Document jNXv8b5QKd0oe15NE5YKr2e2

A cmd C%e#uca& CALVERT CITY PLANT INTEROFFICE MEMORANDUM To: B. D. Helms From: R. W. McGinnis Ra: PVC Procedures - Hygiene Date: 18 January 1980 copies: A* F* Cantor R. c. Lietzau \ Recently prepared Safe Work Practices (SWPs) for PVC and their Emergency Procedures were examined for adequacy on meeting VCM hygiene requirements. A number of deficiencies were observed and are noted on the marked up attached sheets. I have not tried to reconcile the discrepancies, and my comments should be taken only as an indication that the area needs to be examined, as a number of my comments were made in early stages of familiarization before the mosaic had crystal lized into a definitive form. R. W. McGinnis j \i ,r j AP00031883 4 MAJOR VINYL CHLORIDE RELEASE Should a major VC1 leak occur, i.e., flange, broken line or sight glass, blown manway gasket, etc., every attempt to stop the leak should be made as soon as possible. Follow the emergency procodure given below: 1, Sound the VCM spill alarm. Switches to activate this alarm will be plainly marked in the various areas. 1 2. Notify the foreman and all personnel in the area that there is a bad VCM leak. Air masks will be put on by all personnel in the area. -------- t r 3. The following items should be done simultaneously: l-' a. All persons not required for the emergency should go to a _safe area. This includes maintenance, construction, ' engineering, vendors, etc. All non-process equipment (welding machines, cars, trucks, etc.) will be shut down. The decision to leave the building will be made by the supervisor, or in his absence, the senioT floor operator. b. Advise the boiler operator, at Escambia ot the Safety Officer - at Calvert City, who will notify personnel in the other operating areas. c. Barricade all the roads around the PVC Plant. <V / d. Turn on the light at PVOH and Emulsions to notify them of a VCM spill. e. Call the boiler at 274-275 for emergency whistle. # AtkM. 4. Every attempt should be made to stop the leak as soon as possi ble. Proper respiratory (Appendix A)-and protective equipment (Appendix B) should be worn.'. Refer to these sections for detailed instructions. ' 5. Do not enter a fogged area where visibility is limited or whoTe the concentration of VCM is unknown unless it is for the pur pose of saving a life. 6. Do not connect or disconnect extension cords, or drop tools or metaT"objects that could cause a spark. 7. When a deluge system is not present or working, hose down the spill with large amounts of water. Isolate the spill such that waste treatment will not be slugged with a large quantity of VCM*- L X.*.: - IX - AP00031884 3. All ventilating fans should be running.. Turn off all lights in vicinity of leak, if possible, to minimize chance of ignition. 9. After the leak has been secured, the. area should be "sniffed" with the portable hydrocarbon detector (HNu meter) to deter mine if there is any VCM still in the area. 10 11 V./ C 12 After the area is clear, the VCM spill alarm should be shut off. PVOH and Emulsions should be notified that the>emergency is over. Also, the Safety Officer should be notified that the emergency is oveT. /T Everyone exposed to VCM rrmrypf-rar i nn< than 5 PPM sSoii.1 be taken to First Aid for afElood test. The PVC Plant General Foreman and the Assistant Plant Superin tendent should be notified about- the spill. 13. The spill should be investigated. The following two forms must be filled out: a. Environmental Control Report Manual Vent) Valve, Rupture Disc, b. Unusual Occurrence Report. *T *4 rtcrata* |J i - 12 AP00031885 EXPOSURE TO VINYL CHLORIDE To ninimite the risks of vinyl chloride exposure, the following steps are to be adhered to in compliance`with the OSHA ruling of 4 October 1974: 1. Section I and II are regulated areas. 2. Fresh air and canister masks are provided for all' person nel entering a regulated area. See the plant diagrams for location of the fresh air connections. Each connection has a T capable of handling up to 4 masks simultaneously. A separate air breathing system is provided for this pur pose. All personnel may be required to carry a mask with* them at all times in this area. See Attachment A for use of respirator protection. 3. The plant is equipped with chromatograph sensors and red light alarms that indicate 1 PPM VCM or greater. When these lights are on, it is mandatory that all personnel in the area wear their masks. See plant diagrams under FIRES for location, of red light alarms. Below 1 PPM the wearing of masks is not required. 4. All utility men entering vessels are required to wear fresh air masks. 5. The proper protective clothing is necessary when there is a possibility of contacting liquid VCM, strong VCM vapors, or when the job requires. See Attachment B on Protective Clothing. . Fqvp -- -j r** VCM 6 There tfre six^ gas chromatographs/,' each detecting the VCM concentration at various points throughout the regulated area. The location and VCM concentration is displayed continually on the panel board in the appropriate Control-' Room. 7. Obey all standard work procedures and obtain specific instructions from supervisor for any non-routine job. 8. All equipment is to be properly assembled and pressure tested before put into use. 9. All operations are to be monitored for correct temperatures, pressures, recipes, etc. 10. All equipment is to be purged to the recovery system or by the fugitive emission system before opening and/or entering. ! ! i nL i: it .\ i4i - 13 AP00031886 V SAFE WOAX PRACTICE --PVC Plant Page 1 NO. of 2 JOB Changing Miter Cartridge Elsrngnts in VTM and Recovered, VQ4. prepared by R.-L. HalL Reviewed by '< < foreman Foreman V.c Foreman Orig. Date of Issue: sjt~ 7f Revision Date: APPROVED BY:_____________ Safety Engineer APPROVED BY: ArF C- 'Or~T- 7"70 Dept.-Head APPROVED BY: Plant Manager REQ'D PROTECTIVE r---------------- T^ImTi TTn1~ In fety Glasses Utf ... 1 Ag- Fore JOB STEPS IN SEOUEP/CE POTEOTIAL HAZARDS RECOMMENDED SAFE PROCEDURE, 1. Turn on ventilation bloweT 5 check to see that air flow thru . hose is adequate. 2. Valve off filter to isolate Make sure alternate filter is valved into service $ checked for leaks. 3. Attach hose to drain Bad gasket 'in coupling nay valve and to. gasholder cause leak. line. Check all valving on both filters proceeding. Check gaskets and tight fit of ho< fittings. 4. Let down pressure to the gasholder. Open valve slowly and bleed off p: slowly. The following steps require a fresh air mask,*e be woq, 5. Valve off hose, VCM may be evolved. Tt Put on fresh air mask. disconnect from gas holder line connect to Fugitive Emissions line. k//& 6. Valve in and pull into a vacuum. Make sure Fugitive Emissions is i service. 7. Valve off hose and Oxygen may enter gasholder Make sure valves are securely clo disconnect both ends. or recovery. 8. Position ertiaust; hose near top of pot break the vacuum thru the valve. AP00031887 SAFE WORK PRACTICE PVC Plane Page__ l NO. of JOB Changing FilteT Cartridge Elements in VCM and Recovered VCM prepared bv Orig- Date of issues R. L. HalX __________ Revision Date: Reviewed by Foremtaf n APPROVED BY: Foreman Foreman \ Safety Engineer APPROVED BYs Dept. Head APPROVED BY: Plant Manager SEQ'D PROTECTIVE EQUIPMENT: Fresh Air Mask. Safety Glasses. Gloves Fort JOB STEPS IN SEQUENCE 9% POTENTIA ?5V& TO#CO9MM7E*N1DED SAFE PR P. ~r] rlnirnr fj--*t^*: *y*r*TT' monomer may be trapped If monomer is evolved, back off and fully open the pot. in pockets of polymer and the vent fan carry it away. may be released as the skins aTe fractured. Mm Mrr&* lHeT" Remove dirty ^artpid^i Monomer evaporating from i5pDs'e' 4h oj >i+m -- itely '`remo'v from the building. 1^- Wash residue from the pockets in the filter sediment ponds. DO NOT PUT INTO C_ cartridges can raise level DUMPSTER. within confined space. ,, ycri . u Wr tfr*r'0*** Residual vapor within the Check with HNU meter. If Teading pot and if atmosphere room. / ^ppm or below, the mask may be remo' in the room is o.k. air. mask may be removed to complete the job. 1*. Install new filter cartridges,. "0" ring and close up the pot. Mashing fingeTS with heavy Do not expose fingers to possible lid. points. Put a manilla tag on. the pot with time and date filters were changed. Mark"check for leaks"when put in to service. AP00031888 SAFE WORK PRACTICE aryr'^.y C^.t PVC Plant Page___ 2. M0.t of JOB CTKPS. TV ^rQTTTWrE PnrFUTTftT. KR7RPnS 3- 3-C. VCM es cape. 3-C- The purpose for filling with water is to displace the VCM gas in the ~~ 1 ^ ~ -A.X "column. Make sure that nothing on the column or reflux drum is opener until both axe liquid full. Then and only then, open to the atmos phere after the gas line has been closed. 4. After the' column, is 4. full of water, turn on the steam for 1-2 min. Set steam valve at 5-102 open. Too much steam may damage column intern' ala or bum resin in the column. Stand by at the manual valve in thi field to close the valve if the automatic valve fails. 5. Shut off the steam 5. Same as #4 Sams as #4. 6. Drain the column to th pad* Run the bottoms pump in. order to clear the slurry from the column bottom. ,, __vw$T' 7. Repeat'until the water leaving the column is clear. Burn hazard. }t*i I ' a T;V Stay clear of the pump discharge. 8. Open and flush the reflux drum. .8. The drum may contain 8 VCM vapors. A !(<,(/ 9. Close reflux drum and the column Is ready for purging and start up. 9. Valves are closed .that are normally open. Isolate the tank properly and chec internal atmosphere with HNU meter after opening. iA/H/r /-'o- Check field position of all normal open valves 0/'$ Mr. mi-' AP00031889 AIK rKuuutxa ano unc-ruu/ibo f . Chemicals Group Calvert City, Kentucky SAFE WORK PRACTICE PVC_________ __ ___________ No.______ Plant Page 1 of 2 :OB Sampling VCM Containiing Streams 'repared by R. L. Hall Reviewed by Foreman ^rig. Date Revision Issue: 1 Oct. 1979 Date: APPROVED BY: ^PROVED BY: Dept. Head APPROVED BY: Foreman ^Foreman Safety Engineer Plant Manager JEQ'D PROTECTIVE EQUIPMENT: Gloves. Fresh Air Mask or Scott Air ?ak Forsman JOB STEPS IN SEQUENCE POTENTIAL HAZARDS RECOMMENDED SAFE PROCEDURE I. EPA requires chat all sjcTeams greater than 10Z VCM pust be sampled in a closed system. The following will apply to these points: 1) Prepare a'sample bomb 1) VCM exposure 1) If the bomb contains material from the previous sample, connect to che fugitive emissions and vent down. ) 2)2 Connect the bomb to the Leaks, emitting VCM line or vessel to be sampled with V tubing, then connect to the proper vent valve which may be a pump suction or the Fugitive Emissions Reader. 2) Make all connections very carefully. Make all joints tight with two wrenches to avoid twisting off a fitting. 3) Purge the sample thru the bomb. 3) Leaks, check .joints A) Make sure the bomb has 4) Rydrostat and burst a vapor snare. the bomb. ---------------- 5) Disconnect: close all 5) VCM emission valves then put on gloves 6 fresh air mask or Scott air pak. 3) Open first the vent valve on the bom then slowly open the supply valve, . let the sample sweep thru the boob. A) If the bomb is liquid full, a very small change in temperature generate a very high pressure. tv 5) Break unions with wrenches. A small amount of liquid vill escape. Back off and allow pressure to bleed off then finish removal. Tjj/S ?# Tff7/Vt~ mn^r- <f Da r r /// r (Pf Ff f&esr AP00031890 / SATE WORK PRACTICE PVC Plant Page___ NO. of 2 CTVpq TN CFOTiFVrF pnrs'WTTar. witbafic wmvMT>tnpn sift poorpninsr II. Streams Containing . less than 10Z VCM. I) Prepare a sample container by rinsing or if it has been used previously, wash out all residue. 1) Hot water burns. * : 1) Wash and rinse thoroughly in fresh or DM water. If DM water is used, wear gloves to protect hands because it is hot. 2) Put on Scott air pak 2) VCM exposure and bums. 2) Most samples of this order will be or Fresh air mask 6 lurry and will be hot. gloves. /y tq\ if A 3) Collect sample. NOTE: Samples from displacement water tk. or Nash seal water or other similar streams will be treated the same as unstripped slurry but will not he hot. 3) VCM exposure end burns. 3) Open valves slowly and stand behind the valve to avoid a hot spray from contacting clothing or skin. Do not breathe vapors emitted. 4) Put warning on label: "This sample contains VCM: 4) VCM exposure 4) To alert lab person that this sample requires special handling. 5) Bose down area. 5) Housekeeping 5) Wash any spill or residue to the sever imaediately. 6) Deliver sample to the lab. frtfZ l'..- : (fiiM J4 6) Routine 6) Verbally notify the lab person that the sample may contain VCM. \/cri * 4* 3 - AP0003189f *>J'J 4. Training of the wearers of respirators. 5. Use of respiratory protection equipment. Required apparatus when VCM concentration is: Over 4*-PFM Air supplied respirator. Over 1,000 PPM Self-contained breathing apparatus. Over 3,600 PPM Self-contained breathing Apparatus. Entry into area may be made only for purpose of life rescue, fire fighting, or securing equipment to prevent a greater hazard from release of VCM. Over 36,000 PPM - .Self-contained breathing apparatus. Entry into area may be made only for purposes of life rescue. C. Limitations of respiratory protection. 1. Workers with chronic respiratory deficiencies cannot wear respirators. a 2. Workers with a cold, bronchial congestion, hay fever, or any irritation that causes repeated sneezing, coughing, or runny nose, and conditions which require a person to frequently expectorate, etc. cannot wear respirators for any extended period. 3. Communication is poor in respirators. 4. Airlines are cumbersome and create a tripping hazard. tf - 82 - AP00031892 APPENDIX B PROTECTIVE CLOTHING - PVC PLANT A. Purpose The purpose of this section is to outline the jobs or areas where special protective clothing-is required and the type of clothing to be used. ' Where Protective Clothing is Required No . special uniform or protective clothing is required for normal day-to-day operations in the PVC Resin Plant. Special protective clothing is required for the following jobs or operation: 1. Reactor entry and/or cleaning 2. Cleaning of any vessel that contains polyvinyl chloride residue 3. During the opening of any line, vessel or other piece ofequipment that has at any time contained vinyl chloride or polyvinyl chloride regardless of whether the line or piece of equipment has been purged. Protectivei ^be^Worn The following protective clothing is to be worn for jobs B-l and B-2 listed above. ---------------------- .-------- 1. Respirator 2. Rain suit comprising of pants and coat 3. Rubber gloves 4- Cloth cap 5. RubbeT boots 6. Eye protection The following protective clothing is to be worn for job B-3 listed above. Z. Rain coat - 83 - ! i. AP0003I893