Document mqBLEx3xYJYQNZn6YJDdaY5Gb

conoco Interoffice Communication To From Date Subject A.W. Sirmons E.L. Kieschnick February 26, 1975 INSTALLATIONS REQUIRED FOR OKLAHOMA CITY PLANTS REGULATED AREA The regulated area for the Oklahoma City Plant has been est ablished by setting up North, East, South, and West boundary lim its. Included within the limits are the following areas: 1. VCM Unloading 2. VCM Storage 3. V--40 4. Dryer Building 5. Resin Storage Silos Implementation of the regulated area will require installation of additional fencing, regulated area signs and weather protection for rosters at two entrances. The regulated area will have nine (9) entry points, seven of which will normally be locked. The other two, one at the end of the pipe rack south of the dryer building, and the other at the pipe rack near the southeast corner of the control room, will be designated as roster entrances. Access through any of the seven normally-locked entrances will require clearance by the Shift Foreman and an. entry signature on a roster at one of the two roster locations. Entry signatures for the railroad will be entered by the Shift Foreman. Sign locations and additional fencing required are detailed in the work list and on the plant plot plan. E.L. Kieschnick, Process Engineer ELK/kv CC: (RTF-File), CWH, GWS, CHP, JJM, LDJ, MS, JF CCR 000010629 WORK LIST 1. Construct new chain link fence: a. On the west side of the railroad tracks north of the high silos. The fence is to run from the ex isting fence on the, north to a point in line with the north wall of the dryer building. Offset the fence approximately 9% feet west from the center line of the existing railroad tracks. b. Install a 30 foot gate in a southwesterly (45) direction from the south termination point of the fence in par a, above. c. On the west side of the road west of the plant* The fence is to run from the existing fence on the south to the new gate in par b, above. 2. Post regulated area- signs at 50 foot intervals along the pipe rack which runs from the southeast side of the dryer building to just east of the catalyst storage freezers. Continue sign posting east to the plant's eastern boundary fence. 3. Post regulated area signs at all entrances (designated by the symbol^ on the drawing) as follows: Boundary Limit Entrance(s) Northern V- On both sections of the new gate. On the existing gate located at the NW corner of the dryer building. On the two dryer building east entry doors. V- On both sides of the sidewalks at the west end of the pipe rack south of the dryer build ing. W- On both sides of the sidewalk where it crosses under the pipe rack (near southeast cor ner of control room). Eastern On each section of the two southernmost gates in the east fence. OCR 0000l6^ Work List -- Cont'd. Boundary Limit Southern Entrance(s) On each section of the two railroad entry gates. 4. Construct weather protection shelters at the two roster entrances 5. Lock all entrances exceptand CCR 000010631 EXPOSURE SOURCE I. Residual monomer in slurry and resin. n o 7> o o o o O' V** ENGINEERING AND WORK PRACTICE CONTROLS PLAN FOR COMPLIANCE WITH OSHA VCM EXPOSURE STANDARD CONOCO CHEMICALS OKLAHOMA CITY CHEMICAL PLANT April, 1975 WORK PRACTICE CONTROLS ENGINEERING CONTROLS 1. Design and install equipment re quired for steam stripping the slurry. Essentially all processing equipment downstream of the poly merization reactors is designed for atmospheric pressure and there fore open to the atmosphere. Processing slurry or resin in this equipment causes the emission of unreacted VCM which can lead to exposures above lppm. Plant tests have shown that steam stripping before dumping to the blend tanks substantially reduces the concen tration of VCM in the slurry. Thus, the amount of VCM available for emission from the open proc essing equipment will be greatly reduced by steam stripping and exposure problems will be minimized In particular, exposures at the dump screener, chemical wash screener, blend tanks, centrifuges, dryers, resin screeners and resin loading areas will be decreased and residual VCM in resin product leaving the plant will be decreased EXPOSURE SOURCE 2. Obtaining and handling samples. 3. VCM rail car unloading WORK PRACTICE CONTROLS 2. Wear personnel protection equipment wich meets OSHA standards when sampling reactors, slurry, wet cake, or resin. 3. Wear personnel protection equipment which meets OSHA standards while at the un loading rack during car hook up and disconnect. ENGINEERING CONTROLS 2. a) Install a new laboratory hood to - provide more work and storage space for slurry and reactor samples b) Prepare an engineering design for a closed reactor sampling system. Samples obtained during the early part of reaction contain high concentrations of VCM. By enclosing the reactor sampling system, exposure in the reactor area will be decreased because VCM will not be emitted from the sample in the working area. c) Prepare an engineering design for an improved resin sampling system at the M-500 dryer. 3. Prepare an engineering design to install glasses in unloading lines and rearrange valving at the un loading racks. Installation of sight glasses will eliminate venting to the atmosphere when determining liquid to-vapor transition at the end of un loading. Rearrangement of valving will minimize the volume vented during disconnect. EXPOSURE SOURCE 4, Chemical wash screener WORK PRACTICE CONTROLS ENGINEERING CONTROLS 4. Design and install an enclosure and vent system for the chemical wash screener similar to the system on the dump screener. ;5. Reactor rinse after dump * 5. Transfer the effluent from the initial water rinse after reactor dump to the dump system and eliminate transfer to the sewer. 6* M-500 dryer exhaust. 6. Prepare an engineering design to elevate the stack for the M-500 dryer exhaust. Currently, M-500 exhausts at the loading rack level which leads to exposure problems under certain wind conditions. Stack elevation will eliminate this problem. 7a All rotary seals, flexible hoses, pipe unions and flanges, valve stems and swivel joints which are in low or high concentration VCM service. n o vo o o o o 7. At least once per month, measure VCM concentrations at all hoses, flanges, unions, seals, valve stems and swivel joints in low or high concen tration VCM service. Repair or replace leakers on-the-spot, where necessary. List other leakers for repair or replace ment on the maintenance schedule. The fixed point monitor will detect the occurrence of relatively large leaks which will be attended immediately. EXPOSURE SOURCE 8. Opening and working on equipment or piping which may contain VCM in low or high concentrations. WORK PRACTICE CONTROLS ENGINEERING CONTROLS 8. a) Before opening, remove VCM from equipment or 8. Install electropolished internals in all reactors. Plant experience piping to the lowest has shown that the frequency of practical level by flushing, reactor entries for cleaning is purging and/or evacuation, decreased when electropolished where possible, internals are used. This is due to a decrease in polymer build b) Wear personnel protection up on electropolished internals equipment which meets OSHA as compared to the build-up on standards when opening equip other internals. The plant has ment or piping which may five sets of internals. Two sets contain VCM, c) Before commencing repair: work, are electropolished and'installed. One set is at the shop for measure the VCM concentration electropolishing. The other two in or near opened equipment sets will be electropolished or piping to determine what when they can be switched out. protective equipment is required and if further VCM removal should be attempted. o o O oo o o O' OJ O'