Document nNb8qb7oXzZXKGoBw8Y9QoKnR

VICE MEMO PPG CHEMICALS LAKE CHARLES >ON PEREZ DATE: MARCH 28, 1990 SUBJECT: PLAN TO MEET THE NEW 1 PPM EDC IPEL AT LP/EDC < RESPONSE TO OUR DERIVATIVES 1990 ENVIRONMENTAL GOALS, jELOW IS A LIST OF SOURCES OF EDC EXPOSURE AT #1 AND 2 LP EDC PLANTS THAT MUST BE CORRECTED TO COMPLY WITH THE 1 PPM IPEL GUIDE LINES. INCLUDED IS A LIST OF SUGGESTED SOLUTIONS. SOURCES OF EDC EXPOSURE 1. ROUTINE SAMPLES. A. closed loop sampling. 2. ORTHOTOLINE CHLORINE CHECK IN REACTOR CRUDE. A. in line chlorine analyser at rx. condenser drain. 3. ETHYLENE ANALYER VENT. A. system to put vent to incinerator header. B. remove edc with carbon. 4. RECHARGING OF DRYERS AND NEUTRALIZERS. 5. CLEARING OF PUMPS. A. to clear pump suction/bowl for seal job, a portable N2 driven pump will be connected to low point drain and all liquid will be pumped back to system, then N2 purged to vent header. 6. #2 AND #4 EDC TANKS USED AS AREA BTMS STORAGE TANKS. A. install bs&b vent valves and compress vents to incinerator. 7. CLEARING OF TANKS, VESSELS, AND COLUMNS. A. purge to incinerator. B. purge through carbon bed. C. vacuum pump exhaust to incinerator. D. vaporize to incinerator using N2 through portable heater. 8. VENT HEADER LIQUID. A. install knock out pots with pumps to transfer liquid back to system. 9. SPENT SAMPLE ACCUMULATION BOX. A. system to transfer liquid back to system. 10. EDC REACTOR LIQUOR SAMPLES. A. forced circulation closed loop sampling. 11. RUNNING ANALYSES IN PLANT LAB. A. new lab vent hood. B. edc monitor for lab. 12. PUMP SEAL LEAKS. A. double seal system . 13. VALVE PACKING LEAKS. A. change specs to orbit valves. 14. FUGITIVE LEAKS. A. area edc monitor. B. hand held edc monitor. ANY ADDITIONAL ITEMS IDENTIFIED WILL BE SENT AT A LATER DATE. PLEASE FEEL FREE TO ADD ANY ITEMS THAT YOU THINK OF THAT WE MAY HAVE MISSED. cc. D. SAVOY, F. ORTIZ. .E. BULLER R. ANDERSEN SL 072041