condenser want tine T^wtsfer tine corroded Repaired pipe Blown seals on #1 and #2 All organics contained. 15 lbs. low pressure condanaate pcap of HCl escaped to atmosphere DAIE HATEklAl/AHOUMT 7/28 EOC <e> 100 lbs. 7/31 EC (a) 45 lbs. 8/1 EOC (1) 29,000 lbs. 8/2 VCH/EOC/HCI (l) 11/413/46 lbs. 8/9 C12 (0) 9 lbs. 8/9 HaOH (It 500 lbs. 8/12 NCI (0) 3000 lbs. 8/14 CI2 (0) 3 tbs. 8/24 CIHC-ContM. H 0 (I) 200 9*1. H 0 8/31 HCI/TCE/E0C (g> 3/8/3 lbs. 9/5 C12 (0> 6 lbs. REPORTED TO PLANT - LOCATION B EDC NRC/DEO -^Shippir^ . NRC/DEQ (2000 lbs.) 8 - EDC B - VC-I B - VC-I d - Shipping"^ B - IE-II A - Liquefaction 8 - TE-ll NRC/DEO (3 lbs. TCE) B - WTU c* - shipping-^ DESCRIPTION CORRECTIVE MEASURES Rupture disc blew an #3 IP RN Dopp kettle. Valve leaked tv- Stearn valve rapetrad. Level and pressure slams reinstalled. Underground transfer line leaked. Line repaired. OHC to TE-ll transfer line put Operator repriaanded. Super in service before repairs were visors were counselled, complete. Organics hose broke during draining of stripper. Replaced hose. Leak on chlorine addition tine to the EDC Reaction Tank (corrosion). Attempts will be aede to clear lines before stripping insuletion. Valve leaked fay on sunp- Counselled Operators. Leak on HCI heater for high pressure HCI systesi. Replaced steel tubes with aonel. Replaced B/Vs. Leak on transfer line (corrosion). Repaired pipe. Checked other equipaent in area. Valve fell off back of vacuus Vecuua truck owner notified. truck. Valve 'in Bottoas Plant vent cSbpressor installed back wards. Cheat Its line bleu off. CI2 leaked through valve. Uork done by aain shop will be checked fay area aaintenance personnel. Counselled Operators. SL 087248 DATE MATERIAL/AMOUNT REPORTED TO PLANT - LOCATION 9/6 EOC (1) 2000 lbs. 9/6 EDC (l) 200 lbs. 9/6 CI2 (9) 7.6 tons B EDC (jl ^"shippi n^ NRC/DEO A - Liquefaction (4.5 tons/7.5 torts) 9/9 HCI/CIHCs (9) 30/10 Lbs. 9/10 VDCH (g) 100 lbs. 9/10 C C14 (I) 130 lbs. 9/12 HCI/CIHCs (9) 146/308 lbs. 9/14 VCM/EDC (l) 0.9/44.5 lbs. 9/12 VCH/EDC/CHCl (g) 4/11/8 lbs. 9/19 EDC (l) 100 tbs. 9/27 Tri-ethane (t) 50 lbs. 10/3 Tri-ethane (l) 750 lbs. 8 - Per/Tri -*Hhippir3) B - VC-I B - Per/Tri B - IE-l1 NRC/OEQ (4 lbs. VCN) B - UTU B - EDC NRC/DEQ B - TE-11 0* - Shipping^ DESCRIPTION CORRECTIVE MEASURES 3" hose broke during vacuus truck unloading. Vacuus truck owner notified. Overfilled tank truck. Operator reprimanded. #2 York pciwary and secondary Operators and supervision tripped. Operator response counselled. was inappropriate. Vent header overpressured due Replaced valve. to throttled condenser valve. 2H transfer hose broke. Replaced hose. Tank sightglass broke. S/G's will be kept isolated except during level swasureaents. OH feed tank R/D failed presuturely. Replaced R/D. Leak on pipe at quench tower. Replaced pipe. Bleed valve nipple broke at CSS. Frequent inspections will be wade. Overfilled day tank. Sand blasting had broken LT. drrosion of transfer line. Repaired tUhing. Repaired line. Overflowed tank truck when loading swter failed. Repaired swter. SL 087249 DATE MATERIAL/AMOUNT 10/6 NaOH (1) 638 lbs. 10/9 EDC <t) 25 lbs. 10/11 Oil (O 45 lbs. 10/13 NCI (fl) 513 lbs. 10/15 NCI (l> 20 lbs. 10/17 HCI/CIHC (g) 40/30 lbs. 10/20 EDC tO 560 lbs. 10/21 CIMC (9) 4104 lbs. 10/22 Irichlor (O 60 tbs. 10/23 HCI tO 7740 lbs. 10/23 EDC/TCE/Tetra/ Penta (l) 120 lbs. REPORTED TO PLANT LOCATION - Shipping 0 - VC-II c - Silicas 0 - Per/Tri c - Caustic HRC/DEQ cis+trans/VCM 17/2 0 - Per/Tri e - Tetra DEQ 8 - Per/Tri (b - Shipping^ c - Silicas NRC/DEQ TCE/Tetra/Penta 36/24/12 lbs. 8 - UIU South Tenainal DESCRIPTION CORRECTIVE MEASURES Overfilled caustic barge. Counselled loader. DH Stilt vent line broke during sampling activities. Counsel led Lab personnel. Orua knocked over by delivery Counselled delivery personnel. personnel during loading. Rupture disk bleu on vent Checked/repaired back pressure header during swapping between control valve. incinerators. Dole in pipe. Repaired pipe. Maintenance knocked drain valve off of vent header. Repaired notile. Transfer line corroded. Repaired line. Due to insufficient incinerator capacity, Per/Tri vents were put to scrubber. An incinerator was repaired and put back on-strews. Drain plugged and drain pan overflowed. Modified drain pan. Casket blew out of line. 1 Replaced gasket. Underground leak on Puerto Rican transfer line. Abandoned line. ami NaOH (1) t.S tons IWC,DEO am7 CI2 (9) 30 lbs NBC.DEO 01/29 VCH/DCE/MCl (g) 5/5/15 lbs MtC.DCO VCM/OCE S/5 lbs 01/29 C12 (g) <10 lbs Shipping^) C A* QyprnUKj barge. ' A - Elcctolyiers IE II A Mercury Cell leu condensate seal pot on Ckt. 16 during startup. Vinyl stripper vent tine corroded. * Drained acid sunp to M.C. sever, liberating chlorine. Sunp Material not adequately neutralited. k> tr> S Z L 80 Revised: 12/15/82 ENVIRONMENTAL UPSET REPORT ROUTING - OPERATIONS General Foreman Production Superintendent Operations Superintendent Plant Manager Environmental Control SUBJECT: Cl2 Leak Under Valve on Cl2 Car C.W. Amett Please complete the following questionnaire and forward as soon as possible. [This report must be received by the Environmental Control Department within five (5) calendar days of the Incident.] 1. DATE OF INCIDENT: January 17, 1983 2. SOURCE OF RELEASE: Liquid Valve on Cl? Car 3. TIME AND DURATION: 10 Minutes 4. WEATHER CONDITIONS (Clrcle One): Clear Partly Cloudy Cloudy Rain 5. WIND SPEED AND DIRECTION (If a gas release): 2 mph HE 6. HAZARDOUS MATERIAL RELEASED: Chlorine 7. ESTIMATED QUANTITY RELEASED: 3 to 5 lbs. lbs 8. CAUSE OF RELEASE: Faulty seating surface for tung on angle valve to seat properly in groove on tazik car manway, (New Car) IMMEDIATE ACTION TAKEN: ^aI* Put on '3^ow<^OWI1 then to sniff. 10. ACTION PLANS TO PREVENT REOCCURRENCE: Machine angle valve seating surface on car manway cover to proper size. 11. NOTIFICATION MADE (Who. When): Shift Superintendent 'Z2LEnvironmental File #_/l SL 087251 RECEIVED JAN 1 9 1983 KteMsed: 12/15/82 da: ENVIRONMENTAL UPSET REPORT ROUTING - OPERATIONS k-General Foreman ` ,-Preductiun Supm i n Leiulerr -Qpera-t voftS-Stfpen n ten den Plant Manager Environmental Control SUBJECT:. FROM: S /( A ii-nt 4' Please complete the following questionnaire and forward as soon as possible. [This report must be received l>,y the Environmental Control Department within five (5) calendar days of the Incident.] 1. DATE OF INCIDENT: A r -fP \ 2. SOURCE OF RELEASE: _______________ 3. TIME AND DURATION: 31 3p -3'3/ 4. WEATHER CONDITIONS (Circle One): Clear Partly Cloudy Cloudy' Rain 5. WIND SPEED AND DIRECTION (if a gas release): 6. HAZARDOUS MATERIAL RELEASED: ('iJ-r, - mph t s/iP10. ACTION PLANS TO PREVENT REOCCURRENCE: * V ; cW_ ..( OJ (di. u- I'niX'ol \Zcl!\J(L /<, t'kjf* s 0V \J/ C ^ 11. NOTIFICATION MADE (Who,`When): ^ foe-' r Environmental File I /*-'* 7.7 SL 087252 RECEIVED jun 2 n w? ncvlsed: 12/15/82 ENVIRONMENTAL UPSET REPORT ROUTING - OPERATIONS - General Foreman . Production Superintendent Operations Superintendent Plant Manager Envlronmental Control Please complete the following questionnaire and forward as soon as possible. Th1$ report must be received by the Environmental Control Department within five (5) calendar days of the Incident.3 I. DATE OF INCIDENT: ? * 2. SOURCE OF RELEASE: Me ME __________________________ 3. TIME AND DURATION: /iJ/fPa* - J? f* 3 4. WEATHER CONDITIONS (Circle One): Clear Partly Cloudy <2^' Rain 5. WIND SPEED AND DIRECTION (If a gas release): J.2 mph SSA 6. HAZARDOUS MATERIAL RELEASED: j? S' 7. ESTIMATED QUANTITY RELEASED: /ass s# lbs 8. CAUSE OF RELEASE: A-P&r ctx^.a Mt /t*. <rH * 4/^ 'h <r Uot- M* /cfAfjJ //'** /si fo fA* /& ~f~X .2. SP /6 *y/>- /rsy* a&<**> at A ^ A av> A f fay p^) 9. IMMEDIATE ACTION TAKEN: A/<r i !> Aft <A/sso st /A,/ //a ff $* a'aj**s*j'a 0isf~ if f~f.B 2 5~g /4 d> /') //'<J (u*A ,c< Uj<? s at 6ouf j? - 3 at /V4>- fie hf/sars ) Ae fa * a/-} 10. ACTION PLANS TO PREVENT REOCCURRENCE: A// 7T>,, W //_ ,V :fVv fc'/)'a I A< r-s f 7^6" f? *>'>.. - ..- //A-...i.,.'.a.?.f.t/f--/--y- ---,--w,p ' <--r/d--S*>cf <Lj>zre S~f~ap't'f/*r ti 0 -f 4V,, '* 11. NOTIFICATION MADE (Who,'When): ' -/vvrirs* j*> a**tW /><. Sf'^f /** '/?''/ fp *. ^ /X f . Environmental File If SL 087253 S 7^>'- /'*/ 7& /a i,w& S & J2 & psi ) //-t irVfV- per * a / &, .* )n ^ //# / 5 /<6 ^ X? ^ i-~iAit / f ** * @ /9<> /? * /) 'fj'i/i ?/*' / *7 4r.,t,/ /Oc /'fc'f' fS&etsS, 7*vC> y / s->r /> s> *V /* e\J. 7 *v ^ f /'ii'/ * <r'< ' ^ > /<> '/ 7T y b / '*- S?/'** /s*4 1 / 7^V' s- e 'f~;?** ,,/ /O S? //- //'y-P / m**- fe/; if ^/y S^9 ? r~#//*>$s o "f & //*\0 l'c/ /ue t*,As'c A 087254 SL SIGNIFICANT INCIDENT REPORT This form is to be used for first notice reporting of all incidents involving process upsets, near miss accidents (no Injury) and chenical releases of a nature deemed to be significant. It is to be completed by the supervisor(s) of the area. Significant fire damage incidents should be called into Loss Prevention. Vehicular damage incidents should be called Into the Guards. GEOGRAPHIC LOCATION: Plant A ^ B C Complex___ DATE /`J- -/- ?3 Specif ic Location; Q g^ / re. Ts ^ s Xf' Ant k Weather (clear - cloudy - rain - wind - etc) C L ^ ^_______ TYPE OF INCIDENT: (Could be more than one) Near Miss Accident _ Operational Upset Chenical Release DESCRIPTION OF INCIDENT: Detail what occurred; Immediate action taken, ia. clean up, evacuation, etc. How injury was avoided if a near miss accident occurred. ^ J n r / J ? L. s SI U , SL, cj c. Ut S 2-L____ C IX ^ / A/_______________ L .----L--s--?----u------t-----/-<---_--_-_----L--S----S--O-------------,--------------ryS-->--------sv 0 X w. 4.V/T D0 tv $ t *1 / e . 7 h p / /-. 7 /fo IS St / 3 0 // J / sf ** t ! / .4.* s% i SstS 5 in AsJrtrJ O t / Jn . LU Jl -/ns _y "f dsts S?- S AS i> /j "s ... d/ // L-t>T"h 6 AP 3 a A'____ 0. <L 7 ~T k \ S____ *t_ i /* f r t/w * (S h dJ l//? /is ^ -/ ^ ^ * ' fb- c/-f p /<f (Ss7 ^ S p s>n L> J S Si-__ j ` * 11 & i t f~ / <>/ 'aL&____ ESTIMATED DEGREE OF SEVERITY: (Your bast estimate of equipment down time, quantity of mat'l released, injury potential) /} /j * ,, f / P & ,1/- 0 /- /Pert) . on / P /vy? //Vi/t*/*/ /)-/; S M S' 3 At' * C> ssi / , FOLLOW-UP ACTION TAKEN OR RECOMMENDED: ^ 0l <J J p t-l H /h /l / g A L./ t/r, i sj y /Ss l' S* / s s _ s ^ 0 S* f " "'S7 , INVESTIGATED BY; S3- /sfxHn AP._ ___________________________________ Distribution: Originator maintains a copy. Send one copy to the appropriate Depnr-men Superintendent. Send the third copy to the appropriate Plant E.R. Supervisor (Manager of Safety & Health for the Complex Group). Further notification or distribution will be made by the E.R. Supervisor after review with the Department Superintendent. Loss Prevention will be informed of chenical process and property insurance incidents by the E.R. Supervisor. The Manager of Safety and Health will be sent a copy of all completed reports. T>*4' Tv ./if Ice1 ft-.' ip ^ ' ' ( > ' Y '"1 ' ! ' \0 ,ikc \ I a, Tke -.v /- i!^ w o. il . SL 087255 Revised: 12/15/82 ENVIRONMENTAL UPSET REPORT ROUTING - OPERATIONS General Foreman Production Superintendent Operations Superintendent 'Plant Manager Environmental Control SUBJECT: FROM: C ft I /*> A ^p> (I Please complete the following questionnaire and forward as soon as possible. [This report must be received by the Environmental Control Department within five (5) calendar days of the Incident.] 1. DATE OF INCIDENT: /?-//- S 3 2. SOURCE OF RELEASE: c 3. TIME AND OURATION: ^ 4. WEATHER CONDITIONS (Circle One): Clear ISri.r<fartly Clou^y3 Cloudy Rain 5. WIND SPEED AND DIRECTION (if a gas release): ---- moh ___________ ____ 6. HAZARDOUS MATERIAL RELEASED: 7. ESTIMATED QUANTITY RELEASED: 8. CAUSE OF RELEASE: c ______________________________________________ 600lbs Oo0 ^ h.>jc ^ ^OiTJA v *-m f r' J / o /-' H five Caf/i?c.\ <0^ SiinO r+t*>i t '<3, (L- v r <f~ ^ C cTPcV la a.irJi c ii. <V' 9. IMMEDIATE ACTION TAKEN: vol^e wc<e 7HI -4 c os*v. c) 11*? !*^i? W ACTION PLANS TO PREVENT REOCCURRENCE: D i'.g,___ ^ 'JC O St?i' fV>J *3C p\ M~r\ ,,>./! i , 11 l)(. -Sn-J<10 NOTIFICATION MADE (Who. When): t' cl i r'oft v-s-p- (-"I" l~j i > j'P // vAi V,el<3*- five /(0<5o ll V,.Q __ u di.J 'repei-TT TV\t <\ r r* I"S He l~a }-l<> f-ific /r>uk Env ironmental File t 7>c9. d /J t s / <? 'fkc. fScicvrft- v d~A n( T)\e> i A^i -l\^cL .X ,-v oai^6 Reused: 12/15/82 JAM ? 7 1984 ' ENVIRONMENTAL UPSET REPORT ROUTING - OPERATIONS LGperal Foreman /'^Production Superintendent Operations Superintendent r ^oOlant Manager , y JT Environmental Control SUBJECT: FROM: u-mnn Tr'c0cvr^f\nT- Please complete the following questionnaire and forward as soon as possible. [This report must be received by the Environmental Control Department within five (5) calendar days of the incident.] 1. DATE OF INCIDENT: l/^>4-- 2. SOURCE OF RELEASE: Qmjwml @> "a." ___________________________ 3. TIME AND DURATION: 4-: & 4. WEATHER CONDITIONS (Circle One): Clear <fgrtTy Cloudy"^) Cloudy Rain 5. WIND SPEED AND DIRECTION (if a gas release): 6. HAZARDOUS MATERIAL RELEASED: ^ou mph _______________ 7. ESTIMATED QUANTITY RELEASED: 8. CAUSE OF RELEASE: ^Qlbs \ . 9. IMMEDIATE ACTION TAKEN: 10. ACTION PLANS TO PREVENT REOCCURRENCE: /ik&rljUpMgeJufciA /at jttu, ___________________________ ______ _________________________ 11. NOTIFICATION MADE (Who, When): Af\t\s< VUhcLe ^ aap\Oi^ <ia ..^fc, ay\eu.nV Ll^Q^ C\PV ^&SjQ^TCV^- Q VSftQ Environmental File it si S7257 received feb 9 w id* /9ft# ht r O ryn ft X J-p /*/ ft? tt,/s**so 1" d" A J* c f, ClA-t*$fiC 5ft* /-z r- fry fit C M Ll* o/ ft, {llJ fib OH+ V /* y ft A #yi-/ -(s-*-4 > "(JrJy ,, /9n'^ fftu C* X bt/Shf A A * *"* / srsu te+r*- ***sist. ftA>/3 &/- %C" dock tu0 sff ^ H s* S * J Oo Lu*sS *- .. JT*1-'^ J? ol ~t u. r J3*yuj s >t- c/ ft p *9~ <J/'y ft i* +>--/>>j0 oftft. A~* f A-o /*~ t/- 7 /?--<&* t* t~ / 5" S>i * `sv ** /SS - . / h> ftA? y~ j /> yv d 7 As Z/' y ^ /'^ A J mXs j 0 /*/ )0S-t X d S 0ft d>-J* A&s+etr^p 10/9-Au^j Wjtf/os'*; '7~t rjf :X/s? Jtss OyoS/t/ ft A A* > uS ft) 0 * 3 3 ** 0 ^ ft? & ft~ft0r* J) A0t^u s'" y X A-" j~^ A A"A y 0 . ft 7 J S ftft s sU *? 0 jv t* t-y X ft 0 0~y oft X~X~- oft Jft 0 3 />* sr 7v ft 15~Z> /UJ 0 /t-0 m- ft '~& ft ^ X ^ J Ad 0- j~is-0 A (poo Us* "TOTOJL ~5o XA** k& SL 087258 //< ,-dCEIVEO Revised: 12/15/02 ENVIRONMENTAL UPSET REPORT ROUTING - OPERATIONS Opera t ion s- Elant Manager- - Environmental Control SUBJECT: FROM: B ~-5'> T~r /4. Please complete the following questionnaire and forward as soon as possible. fThls report must be received by the Environmental Control Department within five (5) calendar days of the Incident.] 3. TIME AND DURATION: 4. WEATHER CONDITIONS (Circle One): Clear Partly Cloudy ^Cloud^> Rain 5. WIND SPEED AND DIRECTION (if a gas release): mph ____________________ 6. HAZARDOUS MATERIAL RaEASED: 7. ESTIMATED QUANTITY RELEASED: ,;lbs 8. CAUSE OF RELEASE: TTCS._______ (Os&JL ___^_i__-flr 9. IMMEDIATE ACTION TAKEN: 10. ACTION PLANS TO PREVENT REOCCURRENCE: T .* : QpttX&frrtft ^ 11. NOTIFICATION MADE (Who,'When) f\Q Otnm^ qyevo^ oona OprsUign^ OtvxaafvT u'ns cotaj&Si OPAl^..? ,r yr*f TT Environmental File 9 3cR.C tA**t t t l*jtc /??S, ^ 1-0 W.4fig i i. \0Q0 VW^i SL 087259 CHEMICALS INTEROFFICE / LAKE CHARLES TO FROM Jim Lafleur Alton Fonteno DATE SUBJECT February 23, 1984 PPG Barge 209 At 7:15 PM on 2/22/84, Ray Guidry paged me to check a list on PPG 209. I arrived^at MD" dock about 7:20 P.M. I checked the drafts. A slight list was to the starboard side, about 3" to 4". It was straightening up at about the 8'6" to 8'7" mark. C. LeBleu, B. Thompson and I were on the bow end of the barge. Thompson took my light and went to the stem, which was next to the dock. Thompson had painted a mark on 8'9" on the port, stem comer. As he passed H dome, he heard the air and caustic gurgling. He immediately proceeded to pump switch, punched all 4 stop buttons and closed the dock valve. Caustic came out of #4 dome about the time he hit the stop buttons. Very little caustic came out of #2 and #3, as the domes were closed, only the ullage hatches open. No caustic came out of #1. At that time, the barge was at 8'8" on stem and had leveled up side to side, to about 1" difference. It was 7:30 P.M. We proceeded to wash barge down, as caustic had stopped running over when Thompson closed the valve. We pumped material back to shore tank 102, to about 4" air space in #4 dome. I called D. Bourne at about 7:45 P.M., telling him about the spill. He met me at "D" dock, investigated and left to call Enviormental. The Coast Guard patrol boat showed up about 9:30 P.M. Shortly afterwards, I was notified that more Coast Guard people would soon be arriving. They all left about 10:30 P.M., after taking statements. cc: J.M. Porter A. J. Beatrice A. Plauche file (EPA Coast Guard) SL 087260 Revised: 12/15/82 i ENVIRONMENTAL UPSET REPORT .ROUTING - OPERATIONS Genel'a'LNForanan Produc tiofN^u-psFi n tenden t Opera tjj3nSMJ"p^ntenden t Plaptriianager tvi ronmental Control SUBJECT: KO AJjOJJ SpJL FROM: A- P A^n-e-La Please complete the following questionnaire and forward as soon as possible. [This report must be received by the Environmental Control Department within five (5) calendar days of the incident.] 1. DATE OF INCIDENT: Z~Z 2. SOURCE OF RELEASE: 4 __________ 3. TIME AND OURATION: 7'3 n p. /w . /-2. /n.n 4. WEATHER CONDITIONS (Circle One): CCTear^) Partly Cloudy Cloudy 5. WIND SPEED AND DIRECTION (if a gas release): 6. HAZARDOUS MATERIAL RELEASED: SfduAV* inph _____ (E T~ Rain 7. ESTIMATED QUANTITY RELEASED: ' ZdfiO -lbs ' 8. CAUSE OF RELEASE: C -e -e. r #s -e r "x\ V_' i i. w H/n ( .-Vo-L ...i.-. Aj.XV X O'`*5 Wt^'1 A ). \STS' 9. IMMEDIATE ACTION TAKEN: ./ feu: f 1 U-J flay*__ bae./^ <Po__S . MS 10. ACTION PLANS TO PREVENT REOCCURRENCE: 11. NOTIFICATION MADE (Who. When): min%-ed pA Aorg^a^v *,\bA,-eJ) Z^2-Z > T. !SAfh.Q.Lo^ 2/z\ IjaJLaI Environmental File I }>CA,S' Sl 087261 PPe zoq aqI^c^J fh /,sA*j hi <r^ e . 7/^, /*// pcAmf <>n. AAsc/ lUCaJ-J-O affestt* SiJU. o4 Largs k> cJiec-tS Gf'-i't Jrafho^ c/-U $S\ipp'+f'1 ld <\2\Ljvij<O Xy ^C<3*w_ t\j <fi-i. iag A>lw/e h*3t y /^V u/'e/^. pK jief Up { 4-U.'SrVv*-*^ p Jau/n. CU,A-*Vr j '>*' w - * -*i__f i ^ -\* r/rim.i.ri ^.J-^..i ^ t, a/^e ujd. S uJasLJ aj^d <fc3>me CzlclsJ-'c uj<aS pp^fvjO^J bacjP hi </-/*. JaddhxM^s . llLt sSrw'p-'j- Sup^OiSd^ e. %b ctj^di 4b O- _T0 <^*Jilo GU^.p)cdU^d !.<h> PXa. six b&r^Q_ sl`P` C^bGJ*^ h*<S_cS *iV- k>> /?si ^) /u " ou i SL 087262 DEPARTMENT OF TRANSPOF TION UNITED STATES COAST GUARD commanding officer U.S. COAST GUARD MARINE SAFETY OFFICE 2875 75th ST.S HWY 6 PORT ARTHUR, TEXAS 77640 4nrOOtr `T.rvrlu* j P.a. (W___ /Qua 16455 1J, F*to- W U.A f (ri Lfl. Gentlemen: 7060/ This is to inform you that a pollution incident occured or threatens to occur at t?p<Lx FvVv fry1 ___ (7fr<A , c. 0 at ______________ for which yoAi may be financially responsible. Under Federal Statutes, the United States Government has an int rest in this incident, and further, may take appropriate action to minimize the damages which 'may be caused by this incident. / i- . ,\ The discharge of a harmful quantity of -ei-fr is a violation of the Federal Water Pollution Control Act as amended by the Clean Water Act. Under this Act, the person responsible for the pollution is obligated to undcrtake removal action. If he refuses to take adequate removal action, he is financially responsible for actions taken by the Federal Government to remove the pollutant and adequately mitigate its effects. Removal is being done properly if it is in accordance with Federal and State stat utes, regulations and the proceedures and criteria of the National Oil and Hazardous Substances Pollution Contingency Plan. If you undertake removal, the adequacy of your actions will be determined by the U.S. Coast Guard On-Scene-Coordinator. The On-Scene-Coordinator for this area is Cap tai n J .J.WICKS. As long as you are taking adequate action in this matter , F ede ral action will be limited to monitoring the progress of your a ct i vit ies and to provide guidance as necessary. If i t i S d etermined that you are not taking proper and appropriate action 5 to C ontain, clean up and dispose of the pollutant(s), Federal respon se may be initiated. You may then be held responsible for all actual CO St incurred by the Federal Government as set forth in Section 311(f) of th e Federal Water Pollution Control Act, as amended. Should you re qui re further information concerning this matter you should contact: U.S .C. G. MARINE SAFETY OFFICE,' PORT ARTHUR, TEXAS / 713-724-4330. SIGNIFICANT INCIDENT REPORT PPG Industries Lsks Charles, LA This fora Is to be used for first notice reporting of all incidents involving process upsets, near miss accidents (no Injury) and chemical releases of a nature deemed to be significant. It is to be completed by the supervisor(s) of the area. Significant fire damage incidents should be called Into Loss Prevention. Vehicular damage Incidents should be called Into the Guards. GEOGRAPHIC LOCATION: PlantC Complex____ Specific Location; 7D pJa p K Weather (clear - cloudy - rain - wind - etc) C* //'a DATE ____________________ Ms j- j* J. T />?/**/?/ TYPE OF INCIDENT: (Could be more than one) Near Miss Accident Operational Upset Chemical Release DESCRIPTION OF INCIDENT: Detail what occurred; Inmedlate action taken, ie. clean up, evacuation, etc. How injury urns avoided if a near miss accident occurred. IAJ t* < 4t> WA-"*__ Jr H'Jr, t__ f o ^ f 'S'" C it-* -s / j-e_ & ** / / V 'X ESTIMATED DEGREE OF SEVERITY: (Your best estimate of equipment down time, quantity of mat'l released. Injury potential) FOLLOW-UP ACTION TAKEN OR RECOMMENDED; /?j * stn ^ eA/d.--L n Jt-tJ,'_Jv 'f--n/.jl.1 iA/*/v 'd" INVESTIGATED BY: _ Distribution: Originator maintains a copy. Send one copy to the appropriate Department Superintendent. Send the third copy to the appropriate Plant E.R. Supervisor (Manager of Safety & Health for the Complex Group) Further notification or distribution will be made by the E.R. Supervisor after review with the Department Superintendent. Loss prevention will be informed of chmnical process and property Insurance incidents by the E.R. Supervisor. The Manager of Safety and Health will be sent a copy of all completed reports. SL 872fiA INDUSTRIES PPG INDUSTRIES, INC. INDUSTRIAL CHEMICAL DIVISION P. 0, BOX 1000 LAKE CHARLES, LA. 70602 April 5, 1984 Mr. Tom Coerver Department of Environmental Quality Air Quality Division Office of Environmental Affairs P. O. Box 44066 Baton Rouge, LA 70804 RE: Chlorine Release of 3/27/84 Dear Mr. Coerver: In accordance with Section 17.11 of the Louisiana Air Quality Regulations, this letter is the follow-up to my telephone report of March 27, 1984, regarding a chlorine release that occurred at our facility on 3/27/84. At approximately 4:48 p.m. on 3/27, a union to an expansion bottle on the north chlorine Barge loading header suddenly began to leak chlorine to the atmosphere. The leak developed in the header following a chlorine transfer and during clearing procedures of the header. Estimates of the amount of chlorine lost to the atmosphere was approximately 10 lbs. By 5:02 p.m. the leak of chlorine had been stopped. If you should have any questions concerning this release, please call me at (318) 491-4420. Respectfully PMF/bh cc: William Coltrin bcc: File #109.8 Patrice M. McFarlain Environmental Control Assistant SL 087265 SUBJECT: FROM: u Ll " faltsy? s________ L fo siS J). a/ /fyyai Please fill cut the following questionnaire as complete as possible and distribute as indicated below within 24 hours of the upset. This report must be filed when (a) a mercury violation occurs (air and water), (b) a caustic spill results in a pH violation at Outfalls 001, 005 or 021, (c) a release of chlorine that exceeds 10 Ibs/day, or (d) any spill that must be reported to a governmental agency such, as oil, caustic, or HC1. For incidents that occur on Friday, Saturday, or Sunday, the report must be dis tributed no later than 3:00 p.m. Monday. 1. DATE OF INCIDENT: J.2. SOURCE OF RELEASE: A/etlA. 6 L x Brtr# y l 3. '.TIME AND DURATION:. % / /K /'as. t af */3 % 4. WEATHER CONDITIONS (Circle One): Clear Partly Cloudy (JloudyJ Rain 5. WIND SPEED AND DIRECTION (if a gas release): /# 6. MATERIAL RELEASEDl--Q-Ll2:/.1 /^ mph </J 8. CAUSE OF RELEASE:' U/A,`L* /O lbs /V trlA. A y/t-c/sr- s) 0 m i V1? lb r* < j t <zJrjA. /3 JrfjtA Pu l9. IMMEDIATE ACTION TAKEN: / _ /' O rU A/. /? do i^/stA U_____ b s si/ 5 /v / _,,_________ ' IQ. ACTION PLANS TO PREVENT REOCCURRENCE: /t/tlL JAiU^'jlAU/V jfr'dcA&jh'J urifr d^C . U- A0T.ICATI0N ^ (MI'0 whw)! T)- AeU'i'A/i 3/^/py lM-t> toJl !V.eP-- ^ "I1 .V V As . n , ' j j 'Vl ,t' '__ ' j )' .j Distribution: General- Foreman Product'VPnTSuperi ntendent Operations Superintendent Plant Mananger Environmental File cc: Manager, Environmental Control Manager, Operational Services SL 087266 PLANT A 24-HOUR ENVIRONMENTAL UPSET REPORT i. SUBJECT: FROM: CatsiU Spi Dcm-ell L (Ylno re. Please fill out the following questionnaire as complete as possible and distribute as indicated below within 24 hours of the upset. This report must be filed when (a) a mercury violation occurs (air and water), (b) a caustic spill results in a pH violation at Outfalls 001, 005 or 021, (c) a release of chlorine that exceeds 10 Ibs/day, or (d) any spill that must be reported to a governmental agency such as oil, caustic, or HC1. For incidents that occur on Friday, Saturday, or Sunday, the report must be dis tributed no later than 3:00 p.m. Monday. 1. DATE OF INCIDENT: _ 2. SOURCE OF RELEASE: /9l/cr'fW pO P ock 3. TIME AND DURATION: Pflf) $ /tl/M 4. WEATHER CONDITIONS (Circle One): (ffieafrj) Partly Cloudy Cloudy Rain 5. WIND SPEED AND DIRECTION (if a gas release): ___________ mph _ 6. MATERIAL RELEASED: 1TT-SV Ctiysfa'<__________________________ 7. ESTIMATED QUANTITY RELEASED: -7jT OfiU 8. CAUSE OF RELEASE: UilueL rff- T-$D /Oodiry MmPcM f<fPi c^t`* . Gtusir* fn a vahe L tt* f>!i- W ~h Urn. <2t*Jo.er'f/d^,__ade/'rl/Qtoj______ Ujgs hbaki>y & 9. IMMEDIATE ACTION TAKEN: `sAt/f lt(P C?t*sAc_ ie?nlzs ^ dean* y]g iuthf Called (H (race 'b'Vc.k. ft Curie mTh ___ vdye :__________________________________________________________ 10. ACTION PLANS TO PREVENT REOCCURRENCE: /Z)t//g^ -- A" 4h///ltr~ (XTeiul^hn^Jn<c..). &u\<uuil) ^iiAual a^d&AM> QejtJbZ c,\jnA 41 <?#yb/$yscc, 11. NOTIFICATION MADE (Who, When):' t/ftj rvLiP l*3-(. <--v. a/o lUM;J sk', f(- Zvpe,',n-(r*de*i dl~ k-lQ P/Yl 'C *1 . l\ -t\~ `W \ ' . Distribution: General Foreman Production Superintendent Operations Superintendent Plant Mananger Environmental File 0 30i. S~ cc: Manager, Environmental Control Manager, Operational Services  * >/ i >// W V, C ENVIRONMENTAL UPSET REPORT VU 4 H M WlUVJUUlU General Foreman Production Superintends! Operations Superintends; Plant Manager Environmental Control SUGJECT: FROM: L/,_ drAAL/ZHP Li,/>/>**- __________________________ Please complete the following questionnaire and forward as soon as possible. [This report must be received by the Environmental Control Department within five (5) calendar days of the incident.] 1. DATE OF INCIDENT: JefT. S; /9SC/ 2. SOURCE OF RELEASE: 14 Lack C-AS /-JuSf_________________ 3. TIME AND DURATION: mL -Jo M/ur<=s 4. WEATHER CONDITIONS (Circle One): (^CUar ) Partly Cloudy Cloudy 5. WIND SPEED ANO DIRECTION (if a gas release): 6. HAZARDOUS MATERIAL RELEASED: CL /)S S' mph a) Rain 7. ESTIMATED QUANTITY RELEASED: -8 lbs S. CAUSE OF RELEASE: (jAJ' Irfizeo tAjCvOs-aj ^ /./AtJjAjt-n i/Ali'l? /C/}S /Aji~ /Ial yA&t&r A r A///J rfrany JJArjotJ. Cl- G/l-r t&TAftrp /I/OS'*- 9. IMMEDIATE ACTION TAKEN: JS'<jAAJrV AJa&O^jZ -J'a// 'XjJJ'TAll&P 0 a/ c'MO Qt' /-Jpj'f-____________________________ IQ. ACTION PLANS TO PREVENT REOCCURRENCE: Lr Hosts' jja/sJ C.jQ/ir /l/u* T> {JlffJl A>JP Cu-PlAci? LEAk';*6- OALi'tZsr, QaJ GM c>J= TS>. /QAJ'q II. NOTIFICATION MADE (Who, When): .l . 'ly-.'i- "r^T ?> a-1, \ Environmental File //_jjM SL 872ss I ENVIRONMENTAL UPSET REPORT General Fora.m., "" Production Superintender Operations Superintender Plant Manager Environmental Control SUBJECT: (3w<>77cSpJIPsmeGxi I/) D FROM: iaj - CjUfD&ij' -8^/ppr_M& Pb&MA Please complete the following questionnaire and forward as soon as possible. [This report must be received by the Environmental Control Department within five (5) calendar days of the incident.] 1. DATE OF INCIDENT: /0-(o'%< 2. 3. i* ' 4. SOURCE OF RELEASE: DQftlL TIME AND DURATION: 5',0 Pm-lcEK TffUti 3aSeC0*itX _____ WEATHER CONDITIONS (Circle One): Clear fPartly Cloudy`S Cloudy Rain 5. WIND SPEEO AND DIRECTION (If a gas release):mph 6. HAZARDOUS MATERIAL RELEASED: T~SO C4\JV77 c' _______________ 7. ESTIMATED qUAMTITV^ASEO^^^^ 38. 8. CAUSE OF RELEASE: |VBQUCftfcM\ (UAV AfT^ KNKpSmkU (d&iUfr fraO. RfioJlWW T ilmTOe .VnalTo Woff Pu*p, tofliit-hMs imS/oc oE 1W. (Pile*/ IWmMi- rwvrcuAi *n <^r OF* Pump /r^mcoi* 3rappe0 CUwwb auraTTfr/f Po/wT^A-wo Vug SM-^T OAP l/Je 1/A^ue~. 9. IMMEDIATE ACTION TAKENf ^'UuT OPt^ Pump *. * i./Mg V4CL/5 tfftttvvnl.________________ _____________________ Ofrfr 10. ACTION PLANS TO PREVENT REOCCURRENCE^ ^ ir <^igrv "ts A 'WvYfe'Wt&hVw^fcV ctN'WApt* , ^ ^ __________________^ ^ Yawbfr <a>fvr> -a* a sV,tT\w*s>-' J----- * *--vWii_Ul-**ofcLj3r\3*A N^Tn Wlw-SL ex* jdLSser^-bY|- ~n 1 r *rm\XT 1 ~v - | `iffnr 'i jVh, nTun '1 V m. 11. NOTIFICATION MADE (Who, When): hUT.fc.FO St4. Ft Si)peg/11T<?N>i+iT v*. IQfolg ft*T 5: P/>-> j '(Bamm C.cxgac.T^ <$* tg.''--r\Q gxjrsvYp Vooo^r ! ^ Environmental File 8 ^xA.fT* QtsrN-r-&fl7ea-^ Q.-S SL 087269 I TO Johnny Taylor DATE February 13, 1985 FROM Jim Lafleur SUBJECT Caustic Spill from Caustic Barge PPG 208 On January 25, 1985, PPG 208 caustic barge was being loaded from Shore Tank 203. Tankerman J. Terry was topping off the barge. Loader Helper was standing by loading pump to cut it off. The barge started overflowing before the Tankerman could get the valve closed. The barge overflowed approximately 15.20 seconds before the valve was closed. Our loading rate is approximately 600 liquid tons/hour with one pump which we use when loading barges. This calculates to approximately 2.5 liquid tons lost, before the valve was shut and approximately .5 liquid tons lost from the barge loading lines to the barge or a total of 3 liquid tons (1.5 AB tons) lost into the ship channel. After the barge was off loaded to the correct level in the barge, our shore tank level showed we took out 1,262 liquid tons from the shore tank and the barge ullages showed we had 1,263 liquid tons in the barge. At the time of the spill Andy Plauche was notified and he notified all the necessary agencies. Tankerman Jim Terry will be given a minor reprimand. To keep from over loading barges in the future, we will load barges PPG 205 through PPG 245 to a 5 foot ullage, then shut off the loading pump and reduce the loading rate while topping the barge off to maximum load. Barges PPG 251 through PPG 253 will be loaded to a 6 foot ullage then shut the pump off and finish loading at a reduced rate to maximum load. On all other barges (customer) if you don't have a maximum load by the time you are up to 1 1/2 feet from the top of barge cargo tank (not from the gage point), shut off the loading pump and continue loading at a reduced rate to maximum load. Si 8727q CHEMICALS indusimi y. TO Mercury Cell Operators FROM C* L. Tlnney ^ INTEROFFICE / LAKE CHARLES DATE November 14, 1984 SUBJECT H2SO, Unloading/Transfers Recently a very "close call" occurred In the Mercury Cell area involving sulphuric acid. Shipping unloaders were in the process of setting up to unload a sulphuric acid rail car into the east sulphuric storage tank. The Utilities area operator on duty, who had just finished gauging an MC-50 day tank was walking in front of the sulphuric acid unloading manifold when a section of the unloading pipe at ground level blew out under pressure. A large stream of acid came within inches of striking the operator, passing just behind him as he moved. It appears that the practiced unloading procedure has been to pressure up the rail car and all piping up to the storage tank inlet valve at the unloading mani fold. The tank inlet valve is then opened to allow flow into the tank. Shipping has been asked to modify the unloading procedure so that only the rail car is pressured up initially with the car outlet valve closed. All unloading piping should then be lined up through the manifold into the east sulphuric storage tank and the rail car outlet valve be used to regulate flow to the tank. Also effective immediately the Utilities Operator will be responsible for barri cading the street north of the control room before all sulphuric acid transfers and before unloading either a tank truck or rail car of sulphuric acid. The barricades should be positioned at the east end of the roadway and just east of the control building in the vicinity of the chilled water pumps. Permanent barricade posts and chains are being installed at these locations for this purpose. These barricades will restrict traffic flow through the area during acid transfers and will serve as a warning to all persons who must enter the area. Before trans ferring sulfuric acid from the east storage tank to either the west storage tank, acid towers, or cooling tower tank the Utilities Operator and Lead Operator will be responsible for notifying'bll other Mercury Cell operators that the trans fer is about to begin. All personnel should ovoid working directly under the sulphuric acid piping during a transfer without the proper protective clothing. Anyone who must pass near or directly under the transfer header should wear goggles while a transfer is in progress. Special notification should be made to any Maintenance personnel who may be working in the vicinity of the sulphuric acid transfer header. /gc ce: SOP Manual 1 -A-l 8 Sh 087271 chemicals n w <ra INDUSTRIES INTEROFFICE / LAKE CHARLES TO All Tankennen FROM Johnny Taylor DATE SUBJECT February 22, 1985 Due to having two barges overflow while loading, we need to change our loading procedure. We will load barges PPG 205 through PPG 245 to a 5 foot ullage, then shut off the loading pump and reduce the loading rate `while topping the barge off to maximum load, keeping a'close watch on barge ullage so the barge does not overflow. Barges PPG 251 through PPG 253 will be loaded to a 6 foot ullage, then shut the pump off and finish loading at a reduced rate to maximum load, while watching ullages close. On all other barges (customer) if you don11 have a maximum load by the time you are up to 1 1/2 feet from Top of Barge Cargo Tank (NOT FROM GUAGE POINT), shut off the loading pump and continue loading at a reduced rate to maximum load. This is also for our CSCC 201, 202, and 203 barges. The pump cannot be shut off if there is not enough, material in the dock tank to gravity flow to the barge. You will have to use the pump and restrict .the dock valve to get a slower loading rate.. Our main concern here is NOT to overflow any more barges, so watch the cargo ullages very close. Also, the coast guard has notified us that they will be' making spot checks on us when we are loading.barges, so make sure everything is in order. Si, 087272 Written Procedures for Plant 'A' Shipping that relate to the Environment SL 087273 CHEMICALS / So . I^^ i tiKuC^i /'V -- INTEROFFICE/LAKE CHARLES Distribution TO DATE January 29, 1985 FROM Leo C. Comeaux Robert P. Byars Plant "A" Environmental Reporting Procedures There is an increased level of activity in the area of agencies investigating environmental incidents. The purpos of the following notification procedure is to quickly inform those people who will have to deal with the questions raised by these outside agencies. Armed with#the facts, they stand a better chance of keeping a trul/'minor incid nt from growing into a major event. Until"further notice,'in addition'to"those^procedures"now in effect, ' the Shift Supervisor is to verbally "communicate, t r.j the General Foreman of'the"affected'area incidents that* require- our environmental- group -to- notify' anyone 'outside1' ti the plant; 'i.e., EPA,DEQ, coast Guard, General'Office.7 This communication of the incident is'to'proceed'through"the7' channel"of'General.Foreman, " Area'Superintendent,"Operations 7 Superintendent and Plant Manager. In"the'event that contact;* with the first level'cannot , be'made', proceed7toTtheTnextv contact in* the chain.-' .......................... The'determination "as" to "whether" or~'not"the_incident* will'be'" reported to an outside agency or'to the'General"Office"is made by the Environmental Group. The'Shift Supervisor will' have to'get feedback from the'Shift Superintendent on the f notification plans. Th^. General"Foreman should be notifi d prior to or at the "same time that" the" outside" agency-is ' . contacted. It is also important that the Shift Supervisors notify the Shift Superintendent of all spills or releases affecting the environment. This includes spills of short duration over which he may not have control but simply needs to be informed. Distribution Plant "AM shift Supervisors Plant "A" General Foremen Shift Superintendents l/J. M. Porter A. J. Kubicek W. J. Peard /da File; ENVRPROC.LCC SL 087274 CHEMICALS INDUSTRIES TO FROM J. C. LaFleur J. M. DiGiglia INTEROFFICE / LAKE CHARLES DATE May 4, 1982 SUBJECT Check List for Hazardous Waste Shipments Leaving Lake Charles Complex It has come to my attention that we need a double-check for hazardous waste manifests. In the recent past, we have had several instances where manifested loads have left the Complex with improperly completed manifest documents. Since the Shipping Foremen are presently inspecting the trucks, I feel that they would be our best bet to see that this check is made. The following items on each manifest need to be checked and filled out before a load of hazardous waste is allowed to leave this plant: 1. Sequence number 2. Shipping description 3. Hazard class 4. Waste number 5. Weight 6. Packaging 7. Generator name and EPA ID number 8. Transporter name and EPA ID number 9. Disposer name and EPA ID number 10. Generator signature 11. One transporter signature Once a quick check of these items has been made, and everything has been completed, the Shipping Foreman can sign the manifest and send the load on its way. If any of the above items have not been filled out, ask the driver to wait and contact either myself (4370) or Pat Whitley (4899) as soon as possible. /ap cc: W. J. Ardoin C. C. Ellender A. D. Fontenot D. J. Phillips J. M. White File #513.4.04 SL 087275 CHEMICALS INDUSTRIES TO FROM See Distribution J* C. INTEROFFICE / LAKE CHARLES May 1L, 1981 SUBJECT Hazardous Waste Shipment Procedures The Shipping Department has recently been given the responsibility of signing all hazardous waste manifests for all hazardous waste shipments leaving the Plant. In order that there be no question as to what hind of waste is in each individual shipment (Shipping has no means of verifying what waste is in a specific shipment), the attached procedure has been proposed and, if no objections are received, will go into effect on May 20, 1981. The "Generator" in this proposal is the Environmental Foreman for the area in which the waste was generated or the designated supervisor in the unit generating ,the waste. On back-shifts, the Shift Supervisors can sign the manifests in place of the Foreman. /ap Attachment Distribution A. J. Beatrice E. F. Parsons R. L. Jones G. L. Perry A. L. Greathouse/A. P. Flauche' R. J. Hoening Shift Supervisors (A, B-I, B-II, C, Powerhouse, Shipping) Shift Superintendent Chief, Plant Security SL 087276 PROCEDURE FOR SHIPPING WASTE MATERIALS 1. Transporter picks up paperwork at the Main Guard Office. 2. Transporter checks in at the unit which generated the waste materials. 3. Generator of the waste materials checks the paperwork to be sure it is for the waste to be loaded and shipped. Example: A. For vacuum trucks -- Match the Purchase Order No. on the Driver's work ticket with the La. State manifest B. For bulk boxes -- (1) Match the Purchase Order No. on the Driver's work ticket with the La. State manifest. (2) Match the Box No. on the Driver's work ticket with the La. State manifest . C. For drums -- (1) Match the Purchase Order No. on the Driver's work ticket with the La. State manifest. (2) Match the following items on the La. State manifest with the labels on the drums: (a) manifest document number (b) shipping description (c) UN or NA number (d) EPA waste number 4. Transporter loads the waste materials. 5. Generator verifies the loading and signs the following papers: A. All manifests as the generator of the waste materials B. The Driver's work ticket as the shipper 6. Transporter's truck is weighed at the scales and Shipping is called. 7. The Shipping representative will do the following: A. Check the gross w--`ght of the truck B. Check for placards, if required, according to the PPG manifest C. Co-sign all manifests to certify that the shipment has been properly marked and labeled, and is in proper condition to be shipped 8. Transporter signs th manifest at the Main Guard Office. SL 087277 9. A Guard checks all paperwork to be sure there are two signatures for the Generator on all the manifests. 10. Transporter leaves the plant. / SL 087278 Revised: 5/10/84 ENVIRONMENTAL UPSET NOTIFICATION GUIDE Incident WATER Oil Spills Chemical Spills By-pass or any NPDES wastewater facility (i.e., WTU, Hg Treat., Pb Treat., Sodium Formate, Silicas Sand Filters, Brine Treat ment) Actual or Probable NPDES violation if: (1) due to factor(s) beyond our reasonable control; or (2) amount of discharge is twice the permitted maximum Condition Red Chlorine Absorber Discharge Contact M. DiGiglia or P. McFarlain P. McFarlain or A. Plauche1 P. McFarlain J. Wyche P. McFarlain J. Wyche P. McFarlain A. Plauche1 Home Phone 474-3122 478-0188 478-0188 625-8740 478-0188 477-5292 478-0188 477-5292 478-0188 625-8740 AIR Gas/Vapor Release 1. Posing danger to citizens outside the plant 2. Any other gas/vapor releases (i.e., Clvinyl chloride, HCI, others) SO, Alarms Safety local authorities on hot line; also Disaster Coordinator Environ. - W. Peard or J. Wyche or A. Greathouse K. Komoroski or P. McFarlain 477-2209 478-9163 477-5292 478-7447 478-7983 478-0188 K. Komoroski 478-7983 9 SL 87279 Revised: 5/10/84 / Incident III. HAZARDOUS WASTE A. Spills in Transit B. Disposal Problems C. Spills from hazardous waste facilities (WTU, Hg Treat., PH 'C' Asb. Pond, Classifiers, Incinerators, WTU, Feed Surge Pond, VCM-II API Separator) Contact Home Phone Environ. - A. Plauche' or M. DiGiglia Operations - G. Jordan M. DiGiglia or A. Plauche1 A. Plauche* or M. DiGiglia 625-8740 474-3122 625-5080 474-3122 625-8740 62S-8740 474-3122 IV. VISITS BY GOVERNMENT AGENCIES A. EPA, Coast Guard, DEQ J. Wyche or A. Greathouse W. Peard B. OSHA R. Williams 477-5292 478-7447 478-9163 625-7965 . 08^80 9a Revised: 3/1/84 ENVIRONMENTAL CONROL DEPARTMENT PERSONNEL J. M. DiGiglia A. L. Greathouse K. S. Komoroski P. M. McFarlain W. J. Peard A. P. Plauche1 J. E. Wyche Phone Number Plant Home 4370 474-3122 4422 478-7447 4576 478-7983 4420 478-0188 4848 4814 478-9163 625-8740 4840 477-5292 <b & zS> 9b