Document oDvxEL6djVjVnBEVaV5NQQLQr

ABDOO185487 APPENDIX ** A-1 H-1 ABDOO185488 Appendix A ABDOO185489 APPENDIX A Item No. A-l A-2 A-3 A-4 A-5 A-6 A-7 A-8 A-9 A-10 A-11 A-12 A-13 A-14 A-15 TABLE OF CONTENTS DESCRIPTION Letter, R.A.Frohreich (Conoco, Inc.) to Tommie A. Gibbs (Environmental Protection Agency) February 9, 1979 Letter, R.A. Frohreich (Conoco, Inc.) to Tommie A. Gibbs, (EPA) March 5, 1979 Letter, Curry L. Miller (Conoco, Inc.) to Wayne Aronson, (EPA) October 15, 1980 Letter, Curry L. Miller (Conoco, Inc.) to James T. Wilburn, (EPA) April 23, 1979 Document, Training Meeting Attendance Record, April 4, 1977 Document, Training Meeting Attendance Record, July 22, 1977 Document, Training Meeting Attendance Record, March 20, 1978 Document, Training Meeting Attendance Record, June 12, 1978 Inneroffice Communication, J.R. McCrimon to Distribution, REVISION TO OPERATING MANUALS FOR THE LARGE REACTORS EMERGENCY KILL PROCEDURE, February 8, 1979 Document, Training Meeting Attendance Record, February 25, 1979 Document, Training Meeting Attendance Record, February 27, 1979 Document, Training Meeting Attendance Record, March 2, 1979 Document, Training Meeting Attendance Record, March 10, 1979 IOC, J.E. Barton to Vinyl Shift Supervisors, EPA COMPLIANCE, March 20, 1979 Document, Training Meeting Attendance Record, March 23, 1979 4 ABDOO185490 APPENDIX A (Continued) ITEM NO. DESCRIPTION A-16 Document, Training Meeting Attendance Record, March 29, 1979 A-17 Document, Training Meeting Attendance Record, March 31, 1979 A-18 Document, Training Meeting Attendance Record, March 31, 1979 A-19 IOC, J.E. Barton to Vinyl Shift Supervisors EPA COMPLIANCE (REVISED), April 10, 1979 A-20 A-21 Document, Training Meeting Attendance Record, July 7, 1979 Memo, R.Collins, Safety Training Meetins, July 14, 1979; Document, Training Meeting Attendance Record, July 14, 1979 A-23 Document, Training Meeting Attendance Record, July 14, 1979 A-24 IOC, C.R. Miller to Vinyl Shift Supervisors, EMERGENCY SHUTDOWN PROCEDURES, October 25, 1979 A-25 IOC, J.E. Barton to Vinyl Shift Supervisors, EPA COMPLIANCE (UPDATE), October 30. 1979 A-26 Document, Training Meeting Attendance Record, October 26, 1979 A-27 Document, Training Meeting Attendance Record, November 9, 1979 A-28 Document, Training Meeting Attendance Record, November 10, 1979 A-29 Document, Training Meeting Attendance Record, November 12, 1979 A-30 Document, Training Meeting Attendance Record, November 4, 1979 A-31 IOC, M.P. Blackwell to Distribution, 5305 REACTION RUNAWAY LIMITS, March 4, 1981 A ABDOO185491 APPENDIX A (Continued) ITEM NO. DESCRIPTION A-32 Document, Safety Training Meeting Attendance Record, June 28, 1980 A-33 Document, Safety Training Meeting Attendance Record, July 15, 1980 A-34 Document, Safety Training Meeting Attendance Record, April 9, 1981 A-35 Document, Log Sheet, Supervisor's Log Book, March 13, 1978 A-36 Letter, Veldon E. Messick (Conoco Inc.) to Jerry B. Banks, P.E., (Mississippi Department of Natural Resources), June 11, 1984 A-37 Letter, Jerry B. Banks, P.E. (Mississippi Department of Natural Resources) to Veldon E. Messick (Conoco Inc.), July 3, 1984 A-38 Document, Graph, Reactor Pressure, psig versus Minutes After Simulated Power Failure A-39 Document, Table, Reactor Valve/Mode Interlock --Reactor 741 A ABDOO185492 A-1 February 9, 1979 ABDOO185493 Conoco Chomicnls Contmcni.il O'1 Comn.mv P 0. Boii 01 NwH'yh/..i, ' Aberdeen. Mississippi [iO'.'.t'j . A-1. United Stated-Environmental Protection Agency 345 Courtland Street Atlanta, Georgia 30308 Attention: ' Mr. Thommie A. Gibbs, Chief Air Engineering Branch Dear Sir: At approximately 4:00 p.m. on February 2, 1979, our plant experienced a vinyl chloride discharge from a relief valve on one of the polyvinyl chloride reactors. Pursuant to the National Emission Standard for Vinyl Chloride (40 CFR, Part 61, Subpart F, paragraph 61,65 a) we are reporting this to your office. The vessel involved was polymerization reactor D-300. The vessel relieved thru a 6" x 8n relief valve which had a 6" rupture disc between it and the reactor. The rupture disc was rated at 185 PSIG at'20QF and the relief valve setting was 185 PSIG. The reactor design pressure is 200 PSIG at 200F. The release resulted due to overpressure in the reactor after it was charged with vinyl chloride and water. Normal run temperature and pressure for the grade of resin being pro duced in the reactor is 126F and 118 PSIG. Upon completion of the charge and catalyst addition to the reactor, the reactor contents are at a temperature less than 126F. Steam addition to the jacket is used to bring the reactor contents up to run temperature. When the temperature approaches 126F, steam flow to. the reactor jacket is stopped and circulating cooling water is used to remove the heat of polymerization and maintain the reactor temperature at 126F. On this particular batch the reactor temperature and pressure continued to increase after the steam to the jacket was stopped and cooling water circulation to the reactor jacket and condenser was commenced. When the reactor pressure reached 130 PSIG, alpha methyl styrene (polymerization kill agent) was added in an attempt to slow the reaction rate. The temperature and pressure continued to increase and at 140 PSIG alpha methyl styrene was again February 9,.1979 Page 2 ABDOO185494 A-1 added to the reactor to attempt to slow the reaction rate. The pressure continued to rise. At this point the decision was made to kill the reaction with the emergency kill system. This system provides nitric oxide addition into the reactors to kill the reaction in emergency situations. The attempt- to kill the reaction with nitric oxide failed because the one-half inch stainless steel line which is used to oipc the nitric oxide into the reactor blew off when it was pressurized with nitric oxide. Due to the nitric oxide release the area had to be evacuated. Personnel put on Scott Air Packs and returned to the reactor to attempt to put a- large quantity of AMS into the reactor to kill it. As this was being done the pressure in the reactor reached 181 PSIG and rupture disc-safety relief valve relieving system started venting to the atmopshere. This vent is approximately 50 feet .above ground level. At this time the reactor was equalized into an adjacent empty reactor and the pressure dropped immediately. However, the relief valve did not reseat and the reactor continued to vent until approximately 4:30 p.m. No personnel.were exposed to vinyl chloride during the incident. The wind was from the east at about 10 to 15 miles per hour. The amount of the vinyl chloride release is estimated to be 25,500 pounds. This estimate is based on the amount of VCM charged to the reactor, 48,500 pounds, less the amount of vinyl chloride estimated polymerized to polyvinyl chloride prior to the release; .17,000 pounds, less the amount of. vinyl chloride recovered from the equalizing reactor, 6,000 pounds. The following actions have been taken to prevent future dis charges of this type: , 1. Operating procedures have been changed'such that if after any charge for this type resin the reactor pressure reaches 145 PSIG the reaction will be terminated with the emergency nitric oxide kill system. 2. The emergency nitric oxide kill systems for all reactors have been pressure checked to assure integrity of the systems. These systems will be pressure checked every six months. If there are any questions on this matter please contact me at 601-369-8111, ext. 239. Sincerely, R. A. Frohreich c: Wayne B. Anderson - State of Mississippi Air and v.'ater Pollution Control Commission ABDOO185495 A-2 ABDOO185496 (csnoco j A A-2 Conoco Chemicals 01 Continental Oil Company P.O. Box 91. New Highway 25 Aberdeen. Mississippi 39730 March 5, 1979 United States Environmental Protection Agency 345 Courtland Street, N.E. Atlanta, Georgia 30308 Attention: Mr. Tommie A. Gibbs, Chief Air Engineering Branch During Mr. Leon Folsom's visit to our plant on February 21, 1979, he requested we provide some additional information on the previously reported vinyl chloride relief'valve discharges and to correct the size stated for the relieving system in our letter of February 9, 1979. This letter is marked confidential due to the operational information it contains. The initial reports of these releases which give the emission information are included with this submittal and are not marked confidential.' Release: 4:00 p.m. February 2, 1979 Date of Report: February 9, 1979 Our letter of February 9, 1979, reported the vessel relieved thru a 6" x 8" relief valve which had a 6" rupture disc between it and the reactor. The sizes stated are incorrect; the relief occurred thru a 4" x 6" relief valve which had a 4" rupture disc between it and the reactor. The batch which relieved was designated D-300-3490 by the plant numbering system. The resin being produced was Conoco PVC Resin 5385. The water, vinyl chloride, and suspending agent for this batch had been charged to the reactor in the normal manner. The catalyst was then added to the reactor and steam injection into the Teactor jacket was started to bring the batch up to the polymerization temperature of 126F. The time was 2:05 p.m. when the addition of the catalyst was complete. Heatup of the batch also proceeded normally. At 3:20 p.m. the reactor temperature reached 126F, the desired run temperature. The steam injection into the reactor j.acket was turned off about 3:15 p.m. Normally the reactor temperature control system will maintain the reactor at the set point. On this batch the rate of rise of the reactor temperature did decrease for about fifteen minutes when the control system called for cooling. However, after the fifteen minute period the temperature and pressure started to increase at a faster rate rather than being maintained at the set point. At this time the cooling water flow chart indicated the reactor was receiving maximum cooling water flow. When the reactor pressure increased to 130 psig at about 3:30 p.m., approximately one pint of alpha methyl styrene was added to the reactor to slow the reaction rate to allow the circulating cooling water to reduce the reactor temperature and thus the Teactor pressure. This ABDOO185497 United States Environmental Protection Agency March 5, 1979 Page 2 addition of alpha methyl styrene did not slow the rate of the pressure increase. Alpha methyl styrene is normally used to reduce the reaction rate when there is a temperature control problem. This technique has been very effective in the past in stopping the increase in reactor temperature and in allowing the cooling system to bring the reaction temperature back to the control point. The pressure and temperature continued to increase and the pressure reached 140 psig at about 3:40 p.m. Alpha methyl styrene was added to the reactor again in an attempt to slow the reaction rate.. The pressure continued to rise. At this point the decision was made to kill the polymerization reaction with the emergency kill system. This system adds nitric oxide into the reactor to kill the reaction in emergency situations. The nitric oxide system consists of a bank of nitric oxide cylinders and piping to inject the nitric oxide into the reactors. Each reactor has its own cylinders and piping. The nitric oxide pressure in the cylinders (500 psig) is used to pressure the nitric oxide into the reactors. This attempt to add the nitric oxide to the reactor failed because the onehalf inch stainless steel tubing which is used to pipe the nitric oxide from the cylinders to the reactor blew off at a fitting on a valve when the system was pressurized with nitric oxide. Due to the nitric oxide release the area had to be evacuated. Personnel then had to go about thirty-five feet away to get Scott Air Pacs. The Scott Air Pacs were put on and the personnel returned to the reactor to add a large quantity, five gallons, of. alpha methyl', styrene to kill the reaction. As this'was being done the'', reactor pressure reached 181 psig at about 4:05 p.m. and did relieve thru the rupture disc - relief valve relieving system. One of the other reactors in this module, D-400, was empty by this time and was evacuated. The relieving reactor was then equalized into this evacuated reactor thru connecting piping. The pressure in the relieving reactor started dropping immediately. However, the relief valve did not reseat as it should have and the reactor continued to vent until the reactor reached atmospheric pressure at about 4:30 p.m. The amount of vinyl chloride released, 25,500 pounds, was estimated by a material balance. The amount of vinyl chloride charged to the reactor was 43,500 pounds. At the time of the release the batch was partially polymerized. Previous test run data show that thirty-five percent of vinyl chloride charged, 17,000 pounds, would be polymerized at the time the release started. Six thousand pounds of vinyl chloride was recovered from the equalizing reactor D-400. 48.500 #s VCM charged 17,000 tf's VCM polymerized 6,000 #*s VCM recovered 25.500 #s VCM vented After the release the relief valve was inspected. No physical object such as a part of the rupture disc or resin chunks could be found that would have prevented the relief valve from reseating. No other reason could be found for the valve not reseating as normally would be expected as the pressure in the reactor decreased. The valve was then pressure tested and found to relieve at 185 psig. The valve did reseat on testing after the pressure dropped approximately three psi. ABDOO185498 United States Environmental Protection AgencyMarch 5, 1979 Page 3 A-2 CONFIDENTIAL * Also after the release the reflux condenser on the reactor was inspected. The process side of the condenser was found to be almost completely plugged with resin. Due to this condition the condenser was ineffective in removing the heat of polymerization. Thus as the polymerization proceeded the heat of. reaction was not removed from the reactor and the temperature and pressure of the reactor increased causing the release. The process side of the condenser was drilled and brushed before the next batch was charged in the reactor. With this cleaning of the condenser temperature control was maintained in a normal fashion on the succeeding polymerization batches. The batch previous to the release in D-300 reactor, D-3003489, was an abnormal batch. The batch was "coarse". The"coarse"terminology means the size of the polyvinyl chloride particles produced was much larger than normal. This occurs because of a failure of the suspension agent resulting in excessive agglomeration of the polyvinyl chloride particles. The frequency of producing a coarse batch is variable and unpredictable. Approximately six to eight coarse batches a year are produced in all the reactors. Prior to batch D-300-3490 we had not experienced a plugged reactor condenser resulting from a coarse batch. In the past after a coarse batch the standard procedure has been to rinse the reactor and condenser after dumping of the coarse batch and then to charge the reactor in the normal manner. Evidence of condenser plugging caused by ;a boarse batch as indicated .by reactor temperature control prob lems had not previously been encountered. To prevent such an occurrence in the future the operating procedures have been modified so that after every coarse batch the-reactor condenser will be inspected to determine if it is plugged as a result of the coarse batch. If the condenser is found to be plugged, it will be cleaned prior to charging the next batch in that reactor. The following actions have been taken to prevent future discharges of this type: 1. The standard operating procedure has been changed so that if after any charge for this type resin, the reactor pressure reached 145 psig the reaction will be terminated with the emergency nitric oxide kill system. Operating personnel are now required to don Scott Air Pacs before starting the addition of nitric oxide to a reactor. 2. The emergency nitric oxide kill systems for all the reactors have been pressure checked to assure integrity of the systems. These systems will be pressure checked each six months. 3. The standard operating procedure has been modified so that after every coarse batch produced the reactor condenser will be inspected to determine if it is plugged. If the condenser is found to be plugged, it will be cleaned prior to charging the next batch in that reactor. The reporting requirements of the standard pertaining to relief valve discharges are summarized below for this release: * ABDOO185499 United States Environmental Protection Agency March 5? 1979 Page 4 A-2 Source D-300 Reactor Nature Discharge thru relief system on Reactor D-300 Cause Date Time Approximate Discharge Overpressure of D-300 Reactor February 2, 1979 4:00 p.m, 25,500 pounds Method of Determining Discharge Action Taken to Prevent Discharge Material Balance > .. - 'i 1. Kill with alpha methyl styrene three times. 2. Kill with nitric oxide. 3. Equalize with empty reactor. Measures Taken to Prevent Future Discharges 1, Change operating procedures. 2. Pressure checking of nitric oxide Emergency Kill Systems. Weather conditions at the Columbus Air Force Base which is about eighteen miles south-southeast of the plant at about the time of release were: Time Wind Direction 3:50 p.m. February 2, 1979 From 130 Wind Velocity Temperature Barametric Pressure 3 knots 44F . 1022.8 millibars At 3:12 p.m. the wind velocity at the Base was nine knots. At the time of the release we believe the wind velocity at the plant to still have been in this range rather than having already decreased as it had at the Base. This is based on personal observation of the relieving plume and the strength of the wind at the time of the release. The wind direction at the plant was as at the Base, from 130F, This is based on the location of the path of resin which was carried out of the reactor during the release and then fell to the ground, A dispersion calculation for the release has been made and is attached. A wind velocity of nine miles per hour was used in the calculation rather than the velocity at the Base. The program uses Holland's method to calculate the effective stack height and Pasquill's method to calculate concentrations. The top of the stack on the relief valve is 50 feet above grade and is a ABDOO185500 United States Environmental Protection Agency March 5, 1979 Page 5 A-2 six inch pipe. The rate of contaminant release used in the calculation is the average hourly rate of the release. The program predicts a maximum concentration of 88 ppm vinyl chloride at ground level 800 feet downwind of the release. This point is shown on the attached copy of a portion of the Aberdeen Quadrangle, Mississippi - Monroe County Topo graphic Map which is published by the United States Department of the Interior Geological Survey. On February 22, 1979, an anemometer, barometer, thermometer, and wind direction indicator were installed in the plant guard house. These instruments continuously indicate the wind speed and direction, baro metric pressure, and temperature. The guard periodically records these conditions in a log book. He has also be instructed to record and note these conditions if in the future there is a vinyl chloride release in the plant. This will provide more accurate weather conditions for use in dispersion calculations than has been available in the past. Three 10 point Honeywell continuous monitoring units are used to measure vinyl chloride concentrations in the process areas of the plant. One unit each monitors the old reactor module, the new reactor module, and the vinyl chloride tank farm. Once per hour the vinyl chloride concentra tions indicated by the chromatograph are recorded on a log sheet by the panel operator. Copies of these log sheets for February 2, 1979, are attached. These log sheets do not indicate an increase in vinyl chloride levels in the plant during or immediately after the release. Release: 7:15 a.m. February 10, 1979 Date of Report: February 19, 1979 The batch which relieved was designated D-300-3506 by the plant numbering system. The resin being produced was Conoco PVC Resin 5385. The time required to charge the vinyl chloride, water, and suspending agent for this batch was one hour and five minutes compared to a normal charge time of ten minutes. The extended charge resulted because of plugged VCM charge filters, but this extended charge time is not suspected as being the cause for the release. The charge was complete and catalyst added to the reactor at 5:05 a.m. The batch was then heated to run temperature in the normal fashion. About 5:30 a.m. the batch reached 122F and the use of circulating cooling water was started to remove the heat of poly merization. Temperature control of the reactor was maintained until about 7:00 a.m. At this time the temperature and pressure started to increase. One pint of alpha methyl styrene was added to the reactor at 7:05 a.m. At this time the reactor was also vented to the vinyl chloride recovery system to remove inerts which may have been adversely affecting heat removal by the condenser. These efforts did not slow the temperature increase. When the pressure reached 138 to 140 psig the operator was instructed to kill the batch with five gallons of alpha methyl styrene. The operator put the alpha methyl styrene into the charge pot and started it into the reactor. The alpha methyl styrene was entering slowly into the reactor and was not killing the reaction. Preparations were then being made to kill the batch with the ABD00185501 United States Environmental Protection Agency March 5, 1979 Page 6 A-2 emergency nitric oxide kill system. Before the nitric oxide could be added the pressure reached 148 psig and the relief system prematurely relieved. The relieving system consists of a 4" x 6" relief valve ; with a 4" rupture disc. The rupture disc rating was 185 psig at 200F and the relief valve setting was 185 psig. D-400 reactor was empty and was put under evacuation. The reactor batch in D-300 was being equalized into D-400 when the release started. D-500 reactor was also empty and was evacuated and the batch in D-300 was also equalized into D-500. The portion of the reactor strip charts which would have shown D-400 and D-500 to be under vacuum prior to the equalizations were not saved. However, evidence of this is recorded on the Daily Production and Status Report dated February 10, 1979. On this report a bar chart is kept for each reactor denoting the stage of each reactor in the polymerization cycle. This report does show evacuation, recovery, and dump for D-400 and D-500 reactors at the time of the release. The pressure in D-300 dropped and the relief valve reseated when the pressure decreased to 138 psig. The duration of the release was five minutes. The plant will conduct a survey of rupture disc manufacturers and rupture disc types to determine if a better rupture disc is available for this service. If better discs can be found they will be purchased and used to replace the existing type. After the release the relief valve was taken to the maintenance shop and taken apart for inspection. No faulty components were detected and the valve was reassembled. The valve was then tested and set to relieve at 185 psig. On continued pressure testing in the shop the valve did relieve at 185 psig and then reseat when the pressure dropped about three psi. Since this relief valve failed to reseat during the previous release and relieved prematurely this time, a new valve has been ordered as a replacement even though the valve functioned properly when tested in the shop. The new valve will be installed on D-300 upon receipt. The reporting requirements of the standard pertaining to relief valve discharges are surpmarized below for this release: Source Nature Cause Date Time Approximate Discharge Method of Determining Discharge D-300 Reactor Discharge thru relief system on Reactor D-300 Failure of rupture disc and opening of relief valve at less than set pressure February 10, 1979 7:15 a.m. 7100 pounds Relief valve calculation ABDOO185502 United States Environmental Protection Agency March 5, 1979 Page 7 11 A-2 Action Taken to Prevent Discharge 1. Kill with alpha methyl styrene two times. 2. Equalize with two empty reactors. Measures Taken to Prevent Future Discharges - 1. The plant will try to find a more reliable rupture disc for this service. 2. A new relief valve for this system has been ordered and will be installed upon receipt at the plant. Weather conditions at the Columbus Air Force Base at about the time of the release were: Time 6:55 a.m. February 10, 1979 Wind Direction Calm Wind Speed Calm Temperature 16F Barametric Pressure 1031.8 millibars A dispersion calculation for the release has been made using a wind velocity of three miles per hour. We believe at the plant at the time of the release this is a better estimate than the conditions at the Air Force Base. This is based on observation of the plume from the release. The slight wind at the time was out of the northeast. The amount of the release was calculated using a sizing formula given by Teledyne Farris Engineering, the manufacturer of the relief valve. The sizing formula is based on the relief valve being fully open when relieving. The manufacturer does not guarantee the relief valve to be fully open until the relieving pressure is ten precent greater than the set pressure of the valve. In discussions with the valve manufacturer he states that in this case since the relieving pressure was less than the set pressure the relief valve would likely not have been fully open,and the rate of release would have been less than that calculated by the sizing formula. The manufacturer has no method of calculating the rate of release when the valve is not fully open. This can only be checked experimentally in his shop. Therefore; we believe the actual discharge to be less than the 7100 pounds reported, but are reporting the 7100 pounds because we have no method of calculating the rate of the release with the valve only partially open. The pressure drop in the six- inch stack from the discharge of the relief valve to the atmosphere is not large enough to effect the calculated relieving rate. The discharge from the relief valve was assumed to be ninety percent vinyl chloride, the remainder being water vapor and polyvinyl chloride resin. The rate of vinyl chloride release used in the program was the rate calculated from the relief valve sizing equation. The program pre dicts a maximum concentration of 63 ppm vinyl chloride at ground level 1900 feet downwind of the release. This point is shown on the attached copy of ABD00185503 United States Environmental Protection Agency March 5, 1979 Page 8 If IuB'iTIa! A-2 a portion of the Aberdeen Quadrangle, Mississippi - Monroe County Topographic Map which is published by the United States Department of Interior Geological Survey. The daily log sheets for the three Honeywell continuous monitoring units for February 10, 1979 are attached. These sheets do not indicate an increase in vinyl chloride levels in the plant during or immediately after the release. General A copy of the plant Emergency Plan is attached. Although the plan is dated to become effective March 15, 1979, it is in effect except for the portions concerning the plant emergency alarm siren. Installation of the siren will be complete March 15, 1979, and at this time the total plan will become effective. The plan will be ammended to include the State Agencies which require notification in case of an emergency when this information is received from Mr. Wayne P. Anderson of the Mississippi Air and Water Pollution Control* Commission. Please direct any questions you may have concerning this letter to me at 601-369-8111, ext. 239. Sincerely, R. A. Frohreich Chief Process Engineer** tap Attachments c: Leon Folsom - EPA Wayne B. Anderson - State of Mississippi Air and Water Pollution Control Commission CLM, ELK, SJV .L IATrPOL VERSION 73.2 ABDOO185504 A-2 _____ EAlHPOL illPUr UAFA -- -- -- -- 'ianwr'4**-- --< l-IO --->-<---1-1---2is0mmxhU--2-1--*-3-0-- __><__3_1_-_4_0___>*< *4,*!-,5,0,,___x__3_I- "6l*70 >< /1 nIO > TC.-< HeLhASc 2-10*79 lo. 14. 97 ol.3_o2.-j dj200. .1 ~oT. 3 62.5 94o'/0. 374 15. 2.0 3.0 163. 163. 2000. .50 .50 o. o. -- 4ii4nM*ii-4--------intixn*.--: -- -- >**_______ < I-10 >< 11-20 >< 21*30 >< 31^0 >< 4 1-50 >< 61- jo TOi'AL CAROS PROCESSH* = 5 tiTVCiTRELEA'SE 2*10-79 ------------------------------------ --- - - >< 61*70 >< /I > AIR POLLUTION PRE-ICTION PROGRAM ^MULTIPLE STACK VHRSIO.. OPROGRAM " OPRuuRA-' USE* USE * HOLLANDS METHO* TO CALCULATE EFFECTIVE STAC! PA SQUILLS METHOD TO CALCULATE CONCENVAAfl^.i '-is! CUT CONCENTRATION VALUES ARE BASED ON A-.luiEN'TT'tMPERAtURE,' '"" ATMOSPHERIC pressure * _RInJ SPcE* __ __ *"" rf'lN * *1 RECTI ON (FROM) + STABILITY CLASS mixing Depth,"' ......... tLTA OOnNnIn*, DELTA CROSSrtlND, TBA'SE"TIME----------------------~' - CONCENTRATION TIME-AVER AGING FACTOR W7' 15. MINUTE TIME INTERW.S lgi_ "EG F 16.0 PS i A 14.97 MILES PER HP K 3.00 -- ilffiTH-EAST i- B .'METERS y 2000. FT % 100 MINUTES fr 1516 Ff5 . 1.000 -- j i STACK NUMBER " MOLECULAR WEIGHT OF STACK GASES - _MOL'ECULXR_WErCHT"OF CONTAMINANT ' OUTPUT RATE OF STACK GASES, ' OUTPUT RATE OF CONTAMINANT, * STaCK-COiICEnTka TlON TEMPERATURE OF STACK GASES, * *IAaETER OF STACK, uT"EFFECTr7E' STACK HEIGHT, HEIGHT OF STACK, STACK EXIT VELOCITY, `srXa COORD'INATE OF STACK (ACTUADT "Y" COORINAT OF STACK (ACTUAL), OnNNIND CO-ORDINATE OF STACK CROSSiJiN* COORDINATE Or STACK LBS PER HR LBS PER HR PPM(VOL/VOL) DEG F FT ` FT FT FT PER SEC FT FT FT FT 2 r 61.30 W 62.oO 61.30 62.50 194669.9 185199.9 8 74 14.9 0.0 13 26 88.94 0.0 ' 163.0 1 0.50 163.0 0.50 ~26l ;26~ -----245764' i. 50.0 50.0 f 974.76 900.06 0.0 ro.o 0.0 0.0 0.0 -7.1 1 0.0 " 7.1 MAXIMUM CONCENTRATION AMD ITS LOCATION* 02.50229 rPMvOL/VOL) T9T7037'625""MlCR0GHA"MS/CUBIC METER" 0 'X" COOR*1 NATE_JACTUAL) -1343. FEET "Y" COORDINATE (ACTUAL) -1344. FEET *) DO..NNIN* COORDINATE 1900. FEET CROSS WIND COORMINATE____ t 0. FEET i TlME-AVERAGinG FACTORS > >1 TI...E, MI N. FACTOR -- -aMn 3 a ' 15 ik oO 1.22 1.00 0. 74 ... 130 t 430 !* 1 440 1 `I 0.59 0.49 " ' 0.18"' * '' - STACK LOCATION BLANK < 6 PPM ~V> 1 6. TO < 13. PPM -* IS 2 3' 13. TO < 19. PPM 19. TO < 25 7 PPM rv 4 . 25. TO < 31 . PPM n 5 31 . TO < 38. PPM 0 38. TO < 44. PPM Q- 7 44. TO < 50. PPM 8 50. TO < 56. PPM " ---9 56. TO < '63. PPM o- + 63. PPM ----' A . Vc m RBLEft^e. 2-/o-7f + rnfi/. LotfcErtT&hnOfi: 63 PP/7 em^oM source Vrt 3-t-7? issue DATE DRAWN BY CHECKED BY AARROVEO BY CONOCO CHEMICALS ABERDEEN. MISSISSIPPI APtftOVEO QATt NO. 8 \ ABI 001?f55&) 8S l V 1 \ V \V\ l( 8S V ) \ \\ \ \ \ 1 \ Sno V l V \ l l l l l \ rC\T 8o04 \ \ \ \ \ V ) \ V \ 'O 8o V L V [ l V V V \ V a oo04 i \ \ \ l \ \ \ l 1 CONTINUOUS M O N I. 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Q 3*- -"Oo 4f~J< CSU OU a Cc/i U>Os >O, ^r.; O'-jOO'-.UOiHUC- WZ2UG.>cQQtO EGrt- (N^iTi/lOt^COClO u 6o oos si Nj 4 r& XT <> sTt * * 4 A]3D0G4 18545 0\ A *t>o cr^ <r r; 6o Qr~ 5* < \ 11 ; so > gno o8 CN i rsT ^- ri * KV&k1tm: (H T iF T \ C>^j jT % VSV A r\n X\) j G)i "T l l 8o ooV CN oor> CN oo CN CN sS-\r* y4 4. tf4i V V ^v: rt4 G> --L_ cNi _d _Ci_. cVi. S^Sl ci L\/i/ 6^o+H iV* `XT l' ^Sy * v\* KV \ e>s V vN Ci\ i c^4> i ri4 ) i \ \ l ( 8 CN og CN ooo o si s5 r*% xr cv* 4 MA * [ri. * A \ A 4bc i5 a 4 cc T\ tx> cr*s^A/ i \> XT Q gg Ob 0) oS 1 t \. 1 a8 o8 Cb Q 00 c P0 o 0 Or p0 o 0) 0) c oQ j i 1 ( .<!/- 0*- Stream No. Flame On Plant Air On 8in oo 0 u 0 i) o 0 0 0 4i <9 A 0 6 e0 00 i i 8Pi oo CN 0 ji 0 A Q 0 0 (9 Q _SL 0 0 0 Q 0 G 0 Q i 8 M0 Mo8 0 0 00 0 0 0 G 0 i G 0 P p e p (S Q i 088 0oCooO 0 0 0 0 G 0 0 0 Q a- f) i 0 0 0 & (! 0 ZU2<J 8rO*. fl fj - A>4*1 -A 0 ^ -V<*r 0 A Pc* Pvi "V"#e KS 3 ^ ^ "r ^ ^ *t i __ <N <S- ^Y> ^>o Ws. ,4 Cs^ / J j J 1 J J j ] 5- U oo oo u o o u. o r--i U. U- v> P W Ifl 'O o z in to C. r-H <-H ^ 3 O o w u. V. !/> tfl n o XVni Cl. Cl. o 3.-3 6 S 10 = C o t\J\ d 3 3 V. 3 CM o C._ C. rj u AkoA/, > r\j iO 3- t. ^ u O to ^T rr rr oc r>- rs r> r-s W fj i C4 ^ J* c o rto JZ c H y rt r; 4h Uh u- <+-< ^3 r- oOoo U .<-^ o c. ji. C. CX.-K O 2: o rt o O o o o oo o H h* H co k d; 3* 1^ CO u oo C. u. oto r3 ui (NCl ou u > CO E aE >O H iJ O i/> <j X O U X 0< i- c. o O <y o o >M to1 o LO1 O oGoQO o UJ C G > co o O u Xo > o U2u <y 00 <y > C o co o 4ro-1t. a; cH o <v cz V Cw o s o 4-> i Q U-, O 4-t O e o 4-> \0 Q w O 3 i- o o o cz e 3 a TIDh to o >--cl TH> z 4-1 o ca CO 4-> o H o G CO O t-- o u o oa o cc wNrO'JUIOr'OOfflO "0 O ABDOO185509 Vcm RBLte 2-2-71 + C tire.fir/oh;.g& ppm 0 bmtssipu source yem 3-1-19 issue OAT6 n------------------------------------- :---------------------------------------- OAAWN8Y 1: ^ | CMECKtOBY A/p*OVtO ftr CONOCO CHEMICALS ABERDEEN. MISSISSIPPI APfnovto ' DATl NO. CONTINUOUS MONI . ORING LOG SHEET S> c o O. C3 -O >* CD CD ! NAME *"ooioorOOoo0OVn>1 o0rCOon08ao4N4 Y \ \\\__ \ \ \ Sv \ V\\\ \ \ -\ V\ \ \i __\)_ \ y\\ j V-\- \\ \ \\\\\\\ A T \ \ ' A BDC A \\ \i )T \ \\ \ 013f \ ST T \ \ \ 5\0 \ \ T\y \ i \ Y\ V \ \ \ -- ------- -TNjX \ XA \ \ T 04 \ Xs. A hS \ \ \ X ooo04 cQOn X >A A \\ \ \ \ \ \ A \ S T\\ o 8rv o8 8 m oQV ^A\j . i'Yh 'V\ \ * ' )o\\ -- XA X OAA \ XA \ AA' -- V\A i v <A <sTN \s \ X\ A \\ \ *0/ V. /. \ o. \ \ \ \YZs'~ Y " V\ \ . 3 \ / / / 1 1 J \ \ \ VY SOon <1 -j ;v>-^ (^___ o A \ X \Xi vja. a '<r O' N\ / 1 ) i\ 8 A \ s' s \^r- ^/ o 8 \ A \ \ Y\ \** \ V \ _> a s ry r~ J ** 88 X X X X sA x> > i ) ; 8oocon Ah V. rOv C V \ \a ^^x iA <. O a \ CA \ Y\ (i \ i 11__ ',04 n T m - .13 r*^ CO 171 b~ ' ' y\ "Y V ^h\ < ) w 1 i v-r> \ ''J 1 'O- \ 1 N'j r-* r\ <o ^ ^ \ J_ ' r-l XfC'i , K'r\ _v. o rea ^O c0 ocw -/ \Z - < A-2 c <D E o t- <n co in co CO OsJ p-H 4--4 o 10 CM * 10 U7 JX - c co O .H 4-1 4n-> fH cra I~i o rto h" 4-> <^1 iJ T3 > 4C->5 c4o-* co tO 1 o C3 H O 4-> 10 c r--i u Jj!. C2 < M C tOTJ i-- C -h c Cl 5 >-r T) O (113 W f-- M o vO <% rt o 0) --O C"H O 3= X ZD --oi ZC3 4J T3 4-J 3 *a !h O <i-4 o O CO Z U u Lo. C. rtao u o u 4-> o rt 4-) <H CO .i- o c au t-< Q o c --4 --3 oC-. 3~> u r. Q co cn to tt vo r>. co u .ABDOO1-85511 A I a... I iyj. i I 300. 1400. 1-jOO. '1600. I 700. 1 300. 1900. 2000. 2IU0. 2200. 2300. 2400. 2600. 2opo. 2 700. '2300. 2900. 3000. "3100. _3200. 3300. "3400. 3500. 3O00. "3700. ___ .3300. 3900. ----- 4000. _ .4100 4200. 4 300. 4400. 4300. 4 000. 4?00. i 4doo. T" 4900. i i i 1 I i I i l I I I I I ~I I I I I I I I ... j .1 I I I I I I i 1 I 1 I I ------ mint I M 222222211 I f i I 23344444 332 I i I 11 2234455565443221 1 . M23345ooo7o0664332 I I __ _] l I 23446077333776644321 11 .11 1233456/73883877064332 11 I --11123346077399999877654332111 . . .. *" H I 2234550.738999998876 554322_|M_.____ JI 2234456 77399999998 776544 3221 I Mi 2334 5567 33999+ 9998876554 3321 11 ~ 11.(2233456673899999998876654 33 22I M_________ I 11 22334450676399999998676654433221 11 "1 II 22334550673699999993876655433221 ll _. _ 1.1 122234455667308 9 999983 37 665544 32 221 IJ____ II) 1223344556677883883863 77665544 332211 II ITt"22 23344 5566 7 7888 888888 77 665544 33222TTi 1.1 II 222334455 66 7 7788 888887 776* 5544 33 2221 11 I I Ml 22333445566677 7778 777776665544 333221 I I l ' nTf222T334455566677777777766655544333222inr ( 1 ((222333443556666 77 777776 66655544 333222 II M_ 11 111 222333444555666 66 77766666 555444 33322211 11 " i rflT2223334 44 555566666666 6665555444 333222 11 11 ____H IJ 1.2222333444 55 555o6666666655555444 33322221 11 Ml I I 22223334444553556666006555554444 3332222 I I I 1 I I 11 222233334444 5555555555 5555544443 33322221 tl _____HIM I 2222333344 444555555555 555544444333322221 I I 1 Ml II 222233333444 4455 555555555444443333322221 II IMI I I 22 22 35 3334 44 4445555555 55444444 3333322221 11 1 lll l M 22222333334444444455544444 4443 3333222221 1.1 1 IIII M 222223 333344444444444444444443 33 33 22222111 ' "I I II ] IT 22222333 33344444 444444444444 33 33 33 222221 II I IMIli 22 22 22_333333444444444444444333333222222 I 11 II M M 11 2222223333333344 4444444443 33333332222221 II l MM 11 2222222333 33333344444443333333 33 22222221 I I I I I II I 11 2222222333 3333 33 3333 3333 33 3333 33 222222 21 II II 11 11 11 22222222333323333333333333333332 22222221 1 I ""M I II 111 22~222222 33 333333 333333 3333 33333222222221 II III Mil H 1222.222 223 333333 33 33 33333333 3322 2222221 I M Ml IMM1 I 222222222 333 3 3333333323 33 333222 222222 11 11 I i Mill ll I22f2^^`:222-J31i3323 332333322222222222n I I 5000. 5)00. I 1 ..____ m 1 . 5200. 5300. 5400. 5500. j---------- 5600. 'I X I r 1 5700. i 1 3600. r 1 i 5900. " 1 6 000. 1 X 6100. 1 6200. 1 i 6300. 1 i 6400. ` "1 ' 1 6500. t 1 6600. 1 1 6/00. i` * 1 6d00. 1 X ___ I I ' 6900. 7000. 7100. i 1 i 7200. i I 7300. "I i ---.* ;f , 7400. ----- 1 i 7500. X r t 7700. 7o00. `7900. 8 000. X i I I 8100. 1 "8200. I I 3300. i __ I_ iI =~r i 3400. '3500. 8000. 8700. "8500. I 1 l X r S900._ i 9000. i "9 100." r 9200. 9300. "9400. L x i 9500. j 9o00. i 9700. i 9800. i *20QQ ABB0Q18 . ,222;! 33 33 3333 33 223222 222221 I " 'Mill t it in mi .. >,:.'^22333 333333 222222 22222221 II II II II I) *& i mm 222 2.'`22222 22 2222222222 22 222221 11 11 M MU' "H hi ii nil! ..22222222 2 222222222222 22222211 II l_l 1 1 T1 II M I I I 11 I Mill___.22222222 22 22 22 22 2222 22 222211 II 11 I I 11 II Vsj Ti'iTi ll UTCn 2222222 2 2 222222 222222 22 222! 111111111111 1111 ilLILUS -322222222222222222 2222222222 Mil 11 11111111 mi I 11 11 mi II li '222222222 22222222 2222 222211111111111111 ' JTITl 11 M HU .>2222222222222222222222222! I Ml II 11 I I 1 l 11 II 11 11 11 iTa 1 22222222222_22222222222222 ij in 1 m hi 1,1. J JI I Ml IJ itH Ml 2222 222222222222 2222222 11111 111111 1111 I I fffT J MJ.1 I hi 111222 222222222222222222 |:i II 11122222222 222222222 I 111222222222 2222 222222222 11111111111 1111 j j u 11 m 11! 1 u 111 it 1111 11111 11111111 m111 j Li 111 ijjjjj 11 limn 11 111111 liijn 1111 111 _ <4 n mnnrflMi mm ..1 1111 njiSiiii 11 111 11111111 n 111111111 1 iririT him n in _____ _ i 1111 ljJ 11 m m 11 11111111 Pi 111 n 111 ;; 'l 111T1T II m 111.1 in f 1111 im 11111111 11111 mi 11111. 1111111 min 11111 mi u 11 1111111111111 11111 mi 111 III ini 11111 '111 m 1111 Vi immiiii 111 n 111111 mu inn 1111111111 11111 11 11 Itl 111111 i 1 i 1( II 1 I II II II Mill II 1 III I 1 on* !-ir 1 .'Jill i uri 11111111 Mfe i 1111m Mill I II 1 II m 11 j 1 DPI Ml*-- -- ---- HP AM ft- . ABD00185513 T~ IaTkK)L "VERSION in. 2 EAlrtPOL INPUT "ATA '< I -10 ">< 11-20 >< 21-30 >< 31-40 >< 41-50 >< 51-cO <"61-70 >< 71-30 vOm RELeASE 2-2 79 44. 14. d J. 00 2J ol._j o2.d o!200._ oBOOO. 6l.3~o2o ..................61 doO . 4.0 9.0 lo3. 163. 2 1000. .50 "50 10000. 30. h- 100 ,`0. 15. II I 20. ( 0. < I -10 >< 11-20 >< 21-30 >< 31-40 >< 41-50 >< 31-00 >< 6 I - 70 rui'AL CARJS PRUCcSSb* = 3 T/C5~RELtASS 2-2 79 ' " " "" --------------------------------------- r- Alrt POLLUTION PRE-lCriON PROGRAM - MULTIPLE STACK vERSIU.i t >< 7 I-oO (JPROGRAm USEu HOLLANuS *icTHOTO CALCULATE EFFECTIVE STACK HEIGHT OPRUURAM uSE- PASOUlLLS METHOD TO CALCULATE.CONCENTRATIONS ' CONCENTRATION VALUES ARE BASE ON AMolcNl TcMPtHATUHE, ATMOSPHERIC PRESSURE nil** SPEED rfnro-DiREcnoir(FROii) + ' STABILITY CLASS MTXIh'G Oc'PTH. -EL TA -O.iHH IN OcLTA CROSS mIND. dAoc TIME COhCENTRATION TIME-AVERAGING FACTOR 3. MINUTE TIME INTER 'ALS -- Ubu r PS1A MILES PER HR ME 1tHS FT FT " MINUTES 1 44.0 14.83 9.00 : JOTH-EAST a 2000. 1 00. 20. ~ 15.0 |j 1.000 STACK wU.idEH MOLECULAR AtlCHT OF STACK CASES MOLECULAR nEi (XT OF COnTAMINANT OUTPUT HATE OF STACK GASES. OUTPUT RATE Or CON TAM InANT, STACK COiiCi*TRAT1 On TEMPERATURE OF aTACK GASES, lAMcTeH OF STACK. EFFECTIVE STACK HEIGHT, HEiuHT OF STACK, STACK EXIT ftLOCITY, "X" COUR-iNATE OF STACK (ACTUAL), G(X)nJ In A TE OF SI'ACn ( AC fJAL >. LBS PER HR LBS PER HR pp.'.K VOL/ VOL) OEG F FT FT FT FT PER SEC FT FT 1 61.30 ----- 62.50 !' 67999.9 61200.0 3tt2720.00 163.0 0.50 r~ 100.14 50.0 706. It 0.0 0.0 ' 2 ol. 30 62.50 o1560.0 0.0 0.0 1 o3.0 0.50 101.53 30 .0 039.83 10.00.0 KT 0.0 -/. 1 MAAUum COiiCcHFhATIOi* AN- ITS LOCATION* __ oo.4/701 PP/.K vOL/vOL) 24j293.od7 mICHOCRAmS/CUBIC METER J'X" COORDINATE (ACTUAL) "Yr` G(A)R-iNATc (ACTUAL) . "O.i./iiL.U COOR-ihATc . CRO3Sni ii C(X)RUINATE -5oo. 300. 600. 0. FEET FEci FEET FEET TT^c-AvtRAUiNO factors _n.-E,Mi;j. FACTOR ..J \ ABD00185514 1 2 '3~ A 5 0 7 6 9 I 000. STACK LOCATION < 9. PPM V. To < 10. lb. TO < 27. TO < 35. TO < 44. TO < ' 33 . TO < 02. TO < 71 . TO < 80. TO < 27. 35. 44. 53. 02. 71 . 80. 88. 86. PPM PH PPM PPM PPM PPM PPM PPM PPM PPM -1000. ________ -100. 1 ------- --- j 1 j i 0. 100. 200. 300. 400. i 1 1 I 1 _______ c 1 {1 . {4 1; '* C '' :> n 500. I oOO. i 1 700. 1 1 rlQO. l 1 100. I 1200. i 1300. 1 r 1400. IdOO. i t oOO. 1 1 /OO. 1 IdOO. 1 I 900. i 2000. 1 2100. 1 2200. 1 ______ 2.300. 1 I 1 i 1 1 i I 1 I 1 1 > ;> ( A V yt A *7 >1 r c * * * >! * I) A c i 1 ------ jr 1 1 _T i 1 1 1 j I 1 '" 1 i 1 1 1 2400. 2300. 2oOO. i `I i 2/00. I 2800.' ""i 2900. i 3000. 1 3100. I 3200. 1 3300. 3400. 3300. I I 1 3o00. 3700. i I 3d00. I 3900. 4000. 4100. i i I 4200. J J \ ~* ________ it 0 CONFi ihI i 112333 33211 J I 223*506060543221 5 Il2234507869867o 54 32 21 I : 1122345&7o3999998d7*5432211 : 1 I 1 2?li-,6o7i>>vV-*-y.^3 7c)o5~j 2? 11 1 11 I I 2233445^00 // 7/dbii'i 77?o6554 4 33221 11 I 1 I 222 3344 556ooo 77 77 //7o065554433222 11 II 2.12X3344455000Oooo0000*5554443332221 11 2223333444 555550oooo55555444 33332221 1122223334444*1 5o5o5ooo55544444 3332222 I 1 22222333344 44 4444 555444 44 4443333222 22 1222J2233333 44 4444 44 44 44 4443 33 33 222222 I 2 222223 33 333334 44 444444 33333333 222222 II 2.122222333333333 333333333333 2222 222 11 z|g222223333333J3333 333333322222222 I I 122222 22222333 33 333333 3322222222 22 i II IJ22222222222222232222222222222222 II \ l\222 22222222222222222222222222 I I 11i.11 222222222222222222222222222 II I jTTll 22222222222222222222222 11 < (> 1 1 1 1 1 >22222222222222222 I I I f] I 111 I II I I 1222222222 II ifTTl 11 I f| II I I I 11 II I m 1 11 I 11 1 i(TTl uiki 1  r> o Q H U,1 reLl\ aoCO o.-j otr ^&-- w0) taos a ZW* '! (A DOD e^ 'o<a H "*o Oa wo LL_ CCLD3 1o V----- .-- K ABI^00 5 ---- V Y \ \ (\KV Y"ooioll ^ Y \ \ b "Y-Y Vooo? * * \ a \\ \ \ \ \ V V Yoco0>? \ \ s. \ \ V : syoo com t\ i -- \ \ \ \ s \oo / "\ mV o o(oVN O ci \ \ V \\ \ \ \ A ,Y C<OONO \ \ \ \ \ \ VT \ \ \ \ \ \ \ Y T YooCM cm \ \ \ \ s \ Koo j \CM - \ Ao \ \ A Y \8<M '-C > \ K \ - \ YOOo \\ A v* A Y 1aoCO ' -- v- ^3x / s Cr*vV- * tA. Q Y Y Y"s - C C- \ O' -- 1 < } nC T 1500 j1GC0 *" c\~ ~t--%- A v2- ) ~ (o- i' TooT r-' V\ cy . a- -M Y Y \OoCO 4. r- \ J -- \ A "**S :.V'Y3 -- \r^J ; ^ i 1 VoCoM oo cO 'O \ Y Y) J t \ \Ns Y Yyoo Ao Y V_j\ V\ 8\ Y A Y Y8 Va V) v r: \ \ YO' '( ./ ) > >) 0030 j 00*0 \s ---- Y (o \ % -% 'vr) / lV %,v V- -iS V X * > \ \ s \ CM CO VO .<\to CO Cl UI |S YK ^ ^ `Y Y "i 6( ' ^ w2 iuV cs s" \ A 'r^ ^ \*A ) -J rX- *. \1 1 ^Y OV>- k lO \ "i1 C\, w "V 1 V n Oc r Ck < V'O ;) ' VA T, -S'! A <u E E o ou o u. u o 3 C o1V0) CM Sh C.H OSh S >a oH +vJi icUn cXo u _ x6 ahs U O CO COEJ XS-. O> aoO U 4o-> 0fC-)3i oH oO C o ol 4-i O Eti o ioni o ao cw o o giH a 3 O > -h 0 Mr > o O 0 OS OS a, E a 3 Q tO-I cH o <--c< --' "3 -3< 2 oo o *-) *O- CO. *OJ 3 f- 3 o OCh h OSh aOcOU -H cm m rr in o r*. co m o 3 o * (9 a JJ U .r. V) :rj n j i. > :c -) b oi .D * / o Ti o u O -J *o2 o > U- s NAME 0200 0200 0 4 0 0 0200 0060 0090 COIO o* V t>o 1 ' 'J \ *\ \ Ximnri 1 \ j V- 1-61) \\ \ 4 \ \ \\ \ f> \ i \ A\ \ \\ > '^ \ T------\ oo \ CVN \ \ A\ \ -S \\ \ \ 5> . i A-2 2000 21C0 2200 2300 \ \ \ j \ g 'H Cl h o> \ \ o 3 j -j 4 8 r* \ \ \\ G J \ j o o <0 \ 8 \n j v\ \ o o*7 \ \ \\ \ > '1 \4 \ j \ \ \\ \\ i. ^ 8 (0 o 8 \ \ \ \\ \ \ 8 \ o 8 \\ \ lA 1 \\ ^i \ \ \\ \ \ \ \ 8\ r** O Ui< 5 1 E . P~ 35 r Y* * r< | r> o 'J, 4^ \'A. T ^ i fl St. \\ A s \ s\ _r_ \\ --; lO 1 CO rv o '4 4 *? ^ NA CO 01 --s~ ^^ fA O'! W F la m e On On n w*-> --WMi <eCA. OoG f--4 ^ 2 'G A GG A A G. C., O A r* . "3 o -a ,o 3 E E w1 o 3 3G G G ,*j CN o u o *--< rg fO ry ^r T -q- 'T U Gi U ac O tn CJ. ^ o r- r- r^v r- t-> a "*c. G 4-) G 4h U-. Us u-< n F" U CO ri 3 o Oooo U +J ,v-S o 0uc)j TOcc G. G, ft. O. OOoo O F" H F- t~ in u rtm o ou o C > GC in <u z. N^rruiofscooio | Plant A ir 1 ABD0tfl85517 A-2 A CONOCO CHEMICALS ABERDEEN PLANT SAFETY AND HEALTH MANUAL SUBJECT: EMERGENCY PLAN NO: EFFECTIVE DATE: SUPERSEDES: PAGE: APPROVED BY: TITLE: SH-I-1-9 _ _3/15/?9 - -6/1/78 . 1 OF 15 . , Cn m JMLy-- Plant Manager References: PURPOSE: Due to the nature of the chemical process industry and specifically, the Aberdeen PVC Plant, the potential for a vapor release and/or fire can only be minimized by conscientious operation of the plant. Emergency conditions caused by human error or equipment failure can ultimately lead to serious personal injury, loss of life, or severe damage to plant equipment. This plan is therefore being- issued to: 1. Insure the safety and welfare of employees and the general public in the event of a plant emergency; 2. Minimize property damage and provide for the resumption of normal opera tions following a plant emergency; and, 3. Satisfy the legitimate concern of employees, their families, and the general public by providing prompt, accurate information concerning the extent and effects of plant emergencies. DEFINITION OF PLANT EMERGENCIES A plant emergency is any unexpected event or condition which requires immediate action to prevent injury to personnel and/or damage to equipment. Plant emergencies include, but are not limited to: fires, explosions, release of toxic, flammable, or corrosive materials, or an injury which requires removal of an employee from an elevated location A "Vinyl Chloride Emergency" is any massive release of vinyl chloride. This does not include minor leaks of temporary concentrations above permissible exposure limits. IMMEDIATE ACTIONS TO BE TAKEN IN EVENT OF A PLANT EMERGENCY Immediate actions are the .direct responsibility of the Emergency Officer. In his absence, they are the responsibility of the Emergency Brigade Chief (Shift Supervisor). ABD00185518 ___ -sr^i ' f! * A-2 Emergency Plan Page 2 of 15 ^ IMMEDIATE ACTIONS TO BE TAKEN IN EVENT OF A PLANT EMERGENCY (Cont.) The extent and severity of a plant emergency shall dictate the extent to which the Emergency Plan is utilized. The initial determination of required action shall be made by the Shift Supervisor in charge of the affected area(s). The action taken may range from handling the emergency with personnel present at the time to full alert of the emergency organization. In general, the following actions, as applicable are required during an emergency: 1. Activate the Emergency Alarm System Anyone who detects an emergency situation shall communicate it to the Vinyl Control Room by the radio, the Gaitronics System, or by dialing 66 on the plant telephone system. In each case, the caller shall clearly communicate the location and nature of the problem to control room personnel (this infor mation must be recorded on the forms provided). The Operator who takes the message shall then activate the appropriate alarm by depressing that button on the emergency alarm system control panel. Once the alarm system has been activated, that operator shall dial 81 on the plant telephone system and give the nature and location of the emergency in a clear, calm, and distinct manner. This message must be given a minimum of three (3) times in order that plant personnel understand the nature and location of the problem. Plant Emergency Alarm Codes The plant emergency alarm siren is^ a dual tone type which produces a high and * low pitch simultaneously during normal operation. Signal coding is achieved by alternately turning the siren motor on and off, and by opening and closing the air supply tubes feeding the rotating (sound producing) elements of the siren. Following on page 3 is a graphical illustration of the alarm codes used in the Aberdeen Plant. Whenever a plant emergency occurs, the nature of the problem will be communicated to the plant via the siren and the plant P. A. system as noted above. If the conditions require a general plant evacuation, the evacuation signal should be given only after the fire or vapor alarm. This allows the evacuation signal to act as a tornado warning when used by itself as noted in the storm warning section below. 2. Use the Proper Emergency Equipment All employees directly engaged in correcting emergencies involving VCM liquid/or vapor concentrations in excess of permissible exposure limits (1 ppm averaged over an 8-hour period with excursions to 5 ppm averaged over a 15 minute period) shall be equipped with personnel protective equipment which is appropriate for the hazards involved. In the case of VCM emergencies, the location of the spill must be evaluated prior to action on the part of any employee. If the discharge is occuring from a reactor relief line, Soctt Air Paks may be the only-personnel protective equipment required. In the case of major discharges which occur in and around electrically driven process equipment, the Supervisor in charge may ( require his personnel to also wear full fire turnout gear to maintain safety in ABD00185519 A-2 Emergency Plan Page 3 of 15 PLANT EMERGENCY ALARM CODES Vapor (Steady Signal) R/QRER FREQUENCY fF/rCR) LOWER FREQUENCY (P/TCR) Fire (Wailing Signal) Evacuation (Undulating Pulsed/ Dual Tone Signal) All Clear Dial 63 (Steady Signal On Plant P.A. System) ABDOO185520 A-2 Emergency Plan Page _4__ of IS * 2. Use the Proper Emergency Equipment (Cont.) the particular emergency operation. Whenever emergency situations occur where liquid (VCM or propane) is involved, personnel must wear special heat and liquid resistant gloves to protect from freeze bums and potential flash fires. 3. Evacuate Non-Essential Personnel from Danger Areas Always evacuate non-essential and all personnel not properly equipped with personnel protective equipment which is appropriate for the hazards present. Such personnel shall not be allowed to return until the emergency situation has been corrected. In all cases, evacuated personnel shall immediately proceed to primary evacuation areas as noted below. If the wind directs VCM vapors into the primary evacuation areas, evacuated personnel shall proceed to the secondary evacuation area at the guardhouse and assemble in departmental group ings as noted on the fence located east of the parking lot and south of the guardhouse. If that area is noted as being contaminated by VCM vapor, evacuated personnel will be moved to a safe location along the property line north of the plant.. ALL EVACUATIONS MUST BE PROMPT AND ORDERLY! PRIMARY EVACUATION AREAS Vinyl Area - At pad north of the control room. Lab 6 Compound/Plasticizer - Warehouse at northwest comer of the staging area directly south of the plant auditorium. Maintenance (including Warehouse, - Main shop. Yard and Safety) Transportation - East of Lab and Compound/Plasticizer as noted above. Off-Shift Yard and Mechanics - At pad north of vinyl control room. Office Personnel - Lobby in each office area. Contractors - North of main gate. 4. Account for all Personnel When personnel have assembled in the primary evacuation areas, head counts must be made as noted in EVACUATION OF WORK AREAS below. Personnel not accounted for at this time must be regarded as trapped and/or injured and rescue efforts initiated. It is extremely important for all personnel to understand the loca tion of their primary evacuation areas and to get to them as quickly as possible otherwise, other personnel may have to jeopardize their personal safety during search and rescue operations. 5. Rescue Trapped Personnel Search and rescue operations during VCM and propane vapor releases and fires must be attempted only with fire turnout gear due to the likelihood of vapor ignition causing a flash fire or explosion. ABD00185521 A-2 Emergency Plan Page 5__ of 15 A 6. .Activate Fire Protection Systems Activate and utilize Emergency Brigades, support personnel present (under the direction of the Mechanical Superintendent as noted in the EMERGENCY ORGANIZATION, SPECIFIC DUTIES section below) and the Emergency Organization as necessary to prevent or extinguish fires, explosions, or chemical exposures. Activate the Deluge System and/or fire monitors as follows: Delude System - These systems should be activated whenever emergencies which require Deluge System operation include but are not limited to the following: - Serious leaks from rotating equipment seals; - Abnormal discharges of flammable material from process piping, valves, and relief systems. - Fires resulting from either of the above. Fire Monitors - Permanently installed fire monitors in the various areas provide supplemental fire water to locations which may need additional water for equip ment protection due to direct flame impingement, high concentrations of VCM vapor, or during periods when the Deluge System is out of service. During VCM vapor releases which involve the reactor relief systems, the Supervisor may decide to utilize only the fire monitors sihce the point of discharge is above all other operating equipment. (Due to high volume demand of the Deluge Systems, fire streams from monitor nozzles may not reach the top of the relief lines with both systems in operation.) If supplemental fire water is needed or in cases where there is no permanently installed fire protection system (i.e., the initiator freezers), the Supervisor should utilize the portable fire monitor and hose reel stored in the Emergency Equipment Station. 7. STOP ALL HOT WORK! Motor vehicles, portable transfer systems, the incinerator, welding machines and any other source of ignition must be positively shutdown immediately whenever the plant emergency alarm is activated! Shutdown and secure operations as required to prevent further injury to personnel or damage to equip ment . 8. Stop flow of: A. Flammable materials feeding fires or potential fires, including dryer and incinerator gas burners. B. Boilerhouse operation is to be shutdown only in cases where unfavorable wind conditions and flammable material release is great enough to present a hazard. Boilerhouse shutdown can occur only on direct orders from the Emergency Brigade Chief, the Emergency Officer, or the Safety Director. 9. Utilize outside assistance and notify the community as required. A. Aberdeen Fire Department.................................................................... 369-9551 B. Ambulance....................................................... ..............................................369-2455 ABDOO185522 A-?. Emergency Plan page 6 of 15 9. (Cont.) C. Hospital Emergency Room.......................... 369-2455 D. Dr. R. E. Coghlan (office)...................................................... 369-2411 (home)............................... .. ................... 369-4418 E. Dr. J. N. Turnage (office)...................................................... 369-2411 - (home)...........................................................369-6311 F. Aberdeen Police Department...................................................... 369-6454 Have local police warn adjacent plants and residential areas if they are threatened by fire, flammable material releases or toxic gasses (chlorine or hydrogen cloride (HCl) as a result of a VCM fire). Plant Manager approval is required prior to contacting the police department unless the delay increases the danger to the community (see PUBLIC ALERT below). 10. Activate the EMERGENCY ORGANIZATION as required. 11. In the event of a power failure, avoid venting of the large reactors by utilizing the Emergency AMS Kill System on each reactor so equipped. That failing, kill the reactions by utilizing the Citric Oxide Kill System. In all cases, operators using the Nitric Oxide Kill Systems in the field must have donned a rocket pro pellant gas mask and checked for a positive seal prior to working with any part . of the Nitric Oxide System. 12. Locate the boundaries of contaminated areas during vapor releases. This will be done by the Safety Supervisor during weekdays and by the Vinyl Shift Supervisor at all other times. RESPIRATORY PROTECTION REQUIREMENTS Plant emergencies involving VCM and Chlorine shall require the use of Scott Air Paks. Emergencies involving propane and other materials require the use of Scott Air Paks only if concentrations of vapor might decrease the oxygen content of the leak area to levels which will not support life. EMERGENCY ORGANIZATION Please refer to the attached EMERGENCY ORGANIZATION Chart for the following dis cussion. When activated, this organization shall be directed by the Management Group, which bears overall responsibility for meeting the objectives of the plan. Activation - Whenever a emergency occurs in the plant, the Shift Supervisor respon sible for the affected area(s) will be in charge of all immediate actions, including activation of the Emergency Organization if and as required. During normal office hours, the organization shall be activated by the Shift Supervisor by announcing ."ACTIVATE EMERGENCY ORGANIZATION" three (3) times over the P.A. system. During off-A hours and weekends, the Shift Supervisor shall instruct the Plant Guard to "call-out^^ the Emergency Organization. The Guard shall then call all personnel on the left hand side of the Emergency Organization Call List (last page. Page 15) and state the nature of the emergency. Personnel called are then responsible for contacting ABD00185523 A-2 Emergency Plan Page 7 of 15 A EMERGENCY ORGANIZATION Activation (Cont.) the person listed to the right of their name on the Emergency Organization Call List. (All personnel whose names appear on this list shall maintain a copy of the call list at their home.) In the event that a call is not answered, the caller must then call the next person to the right until someone is contacted. Once contacted, people on the Emergency Organization Call List are to immediately come to the plant and assume their emergency responsibilities. Specific Duties - The following is a discussion of specific duties assigned to each position in the Plant Emergency Organization. 1. Management Group The Management Group will consist of the Plant Manager, the Plant Superintendent and the Industrial Relations Manager. The Acting Plant Manager will serve as the executive head of the Emergency Organization in the absence of the Plant Manager. The duties of the Management Group are: A. Provide leadership for the disaster group and coordinate all activities connected with control of the situation. B. Promptly release factual information to the news media, preventing erroneous reports and creating the best possible public image for the company. C. Notify Corporate Management and keep them up to date on the situation. D. Notify next of kin in cases of serious or fatal injuries. E. Determine what information may be given out by the Switchboard Operator. F. Maintain close communication with the Emergency Officer. 2. Emergency Officer The Operations Superintendent of the area affected will serve as the Emergency Officer. He will report directly to the Management Group and will be in overall charge of emergency control activities. He will be assisted in this duty by the Safety Director and the Chief Process Engineer. The alternate to the Operations Superintendent is the Operations Supervisor of the area involved. The duties of the Emergency Officer are: A. Work closely with the Emergency Brigade Chief in determining the most effective manner of establishing control of the situation. B. Keep the Management Group informed of the situation and the action being taken to bring it under control. C. Rely on the advice and help of the Assistant Emergency Officer and the Safety Director. D. Issue instructions for the "Call Out" of off-duty employees and advise , the Security Officer of who is authorized to enter the plant. ABDOO185524 Emergency Plan Page 8 of 15 EMERGENCY ORGANIZATION (Cont.) 3. Assistant Emergency Officer The Chief Process Engineer will serve as the Assistant Emergency Officer. He will assist the Emergency Officer in the evaluation of the situation and the planning of action necessary to establish control of the emergency. He will also provide any technical information regarding the equipment or process that might be necessary. He will keep the Emergency Officer informed of his where abouts at all times. The alternate to the Chief Process Engineer is the Senior Process Engineer. 4. Security Officer The Security Officer position will be filled by the Safety Supervisor and he will report directly to the Management Group. His specific duties are: A. Provide security protection for all plant property and material. This will include procurement and assignment of Guards, if needed. B. Dispatch personnel to the road blocks so that authorized personnel may be identified and allowed into the area. The unauthorized personnel must be turned back in a firm, tactful manner. C. Provide emergency supplies that might be needed during the emergency. D. Monitor VCM concentrations in the area of the secondary evacuation area southwest of the guardhouse. 5. Safety Director The Safety Director will assist the Emergency Officer in any way necessary in bringing the situation under control. His primary responsibility is in helping with fire fighting and rescue efforts. He will work closely with the Fire Chief. Following an emergency, the Safety Director will assist Department Heads in re storing safe conditions throughout the plant. He will also see that emergency equipment is serviced and placed in the proper locations. He will make a de tailed study of the causes of the emergency, action taken, and any recommenda tions made to prevent similar emergencies. The Safety Director will also be responsible for the following areas of emergency readiness: A. Assist Department Heads in training personnel in the functioning and employee acceptance of the plan. B. Organize and regularly train the Emergency Brigades in fire control.methods and emergency actions. ABDOO185525 A-2 Emergency Plan Page 9 of 15 A EMERGENCY ORGANIZATION 5. Safety Director (Cont.) C. Organize refresher courses for the First' Aid Personnel. D. Make sure that all plant personnel are exposed to basic fire fighting techniques pertaining to the use of portable extinguishers, emergency alarm systems, and evacuation procedures. This will normally occur on a every other year basis for all maintenance, operations, and laboratory personnel, and biannually for Emergency Brigades. All new hires will receive basic fire fighting training within 120 days of employment. E. Insure that sufficient fire fighting and emergency equipment is maintained in operable condition at all times. F. Conduct Emergency Plan review and drills at least annually. 6. Fire Chief The Vinyl Shift Supervisor will fill the position of the Fire Chief during emergencies in the Vinyl Reactor, Vinyl Dryer, Boilerhouse, Waste Treatment and Tank Farm areas. The. Compound Shift Supervisor will act as Fire Chief in the Compound, Plasticizer, Laboratory, and Warehouse areas. The Chief will direct the Fire Brigade and others involved in fire control or other emergency action. He will work closely with the Safety Director in the effective uses of manpower and equipment necessary to bring the situation under control. The Fire Chief will usually be the first individual in authority to recognize the existance of an emergency situation. He must make the immediate decisions regarding the emergency action and continue in this capacity until the Emergency Organization can assemble, if it is required. The Vinyl Shift Supervisor, acting as the Fire Chief, will initiate the necessary action to put this plan into effect. The specific duties of the Fire Chief in time of emergency are listed under "IMMEDIATE ACTIONS---" section above. Once the Emergency Officer arrives, the Fire Chief will report to him. 7. Assistant Fire Chief The Compound Shift Supervisor will serve as the Assistant Fire Chief during emergencies in all areas of the plant, except Compound, Plasticizer, Laboratory and Warehouse. In those areas, the Vinyl Shift Supervisor will act as Assistant Fire Chief. The Assistant Chief's duties will be as follows: A. Make sure that all of the Fire Brigade members in his area leave for the scene of the emergency. B. Report to the Fire Chief for instructions. ABD00185526 ''r.'.-:;ri ipQi\T1i1;f-,-|L ,, A-2 Emergency Plan Page 10 of IS EMERGENCY ORGANIZATION (Cont.) 8. Mechanical Chief The Mechanical Superintendent will act as the Mechanical Chief during the time of the emergency. The alternate is the Maintenance Superintendent. In this capacity, the Mechanical Chief will report to the Emergency Officer. He will carry out the following duties: A. Organize and direct damage control work as directed. B. He will be in charge of all personnel reporting to the Shop Area. C. Assist the Emergency Officer in any way necessary to bring the situation under control. D. Establish relations with outside utility companies and work closely with them, maintaining or restoring service as soon as possible. E. Notify the Security Officer of the names of those people in the plant under his direction and of any who have been called out. F. Keep the Emergency Officer informed of his whereabouts at all times. G. Organize and direct clean-up and repair crews for the purpose of getting the plant back into operation as soon as possible. 9. First Aid Chief and Assistants The Nurse will act as the First Aid Chief and will report to the Emergency Officer. The Laboratory Lead Technician will act as an Assistant. The alternate for the Nurse will be the Laboratory Shift Supervisor. A. The First Aid Chief and Assistants will go immediately to the emergency scene whenever the Emergency Organization is activated or there is a call for First Aid help. B. Give First Aid to the injured. C. Advise the Communications Chief if ambulances are needed. D. Keep the Management Group and the Security Officer informed of injuries, including the names and estimates of severity. E. Transport injured personnel to ambulance. 10. Messengers The Messengers will report to the Emergency Organization member to whom they are assigned. ABDOO185527 nr A-2 Emergency Plan Page 11 of 15 A EMERGENCY ORGANIZATION (Cont.) 11. Fire Pump Supervisor During first shift on weekdays, the Safety Inspector will act as the Fire Pump Supervisor. When alerted by emergency signals", he will report to the Fire Pump House. He will keep all four (4) pumps running until the "ALL CLEAR" is sounded. He will be assisted by the Tool Room Man. In the Tool Room Man's absence, the Day Shift- Mechanic will assist the Safety Inspector. At all other times, the position of Fire Pump Supervisor will be filled by the on-duty Shift Mechanic. Whenever there is no coverage by any of the above, the Plant Guard shall insure that all fire pumps are operating. The Vinyl Shift Supervisor shall be respon sible for the shutdown of the fire pumps when the emergency condition has been corrected. 12. Emergency Brigades There are two hose crews. The objectives of these crews are to insure that, through quick action, we will be able to protect employees and minimize any damage due to fire. Both crews are to report to the scene immediately when summoned by alarms, the Shift Supervisor, or when the Emergency Organization is activated. The crews will consist of the following: #1 Emergency Brigade Emergency Brigade Chief - Vinyl Shift Supervisor Chief Operator Dryer "A" Operators (2) Dryer Utility #2 Emergency Brigade Assistant Emergency Brigade Chief - Compound Shift Supervisor Automatic Bag Operator Automatic Bag Utility Line I Bagging Utility Line III Mill Utility 13. Support Group The Support Group will consist of all Maintenance, Warehouse and Yard Personnel (Supervisors and Hourly). They will report to the Maintenance Shop and be under the orders of the Mechanical Chief. The Maintenance Mechanical Superintendent will stay in the shop with the personnel. The Mechanical Chief will contact him for assistance. 14. Guards A. Direct ambulance and other vehicles to the emergency scene. B. Stop all other vehicle traffic into the plant and have it park without blocking the gate. C. Phone the Emergency Organization when instructed to do so by the Vinyl Shift Supervisor, the Compound Supervisor, or their designees.- ABDOO185528 Emergency Plan Page 12 of IS EMERGENCY ORGANIZATION 14. Guards (Cont.) D. Monitor fire pump operation as noted in 11. above. E. Record wind direction and speed, barometric pressure, time and outside temperature at time of release. 15. Communications Chief A. The Director of Administrative Services will act as the Communications Chief. B. Establish the gatehouse switchboard as an emergency and communications headquarters. The Communications Chief shall also prearrange for a Secretary to act as the Switchboard Operator. Several alternates should be planned. The Switchboard Operator should be contacted immediately following receipt of the call to activate the Emergency Organization. C. Handle all incoming and outgoing calls. EVACUATION OF WORK AREAS As noted in the IMMEDIATE ACTIONS... section of the plan, all personnel being evacuated from their work area due to fire or large uncontrolled vapor release shall shutdown the equipment for which they are responsible and proceed to the PRIMARY EVACUATION AREAS for a head count. [To expedite the head count, each department shall maintain a current list of personnel by shift grouping on a clipboard in the Super visor's office. A listing of office personnel shall also be maintained in or near the lobby of each office area.) If conditions warrant further action to avoid danger, evacuated personnel shall proceed to the SECONDARY EVACUATION AREA, southwest of the plant guardhouse. In all cases, evacuated personnel must assemble by departmental grouping for a head count. In the event that this area is unsafe, all personnel must assemble at a safe location south of Highway 25 along the north plant property line. Supervisors must designate non-emergency personnel to act in their place for head count purposes if the emergency condition requires the activation of the Emergency .Brigades or Emergency Organization. Wind direction at the time of a gas or vapor emergency will play an important role in the choice of escape routes. Evacuation routes should always be at right angles to the wind (cross-wind). Use the wind socks located on the silos or slurry blend tank (407) to determine the wind direction. PUBLIC ALERT During an emergency, the Plant Manager (or in his absence, the Plant Superintendent) will determine if and when action is required to protect the public, including re quests for law enforcement assistance. ABDOO185529 *. A-2 . Emergency Plan Page 13 of 15 REENTRY TO WORK AREAS Personnel, except those required to deal with the emergency condition, shall not be allowed to reenter endangered areas until the emergency condition has been corrected and verified. * Upon establishment of control over VCM releases, the Shift Supervisor, equipped with Scott Air Pak and HNU Photoionizer shall verify that all areas have returned to safe levels. Whenever an employee reenters a work area in which a VCM release has occurred, for the purpose of verifying safe levels, there shall be at least two other persons equipped with Scott Air Paks observing from a safe distance. In some cases, this may be done by Honeywell readings. During normal office work hours, the Safety Supervisor shall monitor public and total plant area safety with portable monitoring instruments and Scott Air Pak, if necessary. During his absence, this task shall be performed by the Vinyl Shift Supervisor. Again, this may be checked by Honeywell readings. MEDICAL TREATMENT AND SURVEILLANCE Anyone who is injured during any emergency is to be immediately treated as appro priate to circumstances. Anyone who looses consciousness because of inhalation of any substance is to be taken to the Aberdeen-Monroe County Emergency Room as soon as possible. Medical treatment of any employees injured by any substance will be that determined most appropriate by the Corporate Medical Division or its designee. REPORTING All emergencies will be reported by the Plant Manager to the Vice President of Manufacturing within 24 hours. In addition, VCM emergencies will be reported as follows: 1. The Operations Superintendent will issue a report on each VCM emergency as soon as possible, not to exceed 24 hours. 2. The Plant Safety Director will report the emergency and the facts obtainable to the OSHA Area Director as required by OSHA Regulations. 3. The Chief Process Engineer will report the emergency and the facts obtainable to the Mississippi Air and Water Pollution Control Commission and to the Regional Administrator of the Environmental Protection Agency as required by NESHAP or State regulations. ABD00185530 A-2 Emergency Plan Page 14 of is EMERGENCY TELEPHONE NUMBERS ---------------------- --------------------------------------------- 1. Medical Ambulance,MonroeCounty Hospital....................................... 369-2455 Dr. Coghlan, Office........................................;..................... 369-2411 Home......................................................................369-4418 Dr. Tumage, Office......................... 369-2411 Home..................................................................... 369-6311 2. Police Aberdeen Police Department..................................................369-6454 Sheriff's Office........................................................................ 369-2468 Mississippi State Police..................................................................... (Contact PoliceDept.) 3. Fire Department ' Aberdeen Fire Department............................................... -...369-9551 4. Light and Water Department Aberdeen Light 6 Water Department.................................. 369-4731 or.................................. 369-2159 S. #Headquarters Personnel R. E,Lehmkuhl, Office................................................(713) 965-1727 'Home....................................... (713) 780-1270 M. S.Reynolds, Office..............................................*(713) 965-2806 Home................................................... (713) 445-9187 6. CHEMTREC EMERGENCY NUMBERS See CHEMTREC Call Manual STORM WARNING These procedures are established to give personnel early tornado warning. When atmospheric conditions indicate that a tornado is possible: 1. The Guard will continuously monitor National Weather Service broadcasts for weather reports. 2. If the Weather Service announces a tornado watch for the area, the Guard will A. On days - contact all Department Heads. B. During off-shifts and weekends - contact the Vinyl, Lab and Compound Supervisors. C. Be watchful for an approaching tornado cloud. ABD00185531 Emergency Plan ^2 Page IS of 15 - A STORM WARNING (Cont.) 3. If the Guard spots an approaching tornado cloud, he will call the Vinyl Control . Room and ask that the tornado alert alarm, on the plant siren be sounded, and announce it over the plant P.A. system. 4. Whenever an approaching tornado cloud is announced, all personnel will take whatever action and cover that is established by departmental procedures. . EMERGENCY ORGANIZATION CALL LIST When advised by the Shift Supervisor, the Guard will start calling the names in the left hand column. If the person in the left hand column does not answer, the Guard will call the next person to the right until someone in each horizontal row is con tacted. Each person, after the initial call from the Guard, is responsible for notifying the person on the list to the right of his name (by the same method). C. L. Miller 369-4563 E. L. Kieschnick R. A. Frohreich G. D. Bracken J. C. Coffmar 1-327-6070 J. E. Barton 369-9100 B. F. Hawkins 343-8832 L. D. Honeycutt 343-5505 A. H. Sather 369-9271 J. V. Uptain 369-8109 J. G. Roberts 369-8059* V. A. Belk 369-4416 f. R. Miller 369-9100 R. G. Gilreath A. L. Barr 369-2818 369-8232 S. J. Vincent J. L. Horstman C. E. Davis 369-9298 369-6005 369-8780 R. W. Rye 369-4730 R. B. Martin 369-2691 R. D. Jackson 369-2405 S. D. Cox 369-8752 J. A. Dixon 369-8372 G. A. Morgan 369-6522 J. L. White 369-2991 M. F. Holman 1-324-1682 J. L. Carter 1-327-6816 M. C. Jemigan V. Messick 1-327-9518 1-327-0741 ... EMERGENCY ORGANIZATION ABD00185532 A-2 ABD00185533 A-2 PLANT EMERGENCY ALARM DATA SHEET DATE: A TIME: ALARM: (Circle One) Fire Vapor Evacuation* Tornado** * Evacuation alarm must follow either the fire or vapor alarm. ** The tornado alarm and the evacuation alarm are the same alarm. The difference lies in the fact that the evacuation alarm by itself means a tornado is approaching. The evacuation alarm must be proceeded by either the fire or vapor alarm. .LOCATION: ____________________ SPECIFIC NATURE OF PROBLEM Alarm Activated by: ABD00185534 October 15, 1980 ABD00185535 __________________ ___________A-3 Conoco Chemicals Company Division of Conoco Inc. P.O. Box 91. New Highway 25 Aberdeen. MS 39730 Mr. Wayne Aronson Air Enforcement Branch United States Environmental Reg ion IV ,_r , 3^5 Courtland Street, N.C. Atlanta, Georgia 30308 Protection Agency Dear Mr. Aronson: On August 21, 1979, Pedco Environmental, Inc. under contract with the U. S. Environmental Protection Agency, conducted an inspection of the Conoco Inc. PVC Plant at Aberdeen, Mississippi and subsequently filed a report of that inspection. We have requested and received a copy of that report from Region IV, U. S. EPA. Recognizing that conclusions in the report do not necessarily represent EPA opinion we, nevertheless, feel compelled to comment onthe report. This letter is written to voice disagreement with certain conclusions, suppositions and misunder standings in the Pedco report of September 26, 1979* First I would like to express our appreciation for the comments regard ing Conoco's good faith efforts to achieve and maintain full compliance and other positive comments regarding our cooperation. We do recognize the importance of compliance with these regulations and plan to continue an open and cooperative attitude toward EPA. 1. We disagree with the Pedco Environmental author's opening letter opinion that Conoco has violated Section 61.65 (a) and 61,65 (b) (8) of the NESHAPS regulations and have explained this regarding 61.65 (a) emergency discharges in earlier correspondence and the show cause hearing. Additional remarks about both sections will be covered here. 2. in the last paragraph on page vi we take exception to "Concerned that all control measures taken to reduce- the potential of emergency discharges have been aimed specifically at the type of accidents which have already occurred." Conoco is required by the regulation to specify what actions have been taken to prevent future discharges if a discharge does occur. There is no obligation to report other changes that do not involve changes to control devices or changes in plans filed with EPA. numerous and costly improvements have been and are continuing to be made at this plant to minimize the potential for emergency discharges. Examples of such projects that have been completed are additional instrument air dryers to prevent winter tine problems and double block valve arrangements on key VCM systems to minimize effects of valve failure or valve leakage. r. Mr. Wayne Aronson October 15, 1080 Page 2 ABD00185536 A-3 3. On page vii, there is no indication that the portable gas chromatograph used by Pedco had not been calibrated. Other disagreements with Pedco conclusions on page vii are covered in item 1. A. On page k the production capacity at the top of this page should be 350 million pounds of PVC resin per year. Also the operator shifts are in error. While we do work 12 hour shifts the shift cycle alternates between_3 and k days working and between 1 and 6 days off. 5. .1^ the 2nd paragraph on page 8 the chromatograph sample lines are made of nylon rather than PVC. The cycle time shown here could be misinterpreted although it is clearly indicated in other parts of the report that each sample point is sampled every 10 minutes. 6. In the 3rd paragraph on page 8 a type 5335 resin is mentioned and that should be changed to 5385 as we do not manufacture a 5335 resin. 7. On page 15 under leak detection and elimination procedures, July 6, 1979 was when the current Leak Detection and Elimination Program was approved. The original program was approved on June 30, 1977 and the July 6, 1979 version is a revised program reflecting improvements resulting from improved technology. 8. The last sentence on page 15 states that the leak detection "program is primarily corrective in nature in that it does not include com prehensive preventive maintenance procedures." The Aberdeen Plant's comment is that the Leak Detection and Elimination Program meets the requirements of the standard, has been approved by EPA and does contain maintenance procedures for the continuous and portable leak detection instruments. There is no requirement that any other preventive maintenance procedures be included in the Leak Detection and Elimination Program. Preventive maintenance procedures are implemented on a periodic ..basis. 9. In the 2nd paragraph on page 19* we do not consider that the runaway occurred late in the polymerization. Suppositions in this paragraph relating to effectiveness of AMS at different points in the reaction are erroneous, not based on any information the author had at the time and such conclusions should not be inferred by one inexperienced in PVC manufacture. As we have clearly indicated, the condenser was badly fouled by the coarse batch on February 2, 1979 and this explains why the normal amounts of AMS has no effect. Actions taken by the plant following coarse batches will detect and correct this situation in the future. Mr. Wayne Aronson October 15, 1930 Page 3 ABD00185537 h A-3 10. In the 3rd paragraph on page 19, there is no basis to say that the NO system was not pressure checked frequently enough. No standard exists specifying the frequency of such pressure checks. Plant procedure revisions established a plant standard for this after this incident. The water flow recorder does show low flow for 4-5 minutes but the opinion of the condenser water being shut off during the runaway is erroneous. On page 10 the author comments that he has difficulty matching up the charts for temperature and pressure and cooling water flow rate. An experienced PVC producer would have no problem matching these charts and it is clear the water flow reduction occurred after the relief valve discharge had cooled the reactor down below the temperature control point. Therefore, it had no effect on the runaway. 11. On page 21 in the 3rd paragraph, inference of deterioration of NO quality is made. No loss in effectiveness of NO stored in the plant for years has been found and this failure resulted from a fitting coming loose, not corrosion. Annual on stream inspections for corrosion in the plant have not indicated any corrosion in this system. 12. In the last paragraph on page 21 continuing on to page 22, there is an apparent misunderstanding regarding the use of catalyst (initiator). More initiator can be used in colder weather because of improved heat transfer in the condenser. The amount of initiator used at any one time is dependent upon several variables, is intertwined with reactor technology and goes beyond EPA's or Pedco's responsibility. 13. Pedco's speculation on page 22 that there are underlying problems which have not been recognized is pure speculation. PVC manufacture is a complicated process, especially under cold weather conditions. 14. In the description of Incident Number 3 on page 22, the date of December 10, 1978 is in error. The actual date was February 10, 1979. It is in error in Table 2 also where February 9, 1979 is shown. 15. Regarding page 26, I refer you to the comments in item 2 of this letter regarding where our efforts are directed. The author makes an unfounded comment that no corporate studies are being conducted regarding discharge prevention. In fact we consider ourselves one of the more advanced companies in these studies and work was underway at both our pilot plant and our engineering and research center when he made that statement. No obligation to report that such studies are being conducted exists. This Section 4.12 should be removed from the report since it has nothing to do with compliance. However, since it is currently included, comments will be made on several of the scenarios. Mr. Wayne Aronson October 15, 1930 Page U ABD00185538 " '' A A-3 16. Regarding Scenario 1 and 2 on page 26, a vibration study utilizing specialists in their field was initiated in June of 1979 prior to the Pedco visit and vibration problems have since been solved. 17. Scenario 3, page 27, is prevented by annual equipment inspections. No corrosion has been noted in the areas discussed here. 18. Scenario 5 on page 27, see item 21 of this letter. 19* Scenario 6 on page 27 considers leaks from flanges that have been opened. It is plant practice to pressure check the reactor hydro statically each time a flange is opened and reclosed. This scenario talks of gas used to pressure check the reactor. We use water, and leaks will show up easily if they exist. They are corrected prior to startup. 20. In Section A.2.1 page 28, a specific comment that no control device was found to be out of compliance would be more appropriate. Table 3 on page 29 could be misconstrued to indicate that some relief valves were out of compliance when in fact the appearance of NO under SRV merely denotes the double rupture disc installations without relief valves were in compliance. 21. On page ^3 and kk9 the sample 20 discussion points out that leaks have occurred several times at reactor condenser lid. Each time appropriate action was taken to tighten the condenser lid and stop the leak. In addition, several variations of gaskets were tested, bolts were changed and bolt tightening procedures were reviewed. The final answer to prevention of this excessive maintenance requirement was resurfacing of the condenser flange. When this operation was proven successful on 7^ condenser, all the remaining reactor condensers were resurfaced. 22. We disagree with Pedco's interpretation of a legal leak on page kk and as defined on page 60. On page 60 Pedco infers that Conoco has defined a legal leak. If the Leak Detection and Elimination Program, dated April 6, 1979, developed by Conoco had been studied more closely it would have been clear that 3 consecutive readings of 5 ppm is defined as the action level for the continuous monitoring system. This is clear in the cover letter attached to the program as well as section H and I of the program. It is also in keeping with the requirements of the standard. Our record will show that corrective action for leaks is taken, as required by the standard. The intent of this letter has been to state objections to inaccuracies and several items that can be misinterpreted in the Pedco report. We disagree with any inference of non compliance with the NESHAPS standard. While the Pedco author recognizes his lack of PVC industry knowledge, he repeatedly speculates on technology issues. We reserve the right to comment further on this report at a later date if we deem it necessary. Sincerely, c. Curry L. Miller cjt ABDOO185540 A-4 ABDOO185541 (conoco) Conoco Chemicals Continental Oil Company PO Box 9 l. New Highway 25 Aberdeen. Mississippi 39730 April 25, 1979 Mr. James T. Wilburn Chief, Air Enforcement Branch United States Environmental Protection Agency 545 Courtland Street, N.E. Atlanta, GA 30508 Dear Mr. Wilburn: Pursuant to our conversation of April 11, 1979, we are submitting the attached list of measures currently being taken or in the process of implementation to reduce the potential for relief valve discharges at our Aberdeen Plant. If you have any questions please call me at 601-569-8111, Ext. 255. Curry L. 'Miller Plant Manager Attachment c: Mr. Wayne B. Anderson, P.E. Coordinator Industrial Air Emissions Section P. 0. Box 827 Jackson, MS 39205 ABDOO185542 A A- b ATTACHMENT 1. Additional high level alarms have been ordered and will be installed in the two fresh vinyl chloride receivers. 2. The process leads to the existing level instruments on the fresh VCM receivers will be heat traced and insulated. 3. Revisions to the standard operating procedure have been made to require termina tion of polymerization with the emergency kill system if the reactor pressure reaches 1U5 PSIG during production of 5385 grade resin. b. Operating personnel are now required to wear self-contained breathing apparatus before starting the addition of nitric oxide to the reactor. 5. The emergency nitric oxide kill system has been pressure checked and it or any alternative kill system will continue to be pressure checked every six (6) months to assure the integrity and readiness of these systems. 6. The standard operating procedure has been changed so that after every coarse batch, the reactor condenser will be inspected to determine if it is plugged. If it is found to be plugged, it will be cleaned prior to charging the next batch in that reactor. 7. The standard operating procedure has been changed to require a reduction in initiator loading for any batch following a coarse batch in order to slow down the reaction rate. 8. A new relief valve has been ordered and will be installed to replace the valve which relieved prematurely. 9. Operator training sessions covering the stardard operating procedures will be conducted, on a formal basis once per year and for new employees during their initial orientation period. 10. A new rupture disc holder which can be assembled and pretorqued prior to installation has been ordered and will be installed beneath the relief valve on D-300 to minimize premature rupture disc failure. ABD00185543 A-5 TTT7T ww cr subject o? course or cl'.ss tirx; V:\ii sf/.-sfrr ` A-5 DATE 77 ^CATICN 7 A&. instructor(s) .AS >*Cr* HU13ER 0? HOURS Ug * DESCRIBE VYKAT HAPPENED (Hajor points covered, what was demonstrated, what v/as practiced, what training aids were used, etc,) Attach separate sbec if ncce33ar&*/ > * / .. / X^WS AS-r^JA l ___ T^^rv & XTT/^C* ___Xfzs______ ^ ..fa____t_____y__ __SZ-S^y^- Z//S/S/y//Ss//LL T7ll/XS X//S ' AX /y%trZ^cc<^cSS_ _ <^y? 7^ _ Xl/ y'-t^SZi-f'S X/'/y____SSyfyS<5^___________ ` MOi*/.* yc^^ri^____ X^/Ls S/jvs^Lts ste/farlS. ___ SIGNATURE TRAINEES pJEPT. CLCCN NO, HAME (PRINT) y \ ^-V"----------- <rso 7..' y A 1 10 - *74?. [//til)7) . ^--SffV 'Zr' --N-^^ A^-\orfr Lo-rr</ ArvA^ ... --,- ^roXiX. /) .CAPr-T-t/S. U f<? 7V 0XferVtfF-? !/ lad2. ftK-/*s\ + >t<9l- // *79 z /> v/ rw! .v s /A>/9 /cf Z/i/f*'A7k dept. CLCCN NO. . * .4 * i i i 1....... ........................................................................................................................ HAKE (PRINT) % ! ABDOO185545 ABDOO185546 .Ar6 P . TRAINING VK-.TINO ATTENDANCE RECORD ca s-;dj::c? cy ccr.'.cy cr; cL'.nc Z&aIai? DATE ________n:STaUCTOH(S) ____ LOCATION ^ KUKBER 0? HOURS DESCRIBE V/HAT ED (I'njor pointr. covered, v/hot v/ns demonstrated, whet v;as practiced, v.hot training aids were used, etc.) Attach separate sheet if ne.cosanry. % I ___ s4&i'27/-~ A?*+&/*^--------------- -- TRAINEES DEPT. CLOCK NO. HAKE (PRINT) bLjt . .7,9. DL> \S/) r A uJe.//-' /u-9 tL^anie.'.po^r . it- 2cz. fa WbtfQ- .j.t, ,.tfr.. v ii.T AJ3o Ad. fit ff.UX M C30 S&&V& W % le 9 < M ?-eo LWa.r/~nt M/r^i>r. A /fc^ DEPT. CLOCK NO. NAKE (PRINT) . > ).. . , i -- . ABDOO185547 A-7 ABDOO185548 A-7 \ trait: 11:0 :.T.-.ri::s atti~:d.ar:ct-' record make cr s"dj::c? c? course cr class date , ^ho/7instructor(s)_________________ , ^ ' ____________________ docatici t;t:3En or hours____ _____________ A DESCRIBE 7/1:AT A OPENED (i'.njor points covered; whot v/nn demonstrated, what v;as practiced, whot training aids wero used, otc.) Attach separate sjcci If necessary. * < A'i+t'/. JZt&M *,,9Z*f*6* -- 4*=g! ^` ___ gfltJ^CjCS______ ____ ___ ^___________________________:_____________ /.______________ W_________ :____________ DEPT. CLOCK NO. ^L// *v */ // r/ / * // . // '/ MAKE (PRINT) jM&tJ__ _______ SIGNATURE TRAINEES DEPT. 'CLOCK NO. . O___________ NAME iPRIKf) . f - &tet//r /hdy . . 1 1 ABDOO185549 KAES on SUDJ ABDOO18555555W0* / A-0 OF COURSE CH CLASS /C/'T7/fS. & /- ' DATE INSTRUCTOR (S) _______________________ * UCATICN MUKBER 0? HOURS DDEKS(CRIBE V7KAT HAPPENED (fa Jor points covered, r/hat was derronstrn ted, what y/as practiced, wV.ot training aids were used, etc,) Attach separate ^ sheet if necessary. '*S | 1 ! Z^' - -:- . . - SIGNATURE TRAINEES I ABD00185551 A-9 ' -ABDeei85552- A-9 Interoffice Communication To Distribution Prom J. R. McCrimon Date February 8, 1979 Subject REVISION TO OPERATING MANUALS FOR THE LARGE REACTORS EMERGENCY KILL PROCEDURE Attached is a revision to the current operating manual for the large reactors. This revision includes pressure and temperature limits for killing a runaway reaction. By adhering to these guidelines, uncontrollable runaway reactions can be avoided such as the D-300 runaway on February 2, which resulted in a'relief valve discharge to the atmosphere. This revision also adds a caution in using the nitric oxide system to kill a runaway reaction. If there are any co; .ents on.this revision please contact me as soon as possible. '-Xj. R. Mcefimon Operations Engineer cjt Attachment c: ^CLM,y? JE3* DWH, AH5, RAF, ELK,* JEB(5) Bulletin Board ft i ^ABD001855-53; A-9 Operating Manual D-700 PVC Reactors Page 33 OPERATING PROCEDURES (COUTIIfUED) D. Polymerization (Continued) 2. "A" Operator Duties (Continued) c. When the lead operator instructs the ."A" operator to do so, .the batch is. killed by adding short stop solution to the ' reactor. High pressure service water is used to pressure the short stop solution from the AMS short stop charge pot into the reactor through the same piping as the agitator mechanical seal purge water inboard seal flush. 3* Emergency Shutdown The following parameters are to be the maximum limits on a runaway reaction. The reaction should be killed with AMS if either one of the parameters is exceeded. > Resin Maximum Temperature Maximum Pressure 5385, 5^25, 5^65 1U2F 1^5 ?SIG 53C5 162F 175 F3IC A runaway reaction immediately after charge and heat-up indicates that the reactor condenser may be plugged, and that the reaction must be killed. If AMS will not kill the reaction, use the nitric oxide (U.O.) short step system. CAUTION: H.O. is a highly poisonous orange-colored gas. A Scott Air Pack or a ''Rocket Fuel" ounnister mask must be worn while killing a reactor with the ii.O. short stop sys tern. ___________.... ...^^AmxQm^........,............. ................. .............. .... A Operating Manual D-700 PVC Reactors Page 39.1 III. OPERATING PROCEDURES (CONTINUED) 'D. Polymerization (Continued) 3* Emergency Shutdown (Continued) The runaway reaction must he killed immediately if either one- of the pressure or temperature limits listed above are exceeded. If the reaction is allowed to exceed these limits, it may not be controllable and result in a relief valve or rupture disc discharge to the atmosphere. The following steps are to be taken during emergency shutdown: - a. Use the nitric oxide (NO) system short stop system for killing each reactor. There are six cylinders of HO that can be released for each reactor. The NO system can be activated either at the reactors by manually opening the correct valves or from the control room. b. Use nitorgen to pressurize the Dura-Seal* unit emergency seal water drums with their respective systems must be opened manually. ^ c. There will be sufficient air in the air system surge tank - to operate valves for approximately fifteen minutes. It will be necessary to use the nitrogen backup system to Registered Trade Mark ABD00185555 A-10 THAT'.' IVo KAKS CR SUBJECT 0? COURSE CR CL'.S3 K:-.cu:;n Alt/ ' ft DATE XOTATIC;r ~7^^y INSTRUCTOR(S) &L*n. ?__________ tZcTZ'y&t--' BUK3SR 0? HOURS _____ _ /V`~ 1 DESCRIBJEE 7*HAT HAAP?P?ENIiEED (Toajor points covered, v/hot was demonstrated, what was practiced, what training aids v;ere used, etc.) Attach separate -- .sheet Iif ncecccessasaarr;y. .- / J0i & " ^ 4 J&tJ4+s _ tft/44$**< ^---- .---- .------- C-----------*---------- *=> ^fa, J&^**hp***S ^. --4fW*sr^----------- </?h C^2_ rft ny Sif. ^ >l<> jkrtd* SIGNATURE .' ___ . trad:ees | d?T. CLCClfl 1 KO. ! P-------"7^ HAKE (ERECT) j DEPT. C LCCX KO. KAKE (PR IK?) // // K Vv M Kerf l /^//<7 r / t'*t 7^ ^ 7 l-t-V. ) JyQfZ+f/ -/^sPhM/.uj A, /Z3n 1 n^iL V^AaoftkJ.L> qj>&iauL,^ i % V '.V * - tj __ 1 1 1 ^j a0 # 1 $ 1 *! 1 ABD00185557 A-11 4 ?RA T'.' T!* (} 7;: record KAtfK OR SUBJECT 0? COURSE OR CLASS dMizL & V* {Li}. DATE 1-11-71 _ INSTRUCTORS) ATICN jiJcAJ^ /Crvy^ HUttBER 0? HOURS > .kWLj^ DESCRIBE VVHAT HAPPENED (i.'ajor points covered, what was demonstrated, what v/as practiced, whot training aids were used, etc.) Attach separate shoot if necessary. ., Ia/k^ ***\~tt /y*e^r j'Lill jJ <d-+LU ^d^M. ' &*~*d ^C/ufcc r/ [ ]<LJP /^' *-9/ hyzL <x~J. ^4vw p4*rZ<i~^C ,\ -M*2- ^ Ml <2~qs\jX fLl~ SIGNATURE , TRAINEES J ABD00185559 A-12 ABDOO185560 l TRAINING MEETING AVrCNPANCn KI'.COHD 1 NAME QR SUBJECT OF COURSE OR CLASS _______________________ A-12. * DATE 3-0- 7f INSTRUCTOR (5) //IS/) > LOCATION #cns71 NUMBER OF HOURS /(f) DESCRIBE WHAT HAFPENED (Major points covered, what was demonstarted, what was prac ticed, what training aids were used, etc.) Attach separate sheet if necessary. /5CssjS5rA 77/,- ^ ^x- e/CC / &7JL ZlilcCfrAssAZtr. 7c^> A? " 7o 72?&ec<y///t 779/7//*s/?/C tJ/77/ /7~. Af.O. /S7/S/9t/?7 . ^/^ /7/g7er To A/sttt &&</7~ ; /Qjl)S) /2A/J/3V\ a jy' --s-c>/?7~r- AWc. Ts^/dc sss7e/ri 1 ^.77)7; / rcJ/9.5 777e/e. /ZTS/'Q/J^/g/T./TV T AA/?TA7^A i -7&6TS77'yS' .-^T~ /^r^WSV? 1_ . ^2ok~ 0&S7Tca] -' 7/Jt// Artrs 777<r /k<cc<0//- S77?77p 7o z/<;/7. -Sc/9/7. c/PAJd/sTdrAi AV/teAT: /s7/aJ& /Jo^J/7^ &?#'/.' '/S' 3 AC// /77/9S/A //) ^/7" SIGNATURE yg. r4r>,,/?A U#'i TRAINEES i. 5 UEPf.* ym 1 41 NAME (PRINT) -. . kc To^y B-. JC-Lv DEFT >i CLOCK. no. NAME . (PRINT) . . VtI7 >/ ? <$>z?nc-es> M l m 'Iju^sjo* -- u Jd'-G&p // /9g& Jm . - 'Wr &Z/>Atp ' JSS^- 'H ' *.% ; W ;. .. $ f ** .,' >*-- * ,*?. v> ff $i" * ` >4 V1. J L----------- - ------- 1 i . ABD00185561 A-13 ZUESCninz ;vi:A7 (1'njor points covered,-whot v;ns dorsonstrn ted, v;hn t r was practiced, what training aids wero U3od, etc.) Attach separate sheet if ne.cosaary. r .. .! .USe_d _ y-/<= . deujed j?He.ke.dc.\f . y<;il /kr* /6l^. ,*'c-J/e_ /_____ ^____y_ r\.p/ -/ftliVlb/ iy.-6.-.-l//~C' './1l Sbr7! J . *- 1_7------------------ - 4.' ynK\0oe4u<6zAh______A__l_l________o___p__?_____X_ a' f-liKll_____he|Le_._f_l____T__o__t_e_/____`____S__A__o__u__ic_ d____'_T__R__'J_- po deduce . Uje. d.'s cuJSed ,'t A&Aid p/d____otk - pds--kMh^. ____ i_ J-:__ey-p IPt\ 4<zsl , y-AK-r__,"r ^ ' t/< A* /J v/e. rfe-IaL____ o/fW^ j: llxy. / D <U.oit) heu} ~T~o o/'eAre ~7>(< \l.n. cn{ <s\sTc.h-i o c^o so k.d idjT^ucrcd OA-JeJ Pf>. - ifxpjftTkUjo /q-6A;J v/m~ MgyJ.k-e.iy------- ulowd^i2i.-c^x;jJr -6r,--u);i-k sesrr ^-<1 Pac-ic Jji q do. jZ. coc^et /2/e/ y/J/j/Qjje\7ttiik1G*ature^ rW HHi SecsJfTr//eetd^ ud/ttr J^tratkzzs '1 HffrSC ^ LoCJrTloti f/4 rte-vL iZccdZr Fu-e,/ ^2/bAJrcrr^L _LDEPT. CLOCK NO. NAME (PRINT) DErT CLOCK NO. NAME (PRUITT iiv^L 2,3-0 'OflU.tT_____ Sp Pr^t^ LiLtjfJz Jim . 7^- hStS. Z&aMmiA ua // / gp~^. i // 2o/f' 4| i T 7 * ABD00185563 A-14 > T*- A-l4 Interoffice Communication t From : Vinyl Shift Supervisors : J. E. Barton ot : March 20, 1979 Subject : EPA COMPLIANCE $ The following items need to be done to assure-EPA compliance reguarding VCM emissions. 1. The date must be stamped on the Honeywell recorder charts each morning at 7:00 a.m. When the Honeywell charts are replaced the number of the Honeywell unit is to be written on the bottom of the chart. All used charts are to be turned into me. 2. All recovered VCM receivers are not to be filled above 80%. 3. The high pressure alarms on the blowdown tank in each unit will be Teset to 40 psig. 4. The Emergency Kill Procedure has been revised as follows: Emergency Shutdown The following parameters are to be the maximum limits on a runaway reaction. The reaction should be killed with AMS if either one of the parameters is exceeded. Resin Maximum Temperature Maximum Pressure 5385, 5425, 5465 142F 145 PSIG 5305 ' 162F 175 PSIG A runaway reaction immediately after charge and heat-up indicates that the reactor condenser may be plugged, and that the reaction must be killed. If AMS will not kill the reaction, use the nitric oxide (N,0.) short stop system. CAUTION: N.O. is a highly poisonous orange-colored gas. A Scott Air Pack or a "Rocket Fuel" cannister mask must be worn while killing a reactor with the N.O. short stop system. The runaway reaction must be killed immediately if either one of the pressure or temperature limits listed above are exceeded. If the reaction is allowed to exceed these limits, it may not be controllable and result in a relief valve or rupture disc discharge to the atmosphere. EPA Compliance ' March 20, 1979 Page 2 ABDOO185565 t -5. The emergency nitric oxide kill system for all the reactors has been pressure checked to assure integrity of the systems. These systems will be pressure checked each six months with nitrogen. 6. After every coarse batch produced the reactor condenser will be inspected to determine if it is plugged. If the condenser is found to be plugged, it will be cleaned prior to charging the next batch. 7. Copies of the procedures for the Old Unit, New Unit, and Dryers will be placed on the table between the Lead Operators' desks in the control room. There will also be copies in the Shift Supervisor's office and Operations Supervisor's office for your reference. Please conduct a formal review with your people on the seven items above and the attached Work Practice Controls for the OSHA VCM Standard. Write the review meeting up on the safety meeting form and return it to me. I would like to have all the meetings completed by 4/8/79. cjt c: CLM, ELK, RAF, Shift Supervisors (5) ABDOO185566 A-15 , 'T'V ........... ABDOO185567 ..... ; ;^V..........'.......... .. ........... '.*..... W<k 4 - \' i?' Y^ trait: 11:0 Vr:-Ti::" ATTi~:nA::c!-: v~r.onn ;JSrcn. svbject ts* cou:.sh cx class ('pmdhy-JG?&th\ A-15 ' l'C.h. 1 A ate 3/&3/95'iestpuctcbcs) C]p/j;J.J '1 .cca Tier Ocdr&l - j?z>OM _ j.'uoeh oe hcjus AC 1 /, .ESCRIPE '.VIIAT .`...'.PPPLED (i'njor points covered, what v.n r> demons trn ted , v;hn t ; i. v;os practiced, what training aids v/cro used, etc*) Attach sepornto * [ sheet if ne.co33ajy, , / __ ; ., ~ ^t . -fJJc'd. >7^ t~PA ('f'f-'prPrUC? -^T(d 3-,iPr.j^ , Ay T.C.KAn/J-' fi-j h ? V/-V.; ' f^Prtj - 7~/fe. Aj'/.-e, 7~b /fl f f &Te.<$ y?f< />f ^5 "T A\lc.*z Oh VH /\ rr Cl i Te fjJ&L0 f---/-/--/-/-p---t-v---'------W----- t-----------u---!-c- s * O1 c*'i ^ -&-d - /1U1 *'O,c --*hi & A /r eh . . T i&^.,j.., thk-fr cf I'-C'H* empties d< Tv b* f&fAtecI Td do uj*~ Td Tyv<o *4 e^Jr cf uo h> fxp/Afdd V/at ir etci OHM^- j 1 ~n> f Ajker_ n& Li tfiCj f Kd&' oo Acu) ' a' ujJ**t Acr^cJj Te 1*^ /?f7~ f\e i^(L To feihu' ukj JwT tt Qpt-i^ /,> i<\'rk tAoli b^T I !! ~TP PUd bzdtplr 7b dr y-/~s,_____________________________ . SIGNATURE TRAINEES oO o o-)! DEPT. ' NAME (PKIKT) U-h/L ...%3C Ziv//^- .*7ofifJd- /; ' .-// 9fi S^r.r. a H .<9 * ^/C^y AJs/tT^STXtoA' IU1 (. )Zj- rTCtr.-^^: / lb 5 rertmnie.1 t&iLtenSR. t . b ,thi3r> tf 9U1'7 /<" (9s''J I 5 /'g ' * \13-3I \leb Mwr*fT~* DEPT. CLOCK NO. MAKE CPRUrT) V -......... . * -- r 1 1 ! : -.-------- % 9 i ABDOO185568 A-16  -/ert^ e. SIGNATURE rfRAIKEES DE??. CLCCil NO. hake (paikt) | Dzm'7 CLOCK KO. HAf! vs(& Lse (Lwidees \f/n / '320. ,?< Pe-rYz/S // >kf.. ! Vi./w if if \K ViO*.' /'MUrUt Vr-AH i-% >: 7~7;.-t)dcsi/; Si*/ _S ' ---- ' /> / / '^-'VT.U-- />** C"?o Uvteve7 ^ \^o# 1 . l\ .> ^ 746 y^cj & /a t | * - iiAKE (ri?r;-T) .- * 1 i l ^ /. . . I 5training ks?.tc kecorp KAK5 CR SUBJECT-OP COURSE CH CLASS EPA j'hvh.* A-16' 1 > 5 ^ &z/ DATE lOCATICN ^/- 7 7. |/'tw INSTRUC? CR (S) HOltBER OP HOURS DESCRIBE YmA? IiAPPENED (i'ajor points covered,-what was demonstrated, what. W8S practiced, what training aids were used, etc*) Attach separate sheet, if nc^ssary* -Ills. ~T^C / ' t-fr- / / - ^X / , / ^> 5 rff fA--jy C M 4- xP- yuL^eJti w-t P'C fa ,& 1-y. >-y> ^ ^ cA~'$=<. C^C^A^A n^jnSW\ '/X%-d Ul SIGNATURE TRAINEES DEPT. CLOCK NO. V*iu*P /6^o it NAME (PRINT) j DEPT. ^ tf/Z'b&ts .4%? r,JTS JyZLu- 1i CLOCK NO. t//fyyL i' 77 v #77 )f s) Y?yte'J2-^ /y&yyr&z^ -/ r*? 1 /'i /c~i (PPz^7jr~y~yy~27 yJ^ZZL >Sm4%l. v_' // * *,# * .4 22H fYCtitM C- (>vVlWv\vm*? /Zr? .; t) d 1 1 ' (Y\S< MAKE (PRINT) * ; i ;; ; 1 i i i ~ .* * 1. ': t J I J ABD00185571 \ * A* i A-16 f training r.'f:-.Tr::r, attendance record 9 NAME CE S"SJ."C? CP COURSE CE CL',ES DATE __ 3'3 /" ?_? ___INSTRUCTORS) .r.j3^>i4 LOCATION flcA/I^ct &f r:t- NUME^R OP LOURS ^g? /vti*U 'DESCRIED Y/MAT jrAPPENED (Major pointn covered, what wnr> dor.onstm ted, who t v;ns practiced, what training aids were U3od, otc.) Attach separate sheet if nepesanry. . . 4".. ^ -- '*' . <* -- ".*' ^22}?. *flA CyU A-4L hcA - -~l-,..^.. . * . *'-- ------------- - ' ' - n^y Q-U^T T%' /?/? . . Mu? Mm A ^/T/W-../^ .&*>. /77S)J^srJJ Af^/1 // //c S/)nfn+*?i /%<,<* T/cusS* M #<-5o _T^lJc .-O-dL---- <JtrTj Mi/ft-Tt j'1/ OrfzL SIOKTUE )r) TRAINEES DEPT. CLOCK NO. NAME (PRINT) ^1 * z*1 DEPT. CLOCK NO. iUo. K ti< if iV ' s' d7?<?.. -to 7^/S' PM j. .:,ro * + Mkt / x n k.^fyjt?7 . <5 -?hzf@S // r) )t(C> . NAKE (PRINT) .............. ` " W--------: -- i ABDOO185572 A-17 TRArnro ABD00185573 -loflffi CR subject OP course CR cliss EPA record A-17 A *-J >7tifl l/ct^ <CtZJ- gnATE 2- .3/ " 7 7 INSTRUCTOR (S) xc,OCATICN /^-ty-vv-v MUKBSR 0? HOURS DESCRIBE WHAT HAPPENED (i'ajor points covered, what was demonstrated, what was practiced, what training aids were used, etc,) Attach separate sx^rzf^n lAS-d U- y^< <cf &_5 ff 0^-<A <^y\ ^ fA.*TJ^Z SIGNATURE TRAINEES dept. CLOCK NO, NAME (PRINT) DEPT. CLOCK NO. Vw*? /4><*0 {'./rslddtos rPzTzImSZz- !rv vL 7dz i $9f V<*~ ?jrj -( i"*? /.( /An 3\ P^Z~\-r ~ P$z724%L^ /' // 4- 22zl CaAM^UI C- (j^vO^Vl^>?/Arr7 ,221 ^ * /Pr3 ,** ... | a JrTK. HAKE (PRINT) # ABDOO185574 A-18 :ABD00185575 *' * A-?8 ' ' ' ft tra IK it: o r,-r:-vp i::r, attendance _Rr.conn nav.e cn s'JDcrccr gk ccc:^-* cn cuw _ Idate ^ 3-/~ instructors) vJt^5ctUq/u>un*. ftaw ^ LOCATION /istffti *fi*j >fFt lITiKHEn o? H0otJHS ^i>i i >0 DESCRIBE VAiAT; .J?fA'KD (Vn Jor points covered, whot v;os demonstrated, what v;as practiced, whot training aids v/ero U3od, otc.) Attach separate sheet if nc.coaoary, -*-. i , . I << L -- ..-- - -- - Vi- - * - . ---------- - 3 -- -- kf?' <4___C^uj___jQ- %As1T.. ___ d*:,hpCii\^C,- j/:A D _ />- ______ t! /testertk_ j+ _____ ______________________ ________________________________________ SIOKATURE tr) TRAINEES DEPT. CLOCK NO. NAME (PRINT) l "l /_l DEPT. CLOCK NO. /jLh*i/ iUo, Xy kl jU*-*sYisr Aitr > , .Sfo , ^ sate / 'X f ~tTo TF. V /.-j, , c5 ih^yftpS // n /f/6 M^LL NA KETPRIKT) -....... ......... " \ lf - ( j f 1 ---- ABDOO185576 ABDOO185577 A-19 fc. Interoffice Communication To : Vinyl Shift Supervisors From Dote : J. E. Barton : April 10, 1979 Subject : EPA COMPLIANCE (REVISED) The following items need to be done to assure EPA compliance reguarding VCM emissions. 1. The date must be stamped on the Honeywell recorder charts each morning at 7:00 a.m. When the Honeywell charts are replaced the number of the Honeywell unit is to be written on the bottom of the chart. All used charts are to be turned into me. 2. All recovered VCM receivers are not to be filled above 80%. 3. The high pressure alarms on the blowdown tank in each unit will be reset to 40 psig. 4. The Emergency Kill Procedure has been revised as follows: Emergency Shutdown * The following parameters are to be the maximum limits on a runaway reaction. The reaction should be killed with AMS if either one of the parameters is exceeded. Resin Maximum Temperature Maximum Pressure 5385, 5425, 5465 142F 145 PSIG 5305 162F 175 PSIG A runaway reaction immediately after charge and heat-up indicates that the reactor condenser may be plugged, and that the reaction must be killed. If AMS will not kill the reaction, use the nitric oxide (N,0.) short stop system. CAUTION: N.O. is a highXy poisonous orange-colored gas. A Scott Air Pack or a "Rocket Fuel" cannistcr mask must be worn while killing a reactor with the N.O. short stop system. The runaway reaction must be killed immediately if cither one of the pressure or temperature limits listed above are exceeded. If the reaction is allowed to exceed these limits, it may not be controllable and result in a relief valve or rupture disc discharge to the atmosphere. ABD0Q185578'--- EPA Compliance (Revised) April 10, 1979 Page 2 A-19 5. The emergency nitric oxide kill system for all the reactors has been pressure checked to assure integrity of the systems. These systems will be pressure checked each six months with nitrogen. 6. After every coarse batch produced the reactor condenser will be inspected to determine if it is plugged. If the condenser is found to be plugged, it will be cleaned prior to charging the next batch. If the condenser is not plugged, charge the next batch back with 1/2 gallon less catalyst. If this batch runs normal return to the original catalyst loading. 7. Copies of the procedures for the Old Unit, New Unit, and Dryers will be placed on the table between the Lead Operators* desks in the control room. There will also be copies in the Shift Supervisor's office and Operations Supervisor's office for your reference. Please conduct a formal review with your people on the seven items above and the attached Work Practice Controls for the OSHA VCM Standard. Write the review meeting up on the safety meeting form and return it to me. I would like to have all the meetings completed by 4/25/79. & c' J. E. Barton cjt Attachment c: CLM, ELK, RAF, Shift Supervisors (5) * & ABDOO185579 A-20 ABD901*85580 U_._ -- .. 1 w< A-20 & TRAININC MEETING ATTENDANCE RECORD r^-rs DATE `LfSJECT Or COURSE OR CLVSS 1"7- 9- *> INSTRUCTOR(S) LOCATION^ /s^n- i^v NUMBER OF HOURS DESCRIBE KHAT HAPPENED (Major points covered, what was dcmonstarted, what was prac* ticed, what training aids were used, etc.) Attach separate sheet if necessary.. J.^Lf U. /y ^iSdJ . r^ -------- ^ 7 DEPT. CLOCK NO. S'*/ iff . SIGNATURE /O U-jTe. TRAINEES NAME (PRINT) Q~r-n^<=> "DEPT * CLuCk NO. NAME (PRINT) ' T *. sU-H** ! ' __J ' 1 i -JfJ -j. \* * ", | - ABD00185581 A-21 ABDOO185582 .. . -- -j m(........ tp___ LJU.........Li .cttidLZi. ____ 'i-P.____ 6u<u^ yy)-jL^!t.r- A-21 ..y/w/y * ik-jJl*. ._ ,9^U^J_jk.... <2TMI____X- .*.-r. V, anrfci X / XtfAin 1NG MEETKBPtwrfg^ANCE RECORD .. J . J&ATOPIC ___________ _ DATE: A-2* 7 V*It* A UOfifEf TON: 7~7T NUMBER OF HOURS: ,J2- oim;INE OF PRESENTATION (Major points, demonstrations, what was practiced, slide/tape, film, etc.). Attach separate sheet f necessary. Acu^ if ^suJsL*_ <//f?) 6 /?z j sf\jQ_ W ' IT" ! I7 .^ : t7 % EMPLOYEE SUGGESTIONS AND PLANNED CORRECT ACTION: ~ &v* 7" T/ TRAINEES Instructor/Supervisor EPT. -wl 1/' CLOCK NO. NAME (Print) DEPT. IUI-. fUfcs s---- ^ o g 3C TV uGlfrt Sp/t-As'/J V // t\ It nx 5 (3"? ^Xr-^la-o ' /7^f ,/9- O-^V ") 3c>75 ) ill }&u)/^Pt/\ / ! CLOCK NO. i NAME (Print) # i. ABDOO185584 A-23 DATE TS/oZ /f*f 1 / '/ ' ABD00fr8^S85- IMSTRUCTC;? (S) A-23 LOCATION //T*J6r 7 iiui,:bkr o? hours A //sv/r- ^SCFIIBE V.'ilAT IiA??ENED (i'ajor point.*; covered, what was derr.ons tra ted, what v/as practiced, what training aide were used, etc,) Attach separate sheet if j^cccaaary. >*' - P r---:5^---- -- " 7,Ay^ - " ....................... ........................... ...................... ...............-.V; 77^ 7y------------------------------------------------------------------------------------ ------------------------------------------------------------ <^s',s <r>c/?ry/ _ 1'" " i - Y.S'-rt-'s__ ^ i r,iim i i.i .. mu.^ , Cg) rfJs,,y/L s'vcsuJ '^trrX^ DEPT. CLCC xv NO. ?2 0 iia;.;e (?.-ukt) l ry/.fV SIGNATURE <77-7-7^1- - ^ ^uSassS, 7 TRAINEES iP~t*i~`i^-71* . C mCo 4b NO. HA HE (PRIM1) /f - - Jf-- --/u-- '<~s dCls . ' ___ v . 4 _ 1 1 . * -- # 1................ .................. ABDOO185586 A-24  '........... '2BDt)<JT8S587 A-24 A Interoffice Communication To From Vinyl Shift Supervisors C. R. Miller Date October 25, 1979 Subject EMERGENCY- SHUTDOWN PROCEDURES In the event of a runaway reaction the reactor will be killed with the addition of a minimum of 5 gallons AMS. A runaway reaction is defined as a 10F increase or a 20 psig increase in 5385, 5425, 5465 resins or any temperature or pressure increase in 5305. The following parameters are to be the maximum limits on a runaway reaction. The reaction should be immediately killed with NO if either one of the parameters is exceeded. Resin Maximum Temperature Maximum Pressure 5385, 5425, 5465 5305 142F 162F 145 psig 165 psig If the reaction is allowed to exceed these limits, it may not be controllable and result in a relief valve or rupture disc discharge to the atmosphere. CAUTION: NO is a highly poisonous orange-colored gas. A Scott Air Pack must be worn while killing a reactor with the NO short stop system. EMERGENCY SHUTDOWN DUE TO POWER FAILURE During the event of a power failure the reactors must be killed with NO. The sequence of which reaction to be killed is as follows: 1. All 5305 reactors * 2. Remaining reactors - the reactor in polymerization cycle the longest will be killed first. In all cases of emergency kill the pressure rise in the reaction should continue to be monitored. If the pressure continues to rise, the following steps are to be taken: 1. Equalize the reactor with any other empty or killed reactor of the same type product. 2. If the pressure still continues to rise, vent through the main condenser valve to the recovery system and the recovered VCM receiver. - ' ''T - - - '~TbDooY85$88 A- 2k Emergency Shutdown Procedures October 25, 1979 Page 2 3. If this will not relieve the pressure buildup, then equalize the reactor with a reactor of different type resin. 4. When 1, 2, and 3 alone fail to relieve the reactor pressure, then manually vent at 180 psig as often as needed to maintain control. Note: Step (4) is to be the last resort. Under the new EPA law, any venting must be reported and could result in a fine. K. C. R. Miller Operations Superintendent cjt c: CLM, RAF, JEB, MPB ABDOO185589 A-25 '\h + ' I ........... ABD00ia5.59(X... A-25 A Interoffice Communication to : Vinyl Shift Supervisors p^om : J. E. Barton Oate ; October 30, 1979 Subject ; EPA COMPLIANCE (UPDATE) The following items are needed to assure EPA compliance regarding VCM emissions. 1. The date must be stamped on the Honeywell recorded charts each morning at 7:00 a.m. When the Honeywell charts are replaced the number of the Honeywell unit is to be written on the bottom of the chart. All used charts are to be turned in to me. 2. All VCM receivers are not to be filled above 80%. 3. The high pressure alarms on the blowdown tank in each unit are set at 30 psig. 4. The Emergency Kill Procedure: Runaway Reaction In the event of a runaway reaction the reactor will be killed with the addition of a minimum of 5 gallons AMS. A runaway reaction is defined as a 10F increase or a 20 psig increase in 5385, 5425, 5465 resin or any temperature or pressure increase in 5305. The following parameters are to be the maximum limits on a runaway reaction. The reaction should be immediately killed with NO if either one of the parameters is exceeded. Resin Maximum Temperature Maximum Pressure 5385, 5425, 5465 5305 142F 162F 145 psig 165 psig If the reaction is allowed to exceed these limits, it may not be con trollable and result in a relief valve or rupture disc discharge to the atmosphere. CAUTION: NO is a highly poisonous orange-colored gas. A Scott Air Pack must be worn while killing a reactor with the NO short stop system. ABD00185591 A-25 EPA Compliance (Update) October 30, 1979 Page 2 4. The Emergency Kill Procedure: - (continued) Power Failure During the event of a power failure the reactors must be killed with NO. The sequence of which reaction to be killed is as follows: A. All 5305 reactors B. Remaining reactors - the reactor in polymerization cycle the longest will be killed first. In all cases of emergency kill the pressure rise in the reaction should continue to be monitored. If the pressure continues to rise, the follow ing steps are to be taken: A. Equalize the reactor with any other empty or killed reactor of the same type product. B. If the pressure still continues to rise, vent through the main condenser valve to the recovery system and the recovered VCM receiver. C. If this will not relieve the pressure buildup, then equalize the reactor with a reactor of different type resin. D. The reactor pressure buildup may become sufficient to cause opening of the reactor relief valve system. It is possible that the reactor continue to increase despite the relief valve discharge. If this occurs, the manual vent should be opened as often as needed to prevent failure of the double disc relief assembly. .5. The emergency nitric oxide kill system will be pressure checked each six months with nitrogen to assure integrity. 6. After every coarse batch produced the reactor condenser will be inspected to determine if it is plugged. If the condenser is found to be plugged, it will be cleaned prior to charging the next batch. 7. Copies of the procedures for the Old Unit, New Unit, and Dryers have been placed on the table between the Lead Operators' desks in the control room. There is also a copy in the Shift Supervisor's office and Operations Supervisor's office for your reference. Please conduct a formal review with your people on the seven items above. Write the review meeting up on the safety meeting form and return it to me. ive all meetings completed by 11/16/79. c: CLM, CRM, RAF, Shift Supervisors (5) ABDOO185592 ABD00185593 A-26 & :Ta:.:e cr s-jSJMc? c// f DATE A' -jfy - // LOCATION A;-A/ U 1.i i::r? r* r ' "* instructors) V: ' /'J reoorh / ?>r.: ) NUI3SR 07 HOURS DESCRI7E Y.T:AT 7?r-NED (I'.ojor points covered, v/hot v:nn demonstrated, r;hot v;ns practiced, v.ho t training aids v/cro U3od, etc.) Attach sepornte sheet if ne.cesaary. " ---- 1t *' - L)--. ?'yi, i ;. - ' b ' . ' t HjTT '? r / ' ! - i /? /PC f r '4~/^. A; V7^,_. S?r,i7.?s-S. v t, /*; /*t-f /. r~, y s__/ /% . Tfig ' - .:,- ^ S 5 fv X/^S^ 5 r+r>P'}\ //-.' /- /V < ,.,/' / ^ ^ /^/ ; > . *v iL- A ^/ / fptJs.CJH --. . * L-- r .^v'7.t~ / . cr /* `~rhi. .'J~a,-7Pi, 7<y %i-;CO: SIGNATURE / TRAINEES DEPT. CLOCK NO. It'AJ.!E (PRINT) l/tn'VL .'/ -tW\. ;/,/ yy ,&?<? J&3' C /.. *n"9! rjy~~ * /zn /So 0 Jf<>3 Tfada fotfo .yy 2 12J /V. S^/SpA. A x\ . - \ T v/ DEPT. * C iyCCX KO. -- v r------------------------- NAKE (PRINT) . _ \ f---------- i ----- *- / ABDOO185594 A-27 TOPIC: SAFETY /TRAINING ME^fif^gt^NDANCE RECORD __ ___________________ A-27 A DATE: // / f/7? RATION: NUMBER OF HOURS: OUTLINE OF PRESENTATION (Major points, demonstrations, what was practiced, -* ` slide/tape, film, etc.)* Attach separate sheet If necessary. l/l^^ ./-y-Crf) jfec. yg2&. <zv~t l' A -A gX^g-^- EMPLOYEE SUGGESTIONS AND PLANNED CORRECTIVE ACTION: -^V'kr && . X* >Al jA/Usx i^/ *ArJL^ DEPT. /( 7 CLOCK NO. 7A 122 522. NAME. (Print) 'CostA**' <>. (Z', 7 DEPT.. CLOCK NO. NAME (Print) ABDOO185596 A-28 SAF-XY/TRAIKIKG >2SBDSQ1 3gfrfKDAI''CE RECORD topic: fy# ftTvpp/fKCjr U)CATION: figrfUA (^rpsrrf^ NUMBER OF-HOURS: A-28 A de= uiA>nj ^RjTLINE OF PRESENTATION (Major points, demonstrations, what was practiced, , slide/tape, film, etc.) - Attach-separate sheet if necessary. 47<//frT ____cuJ A- V- _______________________________________________________ __________________________ EMPLOYEE SUGGESTIONS AND PLANNED CORRECTIVE AGTION: TRAINEES DEPT. CLOCK NO. * NAME (Print) Srrmsjr' p* V!Pi/ .TyQcS,`L. sm. C/O-t / ';ifr*rs**p* ' / / /*rr",/n "CLOCK ' DEPT... NO. NAME (Print) "W .1 / i# 1 1 1 i i !` i1 1 -! 11 1 1 1 ! 1 i 1 i ii ABDOO185598 LOCATION: >UbiE -AiMontoW'' QiuTJ Ouj J___ Cg-c/ ue/_ - ocx*f/ *7J DATE: // /d? Ms ObUt^bI /f'ijd. NUMBER OF HOURS: slide/tape, film, etc.). Attach separate sheet if necessary. A GCT *sTt373_ - dLJj '.D +6Uf- o,.a- tJLeu^/L. l^l*J&CL Je+Q. ofi_. ljCA? Lho-t^ -t&r-., nJt 0K. 0*\ EPT. CLOCK u NO. t s>4<l. TRAINEES /*U-. % NAME (Print) DEPT.. ^Instructor/ Supervisor rcrueir NO. NAME (Print) [/ itJ\jL 23o ^pAfObJ I If -Crl**. 'Xt.AKZ P/>7*fa/U I 2/77 * ^~>V> /)fT> e=U J(Y1 1 - # ---- If <303l 1 4^4^ If U/f 1 # 161/ /. h '?7f 1 i/ nc,j Y). LdfU oj I * H % ABDOO185600 A-30 TOPIC: SAFETY/TRAINING MEET^BfiP^lfilbANCE RECORD QW A-30 DATE: // / 7^* ICATION: _______________ NUMBER OF HOURS: ;-- ^RlINE OF PRESENTATION (Major points,. demonstrations, what was practiced, slide/tape, film, etc.). Attach separate sheet if necessary. ^g^Ly^tg^lv1 ____________________ /9pn*d***4____KS /4y/ deSi*d '~/C &^ ^ /t?S . ^ EMPLOYEE SUGGESTIONS AND PLANNED CORRECTIVE ACTION: > '2^ 'fity* 4ht//6^ ^ i<Ps^fyy ,_________________________ TRAINEES Ajarf OX /f=2* Instructor'/ SSuuppervisor 2^/" DEPT. fyd f / * # *1 /( n 1 * -' CLOCK NO. /K? - iao - /<?%> NAME (Print) te<* (2A-/</5 L,Qf/>' ^riVy <T^n 7? XJ/l. . * DEPT.. "CLOCK i NO. NAME (Print) wA ABDOO185602 A-31 * ABDOO18560-3- - l A-31 ft Interoffice Communication To : Distribution From : M. P. Blackwell Date : March 4, 1981 Subject : 5305 REACTION RUNAWAY LIMITS The Old Unit PVC Reactors and D-700 PVC Reactors operating manuals have been revised to reflect the runaway reaction limits on 5305 resin made with the chain transfer agent. The manuals have been revised to read as follows: In the event of a runaway reaction the reactor will be killed with the addition of a minimum of 5 gallons AMS. A runaway reaction is defined as a 10F increase or a 20 psig increase in 5305, 5385, 5425, or 5^65 resins. The following parameters are to be the maximum limits on a runaway reaction. The reaction should be immediately killed with NO if either one of the parameters is eixceeded. Resin Maximum Temperature Maximum Pressure 5385, 5425, 5465 5305 142F 155F 145 psig 155 psig The setpoints for the reactor high pressure alarms (PAH-720, 721, 722 and 723) were also changed in the D-700 PVC reactors operating manual to show the current setting of 140 psig. The high temperature alarms (TAH-706, 707, 708, and 709) currently come on at approximately 160F, as shown in the operating manual. Operations Engineer cjt Distribution: CLM, CRM, PEM, JE8, RAF, Vinyl Shift Supervisors (5) ABDOO185604 A-32 AisDuO 185605 4^~ A-32 LOCATION: /a<xP-~ NUMBER OF HOURS: )UAne OF PRESENTATION (Major points, demonstrations, what was practiced, ^ clide/tape, film, etc.). Attach separate sheet if necessary. /Y^^cC? S f , (/ 7:/,7 if A/., S --'J? ^ ^-------------------------------------------- ---------------------- .----------- --r " y-> ; -^-v . /- S-*'!** <r-77!C\ s ' '7* *-j- -^7 S'- . s+ <r *7. a/ 7./ ^^ (/ ' .^l 7-*- -7* MPLOYEE SUGGESTIONS AND PLANNED CORRECTIVE ACTION: .-v y . . Instructor/Supervisor TRAINEES PT. CLOCK NO. NAME (Print) '\Mi nk\" /f7) t~l floaO /72c; t C- II97) <?<? a 1 ,//N V A/ U// t 0 *? "V. if Jfl y fCCOCK" DEPT. ! NO. NAME (Print) -' 1 -m * ABDOO185606 A-33 : l- f\, TOPIC Nation ; ABDOO185607 SAFETY/TRAINING MEETING ATTENDANCE RECORD C-^Lrt _______________________ NUMBER OF HOURS: A-3> A tDATE: "7 / //7 / OUTLINE OF PRESENTATION (Major points, demonstrations, what was practiced, slide/tape, film, etc.)- Attach separate sheet if necessary. U ._:i ^ 7a /jt t J, ^tOS/ii-r . f.^<~ fr-3-C. //-<- // /tLV /t, '-y{ ^-V/7 EMPLOYEE SUGGESTIONS AND PLANNED CORRECTIVE ACTION 7 /ti- _____________________________________________________ TRAINEES --y Instructor/Supervisor DEPT. CLOCK NO. NAME. (Print) DEPT,. CLock NO. NAME (Print) 7^V h fry 9 3// Ho jlau<r^^ *7 /fait ( <?^fc n?i G/lt\L/V (j^P-r^Myr\ \C<s 3 ,72./ ' * - -- ...**. * * .- ABDOO185608 A-34 ABD00185609 SAFETY/TRAINING MEETING ATTENDANCE RECORD A-34 TOPIC: DATE: ^t? Iff/ TOJ(CATION: NUMBER OF HOURS: OUTLINE OF PRESENTATION (Major points, demonstrations, what was practiced, slide/tape, film, etc.)* Attach separate sheet if necessary. *7 EMPLOYEE SUGGESTIONS AND PLANNED CORRECTIVE ACTION: TRAINEES Ins truetor/Supervisor CLOCK DEPT. NO. U/juV/~' (\ ui > (t 13 0 n ifac9 ft NAME. (Print) A A\ r - f20~P<L4+</<> 1 n-A. v^-oV\ ^^\sv.Vv, rT _/&-&<re4L _ k7*L rfrh.h^ DEPT.. . --- - __ . CLOCK NO. - NAME (Print) i-------------- ABD00185610 A-35 p n t ~ /$-* - ABDOO185611 & pLft - 7-sj n c^% X|^v~^j&4vw rJUst. . (IX Z^. t? %** *, yS ^f-^4 v?}, YVLjUvi^J ft / $*-d Uv^JjO;?Cjy^S ^ OC A-*- Oi1*** ,4-**/ L^v^a. <J ti'- cM fl-i#- c&r4 iyf(t ]30Q-~Z2D0. 6uW V^/yf {J^^l ^Lv O^ / 7Ji*5 &0& ^Urtn. o^-ft {^ftftny o*~ SSQ$ -- J'/S^/7/ ~a^tAnJ^y ft03 4*4oft C*JLs- iK- 15^4^<Jkel t).Q. Jn45fc*- 1 ^i*a/^hA/imaa._f3^-y ijjftb a*~ Cfftjkfrf ^*ft~ JL~Mt 4- r40* 1 2) ^oo ^7 -t^' ^eArtrJL.^CLGs du.L^L. tfi^.}>T^C0.. ck **.__. (Ljb'5^0.. .$85 jio^ o% ^ Hp**^ -t-- _ .$36$- 3^5// UjO+~ 0,?^ L- AttO&uJ. ^`Sfv&L't' <*: r// jvJI&s ABD00185612 A-36 4 June 11, 1984 ABD00185613 A-36 Conoco Chemicals Company Conoco Inc. P. 0. Box 91. New Highway 25 Aberdeen, Mississippi 39730 (601) 369*9111 Mr. Jerry B. Banks, P.E. Mississippi Department of Natural Resources Bureau of Pollution Control P. 0. Box 10385 Jackson, MS 39205 Dear Mr. Banks: This letter will inform you that Conoco Chemicals Company will remove all nitric oxide emergency kill equipment on all polyvinyl chloride (PVC) reactors at the Aberdeen, MS facility. The reasons for the removal of this equipment are: 1) installation and operating experience of a proven emergency kill system that uses alpha methyl styrene (AMS) as a kill agent and 2) concern for the health and safety of our employees as nitric oxide is an extremely toxic gas. Initially the plant's nitric oxide emergency kill system was installed to stop the polymerization reaction in a PVC reactor during an emergency in order to reduce the possibility of an uncontrolled pressure buildup in a reactor and subsequent relief valve discharge of VCM. However, since these original installations, the plant has installed a superior emer gency kill system that uses AMS as a kill agent. The emergency AMS kill system can be activated either remotely from the control panel or manually' in the field, even during a power failure. A description of this system is attached. This type system was tested extensively by Conoco R & D and then installed in Conoco's Oklahoma City PVC plant in early 1980. The Oklahoma City PVC Plant does not have a nitric oxide emergency kill system because of the reliability of the emergency AMS kill system and concerns over the safety of nitric oxide. The Oklahoma City facility has not had an emergency relief valve discharge of VCM to the atmosphere from a runaway PVC reactor since the emergency AMS kill system was installed. The Aberdeen Plant completed installation of the emergency AMS kill system in mid' 1982. Since this installation the Aberdeen plant has successfully used the emergency AMS kill system and has not had occasion to use the nitric oxide system. Our experience has shown the emergency AMS kill system to be effective in stopping the polymerization reaction in almost all types of emergency situations. With the operating experience that we have on the emergency AMS kill system and concern for the health and safety of our employees, the appro priate action is to remove the emergency nitric oxide kill system. Removal of this system will begin io late June. ABD00185614 A-36 Mr. Jerry B. Banks, P. E. June 11, 1984 Page 2 Since some of the information contained in this communication discusses certain aspects of our proprietary technology, the letter and attachments have been claimed confidential. We trust that the Bureau of Pollution Control will protect this information as confidential and will not divulge it to any other party. If you have any questions, please call me at (601) 369-8111, extension 2331. Veldon E. Messick Senior Process Engineer bis ABD00185615 A-36 * EMERGENCY AMS KILL SYSTEM DESCRIPTION CCif!DEi' The emergency AMS kill system consists of a pressurized pot filled with AMS for each reactor with piping and valves to inject the AMS into the reactor. The pressurized pot is maintained at 300 PSIG with bottled nitrogen. Piping runs from the bottom of the AMS kill pot to the top of the reactors. AMS can be injected into the reactor by either of two noz zles. One nozzle has remote operated valves that can be operated from the vinyl control room panel. The other nozzle has manual valves that can be operated manually from the platform at the top of the reactor. Both nozzles inject the AMS into the reactor vapor space. Bottled nitro gen is used to pressurize the injection pot. The pressure in the injection pot and in the nitrogen bottle is checked before each reactor charge. If the pressure in either the bottle or the pot is low, the pro blems must be corrected before the reactor is charged. The remote operated valves are also operated with bottled nitrogen. This not only assures that these valves can be activated during a power failure, but also eliminates possible freezing problems that might occur with instrument air. The pressure in this nitrogen bottle is also checked before each charge to insure enough pressure is available to operate the valves. If the pressure in the nitrogen cylinder is too low, the cylin der must be changed before the reactor is charged. The remote operated valve switches also are connected to the plant's emergency power to insure their operability during a power failure. Each AMS injection pot is equipped with a local level gauge to monitor the amount of AMS available for stopping polymerization. This level is checked before each charge. Each pot also has a low level alarm that will sound in the vinyl control room and light a beacon on top of the reactor if the level in the pot is below a certain point. This level alarm system serves several functions. If the vinyl panel alarm is activated before charge, AMS must be added to the pot before the reactor can be charged. During AMS injection, the low level switch will close the automatic valves. If AMS is injected into the reactor with the manual valves, the beacon on the reactor will alert the operator to close the valves so that nitrogen will not be injected into the reactor. In either the manual or automatic AMS addition, the level alarms are evidence that AMS has actually been injected into the reactor. There are also several other items that insure the operability of the emergency AMS kill system in almost any conceivable situation. 1) Each injection pot is equipped with a low pressure alarm that is activated when the pressure in the pot is below 250 PSIG. If the alarm should sound, the low pressure problem must be immediately corrected. 2) There is also a low pressure alarm on the nitrogen supply to the automatic valve actuators. This alarm will sound if the pressure in the cylinder is below 600 PSIG and the cylinder must then be changed. 3) All the AMS ABD00185616 A-36 EMERGENCY AMS KILL SYSTEM DESCRIPTION kill pots in each reactor module are connected with a flexible hose in such a manner as to allow AMS to be injected manually to any reactor from any injection pot. For example, AMS can be injected into new module reactor D-74I.with AMS from the injection pots for reactors D-742, D-743, D-744, or D-745. 4) The AMS injection nozzles on each reactor are cleaned out weekly. This frequency is often enough to insure that AMS be added to the reactor when required. 5) In addition to the checks made by the operator before each reactor batch, an independent audit of the emergency AMS kill system is conducted weekly by the Engineering Department. Among the items checked weekly are AMS pot pressure, nitrogen bottle pressure, AMS level, and if the proper valves are open. ABD00185617 ABD00185618 MISSISSIPPI DEPARTMENT OF NATURAL RESOURCES Bureau of Pollution Control P. O. Box 10385 Jackson. Mississippi 39209 (601)961-5171 July 3, 1984 ft Mr* Velden 5. Messick Senior Process Engineer Conoco Chemicals Company P. 0. Box 91 Aberdeen, Mississippi 39730 Dear Mr. Messick: Re: Nitric Oxide Emergency Kill System The Bureau concurs with Conoco's decision to remove the nitric oxide emergency kill system on the polyvinyl chloride (PVC) reactors at the plant since the company has effectively operated the AMS kill system on the PVC reactors. If you have any questions, please advise. Yours truly, 1 Jerry B. Banks, P. E., Coordinator 7lorth Air Emissions Section JBB:cm cc: Mr. James T. Wilburn Chief, EPA ABD00185619 A-38 Ncvrm * # co ABDOO185621 ABDOO185622 A-39 Aou6j3ui3 >- zz > >- >- >* > 9- >- > >* >- >* > >- > iiO z zz z z z Z z z z z z z z z z z >* Y Y(l) H!S 9suiy/ue9[3 >- z z z z 9- > z z z > > z z z > z ./"S z z z >* Z >- z z 9- > >* z z z >- z asuiy/diunQ >- z z > z z z z z z 9- >- z z z >- z djJis '*S /AjaAOOsy 9- z z z z z z > z z Z z >- z >* z z N N Aioj z z z z z z z z z z Z z 9> z z z >* NN s6jeq3 9- >- JM z z >* z z >- z Z z 9- z >- z z uojienoeA^ z z z z z z z z z z Z z Z 9- 9- z z 759 712B 711 jsqujnq 3A{eA OQ sr** sr- 760 755 Irn r* 762 716 713 m r- 714 VCM Recovery 752 Rinse Supply 750 Rinse/Chem Wash SIte ll VCM Charge 1) Primary 2) Secondary S lurry IXaip 758 Valve/Hode Reactor Charge 710 In e rt Vent Atmospheric Vent -j ff 3 a u Ucjl 5 u a .Q Sewer Drain Steam S trip C olloid Charge Chren Wash Supply u 6 U 1l ni ABDOO185623 Appendix B ABDOO185624 APPENDIX B ITEM NO. B-l B-2 B-3 B-4 B-5 B-6 B-7 B-8 B-9 B-10 B-ll B-12 B-13 B-14 TABLE OF CONTENTS DESCRIPTION Letter, R.A. Frohreich (Conoco Inc.) to Tommie A. Gibbs (Environmental Protection Agency), February 19, 1979 Letter, R.A. Frohreich (Conoco Inc.) to Jerry B. Banks, P.E., (Mississippi Department of Natural Resources), April 23, 1982 Letter, Veldon E. Messick (Conoco Inc.) to Jerry B. Banks, P.E. (Mississippi Department of Natural Resources), January 17, 1983 Document, Training Meeting Attendance Record, January 31, 1977 Document, Safety/Training Meeting Attendance Record, March 13, 1980 Document, Safety/Training Meeting Attendance Record, March 13, 1980 Document, Safety/Training Meeting Attendance Record, April 20, 1982 Document, Safety/Training Meeting Attendance Record, April 28, 1982 Document, Safety/Training Meeting Attendance Record, June 21, 1983 Document, Safety/Training Meeting Attendance Record, July 18, 1984 Document, Training Meeting Attendance Record, March 15, 1982 Document, Safety/ Training Meeting Attendance Record, January 17, 1983 Document, Safety/Training Meeting Attendance Record, January 19, 1983 Document, Training Meeting Attendance Record, July 16, 1984 & ABDOO185625 APPENDIX ITEM NO. B-15 B-16 B-17 B-19 B-20 B-21 B-22 B-23 B-24 B-25 B-27 B-28 B-29 (Continued) DESCRIPTION Interoffice Communication, C.R. Snowden to Mechanical Engineers, Maintenance Supervisors, PEM, DJM, VEM, March 7, 1983 IOC, C.R. Snowden to J.V. Uptain, RUPTURE DISC TESTING, August 22, 1983 IOC, C.R. Snowden to J.V. Uptain, RUPTURE DISC TESTING REVISED, December 15, 1983 Letter, John P. Clark III to Veldon E. Messick, STAMPING OF DISK TABS ON S 90 DISKS, February 24, 1983 IOC, M.H. Lewis to R.J. Reusch, PREMATURE FAILURE OF PVC REACTOR RELIEF SYSTEMS, January 18, 1980 IOC, M.H. Lewis to J. Friend and C.L. Miller, SAFETY RELIEF SYSTEMS, February 5, 1980 IOC, J. Kirk Carnahan to Max Lewis, METALLURGICAL EVALUATION OF N1 200 RUPTURE DISC FROM OKLAHOMA CITY PVC PLANT, April 22, 1980 Letter, R.A. Frohreich (Conoco Inc.) to Charles R. Jeter (Environmental Protection Agency), September 29, 1981 IOC, C.R. Miller to PEM, SJV, WFH, 1st and 2nd Level Supervisors and Bulletin Boards. (Vinyl & Maint. Storeroom) RUPTURE DISC REPLACEMENT AND TESTING, April 26, 1982 Document, P. Markey, Operating Instructions, April 28, 1982 IOC, Dave Mahler to Distribution, RUPTURE DISC /RELIEF VALVE PRACTICES MANUAL, September 26, 1983 IOC, Cindy Ziobro to Veldon Messick, RESULTS OF TESTING RUPTURE DISKS AT BS & B-Aberdeen, September 27, 1982 Letter, John P. Clark III to John McCulley, August 23, 1982 MEETING CONCERNING DAMAGE OF S-90 DISKS, September 9, 1982 ABDOO185626 & APPENDIX B (Continued) ITEM NO. DESCRIPTION B-30 IOC, M.P. Blackwell to P.E. Markey, REACTOR PRESSURE CHECK OPERATING PROCEDURE, August 2, 1982 B-31 IOC, M.P. Blackwell to Distribution, PRESSURE CHECK LOGBOOK, November 15, 1982 B-32 IOC, Dave Mahler to W. F.Higginbotham, RUPTURE DISC ORDERS, August 3, 1983 B-33 IOC, V.E. Messick and D.A. Miller to C.R. Snowden, REACTOR RELIEF VALVE BLOWDOWN RING SETTINGS, October 29, 1984 B-34 Document, Processing Engineering Safety/Training Meeting Attendance Record, July 13, 1984 ABDOO185627 B-1 tSL February 19, 1979 (conoc )abdoo185628 6 Conoco Chemical* Continental Oil Company P.O. Box 91. New Highway 25 Aberdeen. Mississippi 39730 B-1 United States Environmental Protection Agency 345 Courtland Street Atlanta, GA 30308 Attn: Mr. Thommie A. Gibbs, Chief Air Engineering Branch Dear Sir: At approximately 7:15 a.m. on February 10, 1979, our plant experienced a vinyl chloride discharge from a relief valve on one of the polyvinyl chloride reactors. Pursuant to the National Emission Standard for Vinyl Chloride (40 CFR, Part 61, Subpart F, paragraph 61.65 a), we'are reporting this to your office. The vessel involved was polymerization reactor D-300. The release occurred thru a 4" x 6" relief valve which had a 4" rupture disc between it and the reactor. The relief valve setting was at 185 PSIG and the rupture disc was rated at 185 PSIG at 200F. The reactor design pressure is 200 PSIG at 200F. The release was due to premature failure of the rupture disc and the opening of the relief valve at less than its rated pressure. The reactor was in the polymerization phase of the cycle and the pressure was 148 PSIG at the time of the release. The cause for the rupture disc relieveing below its rated pressure is likely due to faulty manufacture rather than metal fatigue since the disc had been in service for less than a week. The failure of the rupture disc apparently induced a pressure wave which caused the relief valve to open. The reactor batch was equalized with an empty reactor. Equalization reduced the pressure in the relieving reactoT and the relief valve reseated when the pressure reached 138 P?IG. The duration of the release was five (5) minutes. The amount of the release was calculated from the relief valve design to be 7100 pounds of vinyl chloride. No personnel were exposed to vinyl chloride during the incident. ABDOO185629 2- - B-l The plant will conduct a survey of rupture disc manufacturers and rupture disc types to determine if a better rupture disc is available for this service. If there are any questions on this matter, please contact me at 601-369-8111, Extension 239. Sincerely, R. A. Frohreich jf c: CLM, ELK, SJV Wayne B. Anderson - Mississippi Air and Water Pollution Control Commission ABDOO185630 B-2 ABD00185631 :zzn cal- Conoco Chemicals Company Conoco Inc. P. 0. Box 91, New Highway 25 Aberdeen. Mississippi 39730 (601) 369-8111 3& April 23, 1982 Mr. Jerry B. Banks Mississippi Department of Natural Resources Bureau of Pollution Control P. 0. Box 10385 Jackson, MS 39204 Dear Mr. Banks: At approximately 11:40 P.M. on April 14, 1982, our plant experienced an emergency relief valve discharge. Pursuant to the National Emission Standard for Vinyl Chloride (40 CFR, Part 61, Subpart G, paragraph 61.55 (a)) we are reporting this incident to your office. This release has also been reported to the National Response Center under the Comprehensive Environmental Response Compensation and Liability Act of 1980. The vessel involved was the PVC polymerization reactor D-744. The release discharged through a 6" X 10" relief valve on the reactor condenser which has a 6" rupture disc between it and the reactor condenser. The relief valve setting was 175 psig and the rupture disc was rated to burst at 190 psig at 200F. The cause of the release was premature failure of the rupture disc at 155 psig. The release occurred approximately two hours after polymerization reactor D-744 had been charged, at which time the reactor had attained run tem perature and pressure. At this time the shift supervisor who was walking into the control room heard what sounded like a compressed air discharge coming from the direction of the new reactor module. He stepped inside the control room and asked the panel operator if anything was wrong. The panel operator said nothing was wrong and the shift supervisor stepped back outside and noticed the noise had stopped. The control panel was then checked and a slight reduction in pressure was noted on 744 reactor. The shift supervisor then went to the reactor and found the pressure gauge between the rupture dis*a and the relief valve was showing pressure indi cating the rupture disc had failed. The pressure in the reactor had not exceecj!55 psig during the run. Although the reactor pressure did not exceed the relief vnlve pressure setting, the premature failure of the rupture disc at 155 psig apparently caused a sudden pressure wave.resulting in the momentary opening of the relief valve. This, shock wave effect has been documented by Conoco's Research and Development Department studies and. is not an unlikely event. Upon completion of the reactor batch the relief valve was taken to the maintenance shop and pressure tested. The relief valve opened at 173 psig and then quickly reseated. ABDOO185632 Mr. Jerry B. Banks April 23, 1982 Page 2 The amount of VCM discharged to the atmosphere from the relief valve was estimated to be 165 pounds using a calculational procedure provided by the relief valve manufacturer, Teledyne Farris. A copy of the discharge calculation is attached. The relief valv discharge stack is 61 feet above grade, and no personnel were overexposed to vinyl chloride during the release. The weather conditions at the time of the release according to the plant weather station were as follows: Barometric Pressure Temperature Wind Direction Wind Speed - 29.80 in. Hg 58F East Trace No action was taken at the time of the incident to prevent the discharge as the relief valve reseated immediately after the momentary opening resulting from the premature rupture disc failure. In order to minimize the likelihood of such future discharges the plant will continue the following practices: 1. Use of nickel as the material of construction for rupture discs. 2. Replacement of rupture discs on the reactor every six months. 3. Assembly of the rupture discs in the pretorqued holders in the machine shop. 4. Pressure testing of each assembled rupture disc' assembly in the machine shop prior to installation on the reactors. 5. Periodic training of the maintenance personnel by the rupture disc manufacturer in the proper handling, assembly, and installation of rupture discs. 6. Continue contacts with the rupture disc manufacturer to keep abreast of the development of better rupture discs. In addition, the following new practices have been instigated to further reduce the possibility of premature rupture'disc failures. V X. One rupture disc from each lot of discs shipped from the manufacturer will be randomly selected and burst in the maintenance shop to verify the rated pressure of the lot. A supervisor must observe the assembly of the rupture discs into the pretorqued holders and the shop-testing of the assembly to 90% of its rated burst pressure. A supervisor must observe the installation of the rupture disc assembly on the reactor. -- - Conoco has devoted a considerable amount of time and effort to determine the cause and to prevent premature rupture disc failures in the PVC reactors. The plants, corporate engineering, corporate research and the rupture disc manufacturer-have all worked on the problem. Mr. Jerry B. Banks April 23, 1982 Page 3 ABD00185633 % B-2 A few years ago, stainless steel rupture discs were used on the PVC reactors. Stainless steel rupture discs which had failed pre maturely were examined by Conoco's metallurgical specialists using microscopic analysis and were found po have sustained chloride stress corrosion cracking. Upon this finding the material of construction of the rupture discs was changed to nickel which is not susceptable to chloride stress corrosion cracking. While the change of the rupture disc material from stainless steel to nickel eliminated chloride stress corrosion cracking as a cause of premature rupture disc failures, premature failures of rupture discs due to other causes remained a concern. The rupture disc manufacturer (BS & B) was consulted to determine if they had any suggestions for preventing premature rupture disc failures. They stated improper installation of rupture discs in rupture discs holders was a potential cause'for premature failjjcYes. At that time the rupture disc assemblies at the plant had to be field assembled. While the plant's maintenance department had been trained inproper rupture disc installation procedures, it was believed that a different type rupture disc holder available from BS & B, which could be assembled, in the shop prior to field installation, offered an additional level of safety. These new type holders were then installed on all PVC reactors. In addition to metallurgical and manufacturing defects, mechanical damage to the rupture disc during assembly of the disc in the holder can cause premature failures. The disc manufacturers.' has recommended each disc be tested to 90 percent of its rated burst pressure after assembly in the holder prior to installation on the reactor. A damaged disc should rupture in this test., This testing procedure is followed before installation all rupture discs on the reactors. Plant procedures require reactor rupture discs be changed out after six months of reactor operation. This reduces the possibility of premature failure due to fatigue of the disc. Several years ago the rupture disc manufacturer was asked if a rupture disc system could be developed that, if a premature disc failure occurred, it would fail in such a way as not to effect the downstream relief valve. The manufacturer has worked on this concept but to date such a system is not commercially available. The reporting requirements of the standard pertaining to relief valve discharges arc summarized belcw-for this release: -- Source: Reactor D-744, Reactor Module No. 2 Nature: Discharge through relief system on the reactor D-744 condenser. Cause: Premature failure of the reactor D-744 condenser rupture disc caused the relief valve to pop open momentarily after the rupture disc failed, Mr. Jerry B. Banks April 23, 1982 Page 4 ABDOO185634 B-2 Date: April 14, 1982 Time: 11:40 P.M. Approximate Discharge: 165 lbs. VCM * Method of Determining Discharge: Relief valve discharge calculation. Action Taken To Prevent Release: The relief valve immediately reseated itself. Measures Taken To Minimize the Possibility of Future Discharges: 1. 2. 3. Supervision must observe the assembly and shop testing of the rupture disc assembly to 90% of its rated burst pressure. Supervision must observe the installation of the rupture disc assembly on the reactor. One rupture disc from each lot received from the manufacturer will be burst in the maintenance shop to verify the rated pressure of the lot. If there are any questions concerning this report, please me at (601) 369-8111, extension 2239. Sincerely, tap Attachment bcc: JF, CRM, SJV, PEM, ABDOO185635 B-3 ABD0018563^conocoj >V~3 Conoco Chemical* Company Conoco Inc. P. O. Bo* 91, New Highway 25 Aberdeen. Mississippi 39730 (601) 369-8111 January L7P 1983 CONFIDENTIAL Mr. Jerry B. Banks. P. E. Mississippi Department of Natural Resources Bureau of Pollution Control P. 0. Box 10385 Jackson. MS 39209 Dear Mr. Banks: At approximately 10:10 a.m. on January 8, 1983. our plant experienced an emergency relief valve discharge. Pursuant to the National Emission Standard for vinyl chloride (40 CFR, Part 61. Subpart G, paragraph 61.55 (a)) we are reporting this incident to your office. This release was reported to the National Response Center under the Comprehensive Environmental Response Compensation and Liability Act of 1980 on January 8, 1983. The vessel involved was the PVC polymerization reactor D-744. The vinyl chloride monomer (VCM) release discharged through a 6" x 10" relief valve on the reactor condenser which has a 6" rupture disc between it and the reactor condenser. The relief valve setting was 175 psig and the rupture disc was rated to burst at 185 psig at 200 F. The cause of the release was premature failure of the rupture disc at 142 psig. The release occurred approximately one and one half hours after polymeriza tion reactor D-744 had been charged. Reactor temperature and pressure were both below normal run temperature and pressure. At the time of the release, the shift supervisor was near the control room. He heard a loud noise that sounded like an air line had ruptured and immediately ran toward the noise. When he reached the new reactor module, he could see nothing coming from the reactor relief valve discharge stacks, but the noise continued. Thinking an air line must have ruptured, the shift supervisor and the "A" reactor operator vent to the work platform which is on the top side of the reactors. They could see nothing coming from the D-744 con denser relief valve staek. The shift supervisor climbed onto the condenser platform and felt that the relief valve was warm. He bent over and could then see vapors coming from the relief valve discharge piping. The "A" reactor operator standing below the relief valve saw nothing coming from the relief valve stack. Another operator at ground level saw nothing coming from the relief valve stack. The shift supervisor attempted to radio to the panel operator to equalize reactor D-744 with another reactor. He could not communicate with the panel operator by radio due to the loud noise from the relief valve. He came down from the reactor and went to the control room. Radio contact with the panel operator was established while the shift supervisor was on the way to the control room and the panel operator was Instructed to equalize reactor D-744 with reactor D-745 which was empty at the time. fr Mr. Jerry B. Banks January 17, 1983 Page 2 ABDOO185637 B-3 CONFIDENTIAL During this cime, the panel operator had heard the noise and checked the operating status all the reactors from the control panel. Reactor D-744 had the highest pressure of all the new module reactors at the time and was checked first. The pressure in reactor D-744 was 142 psig and the temperature was 148 F. No signs of decreasing pressure or temperature were observed. When the panel operator received word that the relief valve on reactor D-744 was relieving, he immediately took action to equalize reactor D-744 with reactor D-745. Within about one minute after equalization began, the noise stopped indicating the relief valve had stop ped discharging. The total time the relief valve was relieving was 4 to 5 minutes. Although the reactor pressuredid not exceed the relief valve pressure setting, the premature failure of the rupture disc at L42 psig apparently caused a sudden pressure wave resulting in the opening of the relief valve. This shock wave effect has been documented by Conoco*s Research and Development studies and is not an unlikely event. However, the relief valve apparently was relieving at well below its set point for several minutes. In order to understand this, the relief valve manufacturer was contacted. No immediate explanation could be given. A formal request to investigate the problem will be forwarded to the manufacturer. After the reactor batch was completed, the relief valve was taken to the shop and tested. The relief valve opened at 174 psig and quickly reseated. The amount of the VCM discharged to the atmosphere by the relief valve was estimated to be 1,162 pounds. This amount is calculated by a reactor material balance. The calculations are attached. The relief valve discharge stack is 61 feet above grade, and no personnel were overexposed to vinyl chloride during the release. No high readings were observed on the new reactor module fixed point monitoring system. Weather conditions at the time of the release according to the plant weather station were as follows: Barometric Pressure Temperature Wind Direction Wind Speed Conditions 29.98 in Hg 44 F From East 0 gustlng to 1-2 mph Raining slightly Action taken at the time of the release was to equalize reactor D-744 with reactor D-745. This action caused the relief valve to stop discharging. Also, the plant has a rupture disc Inspection, handling, and installation program designed to incorporate all the Information we have to date on how to reduce the possibility of a premature rupture disc failure. The follow ing control measures were used to protect the subject disc from premature failure: 1- The disc was a BS & B S-90 reverse buckling disc. Conoco and DuPont testing has been conducted on this type disc that shows it to be the best proven disc on the market. 2- The disc was constructed of nickel to reduce corrosion. Mr. Jerry B. Banks January 17, 1983 Page 3 ABDOO185638 3- The disc was in service less Chan 6 months. 4- The disc was assembled in the shop using a pretorqued rupture disc holder. The shop assembly was witnessed by a maintenance supervisor. 5- The disc in the pretorqued holder was pressure tested to 90% of its burst pressure in the shop. This testing was witnessed by a maintenance supervisor. 6- The installation of the disc on the reactor was witnessed by a maintenance supervisor. 7- Three training sessions have been conducted in the past year to train maintenance personnel in proper handling, assembly, and installation of rupture discs. 8- Reactor D-744 was hydrotested to 165 psig seven times to check the integrity of the discs during the time this disc was in service. A hydrotest is performed each time a major flange is unbolted on the reactor. The most recent hydrotest was on December 7, 1982, at which time no problems were encountered with the disc. Each hydrotest was witnessed by supervisory or engineering personnel. 9- One disc from the lot of discs was not burst to verify rated pressure of the lot. This is because this lot of discs was already at the plant when the procedure to check incoming disc lots was instituted. However, the plant has documentation that the manufacturer tested five discs from this lot. All five of these discs burst at the proper conditions. As previously discussed in a letter to you on April 23, 1982, Conoco has devoted a considerable amount of time and effort to determine the cause and to prevent premature rupture disc failures. The rupture disc handling and installation procedures have recently been updated to incorporate all the information that we have to date concerning reducing the possibility of premature rupture disc failures. Input into these procedures was received not only from plant experience, but from the manufacturer, our Oklahoma City PVC plant, Conoco's corporate engineering and from DuPont engineering. The plant will continue to follow these handling and installation proce dures. Conoco has also asked the rupture disc manufacturer to develop a disc sys tem that, if a premature disc failure occurred, it would fail in such a way as not to affect the down stream relief valve. The manufacturer has developed a disc for testing. Plans are to install this type disc at our Oklahoma City PVC Plant for testing. If testing of the disc proves to be satisfactory, funds will be requested to install these type discs. At the present time, these discs are only commercially available in an 8 inch size. ABDOO185639 RELIEF VALVE DISCHARGE CALCULATION REACTOR D-744 10:10 A.M. - JANUARY 8, 1983 B-3 CONFIDENTIAL ft P-744 REACTOR MATERIAL BALANCE Immediately after the release, information was gathered to determine the amount of the release by a reactor material balance. The amount of VCM charged to the- reactor was known to be 6105 gallons. This amount was measured by two separate VCM charge meters. The charge volume is accurate because the process demands that quantities added to the reactor be accurate. Close attention is given to the accuracy of the charge meters. The temperature of the VCM was known to be 48 F as measured earlier the morning of January 8. With this information, a charge of 47,351 pounds was calculated. Below is an accounting of what happened to this VCM charge amount. Also given is an explanation of how each was calculated: 1- AMOUNT OF PVC PRODUCED - 6382 POUNDS During the first 1^ hours of reaction, a calculated 6382 pounds of vinyl chloride were polymerized into poly vinyl chloride. After recovery, the volume of slurry in the reactor was measured. Then during the reactor dump, two samples of the slurry were taken. The slurry samples were taken to the laboratory where the percent solids was measured. Then, by knowing the volume of the slurry, the temperature of the slurry, and the concentration of PVC in the slurry, the amount of PVC produced could be calculated as follows: Volume Of Slurry As Measured By Reactor Outage 10,158 gallons Temperature Of Slurry: 155 F Density of Slurry : 8.18 pounds/gallon % PVC In Slurry By Averaging Two Slurry Samples 7.68 Wt % 10,158 gallons slurry x 8.18 pounds slurry x 0.0768 pounds PVC = 6382 pounds PVC gallon slurry pound slurry 2- AMOUNT OF VCM RECOVERED - 36,772 POUNDS The VCM recovered from reactor D-744 after the relief valve discharge was sent to the west recovered VCM receiver. This receiver was isolated and the levels before and after recovery were measured. During normal recovery operations, a small amount of water is also sent to the recovered VCM receivers. Page 1 of 4 Mr. Jerry B. Banks January 17, 1983 Page 4 ABDOO185640 B-3 The reporting requirements of the standard pertaining to relief valve discharges are summarized below for this release: Source: Reactor D-744, Reactor Module No. 2 Nature: Discharge through relief system on the reactor's condenser Cause: Premature failure of the reactor's condenser rupture disc caused the relief valve to open after the rupture disc failed. Date: January 8, L983 Time: 10:10 a.m. Approximate Discharge: 1,162 pounds VCM Method of Determining Discharge: Reactor material balance Action Taken To Prevent Release: Reactor D-744 was equalized to reactor D-745 which caused relief valve to stop discharging. Measures Taken To Minimize The Possibility Of Future Discharges: The plant will continue its rupture disc Inspection, handling, and installation procedures which incorporate all known items in reducing premature rupture disc failures. If there are any questions concerning this report, please call me at (601) 369-8111, extension 2331. Sincerely, & Veldon E. Messick Senior Process Engineer bis Attachments ABDOO185641 RELIEF VALVE DISCHARGE CALCULATION REACTOR D-744 10:10 A.M. - JANUARY 8, 1983 This amount of water was drained from the receiver and sub tracted from the total recovered volume. The net VCM recovered was 154.6 inches of VCM in the 8' 0" diameter vessel. The pounds of VCM is calculated as follows: 154.6 inches VCM xTT(4.0 ft.)2 x 56.78 pounds 12 in/ft ---------------------- * 36,772 pounds VCM 3- AMOUNT OF VCM VENTED TO REACTOR D-745 - 2426 POUNDS In order to stop the relief valve from discharging, reactor D-744 was vented to reactor D-745. Reactor D-745 was at atmospheric pressure and approximately 100 F before the equalization. After venting to reactor D-745 through the recovery manifold, reactor D-745 was at 52 psig and approximately 100 F. The volume of reactor D-745 is 4487 cubic feet. The gas density in reactor D-745 after the vent is calculated to be 0.6112 pounds per cubic feet. The gas density before the vent is calculated to be 0.0705 pounds per cubic feet. With this information, the VCM vented to reactor D-745 is calculated as follows: (0.6112 - 0.0705) pounds x 4487 ft.3 ft. 3 = 2426 pounds VCM 4- AMOUNT OF VCM VENTED TO RECOVERY SYSTEM THROUGH SMALL VENT FOR ONE MINUTE - 123 POUNDS After the relief valve on reactor D-744 stopped discharging, and before the reaction was terminated with kill agent, the reactor was vented for approximately one minute using the small VCM vent. This method is routinely used by the opera tors to remove inerts from the reactor's condenser. The small vent is a 3/4 inch diameter pipe with approximately 16 feet of equivalent length. The calculatlonal method as outlined in Fluid Mechanics, Addison-Wesley Publishing Company, May 1971, by Noel De Nevers, pp. 286-288 was used. An amount of 123 pounds of VCM vented was calculated. This correlation assumes adiabatic flow with friction as the basis. 5- AMOUNT OF VCM VENTED TO RECOVERY SYSTEM THROUGH LARGE VENT FOR ONE MINUTE - 486 POUNDS After the relief valve on reactor D-744 stopped discharging and immediately after the operator vented to the recovery system with the small vent, the large reactor vent to the recover system was used for approximately one minute. This vent is through the 6 inch recovery line to the recovery system. In this case, the flow is limited by the capacity of the Page 2 of 4 ABDOO185642 RELIEF VALVE DISCHARGE CALCULATION REACTOR D-744 10:10 A.M. ~ JANUARY 8, 1983 CONFIDENTIAL recovery compressors. Two compressors were used and the inlet pressure would have been limited to 40 psig by the main recovery control valve. The capacity of each compressor is 420 cubic feet per minute at suction conditions. The density of the gas entering the compressors at these conditions is 0.579 pounds per cubic foot. The amount of VCM vented is calculated as follows: 420 ft.^ x 2 compressors x 0.579 pounds x 1 minute = 486 pounds minute ft 3 Page 3 of 4 ABDOO185643 SUMMARY OF RELIEF VALVE DISCHARGE CALCULATION REACTOR D-744 10:LO A.M. - JANUARY 8, 1983 AMOUNT OF PVC PRODUCED AMOUNT OF VCMRECOVERED AMOUNT OF VCM VENTED TO REACTORD-745 AMOUNT OF VCM VENTED TO RECOVERY SYSTEM THROUGH SMALL VENT FOR ONE MINUTE AMOUNT OF VCM VENTED TO RECOVERY SYSTEM THROUGH LARGE VENT FOR ONE MINUTE AMOUNT OF RELEASE (BY DIFFERENCE) TOTAL AMOUNT OF VCM CHARGED TO REACTOR D-744 Pounds Of VCM 6,382 36,772 2,426 123 486 1,162 47,351 Page 4 of 4 ABDOO185644 ABD00185645 TWINING MEETING ATTENDANCE RECORD NAME OK SUBJECT OF COURSE OR CLASS S'cJ.+jT / (j* " /-3J-)ATE >->_____________ INSTRUCTOR (S)_____ A.fT/,ir Q iV--A *v LOCATI ON / --------------------- DUMBER OF HOURS ^ 4*- DESCRIBE WHAT HAPPENED (Major points covered, what was dcmonstarted, what was prac ticed, what training aids were used, etc.) Attach separate sheet if necessary. - J?/3 - Z.C f S' 0 '/^ V --S?-.-6? * >/*Q ^.uM A* JJ__ - " it /3 * H- J'f&A? {ftyS AnjP-jgg_____ SJ____ __________ ..____________ '. */ / * // ABDOO185646 B-5 ^ W-fcfivp A3D00185647 SAFETY/TRAINING MEETING ATTENDANCE RECORD \' & TOPIC: *F(JPrOtgg Disc. SAfT/ ^^CATION: ca^a7-</ -r-so^/nf/s/g jQ^r^/n _______________ ' DATE: 3 J NUMBER OF HOURS: ^2 ///?_S &0 OUTLINE OF PRESENTATION (Major points, demonstrations, what was practiced, * slide/tape, film, etc.)* Attach separate sheet if necessary. ~7~*-/A y t.A-rtOA/ /orr //.v/ n <? i/Oft ^ AO /V.< A"a/A. /a/a/t&/a/A SAtr/r 7~</ MAA/n<- AA.OPAA. ^ A/ /I/<,r //< < A A ^ ------------ _ EMPLOYEE SUGGESTIONS AND PLANNED CORRECTIVE ACTION: DEPT. CLOCK NO. TRAINEES ~n>fLj Me.&t/UWA) Instructor/Supervisor NAME (Print) DEPT. "Clock no. NAME (Print) P\UC7 P P pg*1* ^yuvtx t/ock. iy !* -- 1 II---------- ' - . .VA^. * ' 'J f,. -.. ' . iSTiS&i* ' jit1' ABDOO185648 B-6 4 ABDOO185649 SAFETY/TRAINING MEETING ATTENDANCE RECORD B-6 * ;q^;: &S *->3 Zh /> ___________________ DATE: J'l/JI Jer .OCATION: /. I NUMBER OF HOURS: / ____________ )UTLINE OF PRESENTATION (Major points, demonstrations, what was practiced-,' slide/tape, film, etc.). Attach separate sheet if necessary. __ A ^7?___ z/- `f*/*.**-> c 7</' cT MPLOYEE SUGGESTIONS AND PLANNED CORRECTIVE ACTION: TRAINEES Instructor/Supervisor EPT . - .. CLOCK NO. U T? X? J?OJ> '77*/ /S4/~ T-. L. //ss fi. /?/*-& > - .-7-. - A 7^ /y. /JV5 O. ///. jr?z~ 'Jo /.M?* C~ OwV/**?.l>. NAME (Print) S?l***<^*-*"' 4//^ . tno // --. k-f/J* r/+LtJ " aC3L ^ept CLOCK NO. nW< ' ,J /Q*^CC\ 7^/A r-^'-- ? I 1 1 1 1 | 1 -- 1 1 *, NAME (Print) ABDOO185650 B-7 ABDOO185651 SAFETY/TRAINING MEETING ATTENDANCE RECORD e-7 topic: LOCATION: ~S/? DATE: // j*0f T'-- NUMBER OF^OURS: //ocf^ OUTLINE OF PRESENTATION (Major points, demonstrations, what was practiced, slide/tape, film, etc.)* Attach separate sheet if necessary. '3s c3 rteexe+jrvo / *JfCse/nAr/oJ os) H6d rg /MfextY haa/oif 4*Jd /*Jsr*ic . rt(Jf7V4~ &/SC oj/hs Alacs-o a aJ rA~ A#aA& <Js<r op n+e~ s-9o SAfen Pi sc trs /=b do/tJb- rtoco&il. A e&'&J Al^q Mete*ire <W /cu td /s) S'e^s/zce resr- rft/j 4&a,js7- 3o s. EMPLOYEE SUGGESTIONS AND PLANNED CORRECTIVE ACTION: DEPT. hi y/A^ i CLOCK NO. NAME ?rint) 7lPT&-\ -- /'(/cvlr,. . ` ^V= i-La>^v---- DEPT. /r /&3Q S - "ii// $ \ 17 r N1/fr. ---- T7--- /AA > /' *t -t//: /.' r'7 /! /i/I // \\ ,iA,.iAfii<o<p?-i / ! V- '> (1 + / . .. ` ?vX .//- fc :il tr W i- rh-; . T- ' ' 'J 7 / y*s /.U \ At/c'AjLrrto') S'. iZ/tJCtzrfJT- 'o.t- A-;C ~i ' ' '_i--,rA - .-fy.-p t.Vf/ijv- JJ. --'h & *> trs \ f w,r (zC.Vag-t '/s'*... w-/. -c~z. zZ>:?rAM5> .. ^TtA'Tu y>Tf --" -t- y . .-.-o : __ .a-r-.' ^ it-nS -- s-+r/a:,{T~ - A^/ulT' /rA/<C r*J G y->/v .'A, y ^3r^'v y'At Oi:' yn,u; i -.Hk_,wV' h- I v 1 i-^ i'\,.- 1 A'l i ' V'/e-y / /v /V . JJ fZ.. . y s' AA//J.-/ A / Y ' A-TA^nv Wt/c-' ! il 1 NAME (Print) ^ // ' ;7tC ^ ,s71 /., ). -- . /--/^ /' .'<6~s'aJS /l/JZi^-3r' 1 yA/. i vi iCi/3 a -.7-7 0 ^2 '' t..ftj2- y * " /. /) t.. /^ 7 4,0 /' /.*- r?,'? 3(7 1 rZzuce /'n :) -- -------------- dflLl/IAJ tlE&AJ A.r>t4 t-<=A ., /<ytr S'/Asis/ Z~Z- ,(/!{' l-\j n .r' jA/eoure A. SAfA/eiD ------- . ABDOO185652 B-8 ABD00185653 4TOPIC: SAFETY/TRAINING MEETING ATTENDANCE RECORD 0</r Lv B-8 DATE : - * ^ Ration: OUTLINE OF o 4k r PRESENTATION v .'j jL ^ n{jmb>ER OF HOURS: --------------- ----- T (Major points, demonstrations, what was practiced, slide/tape, film, etc.)* Attach separate sheet if necessary. OJl '7? -- y^dn EMPLOYEE SUGGESTIONS AND PLANNED CORRECTIVE ACTION: DEPT. n f (> 11 * CLOCK NO. NAME (Print) >y/7 f/uxzrl7Ty/ 17, O' S* iS+jL/cjz/?. y i.-*> f.. A * .. . 1 - TTOTT DEPT.. . . NO. .. * NAME (Print) m---------- 1 ABDOO185654 ABDOO185655 . SAFETY/TRAINING MEETING ATTENDANCE RECORD B-9 DATE: 6- l^yi >7 NUMBER OF HOURS: z' OUTLINE OF PRESENTATION (Major points, demonstrations, what was practiced, slide/tape, film, etc.)* Attach separate sheet if necessary. \ EMPLOYEE SUGGESTIONS AND PLANNED CORRECTIVE ACTION: Q? n__ 7a__________ C?4w/r __ -- C^^c/c a//jCPssy &: TRAINEES Instruetor/Supervisor DEPT. /ywp^t /'Tr CLOCK NO. t Lit H-tH NAME. (Print) LViJ. 7L/^wkP8^mj{). DEPT., j rffi/wJ fcfter CLock -NO. JNAME (Priyitda / 1 ^ //A/ r7 L# mm/* AifS i n it '-iss n 1 / to-n /* 1 95/ TWrT 'JfcziEt- ii>u, >.;.,vTXszr: /7,<? /yi/\aal*s // CVC jAA/p-*~Ah4. ' J ) 7 7 f^TnV^i ^ * -^vnt'Jyw>4 1 Tn&.nv4 /f IW Kpiw|v> y&fi 7*? fL.: lYJ / - Irr--* ' ts/lr' ^///4pVi 4 yrj. f uTfy ^ y -y/ / ^r. xijfrs/ c* ) v r ' 1uIl&CN t . .Uk^lC Jc - ---- ... .- /TvaLv/ /L Drj> / XbX <S27. AA .*/Cm2Z7AVe*.41 : * ,< TP e&>, l= ------ V- vr.Ti- 9~M" n OplauCuf -- A*urea r )Am pw i r.e.r~ ftota tfflPK) KANO</ TVd r Wf^f I&4-H - i.r? .5a A o ,J as > __________ i ABDOO185656 B-10 \/*..\r *--r. ABD00185657 r..*tef.Lri':'.!- CJ.- COJMSi, OK CUSS ___ IP.ZSjC__M 1 BMO ^ ~T- #4/' ___________ INSTRUCTOR (S).{/LjjZ_2> fc/) g S/p, . J/,l, 'Lu^lATT,]non" ' Asto^KUMBER OF HOOKS vt /^ DESCRIBE hHAT HAPPENED (Major points covered, what was dcmonsiaricd, what was prac ticed, what training aids were used, etc.) Attach separate sheet if necessary. s --3,2- .. .. -<2-5 V-fL, , O/dSL ..... ~t*___ -rZSL... ~lr>\ . ,M<.<0X1* _______________ _ S ] GNATUJtE fNps^ TRAINEES ______ j__ ABDOO185658 B-11 ABDOO185659 B-11 * sc- col-kse ckcuss a/ r2/^sas* Wo date LOCATION' ^i KSTRUCTOR (5) y?y jrJ/ ' i J2-00 aA NU?:3ER OF hours ____________ DESCRIBE V,"-Uj HAPPENED (Major points^covered, what was demonstarted, what was prac ticed,-what training aids were used, etc.) Attach separate ` sheet, if necessary. --------- --i--i^i n <4?---------------------------^ t;<; vt^yy -- _______ * `;*V W '* '.? ^f^Yi^4p^;^:SJCNATURE J2l^Ut vT*- *> r-^TP.AlNFES " AREA CLOCK ::o. i;7 3 .1:3-} 1213 951 NANS ::. S. Moore M. C. Laneford v. L. Phillips .7. rr -y'ni' f 1-- ELECT. TNSTR. CLOCK ' NO. NAME 792 Joe Shackelford L4S1 .- -0 is. cony 1474 K. T. Archer 1524 J. R. Hamilton <5/1 q 521 774 n .ja--Hoi on C. ;/. Holcomb Frank Oianchard 532 1241 E. C. Mize W. E. Browr.inp 1032 R. D. Roberts ..-700 . L. M. Stegall 414 1657 1455 7AT? J. L. Walker J. E. Edwards J. ,v. Lowe -J. 0:--~V il M f 1 f ^ 1 . . -.s - 1488 i 1489 `r. G. E. Carnathan S. D. Brown AREA - J-I -r". w J, ^ zsx nV - ,. P. rs^C/7/uj* CLOCK NO. NAME UTILITY CLOCK TOOL RM - NO. . .W NAME 1186 1005 L. J. Woods F. D. Andrews : -J03-- '... , 357 T. 0. Harden 286 S. L. Kennedy -U_ A1 Oi Riiu ^57 1678 990 1630 C. 6. Worrtyn beevie Rambus L. J. ThreadQill W. F. Harlow BOILER HOUSE 4 > /. .* cCLOCX l:. NO. -1387 . Ii70 NAME .7__fl r,n-- L. B. riunn 1313 C. B. Peden 17 57 Bobby Ward .W4 -- Or A Oliver J92 W. D. Troupe VP. * T-Lflff .. t r-.-4fl0 SUIFTk $CLOCK MEGJi'.f #>' NAME y 67A : H. L. Jackson -hAAL(?A/& sM*Vk& (>1043 J:. &. Hail jii'wr .-i ;C -- CLOCK .MACH NO. NAME 132 J. E. Riagan 1244 B. K. Thompson 3LDG. CLOCK ATTD. NO. NAME L7R3 n. R. Q 218Q- r: l. v.iiiiciKH~~ SUPERVISORS J. L. Horstman M. H. Williams C. E." Davis R. W. Rue F. W. Frantz M. E. Skinner ABDOO185660 B-12 ABDOO185661 'fjjw / G> : TOPIC SAFETY/TRAINING MEETING ATTENDANCE RECORD /9/Jt A^ B-12 DATE: / !/?! Z 7 LOCATION : S'j/-C/y "Zr 1 /f~.t" NUMBER OF HOURS: OUTLINE OF PRESENTATION (Major points, demonstrations, what was practiced, slide/tape, film, etc.). Attach separate sheet if necessary. TRAINEES ---------------------------:---------------- inscructor/Supervisor DEPT. CLOCK CLOCK NO. NAME (Print) DEPT.. . NO. NAME (P-rint) / / <%(. .7 A7</ '' 7 /W // / -- (/ r--^-- ---------- ' //s/ffs/ __://) r, : 2? :/*/ />' *' /- / /" /v/wr / s.r.t --rrrtrr . J /j i'l 1 '7 . -'i ,-r? //v// --------------- MAiHT /) u 11 Ilk* It *W 7il vr*.:+., /0 S3. mrv\u+*i t*7 ft *nz a-z-X . >, , ^7/., 'J? v v____________ riuFF 7. < './! > - ' ' '. V' i k * 7*7 /. ? .. ^ ....., ^ &/?*/ r*/P It r~ // fU7L /'AmA? '''a/ //l 7$ -TfZ./7--------^ yy/Vr^-C - W/.. . Jf 7 7/57 /V/nbJy __________ :-)/4 j 'y* '* <" i. * \ TO . J- /M 3 f > ^ 1 l*li L 1 yzrw >>/ j&pr':rFrj\:1/<L1,1>/ . Wf) .' ? .1- ['A ls!^IaASs v op-<L-----1 v / 'TT>*" ----------- i 3 9 f\-/JW%> C .'it'S* ,*. jlArtMT ^yrs>yjz -. s%zzyj'j:>t.--- ----------- 3 T > !<l~> Mk l*n<; ` AA-.'i tpT ^ JfiJr '/) y '1 j"ia pt ^ j tT (!ao"'>6</ ~ \ r*\'*-M1 --' , i ' /! . -; t-J\ ' ABDOO185662 B-13 ABDOO185663 SAFETY/TRAINING MEETING ATTENDANCE RECORD ^^TOPIC: LOCATION: 7^ &/**. /oL^jd,______ ________________ DATE: f / J^j ^3 S^f> NUMBER OF HOURS: / M/ OUTLINE OF PRESENTATION (Major points, demonstrations, what was practiced, , slide/tape, film, etc.)- Attach separate sheet if necessary. *...* CL ^,^cLJL^u} ^ *^A&________________ ^2___ sCLtzA. *______ EMPLOYEE SUGGESTIONS AND PLANNED CORRECTIVE ACTION: TRAINEES Ins true tor/Supe^i:sor DEPT. "I'H/Uv.t . n // CLOCK NO. ' -V > / ' fw ?r ?/><<1/ NAME. (Print! DEPT.. . //,v//u~Jb^ r.9*^ v'/: ^ CLOCK NO. 'NAME (Print) - - - -- - -- -- -- - -- ........... 1 f '_ ABDOO185664 B-14 ABDOO185665 B-14 ABDOO185666 B-15 ABDOO185667 B-15 Interoffice Communication To Mechanical Engineers, Maintenance Supervisors, PEM, DJM, VEM From C. R. Snowden Date March 7, 1983 Subject h 'Z Five mechanics are now qualified to perform pressure checks on rupture discs. The qualified people are as follows: 1) Goodmin 2) Riggins 3) Thompson 4) Holcomb 5) Blanchard C. R. Snowden rah ABDOO185668 B-16 ABD00185669 Interoffice Communication To : J. V. Uptain From : C. R. Snowden at* : August 22, 1983 Subject : RUPTURE DISC TESTING B-l6 A To clarify the procedure for checking and witnessing the testing and installa tion of rupture discs, the following policies are in effect. Mechanics When the need to change a rupture becomes evident, the guard will be expected to call in mechanics to test and install rupture discs. All mechanics are qualified, to install discs and six are qualified to test them. The six men who are qualified to test the discs are: Riggans Goodwin Thompson Blanchard Holcomb Rea Two men are required to remove and install discs. One of these men will be from the list of six above. Witnesses All supervisors and engineers on mechanical weekend call are qualified witnesses. After mechanics have been called in, the guard should then contact the individual who had weekend duty last for the mechanical department. As an example; `if a witness was required on 8/18/83, then the individual responsible for weekend duty on 8/13 and 8/14 should be contacted. If this person Is not available, the individual scheduled for duty the previous week (8/6 and 8/7) will be called. This will con tinue until a witness is^ontacted. oL C. R. Snowden Mechanical Superintendent bis c: JLH, CED, JAD, CRM, PEM, AHS ABDOO185670 B-17 ABDOO185671 B-17 Interoffice Communication To J. V. Uptain From C. R. Snowden at* Oecember 15, 1983 subject RUPTURE DISC TESTING REVISED To clarify the procedure for checking and witnessing the testing and installation of rupture discs, the following policies are in effect. MECHANICS When the need to change a rupture disc becomes evident, the guard will be expected to call in mechanics to test 8 install rupture discs'. All mechanics are qualified to install discs and nine (9) are qualified to test them. The nine men who are qualified to test the discs are: Riggans Goodwin Thompson Blanchard Holcomb Rea Edwards Frye McAllister Two men are required to remove 8 install discs. One of these men will be from the list of nine above. WITNESSES All supervisors and engineers on mechanical weekend call are qualified witnesses. After mechanics have been called in, the guard should then contact the individual who had weekend duty last for the mechanical department. As an example; if a witness was required on 8/18/83, then the individual responsible for weekend duty on 8/13 and 8/14-should be contacted. If this person is not available, the individual scheduled for duty the previous week (8/6 and 8/7) will be called. This will continue until a witness is contacted. C. R. Snowden /tfs. Mechanical Superintendent lpc cc: JLH, CED, JAD, CRM, PEM, AHS ABDOO185672 B-19 ABDOO185673 B-19 SAFETY SYSTEMS February 24, 1983 Mr. Veldon E. Messick Senior Process Engineer Conoco, Inc. P.O. Box 91 Aberdeen, Mississippi 39730 SUBJECT: STAMPING OF DISK TABS ON S-90 DISKS Dear Veldon: This will confirm our conversation of February 22, 1933 regarding the stamping of a 6 inch, 185 psi, 200F, 0 range, S-90 rupture disk. According to ASMS we must stamp the average of the burst to rate a disk. In this case the average of the burst at temperaturewas 190 psi. This was stamped on the disk tab in the upper section of the disk. We also stamped the disk tab at 135 psi because this is what you requested. What BSSB is guaranteeing you is that the disk will burst at 135 psi plus or minus 5?j. This is according to code. The Burst Certifications,which you have,shew disks bursting at ambient temperature between 130 and 192 psi. The Burst Certification also shows that the elevated temperature breaks were both 190 psi. Normally at this temperature we would expect the burst pressure to decrease approxi mately 3% from the average of the test breaks at ambient. Therefore we would expect the disk to break at about 185 psi at 200F. In this case they did not. Hcv/ever because of the tight scatter of bursts both at ambient and at elevated temperature, and because of our past experience and history on these particular disks, we are certain that the disk will break within plus or minus 5% of 135 psi at 200F. There fore we have rated the disk as you requested inclusive of all tolerances. You also asked about the bite seal on our SRB-7RS heads larger then 14 inches. The bite seal height on a new head is between 4 and 5 thou sandths. With time' this bite seal decreases in height. It is our experience that the bite seal^does not have to be remachined until BS&B SAFETY SYSTEMS. INC. /455 E4ST 46TH STREET P.O. 30X45590 TULSA, OKLAHOMA 741454)990 PHONE 918/022-5950 ABDOO185674 To: Mr. Veldon Messick / Conoco From: John ?. Clark / 33^3 Subject: Stamping oi: disk tabs on S-90 disks pnee 2 B-19 A it is reduced to a height of less Than 2 thousandths. 3etween 2 thou sandths and 5 thousandths there is no need to add additional torque to compensate for the reduced height in the bite seal. Also there is no change in the burst pressure of the disk when the height of the bite seal ranges between 2 and 5 thousandths. I hope this answers your questions. Very truly yours. JPC:psb cc: Tom McQuilkin / AFS, Inc. 3.C. Navel / 3SSB Keith Games / 3SSB ABDOO185675 MANUFACTURER'S TEST REPORT FOP. RUPTURE DISKS AS REQUIRED BY* THE PROVISIONS OF THE ASHE CODE RULES ASME SECTION VIII - 1977 EDITION. DATE: 9-9-81 CUSTOMER: Conoco SUBJECT: Your Purchase Order Number: 011-093311-9-65-B,Rel #24 BS&B S. 0. Number: 81006026 BS&B Lot Number: 81006026-1 BURST TEST CERTIFICATE Gentlemen: This is to certify that inspection and burst tests have been accomplished on the rupture disk(s) as listed below and results are as follows: TYPE: S-90 SIZE: MATERIAL: NO. OF PIECES MANUFACTURED: 30 NO. OF PIECES ORDERED AND SHIPPED: 25 BURST TEST RESULTS: 190, 191, 192 psig 0 72 Deg. F. 190, 190 pslg 0 200 Deg. F. RUPTURE PRESSURE: 191 psig 0 72 Deg. F. 185 psig 0 200 Deg. F. CAPACITY SCFM: 62,438 DATE OF TEST: 9-9-81 STAMP DISK TAB: RX D-4, 5, 600, 741, 2, 3, 4 SYSTEMS, INC W. J. Fergusftm Quality Corjprol Manager ABDOO185676 B-20 ABDOO185677 (conocd) Interoffice Communication To R. J. Reusch, Chemicals Research, Ponca City from M. H. Lewis o*t January 18, 1980 subject PREMATURE FAILURE OF PVC REACTOR RELIEF SYSTEMS........ -m .; In the past, several of the safety relief systems on Conoco PVC reactors have failed prematurely, resulting in VCM emission to the atmosphere. Of the two configurations presently used, the double rupture disc ar rangement was found to be less effective in preventing premature releases of VCM as compared to the rupture disc/relief valve setup. However, neither arrangement has proven to be 100 percent reliable in controlling VCM emission upon premature failure of the primary rupture disc. Discus sions earlier in the year with BS&B Safety Systems, Inc. generated several ideas for preventive measures which were later carried out in the plants. In November 1979, consideration was given to the idea of changing all double disc setups to rupture disc/relief valve arrangements. The idea was accepted in Oecember. Two experimental test programs were then drawn up to determine the configuration and optimum spacing required between the rupture disc and relief valve to contain the VCM upon premature failure of the primary disc. One of the tests was designed for BS&B and the other for Conoco R&D. The following report summarizes the progress made in December 1979. Experimental Test Program A joint meeting dealing with the premature failure of PVC reactor relief systems was held December 4, 1979, with Process Engineering Department personnel. In that meeting, the decision to change all double rupture disc setups to rupture disc/relief valve arrangements was confirmed. Also, an experimental test program for BS&B Safety Systems, Inc. was reviewed. The test program, which was drawn up by R&D, proposed two basic rupture disc/relief valve arrangements to prevent the premature release of VCM from Conoco's PVC reactors. Initially, testing of a 6" or 8" relief system was considered, but because of the limited size of BS&B's test facility (120-gallon vessel), a 3" rupture disc/3"x5" relief valve system was decided upon. Although the ability to scale up to larger sizes from the results obtained from the 3" relief system is questionable, the data collected should provide a good starting point for further worfc. On December 10, 1979, the attached experimental test program was pre sented to BS&B at their Tulsa office. BS&B not only agreed to carry out the experimental test program at no cost but also agreed to provide rupture discs and safety holders for additional testing by Conoco at no cost. In addition, BS&B volunteered to perforin another series of tests based upon the results of the first. ABDOO185678 B-20 A R. J. Reusch Page 2 January 18, 1980 A meeting between BS&B, Consolidated Valve, and Conoco was held on December 18, 1979, in Tulsa to finalize plans for the experimental test program. Consolidated Valve personnel were present and were willing to provide (at no cost) pressure gauges and relief valves for the experimental tests. The test program should begin January 22, 1980, with the following people present; George Lowrey (DresserConsol idated), Bob Lowrey (Dresser-Consolidated), John Strelow (BS&B), and Max Lewis (Conoco). The data from these tests should give Conoco a better understanding of the effects of the following variables on premature failures; (1) the space allotted between the rupture disc and relief valve, (2) a tee/elbow arranqement be tween the rupture disc and relief valve, and (3) the annle of the relief valve. Premature Disc Failure The reason for premature disc failure is still under investigation. During the past month, six 6-inch and seven 8-inch rupture discs, which which were taken out of service a couple of months ago, were tested by BS&B for their burst pressure. Although PVC buildup was found on several of the 6-inch discs, all broke within disc specifica tion. However, of the seven 8-inch discs tested, four broke below the 5 percent tolerance limit. Further investigation showed that two of these discs that failed prematurely were from a double disc arrange ment on the 0-301 reactor, and the other two were from a double disc arrangement on the D-302 reactor. This may indicate that the premature failure of the four 8-inch rupture discs should be attributed to disc installation or setup, rather than to faulty disc manufacture. According to BS&B, crown damage is the most probable cause of premature disc failure. However, the alignment and weight of exhaust piping on the relief system can cause uneven stressing of the disc and also result in premature failure. The valve vendors were likewise concerned about the effect of exhaust piping on the relief valve. The rupturing of four 8-inch rupture discs designated for Conoco PVC plants was witnessed while in Tulsa on December 18, 1979. The discs were rated for 206 psi at 72F. The four discs burst at 204, 204, 198, and 202 psi--all within the 5 percent tolerance limit. Recommendations If desired in the future, BS&B will provide rupture discs that meet the ASME code. They will also provide strip chart recordings of the temperature and pressure experienced during the tests conducted to meet the ASME code. It is recommended that Conoco should purchase only ASME coded discs from BS&B. Although the quality of the ASME ABD00185679 B-20 A R. J. Reusch Page 3 January 18, 1980 coded disc would not necessarily be superior to the disc now purchased, the presence of coded discs on the PVC reactors would be to Conoco's advantage if court action resulted from a premature failure. It is also recommended that all safety relief valves on PVC reactors be oriented vertically to assure proper functioning of the valve and that the feasability of altering the exhaust pipe be considered. Heat Up In documenting the premature failure of rupture discs on PVC reactors, Ouane Lewis found that most premature failures occurred during heat-up (IOC of September 24, 1979). By viewing the polymerization reaction in the 50-gallon reactor during heat-up, it was found that the vaporspace disappeared. As the contents of the reactor were heated, the vapor above the mixture became entrained into the liquid, the vortex disappeared, and the whole liquid surface rose inside the reactor. Also during heat-up, the torque on the agitator blades decreased as a result of the vapor entrainment. Whether or not this same phenomenon occurs in the large commercial reactors is not known. However, if it does, the presence of a liquid in the reactor dome would help to explain why the relief valve opens and then fails to close upon premature disc failure. Engineering Research Section vie Enc cc: FK DJR JF CM AJL WF JM ABDOO185680 BSr.O TEST PROGRAM RUPTURE DISC/RELIEF VALVE SYSTEM PRESSURE -200 PSI TEMPERATURE -500F B-20 A Confinuration 1 Space (Pipe Disc Rating (Psi) Diameters) Valve Ratinn (Psi) Test do. 2 0.70 2 0.80 1 C0 2 0.90 3 7 0.70 4 7 0.80 5 7 0.90 6 4 0.70 7 4 0.80 0 4 0.90 9 6 0.70 10 6 0.80 n 6 0.90 12 ,ABD00185681 . ,r A B-20 Configuration 2 Space Past Elbow (Pipe Diameter) Oise Rating (Psi) Valve Rating (Psi) Test no. 0 0.70 13 0 0.00 14 0 0.90 15 3 0.70 1G 3 0.00 17 3 0.90 10 2 0.70 19 2 0.00 20 2 0.90 21 Angle of Relief Valve - Use the pipe diameter spacing that successfully contained the rupture in Phase 1, Configuration 1. Spacing (Pipe Diameters) Angle Disc Ratinq (Psi) Test Valve Rating (Psi) No. To be determined 30 0.70 22 To be determined 30 0.30 23 To be determined 30 0.90 24 ABDOO185682 ABDOO185683 (conoco) Interoffice Communication J. Friend, Chemicals-PVC, Oklahoma City To y'C. L. Miller, Conoco Chemicals, Aberdeen From M. H. lewis. Chemicals Research, Ponca City Daio February 5, 1980 Subject SAFETY RELIEF SYSTEMS B-21 An experimental test program was initiated this past month in Tulsa with participation from BS&B, Consolidated Valve, and Conoco. The purpose of the test program was to better understand the response of a rupture disc/relief valve arrangement to premature failure of the primary disc. The major findings (preliminary) were: 1. In all cases, regardless of piping configuration, the relief valve opened when the primary disc was burst at 70, 80, or 90 percent of the valve rating. 2. It appears that the valve opening is reduced the shorter the distance between the disc and the valve. 3. An elbow/tee arrangement between the disc and the valve may reduce the degree of valve opening. Oiscussion Air testing was performed using a 120-gallon vessel with 3" rupture discs mounted beneath a 3" x 5" safety relief valve. Rupture discs which were manufactured to burst at 90, 80, and 70 percent of the valve set pressure were used to simulate premature disc failure. Initially, the safety relief valve was mounted vertically, in line, over the rupture disc. To determine the effect of rupture disc relief valve spacing in controlling premature gas emissions, rupture discs were burst at a 0, 6, or 9-pipe diameter (p.d.) distance between the disc and relief valve. In all of these tests, the relief valve opened to differing degrees and discharged air when the rupture disc burst. The relief valve opened regardless of the pressure that the rupture disc burst at. Shock waves which are generated when the disc bursts are thought to cause the premature opening of the relief^valve. The testing indicated that the 9 p.d. spacing was the least effective in containing premature disc failure and that the relief valve should be mounted as close as possible to the disc. A tce/olbow configuration (equivalent to 6 p.d.) between the rupture disc and relief valve was later tested. (See Figure 1.) Here again, ft -ABD00185684 - B-21 Joint Letter Page 2 February 5, 1980 the relief valve opened prematurely when the rupture disc burst at 70 and 90 percent of valve set pressure. However, the tee/elbow configura tion was probably the most effective setup tested. A teo and elbow mounted between the disc and relief valve resulted in the least amount of gas discharge from the relief valve upon rupturing the disc. BS&B in Tulsa is currently working on a double rupture disc system which will prevent releases upon premature failure of the primary disc. Possibly this could be incorporated with a relief valve to minimize any VCM release. Testing is proceeding on these possibilities on a high priority basis. M. H. Lewis ^ Engineer Engineering Research Section vie FK DJR RJR AJL JHMc WF BGL & ABDOO185685 FIGURC 1 ii >: v ' 150 lS . rv '/ A ;_V-- -- B-21 ft F I.7T I N 6 S .wV '^L'rT'j ; ;CE pi s c _i_.i ,___ .. i j n 15 t a m o T O lT- 7 D E ~ e Ml L'0 Q ._ 5.7' y ~ ^ TAN MO S A l -- ABDOO185686 B-22 ABDOO185687 {CGftQCO Interoffice Communication To From Oats Subject Max Lewis, Research and Development, Ponca City J. Kirk Carnahan, Maintenance Engineering, Ponca April 22, 1980 METALLURGICAL EVALUATION OF Mi 200 RUPTURE DISCS FROM OKLAHOMA CITY PVC PLANT Conclusion The variation in rupture pressure does not appear to be the result of metallurgical factors. Discuss ion Several rupture discs, both failed and unfailed, were received for evalua tion. The failed discs were sorr.a that had been taken out of service and it burst at the 3SS3 facility in Tulsa. In these burst tests the rupture pressure varied from 135 to 19S psi. The design rupture pressure is 2G0 psi (+ 10 psi) at 172F. These discs were examined visually and microstructurally. The unfailed discs were taken out of service and examined visually. The seven failed discs were examined visually and microstructurally. The visual examination shotted the torque bice groove to be smooth and uniform buc a small void was detected along the cut notch of the disc which ruptured at 135 psi. A section containing this void was removed for microprobe analysis (attached report). Briefly, the report states that the void was the result of an inclusion which was pulled out of the metal when the disc ruptured. It is common to find inclusions like this in metals because molten metals will contain impurities. These impurities are usually the last to solidify and are segreated together as they are pushed along ahead of the solidification front. The impurities are elongated during the rolling operation and show up like the inclusion shown in Figure 2 of the attached report. Inclusions do affect the strength of a material because they re duce the effective cross-sectional area which in turn reduces the effective load carrying capacity. It is doubtful chat an inclusion like this would have a significant affect on'the disc reversing pressure. The microstructure of the other discs was similar to the one shown in Figure 2 of the attached report but there were no inclusions. Several used but unfailad discs were received for a visual examination only. Generally, the torque bite groove was uniform. One disc did have a variable groove depth and some of the discs had impressions on the seating surraces which would indicate dirty or corroded flange seating surfaces. Although there were no signs of corrosion on any of the discs, two discs were dented and two more had a rough surface finish.- Even though I had no way of mea suring the actual wall thickness at the cut notch with available equipment, the notch appeared to he uniform and consistent from disc to disc. ABDOO185688 B-22 Max Lewis Page 2 April 22, 1930 I was cold by Carl Forsythe of 3SS3 chat the chree main things that influence the rupture pressure are: 1) Cut notch depth, 2) Anneal (strength), and 3) Shape and contour of bulge. My observations showed the anneal to be fairly uniform as the grain size and structure was about the same on the discs examined. This would indicate that one of the ocher two variables is causing the erratic rupture pressures. One possibility is shape change due to installation damage or ocher unforeseen sources. Variations in the sheet metal thickness and subsequent disc thickness at the cue notch could have a significant affect on the rupture pressure. J. Kirk Carnahan Engineer, Metallurgical Corrosion and Metallurgy Division jks CC: .Failure File:JFL;DLE:CLS pit Finch, Ponca City .oward Newell, Oklahoma City ABDOO185689 fconoco) A Technical Service Resort No. 22-80-849-1 Conoco )nc. Research and Development Department Production Research Division Ponca City. Oklahoma ^ -j . >rj To From J. F. Leterle, Maintenance Engineering, Ponca ^<ty;s zzc'J\:z;:t a v L. D. Nelson AmD TH Pr,Zr-lr.7'/ C= ^j'-.Zjl ;\ Dote January 28, 1980 Subject Ni 200 RUPTURE DISC FROM OKLAHOMA CITY PVC PLANT. FINAL REPORT. REFERENCE Maintenance Engineering Request No. 80-1, dated 1/11/80. PRD No. 516590. CONCLUSION "Voids" appear to be holes once occupied by inclusions. BACKGROUND The rupture disc had an internal environment cf PVC slurry and steam at iSC-200F under 175 psi and an external ambient environment. The disc was rated by the manufacturer to rupture at 190-200 psi; however, it ruptured at 135 psi. Vie were asked to identify what appear to be voids, as seen in Figure 1. DISCUSSION Both sides of the fracture surface were examined with the scanning electron microscope. All areas in question appeared to be void of any material. Cross-sections of the fracture surface were then prepared metallographicelly and examined. Long inclusions were found in the area of the "voids", Figure 2. Figure 3 shows a microprobe analysis that indicates the inclusions are a nickel/iron type oxide. Most likely the inclusion was pulled out of the parent material when the rupture occurred thus leaving a "void". L. 0. Nelson Technician Material Sciences Group Production Section cp Attachments Copies to: JFL(6)-WWB-FRC(2 J-GDA-BMC RMV-LHC-File. TSR No. 22-S0-349-1 Page 2 ABDOO185690 B-22 A FIGURE 1 - 100X Shows typical area in question. What is or what has caused this void space? FIGURE 2 - 1 SOX 50-50 Glacial Acetic and Nitric Acid Etch. Shows one of the long inclusions found in the general area of the "voids". SR No 22-3C-S49-1 age 3 ABDOO185691 B-22 FIGURE 3 - 50QX Shows microprobe scans that(indicate nickel, iron, and oxygen are the major elements of the inclusions.' ABDOO185692 B-23 ABDOO185693 (conoco) Conoco Chemicals Company Division of Conoco Inc. P.0. Boi 91. New Highway 25 Aberdeen. MS 39730 B-23 September 29, 1981 Mr. Charles R. Jeter Regional Administrator Region IV United States Environmental Protection Agency 345 Courtland Street, N.E. Atlanta, GA 30308 Dear Mr. Jeter: In my letter to Ms. Hanmer dated October 20, 1980, I advised the Agency of our plans to replace all double rupture disc pressure relief devices on the PVC reactors at Conoco's Aberdeen Plant with relief valve/rupture disc assemblies. These modifications were completed on the reactors in Polymerization Module No. 2 on August 17, 1981 and on the reactors in Polymerization Module No. 1 on September 18, 1981. With the completion of this project the possibility of a vinyl chloride release due to premature failure of the double disc assemblies has been eliminated. Also, since all relief assemblies now include a relief valve, the magnitude of a release due to overpressure if one should occur will be minimized as the relief valve will likely reseat as the reactor pressure decreases to thejrelief valve set pressure. Sincerely, R. A. Frohreich Chief Process Engineer cjt c: Jerry Banks - Mississippi Bureau of Pollution Control CLM, CRM, VEM, JJH ABDOO185694 B-24 ABDOO185695 B-24 Interoffice Communication To : PEM, SJV, WFH, 1st and 2nd Level Supervisors and Bulletin Boards (Vinyl & Maint. Storeroom) : C. R. Miller oat. : April 26, 1982 Subject: RUPTURE DISC-REPLACEMENT AND TESTING A potential exists for a rupture disc to burst below its rated pressure due to faulty manufacture of the disc or due to faulty installation. Due to the seriousness of any VCM release, some new procedures have been established to minimize this potential. Therefore, the following procedures will be followed when replacement of rupture discs in VCM service is necessary. These procedures must be followed and deviations from such are not to be allowed. Storeroom 1. On receipt of a new lot of rupture discs, the storeroom will notify maintenance supervision of that receipt. Maintenance 1. When notified of receipt of discs from a new lot, one disc is to be selected from the new lot, placed in a pretorqued holder and the relieving pressure checked by bursting the disc. Deviations of the relief pressure from that listed on the disc should be brought to the attention of the Mechanical Superintendent or Plant Superintendent immediately. A list of approved lots is to be maintained so it can be checked whenever a disc is obtained from the storeroom. 2. All rupture discs removed from VCM service will be burst in the maintenance shop while still in the pre-torqued holder. This burst pressure will be recorded in the rupture disc log book. 3. New discs to be installed in the holder and the holder itself will be examined for dents, scratches, etc. that may affect burst pressure. Damaged discs are not to be used. 4. Whenever a disc is to be installed, it will be placed in holders and pre-torqued in the shop by qualified maintenance personnel only.QThe disc will then be shop tested at 90% of its burst pressure at 72 F. The pre-torque and dirSc test for reactor service will be observed by approved maintenance supervisory personnel. The supervisory personnel will log in the rupture disc book all identifying information on the disc, test pressure, mechanic doing job and supervisor witnessing job. 5. Installation of rupture discs on reactors will be witnessed in the field by approved maintenance supervisory personnel. ABD00185696 Rupture Disc Replacement and Testing April 26, 1982 Page 2 B-2** 6. Qualified rupture disc Installers and maintenance supervisory personnel will be trained at least once per year and documented in the rupture disc log book. A list of currently qualified maintenance personnel is attached. 7. A list of maintenance supervisory personnel who currently qualify to witness pretorquing, shop testing and field installation of rupture discs is attached. Operations 1. On completion of a reactor rupture disc installation by maintenance, the reactor will require a complete reactor hydrotest to 165 pounds per square inch pressure. The hydrotest of the reactor is to be witnessed by one of the personnel approved on the list attached. A reactor hydrotest log is to be maintained and should include the test findings and the witnessing personnel. 2. PVC reactors will operate no longer than six months between rupture disc changeouts. C. R. Miller tap c: JF Attachment ABD00185697 I. QUALIFIED RUPTURE DISC INSTALLERS Maintenance Hourly Personnel W. Harlow D. Rambus D. Nolen D. Andrews B. Oliver L. Phillips C Warren L. Goodwin C. Peden B. McAllister B. Ward H. Jackson W. Troupe T. Staten L. Howell L. Threadgill D. Roberts L. Kennedy J. McWhirter W. Moore J. Edwards F. Blanchard C. Holcomb T. Harden L. Rea J. Walker J. Lowe J. Crosby L. Frye Maintenance/Mechanical Supervisors M. Williams F. Frantz R. Rye J. Windham J. Horstman C. Davis M. Skinner J. Dixon II. MAINTENANCE INSTALLATION OBSERVERS J. Horstman J. Windham M. Richards S. Allen G. Morgan D. Miller J. White R. Rye F. Frantz M. Williams C. Davis M. Skinner J. Dixon R. Hamed III. OPERATIONS HYDROTEST OBSERVERS P. Markey M. Blackwell J. Perez V. Thornhill A. Barfield D. Mahler C. Greene C. Miller V. Messick R. Frohreich J. Friend B. Vick J. Prows B-24 ABDOO185698 B-25 il W-fTrnY 'i*i ABDOO185699 09 ^kibty- jZ:A,'U / cA&fdvt oM f) -A"-- /i*r^*y a Uur 97/ 77.i 7Vi 77/ VYJ- n?s~. pur rnr r?*r J' '-0.& Tji >- //"*<. c~ yds^cd <J^~ /~2tcA y' oA*r*r< y2u.'\C.<^~ oJ-t /lzC*or dd-K. jzt~ 077- ^Cjx. '^':j.. A-y sO'Kku*'-^ <rr, / 2y ~i ' / jC-/,'V/tIecf**. rr^~- /ir-'Ccut'-y. oh-*U y> fc'-J.*. r+A^>ud ,-J.i. / J/?>^( . .'^ '^C&cZr. /} /Xy2<r7^Ct-'-id] & c- rt/'-1' 0\*f( /' 'rj'nj. /Cs*rjl c~xu/yUr* V- / f+1/ o' rlS'^X-J/^tc6'x/ y /?// ^/ixj /tc,/T Oft Cy cAr^c/ ^C//7^f >/ y/r*J-zA^( -Tp -1a. y> cJiS'ip'd_z.t ^ ^Ax,y, /ZltpzX&~l<- C&UZ . :V-\-h - _yit 'y/X>-cxxedi,^jL/ y>^r- ^CC/ztur^ Cr-' ^d-ZyjLd II '3, Jslrp y[sJx<<i j ^ Z^. !t C&\iv**JL /**L 7 //** c?i -5 A^diJ< t^4x<h -y-- o/ y/A - //. . /- i chd Cczinnd^-J CCi'ii.'^'.^cdd~ ',t7 yy'^vLdZ^ `l-~"7\ <sryZUssr?**Ajl _MjlAs^AL~ B-25 ABDOO185700 B-27 ABD00185701 Interoffice Communication To : Distribution From : Dave Mahler Date ; 9/26/83 Subject : RUPTURE DISC/RELIEF VALVE PRACTICES MANUAL B-2 7 Ittached is the most recent version of the rupture disc/relief valve proce dures manual. Please destroy any older versions that may be in your files. fycuj< Dave Mahler Environmental Engineer Attachments c: JF, CRM, PEM, CRS, JLH, MES, WFH, RES, RAF, VEM, VLT, Paul Varner, John McCulley ABDOO185702 RUPTURE DISC/RELIEF VALVE PRACTICES MANUAL CONOCO CHEMICALS COMPANY ABERDEEN, MS AUGUST 29, 1983 B-27 A ABDOO185703 RUPTURE DISC/RELIEF VALVE PRACTICES MANUAL TABLE OF CONTENTS I. INTRODUCTION II. RUPTURE DISC ORDERING AND PRE-INSTALLATION CHECKOUT A. Specification of Rupture Discs B. Lot Inspection and Pre-Testing C. Recordkeeping III. RUPTURE DISC INSTALLATION A. Installation in Holders B. Testing C. Installation in the Plant IV. RUPTURE DISC REMOVAL A. Rupture Disc Changeout 3. Destructive Testing V. RECORDKEEPING VI. TRAINING VII. RELIEF VALVES A. New ReLief Valves B. In-Service Testing C. Recordkeeping ABD00185704 8-27 Rupture Disc/Relief Valves Practices Manual Page 1 X. INTRODUCTION Section 61.65 (b)(4) of the National Emissions Standards for Hazardous Air Pollutant Sources requires that a rupture disc be installed underneath any emergency relief valve in vinyl chloride service, in order to minimize leakage through the relief valve to the atmosphere. In accordance with this requirement, Conoco has installed a large number of rupture discs in vinyl chloride service throughout Che plant. In addition to preventing relief valve leakage, rupture discs also serve the vital function of pro tecting the relief valve from polymer buildup on the relief valve seat, which could hinder the proper functioning of the relief valve in an emer gency. In either case, proper functioning of the rupture disc/relief valve combination is essential for plant safety. This program has been developed because of the importance of maintaining the integrity of rupture discs during their handling and installation. .\dherence to the procedures outlined in this manual will help to ensure chat the chances of rupture disc/relief valve malfunction will be mini mized, and that thorough documentation will be available whenever such a malfunction does occur. This documentation may become extremely critical in the event of a VCM release caused by a premature rupture disc failure or other process upset conditions. ABD00185705 B-27 Rupture Disc/Relief Valve Practices Manual Page 2 II. PvUPTURE DISC ORDERING AND PRE-INSTALLATION CHECKOUT A. Specification of Rupture Discs All rupture discs in VCM service are listed on Table 1. The follow ing specifications must be noted on the purchase order when ordering these rupture discs. 1. Disc size (specify). 2. Type S-90. 3. Nickel material. 4. 0% Mfg. range. 5. Burst pressure (specify). 6. Letter of certification required. 7. ASMS code stamped (where noted on Table 1.) 8. Test each disc to 90% of rated burst pressure. 9. Replaces lot no. . . (specify). 10. Serially number all discs in the lot, B. Lot Inspection and Pre-Testing All new rupture disc lots received at the plant receiving dock must be thoroughly inspected and tested before they are moved to the storeroom. The following procedures are to be used when new rupture disc lots are received at the Plant. 1. When a lot of rupture discs arrives at the receiving dock, use care when unloading the discs from the truck so as not to damage the discs. 2. The receiver must notify Process Engineering that there are new rupture discs at receiving, and a Senior Process Engineer or the Environmental Engineer will count the number of discs in the lot and inspect each individual disc for flaws. ABDOO185706 Rupture Disc/Relief Valve Practices Manual Page 3 B_27 II. RUPTURE DISC ORDERING AND PRE-INSTALLATION CHECKOUT (Continued) Lot Inspection and Pre-Testing (Continued) 3. A flaw is 'defined as follows: a. Any knick or scratch which can be felt. b. Any irregularity in the shape of the domed portion of the disc that can be seen with the eye or felt. c. A pinhole or scratch which could cause the disc to leak. d. A disc without a tag. t e. A disc that will not fit the pins of a holder. f. A disc that is labeled differently chan the other discs in the same lot. 4. Flawed discs must be removed from the lot and returned to the manufacturer. Discs which pass inspection are initialed on the box by the inspector. 5. Rupture discs which are to be installed on vessels in VCM service must be approved by lot before they can be placed in the storeroom. One disc from each of these lots must be sent to the maintenance shop and burst using the procedures speci fied in the destructive testing section of this manual. 6. If any rupture disc does not burst within 5% of its rated burst % pressure, the entire lot from which the disc was taken must be returned to the manufacturer. Maintenance must notify receiving in writing that these discs have either passed or failed this test. 7. Rupture discs which pass inspection and testing are ok'd for placement in the storeroom. Rupture disc boxes which have not been initialed are not to be placed in the storeroom. & ABD00185707 Rupture Disc/Relief Valve actices Manual M 4 IT. RUPTURE DISC ORDERING AND PRE-INSTALLATION CHECKOUT (Continued) C. Recordkeeping B-27 Administrative Services must keep a record of rupture disc receiving and inspection data. An example log sheet is attached. This infor mation must be stored in the plant for a period of at least two years. m. RUPTURE DISC INSTALLATION A qualified maintenance installation observer must be present during all phases of rupture disc installation (vinyl reactors only). The Mechani cal Superintendent will keep an updated list of qualified maintenance installation observers. A. Installation in Holders All rupture discs must be installed in the holders according to the manufacturer's specifications. These written specifications come with each rupture disc. The following steps outline the general procedure which is to be used when installing rupture discs in holders: L. Before a disc is placed in the holder, the disc, the holder and the holder bolts must be inspected for flaws. 2. Flaws are defined as follows: a. A disc that has any of the defects listed in Section II (B)(3). b. A holder face chat is covered with dirt or debris, or is deeply gouged such that it will leak when installed, c. Set screws that are galled or cannot be screwed into the holder bv hand. ABDOO185708 B-27 Rupture Disc/Relief Valve Practices Manual Page 5 III. RUPTURE DISC INSTALLATION (Continued) A. Installation in Holders (Continued) d. A holder with a bite ring that is not 2-5 mils in height, as determined by a feeler gauge. The bite ring must be uniform in height around the holder, and must not be dented at any location. 3. Flawed components must not be Installed in the Plant. 4. Place the disc in the holder and hand install the holder bolts. Using a torque wrench, tighten the holder bolts to the torque specified by the manufacturer. This tightening must be performed in at least four passes; i.e. 25%, 50%, 75% and 100% of the final torque. A criss-cross tightening pattern must be used when tor- quing the bolts. 5. When the installation of the disc in the holder is complete, visually inspect the disc again to see if it has been distorted or otherwise damaged. 6. Rupture discs must not be removed from the holders after instal lation, otherwise the rupture disc must be discarded. B. Testing * All reactor rupture discs are to be pressure tested in the main tenance shop to 90% of their rated burst pressure before being installed in the plant. The following testing procedure must be used when pressure testing rupture discs in the maintenance shop. 1. Clean the flanges of the test bench and the faces of the rupture disc holder where the two surfaces meet. Use an abestos gasket between the flange and the holder. (h ABD00185709 B-27 Rupture Disc/Relief Valve Practices Manual Page 6 III. RUPTURE DISC INSTALLATION (Continued) 3. Testing (Continued) 2. Install the holder on the test bench and tighten the bolts in a criss-cross pattern, waking several passes on each bolt. Torque the bolts to the torque specified for the companion flanges. 3. Warn nearby personnel that a rupture disc is being pressure tested. 4. Using pressurized air, slowly open the test valve and pres surize the space underneath the rupture disc. Increase the pressure to 90% of the rupture disc burst pressure at 72F. 5. Slowly depressurize the space underneath the rupture disc and remove the assembly from the test bench. If the disc appears to have been distorted or otherwise damaged during the test, do not install the disc in the plant. 6. If a rupture disc bursts prematurely (less than 90% of its rated burst pressure) or is damaged by the test, the disc must be given intact to Process Engineering. Other discs from the same lot must be removed from service, where necessary. 7. The calibration of the test bench pressure gauge must be checked with a dead weight pressure gauge every six months. ^l^ture Disc/Relief Valve Practices Manual Page 7 ABD00185710 B-27 III. RUPTURE DISC INSTALLATION (Continued) C. Installation In The Plant Rupture disc assemblies must be installed in the plant accordingly: 1. Before installing the holder assembly between the companion flanges, thoroughly clean the flange faces with a putty knife to remove any solid buildup or debris. 2. Check to see that the flange faces are not gouged or otherwise damaged. Place the rupture disc between the flanges, with the bulged-out side of the disc facing the process. 3. On reactors, use asbestos-type gaskets only. Flexatalik gaskets may be used elsewhere in the plant if desired. 4. When tightening the companion flanges, torque the bolts to the manufacturer's specification using a criss-cross tightening pattern. Make at least four passes on each bolt, IV. RUPTURE DISC REMOVAL A. Rupture Disc Changeout Rupture discs are to be removed from service and changed accord ingly : L. Any rupture disc tihich fails in service must be changed as soon as possible after it is discovered that the disc has failed. 2. Any rupture disc which is believed to be covered with resin or otherwise damaged must be changed as soon as possible. 3. All rupture discs on reactors must be changed at least once every six months. 4. When a reactor is taken out of service for condenser drilling, the condenser rupture disc guard(s) must be installed over Che rupture disc nozzle(s). Rupture Disc/Relief Valve Practices Manual Ae 3 ABDOO185711 B-27 IV. RUPTURE DISC REMOVAL (Continued) A. Rupture Disc Changeout (Continued) 5. Any rupture disc which fails in reactor service must be given to Process Engineering. Use care so as not to damage these discs. Other discs from the same lot must be removed from service, where necessary. Destructive Testing All rupture discs taken off of vinyl reactors must be burst in the maintenance shop when taken out of service permanently. The follow ing procedures also apply to new rupture discs which are burst when they arrive at the Plant. 1. When removing the holder assembly from the reactor and when transporting the holder assembly to the maintenance shop, use caution so as not to damage the disc or the holder. 2. When destructively testing a vinyl reactor rupture disc, a qualified maintenance Installation observer must be present to observe the testing. 3. Install the holder assembly on the test bench and pressurize the disc with air until the disc bursts. 4. If a rupture disc bursts prematurely (less that 90% of its rated burst pressure), the disc must be given to Process Engineering. Use care so as not to damage these discs. Other discs from the same lot must be removed from service. where necessary. A ABD00185712 Rupture Disc/Relief Valve Practices Manual 9 B--2 7 V. RECORDKEEPING Maintenance must keep a record of all rupture disc installation and testing data. An example log sheet is attached (D-300 reactor). This information must be stored in the plant for a period of at least two years. VI. TRAINING All maintenance and engineering personnel involved in this program are to receive annual hands-on training in the installation and handling of rupture discs. Records of all personnel who attend these training sessions are to be kept by maintenance for a period of at least two years. J/II. RELIEF VALVES All relief valves must be periodically checked to make sure that they will operate properly in an emergency situation. A. New Relief Valves All new valves must be tested accordingly: 1. Mount the relief valve on the hydro test bench and pressurize the relief valve until it relieves. 2. After the relief valve opens at its setpoint pressure, check to see that it holds a constant pressure upon reseating and does not leak. 3. If the relief valve does not relieve within 5% of its setpoint pressure, or does not reseat properly after relieving, it must not be installed in the plant. ABD00185713 Rupture Disc/Relief Valve ^octlces Manual 10 B-27 VII. RELIEF VALVES (Continued) B. In-Place Testing Relief valves in service must be tested accordingly: 1. All relief valves in reactor service must be pressure checked every year using the nitrogen test apparatus. This test should be performed immediately before the rupture discs are changed. 2. When using the nitrogen test apparatus, slowly pressurize the space between the rupture disc and the relief valve until the relief valve relieves. If the relief valve opens at less than 95% of its setpoint pressure, take the relief valve out of service for repair. If the relief valve does not open at 105% of its setpoint pressure, top the test and take the relief valve out of service. 3. When the relief valve reseats, check to make sure that it holds pressure without leaking. 4. Following the test, slowly depressurize the space between the rupture disc and the relief valve. 5. Two pressure gauges must be kept on the nitrogen testing appara tus. If the two gauges disagree by more than 5 psig, the gauges must be calibrated against a standard pressure gauge. C. Recordkeeping Maintenance must keep a record of all testing and repair done on relief valves. ABD00185714 B-27 w B. s SS ou S WN XO 0 92 Z-- CO CO CO CO CO CO CO 2 03 03 03 03 03 03 r*> r. r p r- 1 |1 r sCQ 03 CQ CQ CQ CQ CQ 03 03 03 S3 03 03 CO CO CO CO CO CO CO *0 SO CM sO sO sO 06CO CO CO CO CO t/5 CO CO CO CO CO CO CO CO to CO CO CB OS 03 03 03 05 cc 03 03 GC 03 03 03 2 03 2 p r- 1 11 r 1 r-. r** r-* p. 1 riI fv r11. r*. 1 r. t-it r-. 1 r- 00 03 CQ CQ CQ 03 CQ CQ S3 CO S3 as CO CQ CQ 00 CQ 03 03 03 03 03 cc CC 03 03 CC 03 03 03 03 03 03 83 CO CO CO CO CO CO CO CO CO CO CO CO CO co CO CO CO 05CD>O^^C0^'OC0vCvCCDC0\0^ --W Q O H 3ndd q n n >41. >41. 4>1. 4>1. >41. >41- 41 oQ)l Vo) i4d1 nV Un 4)<4>A&uJ4>J4wJ4wJ4w)4tJt4v>>4wJ4> >- >- >- >- >H 222222Z zzzzzzzzzzzzzzzzz A TABLE 1 RUPTURE DISCS IN V IN Y L AREAS OF PLANT U H fit -- W9O to tn h 22 >os Uas 0.' Q. Eju 2^ HHO 2u w 9w QUKO--.' oooo I I I I I I I^ Os 9s Os O' O' CO 2 2 2 2 to VI NooNooNocNooNootooSooNooNooNooNooNooNooNooNooNoNooNo oOfvjoCONi^n--CuC^CtnOoOoOtOri'mOJ(oNOoCOSm-C--i-'CrCiVOoICoONmO--^tn-- oooooooooooooooco I O1 ' OI ' OI ' O1 ' OI ' O1 ' O1 ' Ot ' Ol ' OI ' OI ' Oi ' 0I> OI ' OI ' O1 ' e o 3 5 o s o eseOfiaeflc&cQtific&c3oacocQaffic2 wGweowcQwcawc2tefoiewQwe&wcatc (oww^inwr bb OU b-JJ C2Oo 2WM> -o ^ in -o -o No N OI OI <-I> OIN CMI CMI cmI <*"1 <*0 CJ C"> ('`"I <*o -- n"* fO r^,r^rH.r^.ror^r^r^(*nr^.r^ (rktiijriII sriiii o bb Ob 04 04 CO CO < 41 ** *b 4b Ob 2 i-H r-H 9 -- 99 f--i 9 9z 4) 41 W O rH iH H r~i o rH 9 1-^ "0 9 9 9 13 9 o Qo os 1- h u 4J uH 4) 4) 41 41 e OJ 41 4) c 4) 41 41 C 4) 41 41 c 9< 41 4) 3 o a> 4) O CJ X 2 2 2 o X 2 o 2 2 2 o J= 2 2 0 UH 2< a 2 Cl. 2 2 CO < U) CO CO CO CJ> C/3 CO tfl Vi 2 2 to Vi 2 CJ w 9 2 CO CO 3 9 9 3 as O o o o o o O O o Ho a. 9 9 9 Q 3 o 09 CQ n 9 TT" CM 9 u 9 O o o ooo oo o O o o tn no P"S (n o -9 IPs lA lA lA SO s> sO 'O 1t 1 11 11 as o > > H Sc u U1 9 O Q Q a a a Q c a Q 9 Cl 9 a O a h O fj a: 6 Cl 03 9 5!H V bAl O H2 <0 2 C I s v ii V, 2 r' pi i < 2 a: tn i Pi 1 pf: 2 PI 1 HI 1 f*i in p; V. f i r-s PI fSj -9 1 o U vO <n 0D o sO 00 C.1 a.' O a' CTJ Os O' *n M H 9 O r> O' O' o O fn 6 O r> O' o *S O' C-l CM p"> rt r"i n -9 -9 CM CM <9 CM 9 9 CM -9 -9 r*l bb O o O O o o O % O o o o o o o C C O O O ^r> W 22 << ABD00185715 B-27 u a tli 3 a* o > XH at itl a x ouu --a <MZ tO x tO 01 to 01 to CL X A Z CL as CL 1 P. r- 1 r11 ** 1 r*i* A 00 A x A X X QC BS cL os A as Z V) X tSl C/3 to 03 01 C/3 01 03 03 03 03 X 03 C/1 X to to 01 to 03 to to X X CO X X z c-j- z r- Z r11 . Z r Z r-- z P. z n z P-. z r-- l z r CL "J* a z A Z r- t CL 1 A r-* z z z GL p- z z 1 X X A X X X X X as X A A X A X A A X X X A X X z z A Z z z z z CL Z a: A z A z CL CL z z z A z z 03 03 to 03 01 01 03 01 to 03 to to 03 to 03 to CO X X X CO X X IBCOiOiOglfOifliflaCoaiOCCCCiifliflrucririffiinffliT-! -z t" c S <> u) co tr. in in to in l V O tl u >>>>>>>>* aautwcovcaflC)uQaM)wcninw4ctnwwviava4c)A&ioivcBac/4n>Mwio ?">*>*> z z z zz z z z z z z z ZZZZZZZZZZZZZZZZZ A RUPTURE DISCS IN V IN Y L AREAS OF PLANT Uc,n 3nQh xx > uj a. z a W-- ZS-O" in c/i in in o o in 0 0 3 0 0 0 0N CM N CM M N - in in in in o O in --------- - -- -- -- -- c CM N M CM CM CM Cl OoioOciCiOnno^OoOoCmOon-oOoMmOiccCo-no^oinocionni^nOiOnOinOoOoOiOn- -- CMNCMCMCMN -- OOOOOOOOOOOCOOOO'C'CiCMOinincn OOOOOCOOCOOOOOOf't'-P'-P'-n-P-rCMINNNCMCMCMCMCMCMCMCMNCMCMIM------- ooomooomoooinoooininmininooin OOO'BOOOOZOOC'COOOOM -- --o (MCM--`CMCMp~CM1M -- -CM(M -- - CMNMMCMNCM I 1 t 1 I 11 CO K (O W W 10 K n a acc *3 *3 *3 *S m in i -1 vc mo i/ m .n in m -n. in r~- i-- i~ cn m li1i' l IIIII I I I I I I I I IIIIIIII in to in io co to ift vho to io io to to v) to id io to in cn to to ao*ao0a>eaea*ec*eaeaaaaaaeaaasao>a0>ao>ae<oeaae*ao<cea*oae cocoioioiococoMir, in co -ji to w co to in coco i/i co in to aeaaaaaasaaaaaataaaacae -- -- -- i cm .'i c-l c n -i n C M -j- -- mC or -- -- .t1' r. r-. cC-Mi .t -i mn. nc--. n} mr cj-. i<--* ^r-- p ^r- cn--. a> - r ar. mi--. ci-np a a III III in in in in m X az uj o-- ZH 3< H CJ a. o 3 _J UX oX E --I -- OS -m -- ^ o -- i-H ^3 i"H i"H """C HH-tHHpC'QiMrMpC'Q l II HI C C CJ 41 41 41 C 41 ai . tltlVCdtlCICVCICIC 333 o ox3 in co co u u to to 3iflc3o3io0cj3in3tn3iou0 i3uo. c3Af*li3<o*- o0wio3io3c-3unuu0c-3tn. M3 3cou0uuu iuo. iJo- rt-->-riCMCMCMCM(OnCOPI^^i^^iniOiniOlAlftlA iii ii ii ooa ao o a CaI OsrI MOI PQMI OfIMOINQrIMOINQpI .QPI QiNI OPI'CQIMOIlSO1fiQ.lIsQpIipCIipQiINCNI lOPI iPOI iNaI U Ui 111 Id h lb U IIIII1I mD ^ `P i^ >(*i i^ n n n n n rn ooooc oo aoO< oaOiccnniMoioOzoiOamcianNicoTZ['oOfmiiOaicNnOtCZoiTim'aOi sOi icNinszoiomu> cunii)cisiinuDciUnMni0mii3i-cu3ni oooooooooocooootoooooooo 06 U U3 S_j 0. O x . fiS W a to JUU O NX x-a to z e i- ABD00185716 B-27 fi fi fi fi fi fiCO to (A VI V) co to CO CO CO a: X fi fi 11 11 r. r- r* r*> ji r*. r* r*. ii r*H ji fim fi 3 A fi aa fi fi m ec fi X fi as fi fi as 4/1 V) to CO CO CO CO CO 4/3 CO fi fi fi fi fi fi fi fi fir*i* fiA fifi CO 4/3 X r1o C6 C/3 to X CB as 40 to 06 r- CQ as CO CO fi fi CO to OS r- co os to CO fi fi CO CO fi fi CO CO r* fi fi CO CO ri03 06 to CO r* 03 os CO to 1 fi fi CO CO fi fi CO CO fi 1 CP fi to CO fi r** fi CO CO fi r*- fi CO CO fi 1 fi fi A CO fi r-* fi fi V) CO fi fi fi CO TABLE I RUPTUPE DISCS IN V IN Y L AREAS OF PLANT ut ill -I a OOOOVQOOOO Z2ZZ>ZZZZ2 0 O O (0 0 O il 41 II V Z P" 9- >* >* aa ooooidiooo zzz><>zzz ZZZZZZZZZZ zzzzzzzzzzzzzzzzzzz MKNNNHHMNN oooooooooo MKNNMXNNMKNNHHHHMNN OOOOOOOOOOOOOOOOOOO u h ce KiSU SO to -- CO (0 > W fi. 06 06 ^ Qm CO CJ u to m SUM X a. *> U: to to IU 2S O 06 h* es =3 * a: uu Oa z o o e o omoirtoinoir o(noiruocoufoti/oiiflouiouioifliofnoiMofi i OoOoOooOoOolNoNoNoNoN O('llO--trO'i<O"->OfnOO0O0O0O <-l(-i<-)(--> M *a OOOOOOOOOO II1I1 IIIII (n(n(flVl(0(AIA(A(A oeao{pe<(Qo{Qofljeg<ojop t'lfr^. JrN--omoO--oiro--iuno^onooioOflnoONoONoOoONoOnoOnoOnOnoiOo'i OOOOOOOOOOOOOOOOOOO -- -- ---- -- -- ms m M tn m OOOOOOOOOOOOOOOOOOO Os O' O' O' O' O' O' O' O' O' O' O' O' O' O' O' O' ^ O' uI uI uInInnI nI vI iMI IiDI uI uIir.I w1 iDI oI inIuHI oI BdosttaECdfidicatasiisascsifl 0<o<Oae<Oa0<0aee<a<eao<e<aee^a0M r*s Cf"O* i1 i/N Imt --1 w 44 44 w 44 w o Qm c- o fi 0 p. 0 fi Oc0v fi fi fi fi *- a: c o CN l/S r*> KSO cOc' 'J-\S <t i *4* SO sO C-l r-* <-> V in i/' -9 i/' O' 'O i/*k i/St ITS sy sr^O. utn CNI o _ o O' fvj \T) j <-> -- o Os oO' o O' sO 1 (NJ <bl r- r*- *7 o SC i/"i f^S w C 1 _i r, W 44 44 44 44 H os Ql lu H H a 5 fi fi , a. U 44 w a aa s*' X X X X -4 4 44 B > > H U V 44 44 a V c yy CO CO fi Q. U B s fi o & B fi 0) CQ c XX --4 06 fi fi fi fi 4 4) > u u T3 5 3 eu O * <Q CQ CQ W O U *4 V o e C o o fi Om 0 CJ H (Q C w 44 44 44 44 to CO CO CO CO CO CO 10 IQ cQ 5 5 ac 5 ? C9 as V 01 ^4 fi OS U H o 0 <s psj u > fi fi 44 CJ o X X 6 B o c C C y CQ OOOOOOOOOO oooooooooo IIIIIIIII S BaQ>o>o>5.5---->oso>s OO *- s3 3 >t/>SOCJ O V V* H ucru>,,k>B_4S0CiOCftlOlg>- >ua- S_06-QO>0Sotto^ -o _ -- r. CN r. -* I | aaooooaooo WZb<KXU3Z cozcozxwzcoeqoe h1b1i1h1h1a1a*a1n1s1a OOO'O'O'C'O'C'O OOOOOOOOOO 4oi >-oiJ.4fitN.4i NJi(NNiUNi<NJi fM4i NeinNiOaiOsxiOxiXM<iN<i(xNttO-i Oti.i ^ w n n rn ^ ^ ^ ^ ^ OOOOOOOOOOOOOOOOOOO Hr*** u Vi ui in n u n (0 KBCcecesteKBi r~.r'.r-.r~.r-'.r-.r~.r- III1IIII taaaiooatsdta KKKKKosaiee in in IA I/) VH/l 1/1 vi CbaL: -- 5 HO zzzzzzzz ABD00185717 hU- v> u3 in /U--- V) V) > w a. KKv <y <i <r *- H MCU *W*. O-- fi iaals.l tf--tn.> oooooooo OOOnnnnpi Or>O<*OinOioOOOOOO0 i/iininini/ii/iinv) sonoiiiscs: 0305e*0<l t/i az u o-- OHfoOtS. H<OO-J OS fOt. fOt. f0t. ^* "St*f z z *z^. uwt/inininiAin 3,3355555 cm n r1^.r1~r~1r~)i1^r1r,.1r~. oooaoaaa u uZ ft ui .bi .Qi mi mi aicQi ai oH AZ O^<OvrOti>vO,'nCn'ft'nfttrOt w5 z oooooooo B-27 I X39WIN JOT ^s S .* % g^ Qg< *Q ges Is t\ DISC SIZE NLIfflER OF DISCS DESTRUCTIVE TEST REQUIRED* tor APPROVED (YES, NO) Uj ABD00185718 1 B-27 -- * A l l ru p tu re d is c s in VCT-l 'i.*rvicc. & ABD00185719 D-300 REACTOR Date Installed On Reactor Location Lot No. Design Pressure At 70 F Disc Size Installation In iolder Observed Bv Test Pressure Tested By Test Observed By Installed On Reactor By Installation On Reactor Observed Bv Date Removed Reason For Removal t Removed By Burst Pressure Holder No. i______________________________ _______________________________ B-27 (Example Copy) A ABDOO185720 B-28 ABD00185721 (conoco) Interoffice Communication To From Veldon Messiek, Chemical Plane, Aberdeen Cindy Ziobro, MED, Ponca City Oate September 27, 1982 Subject RESULTS OF TESTING RUPTURE DISKS AT BS&B - ABERDEEN B-28 Conclusion: Burst tests at BS&B showed that damage in the center of the dome is much more critical chan damage in the outer radius. Testing also showed that changes in dome curvature and height, due to damage, are much more critical than scratches or nicks which do not change the curvature of the dome. Discussion: On August 23, 1982, John McCulley (PED), Cary Brown (PED), Craig Johnson (MED), Renny Fritz (OKC), Veldon Messiek (Aberdeen) and Cindy Ziobro (MED) attended a meeting with 3S&B in Tulsa to evaluate the scratches found by the Aberdeen plant on lot 82002673-1. These were 6" disks which were rated at 189 psi at 72F. Several disks were burst as thevwpre, wnen they were received at Aberdeen. One of these disks ruptured psi which is below the +5% tolerance. The attached table shows the results of all of the tests. Some of the disks were intentionally ''damaged1' by Conoco in an attempt to determine what types and sizes of damage were critical. BS&B have done testing to determine the reversal pattern for the SB90 disks. They have shown that the disks should begin reversal from the center and then rupture. Figures 1 and 2 show some of the disks after the rupture. After the rupture some disks appear to have opened evenly like Figure 1. Others appear to have rolled through the reversal and started the rupture on one side (Figure 2). However not all disks which opened unevenly ruptured at a low pressure. Figure 3 shows a disk (No. 3) which was damaged with a large dent. Another theory on the cause of scatter of burst pressures within one lot was the dome height. Disks are made with a set hydraulic load. Thus the dome height may vary from disk to disk within a lot. Dome height was recorded on the majority of the disks. No correlation could be drawn from this data. Perhaps, the most significant test was performed on disks 13 and 15. These disks were damaged in the crown area and the dome height was changed only 0.011" and 0.006". The damage was very difficult to detect without measuring the dome. Both disks ruptured below the +5% pressure limit. Therefore any such damage occurring after the 90% proof test of the disks could go unnoticed. If the pLants want to monitor this type of possible damage, the dome heights would need to be measured after the 90% proof test, prior to installation. Then the dome heights could be measured after being in service and compared to the original height. If a change did occur, it would prove that damage was occurring in the process. ABDOO185722 B-28 Weldon Messick Page 2 September 27, 1982 Samples of the scratched disks are being prepared for each plant. This will provide a reference for the mechanical personnel involved with inspecting the disks for damage. Cmay ^iobro Engineer, Metallurgical Corrosion and Metallurgy Division jks cc: DDD CSJ File John McCulley, Ponca City Cary Brown, Ponca City Renny Fritz, Oklahoma City BURST TESTS FOR BS&B S-90 RUPTURE DISKS X La j=o> O 6Q c 3 C 4J 0) ai u L3xa <cuo Q E "3 05 a.u C oj u u3X\ c. 0 'X rH 1 3 4-1 15 c. CM NO O' -H --4 c 01 > a; u a c 05 C. O ABDOO185723 B-28 00 CO -H -*n a 01 > 0) o 0) c a **N o to i--i ij 0) Q. o -a O' CJ f-J c 05 o, o a H u 4-1 c 0) g 5 o o 3 .c u 0) La o e -T r-v o 05 c o c. o rH 3 4-1 4-1 x at a. 01 HI c r. O 4_i 05 La o e "O o c <r 0) CO c. --t o X 4J 3X 3 0) La 3 OJ 4- .c ai u a. c ac c .c O 4-1 0 V4 o CO T? CO ^4 C o Q X Ct 4_> 'll p c oo cX oX X <-H lo* co o >, 3 1-1 4-1 >--1 4-1 *a 3u a- c ex 3 05 4J rH X X rH 05 o < o Oi .C c1 rr a -- -- Xo *aH 4J 01 0) 1-1 u i- o o oo G oo X X o Cr^N c 0) 4-1 >-l 3 -a eo X 05 H X 4J X 01 X Cl u 01 CL. H CN f- C-I) fv, vs o CcH I uai z C o H 4-1 X rt 05 3 J3 C 05 r>* o 4-5 i/'t o CO rH u O -H XX r4 4-1 G - CO rH rH s H 01 c rH iH ao 3 3 H 0J 3 *0 o -- < oj X 05 01 co 4-1 m 3 --H 4-1 La JZ 05 i--( cO X r* 4-J 0) 4-1 _3 CO ao H r4 05 rH -- 3C 01 2 c 3 0 La fj lu o La <U 0 CN sO CO w H Xu 05 -- 1 0) 4J V 3 L>J c X O o i- U 0) 05 u T3 4J -X 3 X c 05 0 La JZ X *o 0) JZ X 4-J 05 o o 05 4J CO -H La <--H U 0) 10 05 u 00 La 3 O u La X LJ >, . X -* X H 0 05 X O 4H 5 3 T3 3o C 0) N-a lo 35 X 3 -r rH un rH 4J cil -a OJ sz c V 3 La U u 33 X 01 -- L. 4-1 0 o; 0 Ol m L- HJ4-1 X 01 -- u 4-1 4-1 -- 3 CP L. H J 3 X ra i_) c r- 00 3 H La 03 O. O 4J 4-1 CO .C 01 4-1 3, La _ CJ 3 X 4-1 05 CL. > 3 i--a 3o JZ 4-4 0) La c3 o a. X 01 u j-i 3 La a X 4-1 * et .aj -H rH ?n m La rH CJ . S> rH X 05 G 4J U U X 4-1 r- cO ra -4 o t: y X r- r c c o -o <Lj x a E- tHn a o z < S3 U cn r-t <r A B urst Pressure psig O' CO . r-H 0c0>1 -0ca1 o0a. NO OO h >v r0c0>H) T0O1 c o oQ. ABDOO185724 oo cH 0coo. CN OO 4_i 30 Tj 3 01 CO u01 > 0 0O0N r-4 >1 a ?0 -o c0 <y c. o CM ON .rH >. 0>) a 0a1 r3 oc. ( H cX >4-1 H o CO 01 H o u o. TO 01 a. o o <J a 0 >H 4J CO 0> co a. W 0) 0 -S3 0 H JZ JO 3 0) y 4-1 H TO 4-1 cz V) H 0 <r -- i--l Q 3 0 rH CO H n TO 0 E 01 < 4-1 4-1 <3 >, a. 4-* --I *H <0 o> c I--a1. 4-1 e o CO CO 1 CO O H 0 0 r* o 4-4 0 uo cn 0 c >\ *H >H 0 01 0) -C H 0 n3 C cn 0 TO CU CO .33 z C 4J 4-1 O >-. 0 .3 rH 0 (*- -- 4-1 oo3 4J c 01 H o 0) CO X 0 >- c4-* TO Q. *H a 0 3 CO TO O CJ JJ rH cn rH H 0 . t-- TO co c U4 4J 0 03 cu a. cn z <U 0 \C TO 0 *3 --H " Z c o *H CO rH --H O' rH Jn ci--1 >aaj; -a 0c acu. o 0 00 0 TO .c 0 4-4 u J= 0 00 ,3 3 oo rH H c JO CN 4-1 m 0 TO H c c4-1 0 3 0 O ca 3 JO jo cn 4-4 rH rH cn . cn Jtl 0 X to rH H 0 *3 JtC -a cn CO H Z O TO o C1--N1 c >a a; 'O00c)) oCi. J* cn T3 B o cn 0 oo 3 o 00 a. 0 0c a0 rH rH rH 0 0 J-l Uo 0 CJ > cn 0 cn c H 0 TO 3 0c 0 B-28 Disk. A lte ra tio n s (1 ) T e sts were made on 6 " d is k s , Not No. 82002673-1, ra te d a t 189/72 Pressure Tested to p s ig O rig in a l D isk C ondition 11 o r- rH ,C 00 3 o cn um JO rH 4-1 iH 0 c. O Jtf X - *H cn to 0 .c <*- ao 4-4 0H IH 0 ah XB 4-4 0 u .c 00 0 H JO -4 H 0 E0 o H B H J>C *H cn 0 -H cn U TO E O o U 0 H cn jo cn 4J 0cn 0 JO JS, u 4J OO &3 ao iH 3 Vj rr pH 4-4 rH 0 cn H34 TqO; cn rH 3 0O pH j: jo co u rH M cn 0 0 >. m > u a- 0 0 JO cn a h --t o in cn 0 JO CN U -T U H 0 l-i rH y 4-4 0 JO B 00 .H H H 1--4 0 5^ Vuo 0y >X CN r-. 1 rH m vO 'T in rH rH H rH ,. cn cn 00 JO ya 4-1 4-1 B0 u yy cn cn 2o o z 1j CO <r cn m iH rH -H rH , cn cn 00 yy 4J 4J 00 u yy cn cn oo zz no r- oo OOn Disk. No. BURST TESTS FOR B S M ^ - 9 0 RUPTURE DISKS ABDOO185725 00 c H y CO > 0< O) <y u i- 3- 3 \0 CO -3- o JO m CO rH nH >> x <-4 u >s i-i a, fH c CD 0/ H CO > t-t ai CO 3 CO TO *3 yy cc 01 y c_ a. oO as sO rH i--j e 01 > X TO a c 0) a. o *H Ey Oc fli <r H H s rH CM H >o o TO <H o Go CM H 0 4-1 Oa CO 4-1 H y a u e co co y i-- o a f M TO 00 *H U 0<--1 cy y c H y co TO o CN .n u cu m X E rH &o *ec O Mc y c rH H a < 3 B r--1 CO X 3 o TO JC c j= TO U CO o u X U M G y H 01 y OG 4-1 Q 0) 4J y 4J X TO gj TO 3 X. 3U X3 co ai Xay * *-- z: y z: o H o 'X O U3 TT 00 CO G -H cCuOi Mianj aCO eu E- vr-r c o H TO y c6 CoJ 0 o on sr H rH CO . H CO CM CO a y ur y JO (H JO y y x H rH j-j cX 00H .U 4-1 y j= H CO 00 X u y co Uy O O -H o Zx z CO Ln <H ~H . CO y J0 u 4_> X u y 'X o z CO h O QZ u. o CrM- caos m x Ga X I C"r rv-O- CN o O CM CO o z l-oJ CO X co H a vC c o y T5 l0-)i X 3 Si u CO y B-28 & , I I 'i ABDOO185726 B-28 A \ k Figure 1 - Rupture disk which opened evenly upon rupture. This is typical of disks B, C, 1, 5, 6, 7, 9, 10, 11, 12, 13, 14 and 15. 7S Figure 2 - Rupture disk which opened unevenly. This is similar to disks A, 2, 3 and 4. ABD00185727 B-28 ft Figure 3 - Dent in rupture disk 3 which was predamaged and caused a rupture below the +5 psi limits. i ABDOO185728 B-29 ABDOO185729 B-29 SAFETY SYSTEMS September-9, 1982 fohn McCulley, Chief Process Engineer Conoco, Inc. P.Q. Box 1267 Ponca City, Oklahoma 74603 INFERENCE: AUGUST 23, 1082 MEETING CONCERNING DAMAGE OF S-90 DISKS. Dear John: This letter is a foilow-up to our meeting of August 23, 1S82 concerning "low pressure breaks" of 5-90 - 4", 5", and 8" disks. After discussing the problems with your people from Conoco and our engineering, quality control, and manufacturing people; we submit Lhe following suggestions and comments: 1. Regarding scratches on all 5-JO disks irrespective of the sice or material. a. Internal procedures have lean instituted to minimize scratches of the flat sheet stock. b. However, scratches cannot he eliminated and as you witnessed scratches have no noticeable effect on premature bursting of the disk within limits. The primary limit according to our testing is the depth of the scratch. As long as the scratch ices not exceed 70% of the thickness of the disk, no noticeable change in burst pressure cun be de fected. Therefore, we suggest as part of your quality control procedure that you reject disks only when a scratch exceeds 50% of the disk thickness. This would leave margin for error in measuring the depth of scratches. This will be a quality control procedure wo will instituted at 5S6B as well. Regarding damage of the disk: a. An pointed out in the tests, damage in the crown of the disk due to dropping, hanging, etc., will lower the burst pressure. V/c have knov/n rhis for many years. Mince A BSAB SAFETY SYSTEMS, INC. 7455 EAST 4GTH STREET * PO. BOX 45590 TULSA. OKLAHOMA 741450590 PHONE 918/622-5950 To- John McCul'ley from: John P. Clark ABDOO185730 Page 2 of 2 B-29 this damage is often not detectable by visual inspection, we suggest that you proof pressure test each rupture disk to 9p% of the rated burst pressure. For a small premium we will do the same with your orders. b-. Also we recommend that you stress to those people within Conoco,who actual handle the disk,that if the disk is dropped or damaged prior to installation that it not be used until reinspection and proof pressure retesting to 90% of rated burst pressure.. 3. Regarding conformity to these new specifications (i.e. Scratch depth and proof pressure testing): ' a. RSSB will provide a letter of conformance with each disk shipped if you feel it is necessary. John, I would appreciate any comments you may have. Very truly yours, John P. Clark III General Sales Manager JPC :psb cc.: Veldon Messick, Senior" Process Engineer Conoco, Inc. P.0. Box 91 Aberdeen, Mississippi 39730 Jim Rapp / D.D. Frederick Tom McOuilkin / A F G Keith Games / BS^B Lou Harris / RS&B Ron LaPelle / BS&B J lm Hale / BSB Sam Ou / BS&3 _ B.C. Navel / BSSD Wayne Ferguson / BSCS 9 SAFETY SVSTEMS.tNC EAr;r .,rth s i ne E r p o no* riu sa Oklahoma phone 9ie/622 39o ABD00185731 B-30 .....ABB0Q185732 ....... ..... .. ................. (conoco) B-30 Interoffice Communication To From P, E. Markey M. P. Blackwell D# August 2, 1982 Subject Reactor Pressure Check Operating Procedure Attached is a proposed operating procedure for pressure checking vinyl reactors* The procedure is designed to efficiently pressure check, reactors and protect reactor rupture discs from damage during the pressure check process. The procedure requires that the testing be witnessed by approved observers. Please review and jreturn any comments to me by 1 August *7, 1982. Uct&f //t<^ Mickey'Blackwell Vinyl Operations Engineer ros c: JF, CRM, Vinyl Shift Supervisors (5), ILH, AHS, RAF,(gg& VLT, DLM Operating Manual Old Unit PVC Reactors Page 1 ABD00185733 B-30 1X1. OPERATING PROCEDURES (CONTINUED) N. Reactor Pressure Check General Information Prior to the startup of a reactor after an extended outage or following maintenance work that involves breaking a connec tion to the reactor such as replacing actuated valves, cleaning the condenser tubes, or replacing a rupture disc, the reactor must be pressure checked. This is done by filling the reactor with water until a specified pressure is reached. A properly performed pressure check shows that no reactor leakage will occur, either inward or outward, during subsequent operations. The reactor must be pressure checked to 90% of the pressure of the lowest rated rupture disc on the reactor condenser. Use the following to deter mine the pressure required for a proper pressure check: Reactor Size Lowest Rupture Disc Pressure Required Pressure For Pressure Check Large (32,000 gal.) 205 psig 185 psig Small (18-22,000 gal.) 185 psig 165 psig The operators involved must be extremely careful during pressure check procedures not to burst or damage a rupture disc. Bursting a disc during the pressure check will cause reactor downtime to change the disc. A disc can be damaged by hydraulic shock if the reactor becomes liquid full during the pressure check. A damaged rupture disc may burst at lower than the rated pressure, causing ABDOO185734 B-30 ^^rating Manual Old Unit PVC Reactors Tage 2 III. OPERATING PROCEDURES (CONTINUED) Reactor Pressure Check (Continued) General Information (Continued) leakage through the reactor relief valve. In addition, a damaged disc may not burst at the rated pressure, which could allow a reactor to overpressure. Any reactor pressure check, must be witnessed by an approved pressure check, obeserver. A list of approved pressure check observers and a call list will be kept on the Vinyl Shift Supervisor's bulletin board. The pressure check observer must watch the pressure check from the field as it rises on the reactor and must verify the final reactor pressure. The reason for the pressure check, the signature of the approved observer, the * final reactor pressure, and other test findings will be noted in the reactor pressure check log kept in the Vinyl control room. NOTE: PVC reactors will operate no longer than six months between rupture disc changeduts. Procedure 1. When the reactor is ready for pressure check, the lead operator will move the mode advance switch untiL the reactor is in the SWIRL node. All the reactor valves should be closed and the lead operator will check to make sure that they are. ABDOO 1857.35 B-30 Operating Manual Old Unit PVC Reactors Page 3 III. OPERATING PROCEDURES (CONTINUED) N. Reactor Pressure Check (Continued) Procedure (Continued) 2. Turn the reactor agitator off. The lead operator will check the amps to make sure that the agitator is not running. 3. The lead operator will notify the reactor "A" operator that the reactor is ready for pressure check. He will then instruct the "A" operator to shut off the reactor lip seal flush, to shut off the sprayhead flush, and to open the top manway. The lip seal flush must not be turned off until the agitator is shut off. The "A" operator will notify the lead operator when the flushes are shut.off and manway is open. NOTE: Manway opening procedures are listed in Section III, M of this manual. 4. The lead operator will take the following steps to fill the reactor: a. Check to make sure the charge water pumps are available for use. b. When the charge water pumps are available for use, notify the "A1'2 o3p4erator that the reactor is ready to be filled for the pressure check. ABDOO185736 B-30 Operating Manual Old Unit PVC Reactors Page 4 III. OPERATING PROCEDURES (CONTINUED) N. Reactor Pressure Check (Continued) *3 Procedure (Continued) c. Set the charge water temperature controller down to 100F. This will conserve energy while pressure checking the re actor. d. The reactor hot water charge water and main dump valve must first be checked for leakage. Turn on "AM charge water pump and open the discharge valve. The charge water meter should count a few counts and then stop. Wait about 15 seconds to make sure the meter does not count. If the meter does show additional counts, it indicates a leaking hot water valve. Report this condition to the Shift Supervisor and note it in the pressure check logbook. e. When the reactor hot water charge valve leak check is com pleted, open the hot water charge valve so that the reactor charge (main dump) valve can be pressure checked. The hot water counter on the panel should show a few counts, then stop. Wait about 15 seconds to make sure the meter does not count. If the meter does show additional counts, it indicates that the main dump valve is leaking through. Report this condition to the Shift Supervisor and note it in the pressure check logbook. f. When the reactor main dump valve leak check is completed, open the main dump valve. ABDOO185737 B-30 Operating Manual Old Unit PVC Reactors Page 5 III. OPERATING PROCEDURES (CONTINUED) N. Reactor Pressure Check (Continued) Procedure (Continued) g. Turn on "Bm charge water pump and open the discharge valve. Using both pumps for pressure checks will reduce the time to fill the reactor. h. Monitor the charge water meter counter to make sure water is going into the reactor. i. Fill the reactor until water reaches the bottom of the w Te reactor manway. When notified that the water is coming-out. the manway, shut the reactor main dump and hot water charge valves and the discharge valves on "A" and "B" charge water pumps, then shut down the pumps. 5. The "A" operator will close the reactor top manway, and notify the lead operator when it is closed. NOTE: The "A" operator will inspect the manway "O'* ring for wear or defects and will replace it, if needed, prior to . to closing the manway. 6. The lead operator will inform the reactor "A" operator chat water will be put into the reactor until the reactor reaches (3Q^isig (8Q psig for D-7Q0 or 745 reactor). The pressure check observer will go to the top of the reactor and monitor the pressure on a reliable pressure gauge and will inform the lead by ABD00185738 B-30 A Operating Manual Old Unit PVC Reactors Page 6 III. OPERATING PROCEDURES (CONTINUED) N. Reactor Pressure Check (Continued) Procedure (Continued) radio of each 10 psig increase in pressure. NOTE: It is the "A" operator's responsibility to keep pressure gauges in the unit changed out as needed. The lead operator will then take the following steps: a. Set the charge water temperature controller setpoint back to the normal charge water temperature. b. Check to make sure all reactor valves are closed. c. Start one hot water charge pump and open the discharge valve. d. Open the reactor hot water charge valve and the main dump valve, while monitoring the reactor pressure. e. Fill the reactor until it reaches 30" psig pressure, either by the control panel pressure indicator or the gauge in the field that is monitored by the "A" operator (Fill D-700 and reactor 745 to 80 psig). This should take 20-30 counts of water (167 counts for 745 or D-700). f. When the reactor reaches the pressure specified in step e, close the reactor main dump and charge water valves, and immediately close the charge water pump discharge valve and shut down the pump. ABD0.0185739 B-30 ft Operating Manual Old Unit PVC Reactors Page 7 III. OPERATING PROCEDURES (CONTINUED) Reactor Pressure Check (Continued) Procedure (Continued) 7. The "A" operator will proceed to the reactor catalyst bomb and will use the following steps to finish filling and pressure checking the reactor. a. Make sure the catalyst bomb is empty. b. Close all the valves on the bomb except the one to the pressure gauge. c. Open the valve that supplies high pressure service water to the catalyst bomb. d. 3e sure that the valve which separates the bomb from the pressure gauge is open. The pressure should come up to about 200 psig and the HPSW meter will stop turning. e. Notify the lead operator and the person on top of the reactor that water is about to start going into the reactor through the catalyst bomb. DO NOT begin water injection through the bomb until the lead operator is ready (watch ing the control room pressure indicator) and the person on top of the reactor is in position and watching a reliable pressure gauge. ABDOO185740 B-30 Operating Manual Old Unit PVC Reactors Page 8 III. OPERATING PROCEDURES (CONTINUED) N. Reactor Pressure Check fContinued) Procedure (Continued) f. When the lead operator and person on top of the reactor are ready, open the catalyst injection ram valve for the reactor, using the local hand switch at the catalyst bomb. The catalyst bomb pressure should drop to about 15-20 psig above the reactor pressure (due to the head of liquid in the reactor) and the UPSW meter should resume turning. .8 All three operators, the lead operator, the "A" operator, and the person on top of the reactor will monitor the reactor pressure as it rises and will communicate the pressures ob served at 10 psig intervals. The pressure reading shown in the control room and on top of the reactor should be identical. If they are more than 5 psig apart, shut off the water going into the reactor and change the gauge or have the pressure transmitter recalibrated (this takes an instrument maintenance work order). The pressure shown on the gauge at the catalyst bomb should read 15-20 psig more chan the gauge on top of the reactor due to the head of liquid in the reactor. The pressure increases should be no faster than 10 psig every 10-15 seconds to allow all three operators to communicate the pressures effectively. As the reactor becomes full and the pressure rises faster, the "A" operator must crack the manual HPSW valve closed to slow the rate A ABDOO185741 B-30 ^^erating Manual Old Unit PVC Reactors Page 9 III. OPERATING PROCEDURES (CONTINUED) N. Reactor Pressure Check (Continued) Procedure (Continued) of pressure increase so that the pressures can be communicated effectively. 9. The lead operator will inform the pressure check observer when the reactor high pressure alarm comes on. This information will be recorded in the pressure check logbook. When either the indicator in the control room or the gauge on top of the reactor reaches the desired pressure, the "A" opera tor will immediately close the HPSW valve to the catalyst bomb and then the catalyst injection ran valve. The "A" operator and either the chief operator or a supervisor will check the entire reactor from the bottom to the top of the condenser for leaks. If a flange or gasket has been changed, check these very closely. All rupture discs'' gauges must be checked to make sure they are not leaking. The lead operator will monitor the reactor pressure. If the reactor holds pressure for ten minutes, the pressure check is completed. This pressure must be verified by the pressure check observer on the gauge on cop of the reactor. If the reactor loses pressure, check the reactor for leaks and have them repaired. After the leaks are repaired, the reactor must ABDOO185742 B-30 perating Manual Old Unit PVC Reactors Page 10 III. OPERATING PROCEDURES (CONTINUED) N. Reactor Pressure Check (Continued) Procedure (Continued) -jj be brought back up to at least 150 psig.^HPSW through the catalyst bomb to make sure that the leaks are stopped. 13. When pressure check Is completed the lead operator will open the reactor sewer valve and main dump valve and drain water from the reactor. When the reactor pressure reaches 0 psig, the lead operator will open the reactor vent valve to complete draining of the reactor. 15. The "A" operator will vent and drain the catalyst bomb and then will turn the lip seal flush and reactor sprayhead flush back on after verifying with the lead operator that there is no pressure on the reactor. 16. The MAM operator will notify the lead operator when the lip seal flush is turned on, ar.d the lead operator will turn on the reactor agitator. NOTE: DO NOT turn on the reactor agitator until it has proper lip seal flush flow. ABDOO185743 B-30 Operating Manual Old Unit PVC Reactors Page 11 III. OPERATING PROCEDURES (CONTINUED) N. Reactor Pressure Check (Continued) Procedure (Continued) ,> 17. The lead operator will monitor the reactor amps as they fall to the no-load amperage. He will then notify the "A" operator to watch the sewer bullseye for when the reactor comes empty. The "A" operator will notify the lead operator via radio when the sewer bullseye shows that the reactor is empty. If the ''A" operator is unsure whether the reactor is empty or not, he will notify the lead operator to run some water through the condenser rinse nozzle to make sure the flow starts and stops in the sewer bullseye. The lead operator will follow steps 2a - 2e of the Rinse Procedures to start flow through the reactor and then shut off the flow according to Rinse Procedure steps 21 and 2m. MOTE: Do not flush water through the charge manifold to the sewer to check for the reactor being empty. This - could give a false indication because no water will actually flush through the reactor. The "A" operator will observe the water flowing through the bullseye and then stopping as the reactor is emptied. When the bullseye shows that the reactor is empty, the reactor is ready for evacuation and charging. A ABDOO185744 ABDOO185745 (conoco) Interoffice Communication To Distribution From M. P. Blackwell November 15, 1982 Subject PRESSURE CHECK LOGBOOK B-31 Attached is a copy of a page from the vinyl reactor pressure check logbook. All reactor pressure checks are to be recorded in the logbook. Guidelines for filling out the logbook are included in the front of the logbook, and a copy of these guidelines is also attached. It is the responsibility of the pressure check observer to make sure that all of this information is correct ly recorded whenever a reactor is pressure checked. If you have any ques tions or comments on this procedure, contact the Vinyl Operations Supervisor. Vinyl Operations Engineer bis Attachments c: JF, CRM, PEM, DJM, Vinyl Shift Supervisor (5), JLH, AHS, RAF, VEM, VLT, DIM, JCG, JPV, SCH, MLN, FGJ I9 (rviPt $ "Title - rV/ef of p ret S .' re c. lr< k-. Atfrnc* 7<f-'J a/fa^ p,mvtf. link Ma i botjurS f^r <rAf-/j /**&> feat fn). %Atn - N*/*nf*rt Ozr*g\i\:,L - Vn**k- oL srr utr 5 (\a&C. & Chrtf&e KiUtfr Le rf-A?. (fa * M>)"^5S- <-LA *4 fin* ibid i^'iTk \^ier <x*il verify 'fid if*!v* {ice* s/f /*ak (/f t&'jfili ilovjs/ &*\ vjafar (Cli/iftr t4 /5~ A). TT y^L-e Irei4; fiuu*i-/f!ttt*,ct ,,o'o/ k. t refer sfc*r/ef de fa OS/ sa/he. 7Xs /< e/,r/ /? <*<* m/4v Pffi*f rfredr. Hct U^A?F/e Cflfltee If/iA? (Y?1 e, M)^ Mti-i readier cLreft df>*e/, pressure cftip y/,? re&c 6* /a/ t*s*t fee l<- toLtfa f,((i^ reoeftr, // ccc/ifs sfet/ff 5 lev os/ u'a Ur /**> /*r 4 fS Se. e &wfs io /X fa & rs (foie/f. T~f fO-Pc /r'cl/jjCK motJ-in *<-<* u/ork order' ^deJd lop IvrueJ I*. OS/ Sant#. Ok\Rf>Ns. ? (/ Of //c)"~ ~Pf-rSivre 'fra*\$m,YK*ff 9o Cfrv // poHi n-d<fK kcr iftjff f?t w tffuH fo ^ -rt e-f We r*oef*y 'f*p> 'ffe reath /// fkt pfekd, s/o'fj c (a*<f- ^ VtCcfffi} rf J fuff (1 corrttf . VJO f l Orcftr mud pe ~/v r / fj fo Czf'kfkf ^4 ~fro A/rfit t f/fr ftlGrt T^ZrSlt/ff | " $pcOrfi p/rSsvrf kjk p>frtSS*f't <xUrm ca*iP erf /. 44j $-7td oAJ 79f JauC 2 prsfsvfe pLrmS, 'Bc'ff shrefJ he rf (Ore/stf, j$rsst'f CrffUeo 77 " kbeerf pt+sstf* ifd realUr tviO S prriivr'Z. t(f<.k*c( fo. [ Sic<-`lf le. fSiy ~&r 7V/-7^V- a*J )-3^c' 'llreryl 1>-6TO ^ shM he. /SJfS'j ftr b-7O0 e^ef 79$\], Tftf^svte CW fpMOeeb- Ohsrrttr sno^f stf* J,,? a. frj"' prroivre ckeik )* ierf?/efr>J tfA'/ Y7& re*tkor /s ok^y ~te /e juf \oolL /nA' N&un*.i fp9?f'f,PA/*. Jt'OTf: lOkfirt tL'u Tfa r^^lor w;*W cste CLjt G^r fj1f reirtic-j jfldA^wa reaefer s fovlf he Piled v* f -follt^i^i| ptr^vre Js rro(.le$ l D-7CC 0J ft. 7^5 .' / 2.0 tcc * 7^f-7*/*V; TiO ABDOO185748 B-32 ABD00185749 (conoco) Interoffice Communication To : W. F. Higginbotham From : Dave Mahler Oat* : August 3* 1983 Subject : RUPTURE DISC ORDERS B-32 When ordering rupture discs for vinyl reactor service (6" and 8" discs) please specify the following items on the purchase order. 1. Disc size (currently done). 2. Type S-90 (currently done). 3. Nickel material (currently done). 4. 0% Mfg. Range (currently done). 5. Burst pressure (currently done). 6. Letter of certification required (currently done). 7. ASMS code stamped. 8. Test each disc to 90% of rated burst pressure. 9. Replaces lot no........................ 10. Serially number all discs (i.e., if lot 81005165-1 has 20 discs. the discs would be labelled 81005165-1-1 through 81005165-1-20). Dave Mahler Environmental Engineer bis c: CRS. RAF ABDOO185750 B-33 ABD00185751 To: C. R. Snowden 8-33 ; A From: Date: Subject: V. E. Messick and D. A. Miller October 29, 1984 REACTOR RELIEF VALVE BLOWDOWN RING SETTINGS VIS1A All reactor relief valve blowdown ring settings have been changed to 30 notches. Attached are tables documenting the changes. Attachment c: JT, JWW, RAF, DWH, CWT, JLH ABD00185752 C 3M cC 3 *3 0) 3 44 z 0 4J pH 0J 03 c c c ooooc a r" A A A rr A A a A A A A A A A A A A A A A A A A A A A A A A A A A A A 6C C c 3 re -H C c 4-1 3 CO 3 4J pN 0 4J X pH 01 b- 03 C/3 u c ft u X "* ft re V. IA -- A 0 fs. X CM M O' O' rs rs A O' CM mm mm mrn A O' O' rs 0 CM O' A CM CM w (SI cm CM CM CM M A mm A mm A CM CM CM mm mm A mm mm mm CM mm mm CM * re re re re re re re re re a re re re re re H H mH MH kk ki H H PM M H b b u b b k. b b k. w k. k- Ik k. b b b k> k- k> b b k. Ik k. k. >k Ik u re re re re re re re re re re re re re re re u. b. u. u- u. u> Lu u. u. b. bk b. 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A rs rs rs rs rs mH PH MH P-i pH H -k MM MS n re re re re u Vx x oc re pH mH c re T> re C re re o re c re re re c re re m4 re pH re C c re H pH mH 3 ki mH *3 re c re re re c re re re C 0 CJ X X X 0 o X w X X 0 CJ X X X 0 X X X o 0 o X X X X 0XXX XXX O u *0' *0 <0 _ 0 CM 0 CM 0 CM 0 CM 0 A 0 A 0 A 0 A fs rs PS. rs rs. rs rs rs fs A A AAAA A o o0 0 0 0 0 0 0 o o o o o o o o o ors A fs fs rs rs o O O o o o o \A a o o o a0 1 IA *0 4A 0 1 IA 0 1 A 0 1 A 0 1 A 0 1 A 0 1 A 0 1 A 0 1 A 0 1 A 0 0 0 i 0 0 A 0 A 0 A 0 A 0 A 0 A 0 A 0 A A A a A A C 0 o 0 0 1 0 1 A > A A A 1 tt-a ABD00185753 S e a l Removed S eal B rand E x is t in g New Blowdown Blowdown R e a c to r L o c a tio n Company M a n u fa c tu re r S e ria l o Cl Cl o Cl Cl ci eci cci ori o oci cci \cccff'voecjiAcoNC -- -- Ci CJ N N (N -- PsJ & to to N H H C bi b 0) U b~ Ct ec b. b- t- tc- V Of) 5 CO CO to mm 3 H c m4 0t .* mm mm ^4 to 0) (0A) co wCO co caCoOt o u CO co mat caCo>O CO at to co at to Ca(/0tj > > zo z0 eo at zo z0 z0 z0 zO to < inl Cml O mm < M Cl in o o 9mm < 1 XX X Cl < I rX Cl Cl -- mm c r** U H O' x Cr-l U H oc mm Crl a: H mm c r-. b2 H m mm Cl rW H at' co i- fsj -c OL at z iinn 0b0: oH z o *D *U O a o "O at wat uat wat wat 4abt 4aJt to H w V4 hto w w to H U u trot W 1* a **o4 co t*J* co *o4 CO ^u44 co o H -4 CO Hv ^4 to Mo 4 b4buCO CO CO CO u. (fa 0to c otco otco o CcO o tco tcoo 0 cCO 0 o 0 o u 0 0 o cOo' n O' -- 0 11 i1 ii ao 00 f- r* r-. <O' O' CD rnm O' OO' CM O' Cl O' 00 00 CVJ 1 fMI1 CN 1 CM i| CM 1 (SI 1 CM i 00 00 cc CO oo 00 r- r-. r-. r- r*. r~- r- Number S e ttin g Tag No. _______ ____________________ _______ >___ S e t t i n g ^4 ^4 at Xco at Xco ^4 4 at X to o c 0 ^4 mm at X to at X to H at X co at X to t-H at X to o c0 *D c c ooooo o X1 o X|V o o Xa11 X 11 a fs. 11 r-. a11 r-11. O |1 o r-. f1i F-. 1 n* f1i -8 ABDOO185754 B-34 -------------- ABD00185755 pf2oC6S SAFETY/TRAINIKG MEETING ATTENDANCE RECORD . B-34 ", * IC: j>U 4 SATION: fln Kl i/fkj/Z'S' DATE: ~ /5//SY f?.UO '/A__________ NUMBER OF HOURS: 4 T M t <V . OUTLINE OF PRESENTATION (Major points, demonstrations, what was practiced, slide/ tape , film, etc.)- Attach .-separate sheet if necessary. r^rMctpr^ op- ^ oPfctZA-T?$Ai ftt /Cj SL(t~r /hv> Tl/C S TM P M 73__________________________________________ _____ EMPLOYEE SUGGESTIONS AND PLANED CORRECTIVE ACTION: ________________ TRAINEES \f(X>Grt />(^/CC Instructor/Supervisor DEPT. &MO- i i i 1 CLOCK NO. i NAME. (Print) ! DEPT.. 1/l>oh cz. MsS/CfeL i 1 / `'S- . 1'yii . 1 uuy,ue n\v<ls; '1 -/-'-/. ;? . '? ''! -5 i 1 ^ . TT~S:^-'`V^O/V . >-J i ; i r-* a4 1 i rT-^' , /V. /4, rkort/'* iCri 1 1 i , rCLocK ! NO. j 1 1 | j | j 1 NAME (Print) ii !L _ I I 1 1 1 . } 1" ... _ _ ... i1 l .. i 11 1i !i ! 1 1 It :| 11_________ 1 | 1 't i 1 1 ! i . i 1 ii ! i! ! 1 i j ABDOO185756 Appendix C ABDOO185757 APPENDIX C ITEM NO. C-l C-2 C-3 C-4 C-5 C-6 C-7 C-8 C-9 C-10 C-l 1 C-12 C-13 TABLE OF CONTENTS DESCRIPTION Letter, R.A. Frohreich (Conoco Inc) to Regional Administrator, Region IV (Environ mental Protection Agency), January 24, 1980 Letter, R.A. Frohreich (Conoco Inc.) to Wayne Aronson (Environmental Protection Agency), March 4, 1980 Letter, Veldon E. Messick (Conoco Inc.) to Jerry B. Banks, P.E.,(Mississippi Department of Natural Resources), January 21, 1983 Interoffice Communication, M.P. Blackwell to Distribution, REACTOR EMPTYING PROCEDURES (OLD REACTOR MODULE), January 21, 1980 IOC, M.P. Blackwell to Distribution, REACTOR EMPTYING PROCEDURES (NEW REACTOR MODULE), January 21, 1980 Document, Safety/Training Meeting Attendance Record, January 26, 1980 Document, Safety/Training Meeting Attendance Record, January 27, 1980 Document, Safety/Training Meeting Attendance Record, January 31, 1981 Document, Safety/Training Meeting Attendance Record, January 31, 1981 Document, Large Reactor Batch Sheet, Batch 745-918 Document, Amperage Recording, Batch 745-918 IOC, Don Johnson to Robert E. Morgan, DISCIPLINARY SUSPENSION, January 14, 1983 IOC, D. F. Johnson to J.D. Sims, Inattention To Operations, July 13, 1981 IOC, P.E. Markey to All Vinyl Operators, EMPTY REACTOR CHECKOUT PROCEDURES, January 25, 1983 A ABDOO185758 APPENDIX C (Continued) ITEM NO. DESCRIPTION C-15 Document, Training Meeting Attendance Record, July 18, 1979 C-16 Document, Safety/Training Meeting Attendance Record, March 12, 1982 C--17 Document, Safety/Training Meeting Attendance Record, March 13, 1982 C-18 Document, Safety/Training Meeting Attendance Record, March 19, 1982 C-19 Document, Safety/Training Meeting Attendance Record, July 8, 1982 C-20 Document, Safety/Training Meeting Attendance Record, July 14, 1982 C-21 Document, Safety/Training Meeting Attendance Record, July 17, 1982 C-22 Memo, Mickey Blackwell to P E Markey, June 18, 1982 ABDOO185759 ABD00185760 -:____ Conoco Chomieafo Company Oivmon of Conoco Inc. P 0. Box 91, New Highway 25 Aberdeen. MS 39730 January 24, 1980 Regional Administrator Region IV United States Environmental Protection Agency 345 Courtland Street, N.E. Atlanta, GA 30308 Dear Sir: On January 19, 1980, at approximately 6:15 p.m., our plant experienced a minor relief valve discharge. Pursuant to the National Emission Standard for Vinyl Chloride (40CFR, Part 61, Subpart F, paragraph 61.65a) we are reporting this incident to your office. The vessel involved was polymerization reactor D-400. The vessel relieved momentarily thru a 6'* x 8" relief valve which had a 6" rupture disc between it and the reactor. The rupture disc was rated at 185 psig at 200F and 187 psig at 72F. The relief valve setting was 185 psig. The reactor design pressure is 200 psig at 200F. The stack from the relief valve is 50 feet above grade. The release occurred as reactor batch D-400 - 4544 was being charged. The cause of the release was hydrostatically filling the reactor during the charge. This happened because the rinse water from the previous batch was not completely dumped from the reactor before this batch was charged. The previous batch did not completely drain from the reactor because the dump line was plugged with large chunks of polymer. When this reactor charge was about 87% complete, the panel operator observed the pressure in the reactor was increasing rapidly; the pressure was approximately 110 psig at this time. This rapid increase in pressure indicated the reactor to be full. The panel operator immediately shut off the VCM and water charge pumps. Before the panel operator could put the reactor on the recovery svstemt the pressure in the reactor reached 182 psig as indicated by the reactor strip chart. At this time, there was a momentary release thru the relief valve. The shift supervisor was outside near the reactor at the time. He heard the release but it was of such short duration that by the time the shift super visor could turn his head and look up to see what was relieving, the relief valve had reseated. At this time, the shift supervisor closed two water flush streams to the reactor. The combined flow of the flush streams is 0.8 gallon per minute. The pressure in the reactor dropped rapidly when recovery was started on the batch and no more vinyl chloride was released. ABDOO185761 c 2- - c c-i After the batch was recovered, the water in the reactor from the previous batch and the-water from this charge would not dump from the reactor. At this time, it was determined the dump line contained chunks of polvmer which prevented the reactor from draining. The chunks were dislodged and removed from the line by back flushing with water. After the reactor was emptied, the relief valve was tested. The valve was found to relieve at 184 psig and reseated properly. All rupture discs on the-reactor were removed and replaced with new discs and the relief valve was re-installed on the reactor. No personnel were exposed to vinyl chloride from the release. The weather conditions from the plant weather station at the time of the release were as follows: Barometric pressure 30.14 in. mercury, temperature S0F, wind direction N.W. but zero miles peT hour at the time. The amount of vinyl chloride released is estimated to be twenty-four (24) pounds. This is based on a relief valve capacity calculation procedure provided by Farris, the manufacturer of the relief valve. The calculation was based on a two-second release, one percent overpressure of the relief valve and the reactor containing 34% vinyl chloride by volume at the time of the release. A copy of the calculation is attached. To prevent future discharges of this type, the standard operating procedure has been modified as follows: 1. After reactor rinse is complete, the panel operator will check the reactor agitator ammeter to assure that it indicates no-load on the agitator. 2. The outside operator will check the drain bullseye and indicate to the panel operator there is no flow from the reactor. 3. The panel operator will then put rinse water into the reactor and the outside operator will observe the dump bullseye to determine flow from the reactor is normal and thus will complete^:drain. 4. The outside operator will continue to observe the bullseye and inform the panel operator when flow stops. 5. The reactor will then be evacuated and charged if the previous steps proceed normally. If high amperage on the agitator or improper draining are detected, the shift supervisor will be notified and he will further check to assure the reactor is empty before charging. The reporting requirements of the standard pertaining to relief valve discharges are summarized below for this release: ABDOO185762 -3- C Mi C-l Source: D-400 Reactor Nature: Discharge thru relief system on D-400 reactor. Cause: Overpressure of D-400 reactor due to overfilling. Date: January 19, 1980 Time: 6:15 p.m. Approximate Discharge: 24 pounds of vinyl chloride. Method of Determining Discharge: Relief valve calculation Action Taken to Prevent Discharge: 1. Charge stopped when high pressure observed. 2. Reactor put on recovery system. 3. Flush water to reactor stopped. Measures Taken to Prevent Future Discharges: Changes to the standard operating procedures. If there are any questions on this matter, please contact me at (601) 363-8111, Extension 239. Sincerely, 'V' ((' FfW^JLOC^x. R. A. Frohreich Chief Process Engineer jf c: Wayne B. Anderson - Bureau of Pollution Control BCC: Cm, CRM, JEB, MPB, SJV ABDOO185763 4 , c-i RELIEF VALVE DISCHARGE CALCULATION D-400 REACTOR 6:15 P. M. - JANUARY 19, 1980 FROM: Farris Relief Valve Catolog No. FE336, Page 3.3 24.3 Vi.25 (Px-P2) Kp Kg Ku Where: A * Orifice Area (In.^), Q Orifice = 11.05 In.^ Vl * Liquid caoacity in U.S. gallons per minute. Pi Set pressure at inlet, psig * 185 ?2 s Back pressure at outlet, psig * 0 Kp = Overpressure sizing factor, 1% overpressure (From: Farris Book Page 3.7) = 0.07. Kg = Sizing factor for specific gravity G = Specific Gravity Ku = Viscosity correction factor from curve on Page 3.8 = 1.0 Temperature of reactor at time of release * 109F. Reactor contained 34% Vinyl Chloride by volume. Specific Gravity of water 0 109F = 0.99. Specific Gravity of Vinyl Chloride 0 109F = 0.87. Specific Gravity of Mixture = (0.34)(0.87) + (0.66)(0.99) = 0.94 ABDOO185764 (C Kg s yf 0.94 Then: 1.03 VL = (11.05) (24.3) V 1.25(185-0)" (0.07) (1.03HI.0) = 294 gallons per minute total discharge. @ 34% Vinyl Chloride Discharge of Vinyl Chloride = (0.34)(294) = 100 gallons per minute. Vinyl discharged in two seconds: or 725 #'s VCM/Minute = 725 #1s VCM X 1 Minute X 2 Seconds 24 #'s VCM Min. 60 Seconds ABDOO185765 C-2 ABDOO185766 Conoco Chomieal* Company Division of Conoco Inc. p 0. Box 91. New Highway 25 Aberdeen. MS 39730 C-2 March 4, 1930 Mr. Wayne Aronson Enforcement Division Region IV United States Environmental Protection Agency 345 Courtland Street, N.E. Atlanta, GA 30308 Dear Mr. Aronson: Per your phone request, please find attached a copy of the strip chart for batch D-400-4544. Sincerely, R. A. Frohreich Chief Process Engineer Attachment c: Wayne Anderson - Department of Natural Resources b/c: * ABDOO185768 C-3 January 21, 1983 ABDOO185769 (conocol C-3 Conoco Chemicals Company Conoco Inc. P. O. Box 91. Now Highway 25 Abardaan. Mississippi 39730 (501) 3694111 CONFIDENTIAL A Mr. Jerry B. Banks, P.E. Mississippi Department of Natural Resources Bureau of Pollution Control P. 0. Box 10385 Jackson, MS 39209 Dear Mr. Banks: At approximately 2:05 p.m. on January 13, 1983, our plant experienced an emer gency relief valve discharge. Pursuant to the National Emission Standard for Vinyl Chloride (40 CFR, Part 61, Subpart G, paragraph 61.55 (a)) we are report ing this incident to your office. This release was reported to the National Response Center under the Comprehensive Environmental Response Compensation and Liability Act of 1980 on January 13, 1983. The vessel involved was the PVC polymerization reactor D-745. The vinyl chloride monomer (VCM) release discharged through an 8" x 10" relief valve on the reactor shell which has an 8" rupture disc between it and the reactor. The relief valve^ setting was 195 PSIG and the rupture disc was rated to burst at 205 PSIG at 173 F. The release was caused by hydrostatically filling the reactor which occurred due to operator error. On January 13, polymerization reactor D-745 experienced quality problems. After reactor batch 745-917 was dumped, the lenape manway on the reactor was opened for inspection. During the inspection it was requested that the agitator be turned off. Turning off the agitator caused the low dgltator amperage alarm to activate which the operator acknowledged to silence the alarm annunciator. The panel alarm light remained on since the low agitator amperage condition had not been corrected. After reactor inspection the reactor manway was closed. The panel operator then proceeded with normal rinse and chemical wash procedures with the agitator off and the low agitator amperage panel alarm lighted. Then the panel operator checked to see if the reactor was empty, but did not use the proper procedure. Instead of using the rinse system to run water through the reactor and the dump bullseye, the panel operator used the charge system. In effect, rinsing with the charge system made sure that there were no obstructions in the dump line. This did not check for pluggage in the reactor or the sever piping. The panel operator then proceeded to fill out the batch sheet for the next batch. For the blank marked "precharge amps", he recorded what the agitator amperage should have been instead of actually reading the amperage. The agitator was still off at this time. The panel operator then evacuated the reactor. During evacuation, he noticed that the agitator was off but did not turn it on until evacuation was complete. When he turned the agitator on, he ABDOO185770 C-3 A Mr. Jerry B. Banks, P.E. January 21, 1983 Page 2 never looked aC the amperage reading. This amperage la recorded on a strip chart. Analysis of this strip chart shoved that the amperage was too high after the agitator was turned on. The panel operator then proceeded with the charge of reactor D-745. The out side operator was working to the northeast of reactor D-745. He felt material spraying on him and looked up to see material coming from the relief valve stack on the northeast relief valve on reactor D-745. He Immediately radioed to the panel operator that the rupture disc had blown on reactor D-745 and to stop charge. The outside operator then moved to a location where material coming from the reactor would not fall on him while the panel operator stopped charge. Vhen the outside operator looked up again, the relief valve had stopped dis charging. His best estimate of the time the relief valve discharged was 10-15 seconds. The release occurred because the reactor was partially full before charge began and therefore became hydrostatically full during reactor charge. The panel operator was given appropriate disciplinary action for his failure to follow proper operating procedures. The amount of VCM discharged was estimated to be 222 pounds. This amount was calculated by obtaining the flow rate of the pumps running during this part of charge. The flow rates were obtained from pump curves at the discharge pres sure at the time of the release. These calculations are attached. Weather conditions at the time of the release according to the plant weather station were as follows: Barometric Pressure Temperature Wind Direction Wind Speed Conditions 30,01 in. Hg. 56 F South 0 MPH Clear Skies Action taken at the time of the release was to Immediately stop the charging of reactor D-745. This action Immediately stopped the discharge from the relief valve. In order to prevent an occurrence of this type in the future, an interlock will be added to the reactor that will not allow automatic reactor charge if the agitator amperage is below a certain setting or above a certain setting. ABDOO185771 Mr. Jerry B Batiks, P.E. January 21. 1983 Page 3 A CONFIDENTIAL The reporting requirements of the standard pertaining to relief valve discharges are summarized below for this release: Source: Reactor D-745, Reactor Module No. 2 Nature: Discharge through relief system on Reactor D-745 northeast shell relief valve Date: January 13, 1983 Time: 2:05 p.o. Approximate Discharge: 222 pound VCM Method Of Determining Discharge: Calculation of pump flow rate at time of discharge Action Taken To Prevent Release: Charge of reactor D-745 was stopped Measures Taken To Minimize Possibility Of Future Discharges: An Interlock to reduce the possibility of reactor charge if agitator amperage is too high or too low If there are any questions concerning this report, please call me at (601) 369-8111, extension 2231. Sincerely, Veldon E. Messlck Senior Process Engineer bis OF, CRM, PEM, DIM, JCL ABDOO185772 RELIEF VALVE DISCHARGE CALCULATION REACTOR D-745 2:05 P.M. - JANUARY 13. 1983 A CONFIDENTIAL Flow through the D-745 relief valve was calculated using the charge system capacity at conditions during the release. The calculated flow was then cross checked against the relief valve capacity at the respective conditions. In general, the relief valve discharged at a rate of 925 gallons per minutes for a period of 15 seconds, at a pressure of 200 PSIG (2% overpressure). The follow ing conditions were used in the calculations: 1) The VCM charge tank would have been half empty at the time of the release, which corresponds to a level of 20 feet above grade. Using a VCM temperature of 50 F, a static head of 8 PSIG would have been present. 2) The VCM pressure in the VCM charge tank would have been JQ PSIG. 3) The pressure drop through the VCM charge filters would have been 17 PSIG at a VCM flow of 925 gallons per minute. 4) The pressure drop through the VCM charge meters (2) would have been 7 PSIG at a VCM flow of 925 gallons per minute. 5) The pressure drop through the VCM charge piping would have been 14 PSIG at a VCM flow of 925 gallons per minute. 6) The hot water charge tank would have been half empty at the time of the release, which corresponds to a level of 20 feet above grade. A static head of 9 PSIG would have been present. 7) The pressure drop through the water charge'meters would have been 0 PSIG at a water flow of 0 gallons per minute. 8) The pressure drop through the water charge piping would have been 0 PSIG at a water flow of 0 gallons per minute. 9) The relief valve on D-745 is 50 feet above grade. Since the D-745 contents would have been 12.5% VCM by volume, a static head of 21 PSIG would have been present. 10) At a flow of 925 gallons per minute the pressure at the D-745 relief valve would have been 200 PSIG (2% overpressure). CHARGE WATER PUMP FLOWRATE TDH Of Charge Water Pumps * Reactor Pressure + Reactor Static Head + Charge Water Piping Pressure Drop + Charge Water Meters Pressure Drop - Charge Water Tank Static Head Page 1 of 2 ABDOO185773 C-3 RELIEF VALVE DISCHARGE CALCULATION REACTOR D-745 2:05 P.M. - JANUARY 13, 1983 TDH Of Charge Water Pumps * 200 PSIG + 21 PSIG + 0 PSIG +0 PSIG - 9 PSIG - 212 PSIG The pump curve for the hot water charge pumps indicates a flow of 0 gallons per minute at 212 PSIG TDH. Therefore, the water flow rate into D-745 would have been 0 gallons per minute. VCM CHARGE PUMP FLOWRATE TDH Of VCM Charge pumps Reactor Pressure + Reactor Static Head + VCM Charge Piping Pressure Drop + VCM Charge Meters Pressure Drop + VCM Charge Filters Pressure Drop - VCM Charge Tank Static Head - VCM Charge Tank Pressure TDH Of VCM Charge Pumps = 197 PSIG + 21 PSIG + 14 PSIG + 7 PSIG + 17 PSIG - 8 PSIG - 20 PSIG - 180 PSIG The pump curve for the VCM charge pumps indicate a. flow of 925 gallons per minute at 180 PSIG TDH. Therefore, the VCM flow into 'D-745 would have been 925 gallons per minute. The net flow of water and VCM into D-745 at the time of the release would have been 925 gallons per minute. VCM Discharge Calculation At the time when the, panel operator stopped the charge system, the VCM charge meters read *Wl9 and V23 counts. It is assumed that7<tf2l counts of VCM 0B210 gallons) would have been charged into D-745 at the time of the release. The total volume of D-745 equals 4,487 cu. ft., or 33,560 gallons. The specific gravity of VCM at the reactor temperature would have been 0.92. Volume percent VCM in D-745 4,210 gal. 12.5% VCM 33,560 gal. VCM discharged in 15 seconds * 925 gal, x min, x 15 sec, x 0.125 gal. VCM x 8,34 lbs. min. 60 sec. gal. gal. H-0 0.92 gal. H,,0 - 222 lbs. VCM 1 gal. VCM x Page 2 of 2 ABDOO185774 C-4 ABDOO185775 (conoco) Interoffice Communication To DISTRIBUTION From M. P. Blackwell Date January 21, 1980 Subjaet REACTOR EMPTYING PROCEDURES (OLD REACTOR MODULE) C-k & After each reactor rinse or swirl immediately prior to reactor evacuation, the following steps must be taken to make sure that the reactor is empty and ready to be charged: 1. The lead operator will check the reactor ammeter to make sure that there is no load on the agitator. No-load amps will be posted on each reactor ammeter. NOTE: If reactor ammeter does not read the correct no-load amps, do not recharge the reactor until the problem is corrected. 2. The lead operator will notify the "A" operator to check the sewer bullseye and make sure that the reactor is empty. (The reactor main dump, sewer, and atmospheric vent valves should be open.) 3. After the "A" operator verifies that the reactor is empty, the lead operator will: a. Close the reactor sewer valve. b. Open the reactor slurry dump valve. c. Open the condenser rinse valve. d. Turn on the rinse pump and slurry pumps. e Turn off the rinse pump when water begins flowing through the dump bullseye and close the condenser rinse valve. f. Watch the dump bullseye and make sure that the level drops normally, indicating that the reactor is empty. g. Turn off the slurry pumps after all the water has drained through the bullseye. h. Check the reactor ammeter again to verify that the reactor is empty. i. Close the reactor main dump and slurry dump valves. If the previous steps proceed normally and the reactor is empty, the reactor can then be evacuated and charged. If any of the above steps do not proceed normally, notify the shift supervisor who will further check to make sure the reactor is empty before charging. ABDOO185776 Distribution January 21, 1980 Reactor Emptying Page 2 Procedures (Old Reactor Module) jf DISTRIBUTION: CLM, CRM, JEB, RAF, AHS, Vinyl Shift Supervisors (5), Vinyl Bulletin Boards ABDOO185777 C-5 ABDOO185778 C-5 & Interoffice Communication To DISTRIBUTION From M. P. Blackwell Date January 21, 1980 Subject REACTOR EMPTYING PROCEDURES (NEW REACTOR MODULE) After each reactor rinse or swirl immediately prior to reactor evacuation, the following steps must be taken to make sure that the reactor is empty and ready to be recharged: 1. The lead operator will check the reactor ammeter to make sure that there is no load on the agitator. No-load amps will be posted on each reactor ammeter. NOTE: If reactor ammeter does not read the correct no-load amps, do not recharge the reactor until the problem is corrected. 2. The lead operator will notify the "A" operator to check the sewer bullseye and make sure that the reactor is empty. (The reactor main dump, sewer, and atmospheric vent valves should be open.) 3. After the "A" operator verifies that the reactor is empty, the lead operator will: a. Open the condenser rinse valve. b. Turn on the rinse pumps. c. Turn off the rinse pumps when water begins flowing through the sewer bullseye. d. Close the condenser rinse valve. e. Watch the sewer bullseye and make sure that the level drops normally, indicating that the reactor is empty. f. Check the reactor ammeter again to verify that the reactor is empty. g. Close the reactor main dump valve. If the previous steps proceed normally and the reactor is empty, the reactor can then be evacuated and charged. If any of the above steps do not proceed normally, notify the shift supervisor who will further check to make sure the reactor is empty before charging. 'Micke^ P. Blackwell Operations Engineer DISTRIBUTION: CLM, CRM, JEB, RAF, AHS, Vinyl Shift Supervisors (5) Vinyl Bulletin Boards ABDOO185779 TOPIC: SAFETY/TRAINING J185/8U ATTENDANCE RECORD fad DATE: A C-6 / /W/3o ^CATION: ' NUMBER OF HOURS: , *yj OUTLINE OF PRESENTATION (Major pointsdemonstrations, what was practiced, slide/tape, film, etc.). Attach separate sheet , if necessary. EMPLOYEE SUGGESTIONS AND PLANNED CORRECTIVE ACTION: , ^ _____ /^Pjrrl____ ^ / /' ' --------------------------------------------- _____^<S&riL^s ^ r/V^> ) DEPT. CLOCK NO. Lfctjrfzl // u 'n*f u v?A sr?o TRAINEES Instructor/Supervisor NAME, (Print) aIg. Lee (Lt4,idK'^ TXcJCir DEPT. NO. NAME (Print) 0" ABDOO185781 C-7 -topicr~3>A<LTD/f h^iy'J& LOCATION; QeMoi 1J2tL KECUKD 'Poe^4.u*j ________ NUMBER OF HOURS; C-7 * DATE: / hfr/A o */j________ OtffelNE OF PRESENTATION (Major points, demonstrations, what was practiced, ^ slide/tape, film, etc,). Attach separate sheet if necessary. &2^LJfL JhuM___________________ ^ ___ tJe . U? Uj'fjlAl. ~ a7^io tz. i CJcL^ 0,0YEEs3gGESTIGNS AND PLANNED CORRECTIVE ACTION: Instructor/Supervisor S' ; TRAINEES CLOCK n. NO. NAME (Print) DEPT. ^sL J(U w* &93 J7^ s~/?s 7~^nttW | -/-. #?o n. <mwaJ / I-f MM (p/t ^ 1// %dh ' im | nt^r O - cl IdiLkrviA . I CLOCK NO. , % i NAME (Print) i 1* 1 ABDOO185783 C-8 7, TOPIC: L^' TION: ABDOO185784 ^iartn/Tgx3nwc meeting ATTarowcg meem /> s.v NUMBER OF HOURS: C-8 DATE; A f/ OUTLINE OF PRESENTATION (Major points, demonstrations, what was practiced, slide/tape, film, etc.)* Attach separate sheet if necessary. jQa EMPLOYEE SUGGESTIONS AND PLANNED CORRECTIVE ACTION: Ha. bj TRAINEES Instrile tor/Supervisor "CLOCK" DEPT. NO. *l--/t+ttf--/ f7<? /< . /rr3 \ //*;? | M ~ Sv | i V /6tfo i 'r ; /( ?i> So?1 J NAME (Print) /?<* /&?c,f=: <&uu* - 1 IdEPT.. I "CLOT NO. 1 NAME (Print) - *u I *. ABDOO185785 SAFETY/TRAINING MEEXBIg@0M5EB8DANCE RECORD *aUTOPIC: V WCAITION: ______ NUMBER OF HOURS: c-9 A DATE: J 13/1IV TOTLINE OF PRESENTATION (Major points, demonstrations, what was practiced allde/tape, film, etc.). Attach separate sheet 4ifC necessary ->r^4v. ------ r^utS^__ -___ SJSA/& .^L^ x ^ EMPLOYEE SUGGESTIONS AND PLANNED CORRECTIVE ACTION: TRAINEES rrictorjuperv$r^ DEPT. CLOCK NO. . NAME. (Print) ./ -JttU /? ^ U "CLOCK DEPT,. NO. NAME (Print) - < ABDOO185787 C-10 ABDOO185788 -- ^ARGE..ttEACTQR. BATCH c-.io ft. *--- 1 l .................. -/ -a * *' >" ,7? ' TYPE SZ0 J OATTE 7.. V_H "d^T FORMULA_____ DURA SEAL ^ ^fcterTk. L&J Counts OiT Level &K .Inches f* ^ coUoid-LLLca VC Tank * *1 Catalyst j^Z_Cl. Pre-charge *>p 2. ^ rnrhj>t _ *Coun(s ?fiSFVCM. JZsUZLt ype 2j A Running Temp. ,F Pressure Counts .RVCM psi( TIME INITIAL Reactor &. Material O.K. For Charge Oil Pressure 7*V 0 -Psij Seal Water_______L. .CPM / >0 Seal Water Press;Psig pva in. &T- Ltftffl __2Jl^Befo %T fiess . "L(& e~\ . f,JZT &TTle fan tIfilVF ' < Net ^OT) Tvgu p-- 0-- Evacuation Start Evacuation Stop Charge Start ZJr. ) ' Inches Kg. U3j Standard 10 Minutes Actual __ Dev. Standard 11 Minutes -y ro /'rn /cTt-U Charge Complete Catalyst Start Time Reaction Temperature Reached Actual ______ Dev. Standard 3 Minutes Catalyst Complete Actual _ >--Dev. C) )r 1 S' Turn Around Time Recovery Start Run Time Standard 30 Minutes -- - - - - .=rr- flrrmury rnmplnti nit ----rrifTffM Dump Start To Tank ________ Bldg." No. Standard- 25 Minutes, '# Dump Stop Chcm Wash Start Chcm Wash Finish Rinse Start Rinse Complete Total Stripping Steam lime Reaction . Killed Actual ______ Dcv_ Standard 25 Minutes. Actual --------- Dev_ Standard 10 Minutes Actual --------- Dev. - Swirl Start Swiri Complete Total Std. ,pev. ABDOO185789 C-11 <* ABDOO185790 C-11 ABDOO185791 ABDOO185792 (conocoi) Interoffice Communication To * Robert E. Morgan From Don Johnson Data January 14, 1983 Subject DISCIPLINARY SUSPENSION On January 13, 1983, you were in the process of charging reactor 745 in the new reactor module without following proper safety precharge procedures. The reactor became overpressured during the charge sequence which resulted in a VCM relief valve discharge. When I talked with you to get your side of the story, you stated that you had failed to check the precharge agitator amps as a final check to ensure the reactor was empty. In reviewing the batch sheets, it was also noted that the precharge amps had been filled out prematurely, the reactor agitator was not on until charge and that once on, the agitator amps were well above the accepted level. Had you checked the precharge amps, you would have seen the reactor was not empty. As a result of this incident you are being given a two-day disciplinary suspension. You will be on suspension January 15 and 16, 1983, and should return to work on your normal scheduled shift 7:00 p.m., Tuesday, January 18, 1983. It is hoped that as a result of this suspension you will recognize the need to pay closer attention to the reactor operation and the need to monitor and record proper information as required. Future incidents of this nature could result in a more severe disciplinary action. f%r. pU****- (/*+) Don Johnson Vinyl Shift Supervisor cjw c: JF, CRM, PEM, DJM, RAM(2), JS ABDOO185793 ABDQO185794 (conoco) C-13 Interoffice Communication To J. D. Sims From D. F. Johnson July 13, 1981 Subjtct : Inattention to Operations On July 7, 1981, at 5:35 a.m., you charged D-500 reactor, recorded an erroneous pre-charge amp reading, and also used the wrong temperature set point. You set the reactor temperature at 130F and it should have been 138F. The pre-charge amps you recorded as 138. The errors were detected on the next shift. When I talked with you to get your side of the story you said you thought you had set the run temperature at 138F and didn't know why you set the "run temp" at 130F. You stated you looked at the amps but did not record them. You stated you were busy charging, taking silo readings and getting some information together for the morning report. You are responsible for accurately recording the pre-charge amps as well as other information on the batch sheets. This assures the reactor is empty and the agitator is functioning properly prior to charging. You are also responsible for operating the reactors at the correct run temp erature. Run temperature is critical in making specification molecular weight resin (i.e. resin with correct viscosity). I want to bring to your attention the seriousness of these errors. You are being given this written warning so that you can improve your performance in these areas. However, I want you to understand that future mistakes of this type will result in more severe disciplinary action. D. F. Johnson Vinyl Shift Supervisor cjt c: CLM, CRM, PEM, MPB, RAM(2), JS ABDOO185795 ABDOO185796 (conoco) C-14 Interoffice Communication To All Vinyl Operators From P. E. Markey January 25, 1983 Subjoct EMPTY REACTOR CHECKOUT PROCEDURES Before evacuation and charge of a reactor, the reactor must be empty. In order to Insure that the reactor is empty, the following procedures must be followed: 1) The agitator amperage must indicate a no-load condition. This must be accurately recorded on the reactor batch sheet inmediately prior to evacuation. 2) After rinse is complete, the sewer bullseye is to be checked for a no-flow condition. This can be done with the TV camera if it is functioning properly. If not, the outside operator must check this. When a no-flow condition is present in the sewer bullseye, the panel operator must open the shell rinse valve and rinse with a few counts of water. This water must then be seen in the sewer bullseye with use of the TV camera or by the outside operator. The panel operator must then shut the shell rinse valve and a subsequent no-flow condition must then be observed. This procedure will show that there is no significant pluggage in the re actor or the sewer piping. If the no-flow, then flow, then no-flow con ditions in the sewer bullseye are not observed, this would indicate an obstruction in the path of the water between the rinse valve and the sewer bullseye. This pluggage could mean that the reactor is not empty. This f,J"1 rected before evacuation and charge can begin. P. E. Markey Vinyl Operations Superintendent rah ABDOO185797 C-15 rTiHf,Aft IT..-. ... ......... ABDjOO 1*8-5798 NAME CR SU3JEC? 0? COURSE CH CLASS > 7DATE - /< - I 1 ________ INSTRUCTOR(S) K..' U Ay C-15 __________________ A DESCRIBE '.THAT HAPPENED (i.'ajor points covered, v;hot was demonstrated, -hat v/ss practiced, v;Hat training aids were used, etc.) Attach separn t c sheet if necessary. r"u*-v tL/v-X*~-e <Z*r^ -r ' . fV . " jfl ^ . / // 1 1 DEPT. Ci-CCiv NO. I'. A vL ft ;;a.v. . *" . l SIGNATURE /(L trainees ] rr~?i . i ! C LCC H | NO. ! ii A r.'E (r H LL T) | i ' ABDOO185799 C-16 SArLii, ;e,:ckd TOPIC: U^i I^VTION: C4. fi^~U /C /la/1- /^-v NUMBER OF HOURS: C-16 A DATE: 3 f/Lit L _ Jf-^ -- OUTLINE OF PRESENTATION (Major points, demonstrations, what was practiced, slice/tape, film, etc.). Attach separate sheet if necessary. ___ />5 rf <-1 ^v~<!r /Cy *^0^ tj EMPLOYEE SUGGESTIONS AND PLANNED CORRECTIVE ACTION: vy''/ <-t TRAIN S //I U. Instrue tor/Supervisor DEPT. t/f K ,/ f ./ // - CLOCK NO. mi /rr3 NAME (Print) pOl ------ ''Ji* //M Ohr-?T>*> i !de?t. i j I CLOCK. ! no. j NAME (Print) i ! ii J i i i i j ABDOO185801 C-17 SAP Li 1 / I:v-. - .>v^_ 'AftDflOVft.W)? r.L- :^W:uj ,?IC: -d- ^CATION: led_____ * Q , Qjtlfrr .foj NUMBER OF HOURS: C-17 _ DATE: *J A OUTLINE OF PRESENTATION (Major points, demonstrations, what was practiced, slide/tape, film, etc.). Attach separate sheet if necessary. &uZ... /^V J9 /?c&*- A -&L *cip 7f n sfr-4+f- a&ozo ^ EMPLOYEE SUGGESTIONS AND PLANNED CORRECTIVE ACTION: 1 fDEPT. ft CLOCK NO. 1 /2<6 /o^Z NAME (Print) \ ' ! IDEPT. i j 1 CLOCK ! NO. NAME (Print) \ ! ! i i 1 i i t ii 1 i ! ABDOO185803 C-18 ABDOO185804 SAFETY/TRAINING MEETING ATTENDANCE RECORD C-18 A /JJZZ*' /fcS DATE: *3 fy9f LOCATION: ____ NUMBER OF HOURS: cg2> ,W OUTLINE OF PRESENTATION (Major points, demonstrations, what was practiced, slide/tape, film, etc.). Attach separate sheet if necessary. -<S? &*** A'JgS &**<* &*. ^4/ S&r+ <g^-^^ 2r --------- <4*^^ x--te4+y EMPLOYEE SUGGESTIONS AND PLANNED CORRECTIVE ACTION: s42SZ*//' ~ j*> ^ <0^ Jtj&f *& i**k a;*-* 4^ TRAINEES Instructor/Suoervisor i -DEPT. CLOCK NO. V/Z/Y/ i" //- <5 - 'I| NAME (Print) Idept. "CLOCK" NO. I __ UkLhz^_________ t Ii 1------------- llll NAME (Print) ABDOO185805 C-19 ABDOO185806 C-19 4 TOPIC: DATE: 7 l>l LOCATION: NUMBER OF HOURS: /f~~ OUTLINE OF PRESENTATION (Major points, demonstrations, what was practiced, slide/tape, film, etc.). Attach separate sheet if necessary. EMPLOYEE SUGGESTIONS AND PLANNED CORRECTIVE ACTION: /y>r TRAINEES Instructor/Supervisor DEPT. ////y / / ^ n * CLOCK NO. ~nrT3 Tu./ llM NAME (Print) lV111 (JjSSut. * 1 -------------- 1 CLOCK DEPT.. ! NO. 1 i 1 - NAME (Print) i 1 p __________ _________________________________ i__________ i i H i 1) || 1H i ABDOO185807 C-20 TOPIC: ABD00185808 SAFETY/TRAINifto ff /%/? Jto&AA. _ C-20 4 DATE: 7 //W/--L LOCATION: / NUMBER OF HOURS: -------- ^---------------- OUTLINE OF PRESENTATION (Major points, demonstrations, what was practiced, slide/tape, film, etc.)* Attach separate sheet if necessary. j2^.--rf i _____________________________________ EMPLOYEE SUGGESTIONS AND PLANNED CORRECTIVE ACTION: - -- ___________ /^-7_^_______ _____ - _ TRAINEES ctor/Supervisor CLOCK DEBT. /? NO. /V/auA/ b?Vr i f/ * /Os f f -t (* ' "CLOTT DEPT.. . NO. NAME (Print) . * ,, ~ -- ----- --. --1 -- - 1 1 -- ii ABDOO185809 C-21 ABD00185810 anfLU/ ifw-umno r;cx i unu t\ i i c7nU---nf--llc. ne.lUrt.U C-21 A TOPIC: ^OCATION: I^r----------- lH____'.,,_r ' "' NUMBER OF HOURS: DATE: 7 b,t y OUTLINE OF PRESENTATION (Major points, demonstrations, what was practiced, slide/tape, film, etc.)* Attach separate sheet if necessary. gft* 'fa/id Of?--------------------- 'YrfCrfr 4. gy-t. --'V-tvL.r--<, ry4-.--/-'"'S-j -f *- EMPLOYEE SUGGESTIONS AND PLANNED CORRECTIVE ACTION: CLOCK DEPT. NO. \rir*>\yV \ w \\ }?(> v- < \ rzrC' n/r yf/6 Mil n <*7? NAME (Print) _l. hrfLA./1^-- * I\ . Jt _ 1 to I-------------- ("CLOCK 1 DEPT. ! NO. 1 I I 1 1 1 [- 1 1 1 1 1 1 ! 1 1 1 1 1 1 1 1 1 1 NAME (Print) ABDOO185811 ABD00185812 , iw. - . C-22 '***,%*Wj^4iV * Mickey Blackwell (COfiOCo) ~cTtm jTp Dtt 6 ft8/8 z /{fUchJ IS 4LQjrtfl** ex*t* 4tr f&thr ft are #xp*c4t<i C&f'ffcft &n SCi/erS , D* Pfrryj V ?. /4w/* toUf ft* ft<* exa* 4v fall refturtf k\e(i f*%4**<j e* eocl frpA*Mi0 Vxe{S 4'sh*<\ U)'ili thtluJt tlio4j(*y V- ktllthj a re*uhi ^ M*k\**i i/f mt4kc*Sl, -fclUf (A/fuJ^ /Xtjtfuxf j 'fth chetij &r'<4 ; emtrjt*ty killj -ukr$ f &*k otvr*p fiWsJLify iU eta* loti/ U "cfUr i>cdk,f ujftri o*m Q*A6***toa kith* jBtoA 0*M 'ftfyorbifjify uat\ I 't&L, &JLItfij/dr i/AKQrsi'a*^4 Ju*4u)S. 'fie cuuM- Y&*A- U*t(f L* *4vrn*J 4&*1' ifc *ft*'cfWfcflfe. */&& **^*^$3* ABD00185813 Home -/<-*^ C-22 T" ' A ftno&er fa lUwtrf ihf /har^i^ / or ^ /A Yl^ b/+*l k?s*(l +A ch s^cfam T /. __________ CcUl^i fj ht~far +too hree pa*rf / tA+HAf/lb &** 4 fa fafa cha. ,rye fade ha**h de-fax. T4# #*' Q^emfae^ fAOS'f yt*y ccf 'if*. Cot4 ^ S fa 6*4*4 +u pnArf '-h(*Ur farnfa wf+r. AS Jet*.* fafmlied fahraofh if* ... _______ ^ -3. (fb J UJtfi AO c----*" "rt# &A*c&t i ^ ">' wy '*'' yn u^'ry/* h> /'^tC/n /bJ or*ssere_ o* yi* faM6._Jcfi( a* fa- ncfr*f+*\ ft" cjerafa 'tJ.fk.'f&L erects* m peAfhf )*fe a//>^ m/t*n /fa fa jfafe x_v. th*t*<f. - ______ .. . _______ _____ _ -Rtttfar eva*'//*V MvtT retd / Zees'/' $8,S' tncjes frtercvry VACUO/* btfere ft^e r+mcftr Co** ie c4**f*fa *md Muff /be (*t if* rtacfa. tyr cptfpfae **)^f*0 ma*0m*ftr b+lorf tofaj. cJtuqe* 5. you. eee_ c*o*jf*y' Ce o**i**{a- fav.heytAj ovmfifif-tL /am so* */uc u*t , ____ _ ____ ______ r Ptslfae/..J***pfts mosfa it.. /a faffoffr0f*rb d/4 oe -ft lejt F 7. 24./* c4,fv -fti/e (a%fasfa_ d*/$sljb fa& f&r^rfaZ. fa* Cocfa fafa**t Utfl/t Ca. ftt fafa /S- /+ V4.V*dL._ F /f. -- *r 7- re* cm ^ fa**d*. __________ ______ _________ ______ 5a.+i^ rofes ur fa faftfaea mainly o*i fays vJm* Ma*tAf4e#jft_fa Stefa fer*t***f *re_/* ar+aS, n A* dr!s resj*s/J>/Jfy 4a dtsyaese 6 a}r. .-MG-sis. properby 'ffCem c/rs/psu/e^ mq*r&* y* '* caas a tss/*f. /'f&_ #?* $A. F . ;o. 4rf...hob4\#V. rf. a_ riM-h*k... /V aoa^..r**c.j^_ u*jj_ W. /J si+uht ^*1 y^4flff/sftyA /J. fto yeb. **i- tbM#. AoJl 7**4.. ___F_. _ JL_____ _-X_. U you..O&urre iHA)<4c,Tfdtuh\iy**((***>ydWj'(-*/ryrr#iA+iT* rre?eeo*\ur*f__,j 'A+'hp, ^ust- /^. ( 6OrI_.--__/rf >4+* Tj** oh wy &*f**jf**- jer-___/g **/**.. i'& h jot, . Yw ft** fpAccJb... ft> J&r'f~ auMt*f ajffbh_rtaC70r. n. 'Tkt..*ft" *per*f*r_ fallsUmJ! &pAecfor_ (/**., r*cftp_ At/t*. /V /s ft .siirf_Y^UTtry_AH A.^0tc/tt,________ .13 X/ a. fhtroj n H/e **X a A jfA/S Z*ier*t*cy leiff Pob. jj re*di\% //ofl p*<j) J/ should kt cMmff^.. frtr.yf* fyr**___ chance yen ffft toffdotct ho fafft/pfift rfrttm cJoeftfij* ABD00185814 Appendix D APPENDIX D ITEM NO. D-l D-2 D-3 D-4 D-5 ABD00185815 TABLE OF CONTENTS A DESCRIPTION Letter, R.A. Frohreich (Conoco Inc.) to Rebecca W. Hanmer (Environmental Protection Agency), April 8, 1980 Letter, R. A. Frohreich (Conoco Inc.) Rebecca W. Hanmer (Environmental Protection Agencv), April 16, 1980 Interoffice Communication, J.R. McCrimon to Distribution, BLOWDOWN TANK STRIPPING PROCEDURE: OLD UNIT, April 27, 1979 Document, Safety/Training Meeting Attendance Record, April 6, 1980 Letter, R. A. Frohreich (Conoco Inc.) to Rebecca Hanmer (Environmental Protection Agency), June 1, 1981 ABD00185816 D-1 ABD00185817 Conoco Chtmicolo Company Oivision of Conoco Inc. P 0. Bo* 91. New Highway *5 Aberdeen. MS 39730 D-1 A April 8, 1980 Ms. Rebecca W. Hanmer Regional Administrator Region IV United States Environmental Protection Agency 345 Courtland Street, N.E. Atlanta, GA 30308 Dear Ms. Hanmer: At approximately 11:07 a.m. on April 3, 1980, our plant experienced a minor relief valve discharge. Pursuant to the National Emission Standard for Vinyl Chloride (40CFR, Part 61, Subpart F, paragraph 61.65 a) we are reporting this incident to your office. The vessel involved was water stripping tank, D-9. The vessel relieved momentarily thru a 4" x 6" relief valve which had a 4" rupture disc between it and the stripping tank. The rupture disc was rated at 61 psig at 200F. The relief valve setting was 60 psig. The pressure rat ing of the water stripping tank is 66 psig. The stack from the relief valve is 15 feet above grade. The release occurred due to overpressuring the water stripping tank. The water stripping tank is used to collect and strip vinyl chloride from inprocess waste water. The tank is piped to receive the various inprocess waste water streams from the old module polymerization area and is connected to the emission recovery system. The emission recovery system consists of a vacuum pump, compressors, tanks, heat exchangers, and circulating pumps necessary to recover the VCM vapors from the water stripper. Just prior to the release the automatic drain valve on the inlet knockout tank to the emission recovery system was observed to be cycling on and off. ihis was an indication the level well on the knockout tank was partially plugged with resin. The level well was then flushed with high pressure service water for about one minute to dislodge the resin. The high pressure service water was then shut off. An actuated valve in the vapor line to the emission recovery system was open. At this time it was observed the emission recovery system vacuum pump an<t,compressor were not running. The vacuum pump and compressor apparently shutdown due to the high level shutdown in the knockout tank being activated while the level well was being flushed out. Immediately the start button on the compressor was pushed and the compressor made a few rotations and shut down. The start button was pushed again with the same results. Apparently the level well on the knockout tank was draining slowly and the high level shutdown had not yet reset. ABD00185818 April 8, 1980 Page 2 At this time the relief valve on the water stripping tank relieved for approximately fifteen seconds. One of the people at the scene ran to notify the control room of the situation. The other person at the scene shut the manual suction valve on the emission recovery system compressor, realizing the pressure on the blowdown tank was likely coming from the discharge of the compressor back through the emission recovery system. Personnel in the control room switched the main recovery system to the water stripping tank. The pressure in the water stripping tank dropped rapidily and the relief valve reseated. The tank relieved at about 60 psig and the temperature in the tank was about 175F. A 4" check valve in the line between the emission recovery system and the water stripping tank apparently failed to prevent the flow of vinyl chloride vapors from the emission recovery system back to the water stripping tank thus causing the overpressure. No personnel were exposed to vinyl chloride from the release. The weather conditions from the plant weather station at the time of the release were as follows: Barometric Pressure Temperature Wind Direction Wind Speed 29.82 in. mercury 66F S 2 to 6 miles per hour The amount of vinyl chloride released is estimated to be 180 pounds. This is based on a relief valve capacity calculation procedure provided by Consolidated, the relief valve manufacturer. The calculation is based on a 15 second release, relieving pressure of 60 psig, and the vapor space in the stripping tanks containing 91 volume percent vinyl chloride. A copy of the calculation is attached. To prevent future discharges of this type the standard operating procedure will be changed such that the actuated valve in the vapor line from the water stripping tank to the emission recovery system will be closed if the level well on knockout tank is to be flushed. The check valve in the line was removed, reworked, and reinstalled. Long range the water stripping tank will be replaced with a tank with a higher pressure rating. The reporting requirements of the standard pertaining to relief valve dis charges are summarized below for this release: Source: Water Stripping Tank, D-9 Nature: Discharge thru relief system on Water Stripping Tank, D-9 Cause: Overpressure of Water Stripping Tank, D-9 ABD00185819 April 8, 1980 Page 3 Date: Time: Approximate Discharge: Method of Determining Discharge: Action Taken to Prevent Discharge: Measures Taken to Prevent Future Dischages: April 3, 1980 11 :07 a.m. ICO pounds of vinyl chloride Relief valve calculation 1. Manual valve on suction to compressor closed. 2. Main recovery system switched to Water Stripping Tank. 1. Change to the standard operating procedures. 2. Check valve reworked and replaced. 3. Tank will be replaced with tank having higher design pressure. If there are any questions on this matter, please contact me at (601) 369-8111, extension 239. Sincerely, R. A. Frohreich Chief Process Engineer cjt Attachment c: Wayne Anderson - Mississippi Bureau of Pollution Control be: CLM, CRM, JEB, MPB, SJV, JJH ABDOO185820 -o-i....... .A RELIEF VALVE DISCHARGE CALCULATION HATER STRIPPING TANK D-9 11:07 A.M. - APRIL 3, 1980 From: Consolidated Safety Relief Valves Catalog No. 1900B, Page 46 A Where: A W T 2 C M w /T/T c p /TT 22 Orifice Area, in. , P Orifice = 6.38 in. Relieving Rate, lb./hr. Inlet Relieving Temperature, R = 635R Compressibility Factor, = 1.0 Nozzle Gas Constant, page 48, = 307 Relieving Pressure, psia = 74.65 psia Average Molecular Weight of Vapor = 58.50 Then: u = (6,38) (307) (74.65) \/ 58.50 'J 635 x y/ 1.0 W = 44,380 lb./hr. Vapor Vapor is 0.972 Weight Percent Vinyl Chloride Discharge Rate of Vinyl Chloride = 44,380 x 0.972 = 43,140 lb./hr. Vinyl Chloride Discharged in 15 Seconds 43,140 1b. hr. x 1 3600 hr. sec. x 15 sec. 180 1b. ABDOO185821 D-2 .v ABDOO185822 o; Conoco Chomicolt Company Division of Conoco Inc. P.O. Bo* 91. New Highway 25 Aberdeen. MS 39730 Ui A D-2 April 16, 1980 Ms. Rebecca Hanmer Regional Administrator Region IV United States Environmental Protection Agency 345 Court!and Street, N.E. Atlanta, GA 30308 Dear Ms. Hanmer: At approximately 3:27 p.m. on April 7, 1980, our plant experienced a minor relief valve discharge. Pursuant to the National Emission Standard for Vinyl Chloride (40 CFR, Part 61, Subpart F, paragraph 61.65 a) we are reporting this incident to your office. The vessel involved was water stripping tank, D-9. The vessel relieved momentarily thru a 4" x 6" relief valve which had a 4" rupture disc between it and the stripping tank. The rupture disc was rated at 61 psig at 200F. The relief valve setting was 60 psig. The pressure rating of the water stripping tank is 66 psig. The stack from the relief valve is 15 feet above grade. The release occurred due to overpressuring the water stripping tank. The water stripping tank is used to collect and strip vinyl chloride from inprocess waste water. The tank is piped to receive the various inprocess waste water streams from the old module polymerization area and is connected to the emission recovery system. Prior to the release the water stripping tank had been taken out of service to repair an actuator on a valve in the line to the emission recovery system. At the time of the release the water stripping tank was being put back in service. When a water drain line from the main recovery system to the water stripping tank was opened, the water stripping tank momentarily overpressured and a discharge occurred from the relief valve for approx imately three seconds. The relief valve then reseated. At this time the main recovery system was switched to take suction on the water stripping tank. No personnel were exposed to vinyl chloride from the release. The weather conditions from the plant weather station at the time of the release were as follows: 4 Ms. Rebecca Hanmer April 16, 1980 Page 2 ABDOO185823 C 0-2 Barometric Pressure Temperature Wind Direction Wind Speed ' 29.72 in. mecury 74F From South 7 to 9 miles per hour The amount of vinyl chloride released is estimated to be 36 pounds. This is based on a relief valve capacity calculational procedure provided by Consolidated, the relief valve manufacturer. The calculation is based on a 3 second release, relieving pressure of 60 psig, and the vapor space in the stripping tank containing 91 volume percent vinyl chloride. A copy of the calculation is attached. To prevent future discharges of this type the standard operating procedure will be changed such that the recovery system will be switched to the water stripping tank before opening any valves to put the tank back in service. Also the tank will be replaced with one with a higher pressure rating. The reporting requirements of the standard pertaining to reporting relief valve discharges are summarized below: Source: Water Stripping Tank, D-9 Nature: Discharge thru relief system on Water Stripping Tank, D-9 Cause: Overpressure of Water Stripping Tank, D-9 Date: April 7, 1980 Time: 3:27 p.m. Approximate Discharge: 36 pounds of Vinyl Chloride Method of Determining Discharge: Relief Valve Calculation Action Taken to Prevent Discharge: Main recovery system switched to Water Stripping Tank, D-9 Measures Taken to Prevent Future Discharges: 1. Change in standard operating procedure. ABD00185824 C. c D-2 Ms. Rebecca Hanmer April 16, 1980 Page 3 Measures Taken to Prevent Future . Discharges: 2. Tank will be replaced with tank having a higher design pressure. If there are any questions on this matter, please contact me at (601) 369-8111, extension 239. Sincerely, R. A. Frohreich Chief Process Engineer cjt Attachment c: Wayne Anderson - Bureau of Pollution Control be: CLM, CRM, JEB, MPB, SJV, JJH ABDOO185825 RELIEF VALVE DISCHARGE CALCULATION WATER STRIPPING TANK P-9 3:27 P.M. - APRIL 7, 1980 D-2 i From: Consolidated Safety Relief Valves Catalog No. 1900B, Page 46 A Where: wj/jVT c p yir 22 Orifice Area, in. , P Orifice = 6.38 in. Relieving Rate, lb./hr. Inlet Relieving Temperature, R = 635R Compressibility Factor, = 1.0 Nozzle Gas Constant, page 48, = 307 Relieving Pressure, psia = 74.60 psia Average Molecular Weight of Vapor = 58.50 Then: w = (6.38) (307) (74.60) ^ 58.50 V 635 x 1.0 W = 44,350 lb./hr. Vapor Vapor is 0.972 Weight Percent Vinyl Chloride Discharge Rate of Vinyl Chloride = 44,350 x 0.972 = 43,108 lb./hr. Vinyl Chloride Discharged in 3 Seconds * 43,108 lb. hr. x 1 hr. 3600 sec. x 3 sec. 36 lb. A ABDOO185826 D-3 ABDOO185827 (conoco) D-3 Interoffice Communication : Distribution : J. R. McCrimon : April 27, 1979 i : BLOWDOWN TANK STRIPPING PROCEDURE: OLD UNIT 1. Maintain tank temperature at 175F until it is ready to be stripped. .2 When the water level in the tank reaches one-half full, set the steam stripping temperature controller to 250F. Note: DO NOT ALLOW THE TANK TO GET MORE THAN ONE-HALF FULL WITHOUT STRIPPING. Do not drain the receivers until the blowdown tank has been pumped out. Use the Emission Recovery System to recover the blowdown tank. When the temperature gauge on the north end of the tank shows 220F begin pumpout with steam on and the Emission Recovery System on. Use steam pressure to break vacuum on the tank if required. DO NOT USE VCM PRESSURE because it will reabsorb in the water. Obtain a water sample from every pumpout shortly after beginning pumpout for laboratory analysis. By law, this stripped water must contain less than 10 ppm VCM. Reset the steam stripping temperature controller to 175F after pumpout. 'Jimmy R. McCrimon Senior Process Engineer CJt X-- Jc: CLM, ELK, JEB(5), DWIURAF JRM, JLS, CONTROL ROOM BULLET I ON BOARD (1) ABDOO185828 D-4 nu La a/ i i i'iC.C. I RECORD A TOPIC:f^sX tlbtf r*,r* DATE: / </ LOCATION: / NUMBER OF HOURS: <&? ^ ^ Hi^ENE OF PRESENTATION (Major points # demonstrations, what was practiced, slide/tape, film, etc.). Attach separate sheet if necessary "7 2. ?/r<2^Lo /^^~ ^2-gwr^ cu^S TtLt MPLOYEE SUGGESTIONS AJID PLANNED CORRECTIVE ACTION: TRAINEES Instruecor/Supervisor CLOCK ?7. NO. NAME (Print) 7<76 1 TP: /y b / h S30 \ A'S-tiYe <t C' CjL$/u~*~s - DEPT. CLC^-n NO. - -' , NA>S (Print) - 1 i _ __.. , . 1 | .! I ABDOO185830 D-5 ABD00185831 Conoco Chemicals Company Division of Conoco Inc. PO. 8ox 91. Nw Highway 2S Aberdeen. MS 39730 _____& June 1, 1981 Ms. Rebecca Hanmer Regional Administrator Region IV United States Environmental 3^5 Courtland Street, N.E. Atlanta, GA 30308 Protection Agency Dear Ms. Hanmer: In my letter to you dated October 20, 1980, I advised you of our plans to install a new batch inprocess waste water stripping system. Installa tion of the project is nearing completion with startup of the system scheduled by June 30th. An emission test of the water strippers is planned the week of July 14th. Please advise if you desire to have an observer present during the test. You may contact me at 601-369-8111, extension 2239. Sincerely, R. A. Frohreich Chief Process Engineer cjt c: Jerry Banks - Mississippi 8ureau of Pollution Control be: CLM, CRM, SJV, PEM, VEM, JJH ABDOO185832 Appendix E ABD00185833 APPENDIX E ITEM NO. E-i E-2 TABLE OF CONTENTS DESCRIPTION Letter, Veldon E. Messick (Conoco Inc.) to Charles R. Jeter (Environmental Protection Agency), September 23, 1981 Letter, R.A. Frohreich (Conoco Inc.) to Charles R. Jeter (Environmental Protection Agency), November 13, 1981 A ABDOO185834 E-1 ABDOO185835 (conocd) Conoco Chomieaio Compony Division of Conoco Inc. P 0. Box 91. Now Highway 25 Aberdeen. MS 39730 E-l September 23, 1981 Mr. Charles R. Jeter Regional Administrator Region IV United States Environmental Protection Agency 345 Courtland Street, N.E. Atlanta, GA 30308 Dear Mr. Jeter: At approximately 12:25 p.m. on September 16, 1981 our plant experienced a minor relief valve discharge. Pursuant to the National Emission Standard for vinyl chloride (40' CFR, Part 61, Subpart F, paragraph 61.65 a) we are reporting this incident to your office. This discharge was also reported to the National Response Center on September 16 under the Comprehensive Environmental Response, Compensation and Liability Act of 1980. The relief valve discharge occurred on the north fresh VCM charge filter in reactor module No. 1. The discharge occurred through a 3/4" X 1" relief valve with a 1" rupture disc between it and the filter. The relief valve setting was 275 psig. The rupture disc was rated at 300 psig at 72F. The stack from the relief valve was approximately 10 feet above grade. The release occurred when the equalization line from the filter to the fresh VCM receiver became plugged due to vinyl chloride polymerization. The filter was effectively blocked in and liquid full. As the ambient temperature increased, the liquid expanded, causing the rupture disc to blow and the relief valve to lift. The actuated valves that block in the filter had been closed since about 9:00 a.m. when a reactor was charged. The ambient temperature at that time was 70F. By the time of the relief valve discharge, the ambient temperature had increased to 80F. When the discharge was discovered, the filter was taken out of service. The relief valve was isolated and the filter was evacuated. No personnel were overexposed to vinyl chloride. The weather conditions at the time of the release were: Barometric Pressure: Temperature: Wind Direction: Wind Speed: Clear Skies 29.91 inches mercury 80F North North East 0-2 miles per hour ABDOO185836 Mr. Charles R. Jecer United States Environmental Protection Agency September 23, 1981 Page 2 The amount of vinyl chloride released is estimated to be 20 pounds. This differs from the amount of vinyl chloride reported to the National Response Center (5 - 10 pounds) which was based on preliminary calculations. The calculation is based on the liquid expansion of vinyl chloride from 70F to 80F. To prevent future discharges of this type from happening again, the following action steps have been or will be taken. 1. A portion of the equalization line frcm the filter to the fresh receiver was replaced and the balance was checked for pluggage on September 17. 2. An improved rupture disc holder that can be pretorqued in the shop was installed on September 17. 3. The relief valve was tested to insure relief at the proper pressure. 4. The relief valve discharge will be routed into the batch water strippers which operates at a low pressure. The relief valve will be modified to allow it to relieve to a variable back pressure. The standard operating procedures have been changed to include a daily check of the filter to make sure that the equalization line between the filter and the receiver is open. This will be done by monitoring the charge filter pressure after reactor charge to make sure the pressure equalizes with the receiver pressure. The reporting requirements of the standard pertaining to reporting relief valve discharges are summarized below: Source: North Fresh VCM Charge Filter, Reactor Module No. 1 Nature: Discharge through relief system on North Fresh VCM Charge Filter, Reactor Module No. 1 Cause: September 16, 1981 Time: 12:25 p.m. Approximate Discharge: 20 pounds Method of Determining Discharge: Density Difference Action Taken to Prevent Discharge: Filter taken out of service and evacuated Measure Taken to Prevent Future Discharges: 1- Equalization line replaced 2- Improved rupture disc holder installed Relief Valve tested Routing of relief valve dis charge to batch water strippers Daily monitoring of filter pressure to insure equalization line is open ABD00185837 Mr. Charles R. Jeter United States Environmental Protection Agency September 23, 1981 Page 3 If there are any questions concerning this discharge, please contact me at 601-369-8111, extension 2331, Veldon E. Messick Senior Process Engineer tap c: Jerry Banks - Bureau of Pollution Control CLM, CRM, PEM, MPB, SJV, JCL ABDOO185838 E-1 RELIEF VALVE DISCHARGE CALCULATION NORTH FRESH VCM FILTER-REACTOR MODULE NO, 1 12:25 P.M. - SEPTEMBER 16, 1981 Ambient Temperature At Beginning of Blocked-In Condition (9:00 A.M.): 70F Ambient Temperature at Time Of Release (12:25 P.M.): 80F Vinyl Chloride Density at 70F: 0.912 = 7.597 pounds/gal. Vinyl Chloride Density at 80F: 0.908 = 7.564 pounds/gal. Approximate Volume of Filter and Piping Blocked In: 600 gal. Mass Before Release (70F) = (600 Gal.) (7.597 Pounds) = 4558 pounds Gal. Mass After Release (80F) = (600 Gal.) (7.564 Pounds) = 4538 pounds Gal. Amount of Release (Difference) - 20 pounds ABDOO185839 E-2 ABDOO185840 (c noco) Conoco Chemicals Company Conoco Inc. P 0. Box 91. New Highway 25 Aberdeen. MS 39730 E-2 November 13, 1981 Mr. Charles R. Jeter Regional Administrator Region IV United States Environmental Protection Agency 345 Courtland St., N.E. Atlanta, GA 30308 Dear Mr. Jeter: At approximately 12:30 p.m. on November 5, 1981 our plant experienced a minor relief valve discharge. Pursuant to the National Emission Standard for vinyl chloride (40 CFR, Part 61, Subpart F, paragraph 61.65a) we are reporting this incident to your office. This discharge was reported to the National Response Center on November 5 under the Comprehensive Environmental Response, Compensation and Liability Act of 1980. The vessel involved was the north fresh VCM charge filter in reactor module No. 1. The vessel relieved through a 3/4" x 1" relief valve which has a 1" rupture disk between it and the filter. The relief valve setting was 275 psig and the rupture disk was rated at 300 psig at 72F. The release occurred shortly after polymerization reactor D-600 was charged. An operator in the field noticed the discharge from the filter and notified the control room using the plant radio system. Another operator who was in the control room at the time immediately put on a self contained breathing air system and went to the filter. He blocked the filter in by closing 6" manual valves on the inlet and discharge of the filter, opened the valve on the filter to the recovery system and shut a manual valve under the relief valve which stopped the release. The time required to stop the release after it was detected was approximately two and one-half minutes. The release was stopped at 12:39 p.m. The charging of D-600 reactor just prior to the release appeared to be normal. The reactors are charged automatically with a programable controller. This controller opens and closes valves and stops and starts pumps based on signals from flow meters which measure the amount of water and VCM charged to the reactors. Since there was no apparent cause for the relief valve discharge, charging of reactors was ceased until a reactor was test-charged with water to determine ABDOO185841 Mr. Charles R. Jeter United States Environmental Protection Agency November 13, 1981 Page 2 if the programable controller was working properly. The test charge revealed that the automatic on/off valve on the discharge side of the VCM charge pump did not close properly after the VCM charge was complete. After a built-in time delay in the sequencing operation, the programable controller restarted the VCM charge pump and then the automatic on/off valve closed properly. During this restarting of the pumps the VCM charge valves down stream of the filter prior to the reactor remained closed resulting in the pump momentarily dis charging into the blocked-in filter. It is believed this is what happened on the previous charge to D-600 and the dead head pressure of the VCM charge pump was a sufficient hydraulic shock to burst the rupture disk and to open the relief valve at the filter. Since the pump discharge valve closed almost immediately after the pump restarted, the relief valve should have reseated very quickly as soon as the pressure of the filter decreased to 175 psig. The relief valve was taken to the shop and inspected after the release and found to contain debris that kept the valve from reseating. Therefore, based on the testing of the charge system and the inspec tion of the relief valve, we believe there was a momentary (approx imately 10 seconds) liquid VCM discharge from the relief valve until the VCM pump discharge valve closed and then a VCM vapor discharge until the manual valve under the relief valve was closed. The charge on D-600 was complete at 12:30 p.m. The vapor discharge lasted about nine 'minutes since the manual valve under the relief valve was closed at 12:39 p.m. Using relief valve discharge calculational procedures provided by the relief valve manufacturer, Farris, the amount of liquid VCM released is estimated to be 18 pounds and the amount VCM vapor released is estimated to be 71 pounds; the total release is thus estimated to be 89 pounds of VCM. Copies of the discharge calculations are attached. The relief valve discharge stack is 10 feet above grade and no personnel were overexposed to vinyl chloride. The weather conditions at the time of the release according to the plant weather station were as follows: Barometric Pressure Temperature Wind Direction Wind Speed 29.94 inches of mercury 74F From Northeast Trace To minimize the possibility of future discharges of this type a suitable relief valve which was previously used in another part of the plant was installed on the VCM filter. The discharge from the relief valve was piped to the VCM receiver before another reactor in the module was charged. Charging was delayed for 24 hours which resulted in one day of lost pro duction. Thus if in the future the filter should become overpressured, it will releive into the VCM receiver and not to the atmosphere. Also the charge sequence was reprogrammed so that the VCM charge pump cannot ABD00185842 Mr. Charles R. Jeter United States Environmental Protection Agency November 13, 1981 Page 3 * E-2 MDENTIAL start unless the VCM charge valves and the main reactor valve are open thus preventing the pump from discharging into the blocked in filter. A balanced bellows relief valve for the VCM filter had been ordered prior to this release but delivery is not expected until early December 1981. Plans were to install the relief vlave on the filter and to pipe the discharge to a vessel in VCM service. The reporting requirements of the Standard pertaining to relief valve discharges are summarized below: Source: \ North Fresh VCM Charge Filter, Reactor Module No. 1 Nature: Discharge through relief system on North Fresh VCM Charge Filter, Reactor Module No. 1 Cause: Overpressure of the filter due to pump discharging into the blocked in filter and failure of the relief valve to reseat. Date: November 5, 1981 Time: 12:30 p.m. Approximate Discharge: 89 pounds VCM Method of Determining Discharge: Relief Valve Calculation Action Taken to Prevent Release: 1. Filter blocked in 2. Filter put under evacuation 3. Manual valve under relief valve closed Measures Taken to Prevent Future Discharges: 1. Relief valve on filter replaced with another relief valve and the discharge from the relief valve is piped to the VCM receiver. 2. The charge sequence was reprogrammed such that the VCM charge pump cannot start unless the VCM charge valves and the main reactor valve are open. Mr. Charles R. Jeter Uuited States Environmental Protection Agency November 13, 1981 Page 4 If there are any questions concerning this report, please contact me at (601) 369-8111, extension 2239. Sincerely, R. A. Frohreich tap c: Jerry Banks, Bureau of Pollution Control JF, CRM, PEM, SJV, DLM, JJH ABDOO185844 RELIEF VALVE DISCHARGE CALCULATION NORTH VCM CHARGE FILTER - REACTOR MODULE NO. LIQUID DISCHARGE 12;30 P.M. - NOVEMBER 5, 1981 1 E-2 CONFIDENTIAL- From: Teledyne Farris Safety Relief Valve Sizing Bulletin FE-336, page 3.1 V A 38.0 Kd OS' P\ -'?2 Kp Ku Where: A = Effective Orifice area, in. 2 * 0.098 in."2 VL = Relieving Rate, gallon per minute G = Specific Gravity, = 0.9 Kd = Coefficient of Discharge = 0.64 Kp = Liquid Capacity Correction Factor, for 4% overpressure = 0.32 Ku = Viscosity Correction Factor - 1.0 Pj = Set Pressure at Inlet, psig = 275 psig ?2 = Back Pressure at Outlet, psig = 0 psig Then: V, (0.098) (38) (0.64) Vl725 x~275 - 0 (0.32) (1.0) NfOTT = 14.9 gallons per minute Vinyl chloride discharged in 10 seconds = 14.9 gallon X 7.5 pound X 1 min. X 10 sec. =18 pounds VCM min. gallon 60 sec. ABDOO185845 RELIEF VALVE DISCHARGE CALCULATION NORTH VCM CHARGE FILTER - REACTOR MODULE NO. VAPOR DISCHARGE 12:30 P.M. - NOVEMBER 5, 1981 1 CONFIDENTIAL From: Teledyne Farris Safety Relief Valve Sizing Bulletin FE-336, page 31 A= W c kTpTm-KfcT Where: A W T Z C Kd M Kb P * Effective Orifice Area, in. 2 = 0.081 in. o (Valve orifice area assumed to be one-half plugged) * Relieving Rate, pounds per hour = Inlet Temperature, R = 460 +74 = 534R = Compressibility Factor = 0.92 = Gas Flow Constant = -0 92- 3/5" Coefficinet of Discharge = 0.95 = Molecular Weight - 62.5 * Back Pressure Correction Factor = 1 = Relieving Pressure, psia = 54.4 psia (Vapor pressure of VCM @ 74F) Then: W= (0.081) (315) (0.95) V534 * \J0.92 (54.4) '/62TF (1) = 475 pounds per hour Vinyl chloride discharged in 9 minutes = 475 pound x 1 hr. x 9 min. = 71 pounds VCM hr. 60 min. ABDOO185846 Appendix F ABDOO185847 APPENDIX F ITEM NO. F-l P-2 TABLE OF CONTENTS DESCRIPTION Letter, R. A. Frohreich (Conoco Inc.) to Charles R. Jeter (Envlmonmental Protection Agency), October 26, 1981 Interoffice Communication, P. E. Markey to File, VCM RELEASE, VCM UNLOADING AREA, 10/16/81 CORRECTIVE ACTION STEPS, November 17, 1981 ABDOO185848 F-1 ABDOO185849 A % F-l Conoco Chemicals Company Division of Conoco Inc. P.0. Sox 91. New Highway 2 S Aberdeen. MS 39730 October 26, 1981 Mr. Charles R. Jeter Regional Administrator Region IV United States Environmental Protection Agency 345 Courtland Street, N.E. Atlanta, GA 30308 Dear Mr. Jeter: At approximately 11:05 p.m. on October 16, 1981, our plant experienced a relief valve discharge. Pursuant to the National Emission Standard for vinyl chloride (40 CFR, Part 61, Subpart F, paragraph 61.65 a) we are reporting this incident to your office. This discharge was reported to the National Response Center under the Comprehensive Environmental Response Com pensation and Liability Act of 1980. The vessel involved was a surge tank, T-201, in the VCM railcar unloading area of the plant. The vessel relieved through a 2V' X 3V' relief valve which had a 2" rupture disk between it and the surge tank. The rupture disk was rated at 150 psig at 72F. The relief valve setting was 150 psig. The pressure rating of the surge tank is 150 psig at 366F. The stack from the relief valve is sixteen feet above grade. The release occurred during the unloading of VCM from railroad cars into the VCM storage sphere. The operator inadvertently did not open a valve on the discharge of one of the VCM unloading compressors. As a result of operation of the compressor in a blocked in condition the pressure at the compressor discharge increased and relieved through the relief valve on the compressor into the surge tank. This resulted in overpressuring the surge tank causing the relief valve on the surge tank to discharge. The operator then shut the compressor off and the relief valve reseated. The operator estimates the relief valve discharged for approximately two and one-half minutes. The weather conditions from the plant weather station at the time of the release were as follows: Barometric Pressure - 29.96 in. mercury Temperature - 64F Wind Direction - From Northeast Wind Speed - Trace Sky - Cloudy Mr. Charles R. Jeter United States Environmental Prctection Agency October 26, 1981 Page 2 c F-1 'irr* Ji .1 The amount of vinyl chloride released is estimated to be 357 pounds. This is based on a two and one-half minute release and on a relief valve capacity cal culations! procedure provided by Consolidated, the relief valve manufacturer. Relieving conditions of 150 psig and 158F are used in the calculation. A copy of the calculation is attached. To minimize the possibility of future discharges of this type, the operators at the VCM unloading area will be reinstructed in the proper unloading pro cedures with special emphasis placed on not operating a compressor blocked in. Also high temperature switches will be installed on the compressors to shut them down if they are started up in a blocked in condition. A high pressure switch will be installed on the surge tank to trip an alarm and shut down all of the unloading compressors in case of high pressure in the surge tank. The reporting requirements of the Standard pertaining to relief valve discharges are summarized below: Source: Surge Tank, T-201 Nature: Discharge through relief system on surge tank, T-201 Cause: Overpressure of surge tank, T-201, due to operation of a VCM unloading compressor in a blocked in condition. October 16, 1981 rime: 11:05 p.m. pproxlmate ischarge: 357 pounds of vinyl chloride tthod of termining scharge: Relief valve calculation ion Taken Prevent charge: Compressor shutdown ;ures Taken revent re Discharge: 1. Operators reinstructed in proper VCM unloading procedures. 2. A high temperature shutdown will be installed on each unloading compressor. 3. A high pressure switch which will shutdown all VCM unloading compressors will be installed in surge tank, T-201. ABDOOl 85851 United States Environmental Protection Agency October 26, 1981 Page 3 0 If there are any questions concerning this report, please contact me at (601) 369-8111, extension 2239. Sincerely, Fubtm.-L R. A. Frohreich cap c: Jerry Banks, Bureau of Pollution Control be: JF, CRM, PEM, SJV, DIM, JJH Relief Valve Discharge Calculation Surge Tank, T-201 11:05 P.M. - October 16, 1981 From: Consolidated Safety Relief Valves Catalog No. 1900 B, page 46 Where: a = w c vT~ yT~ p 'fir A a Orifice area, in G orifice = 0.503 in^ W * Relieving Race, lb./hr. T * Inlet Relieving Temperature, R * 618R Z Compressibility Factor, 0.82 C Nozzle Gas Constant, page 48, * 295 P * Relieving Pressure, psia * 164.7 psia M Molecular Weight of Vapor * 62.5 Then: W (0.503') (295) (164.7) V62.5 '/elsT x VoTai a 8580 lb./hr. Vinyl chloride discharged in 2.5 minutes * 8580 lb. X 1 hr. X 2.5 min. 357 lb. hr. 60 min. ABD00185853 Interoffice Communication to : File From : P. E. Markey Dat : November 17, 1981 Subject : VCM RELEASE, VCM UNLOADING AREA, 10/16/81 CORRECTIVE ACTION STEPS Pursuant to R. A. Frohreich's letter of October 26, 1981 to Charles R. Jeter, EPA, regarding the subject release, (See Exhibit A) the following corrective measures have been completed. 1. Operators were reinstructed in proper VCM unloading, procedures in the form of a safety meeting. (Completed 11/5/81, See Exhibit B) 2. A high pressure switch which will shutdown all VCM unloading compressors was installed on surge tank T-201. (Completed and tested 11/13/81, witnessed by Tom Bales, A1 Barfield). Compressors shutdown at 100 psig. ditional steps taken included: 1. A 2-day disciplinary lay-off for ''inattention to operations" for the yard operator who improperly lined up the valving at the tankfarm. (See Exhibit C) 2. Instituted a daily check list on proper tank farm "line-ups" which will be turned in to operations c: JF, CRM, RAF LDH ABDOO185855 Conoco Chomieais Company Division of Conoco Inc. P 0. Box 91, New Highway 25 Aberdeen. MS 39730 F-2 A October 26, 1981 or Mr. Charles R. Jeter Regional Administrator Region IV United States Environmental Protection Agency 345 Courtland Street, N.E. Atlanta, GA 30308 Dear Mr. Jeter: At approximately 11:05 p.m. on October 16, 1981, our plant experienced a relief valve discharge. Pursuant to the National Emission Standard for vinyl chloride (40 CFR, Part 61, Subpart F, paragraph 61.65 a) we are reporting this incident to your office. This discharge was reported to the National Response Center under the Comprehensive Environmental Response Compensation and Liability Act of 1980. . The vessel involved was a surge tank, T-201, in the VCM railcar unloading area of the plant. The vessel relieved through a 2H" X 3H" relief valve which had a 2" rupture disk between it and the surge tank. The rupture disk was rated at 150 psig at 72F. The relief valve setting was 150 psig. The pressure rating of the surge tank is 150 psig at 366F. The stack from the relief valve is sixteen feet above grade. The release occurred during the unloading of VCM from railroad cars into the VCM storage sphere. The operator inadvertently did not open a valve on the discharge of one of the VCM unloading compressors. As a result of operation of the compressor in a blocked in condition the pressure at the compressor discharge increased and relieved through the relief valve on the compressor into the surge tank. This resulted in overpressuring the surge tank causing the relief valve on the surge tank to discharge. The operator then shut the compressor off and the relief valve reseated. The operator estimates the relief valve discharged for approximately two and one-half minutes. The weather conditions from the plant weather station at the time of the release were as follows: Barometric Pressure - 29.96 in. mercury Temperature - 64F Wind Direction - From Northeast Wind Speed - Trace Sky - Cloudy ABD00185856 Mr. Charles R. Jeter United States Environmental Protection Agency October 26, 1981 Page 2 The amount of vinyl chloride released is estimated to be 357 pounds. This is based on a two and one-half minute release and on a relief valve capacity calculational procedure provided by Consolidated, the relief valve manufacturer. Relieving conditions of 150 psig and 158F are used in the calculation. A copy of the calculation is attached. To minimize the possibility of future discharges of this type, the operators at the VCM unloading area will be reinstructed in the proper unloading pro cedures with special emphasis placed on not operating a compressor blocked in. Also high temperature switches will be installed on the compressors to shut them down if they are started up in a blocked in condition. A high pressure switch* will be installed on the surge tank to trip an alarm and shut down all of the unloading compressors in case of high pressure in the surge tank. The reporting requirements of the Standard pertaining to relief valve discharges are summarized below: Source: Surge Tank, T-201 Nature: Cause: Date: Discharge through relief system on surge tank, T-201 Overpressure of surge tank, T-201, due to operation of a VCM unloading compressor in a blocked in condition. October 16, 1981 Time: 1L:05 p.m. Approximate Discharge; 357 pounds of vinyl chloride lethod of (Determining discharge: Relief valve calculation ction Taken 'o Prevent discharge: Compressor shutdown Measures Taken 0 Prevent uture Discharge: 1. Operators reinstructed in proper VCM unloading procedures. 1 2. A high temperature shutdown will be installed on l each unloading compressor. A high pressure switch which will shutdown all VCM unloading compressors will be installed in surge tank, T-201. ABDOO185857 Mr. Charles R. Jeter United States Environmental Protection Agency October 26, 1981 Page 3 F-2 If there are any questions concerning this report, please contact me at (601) 369-8111, extension 2239. Sincerely, /P/l firvhz R. A. Frohreich tap c: Jerry Banks, Bureau of Pollution Control be: >F, CRM, PEM, SJV, DLM, JJH ABD00185858 Relief Valve Discharge Calculation Surge Tank, T-201 11:05 P.M. - October 16, 1981 From: Consolidated Safety Relief Valves Catalog No. 1900 B, page 46 Where: A= W C VT y Z P v/m~ A * Orifice area, in G orifice - 0.503 in^ W * Relieving Race, lb./hr. T Inlet Relieving Temperature, R * 618R Z - Compressibility Factor, = 0.82 C = Nozzle Gas Constant, page 48, * 295 P Relieving Pressure, psia = 164.7 psia M Molecular Weight of Vapor = 62.5 Then: W = (0,503') (295) (164.7) V62~T V618 X V0.82 = 8530 lb./hr. Vinyl chloride discharged in 2.5 minutes 8580 lb. X 1 hr. X 2.5 min. = 357 lb. hr. 60 min. TOPIC: LOCATION: SAFETY /TRAINING M^Pfl&8^xENDAKCE RECORD eaAS*Ljj ait's NUMBER OF HOURS: 'F-2 A DATE: //// SI !/z Houa. OUTLINE OF PRESENTATION^Maj or points, demonstrations, what was practiced, slide/tape, film, etc.). Attach separate sheet if necessary. J=LAJL/*^ Ajaq cJbe.JlA.-jJ~ ** tAxdu file**- Qj4JL& jfc -LA.. iMJo. (XMjtv/tfiC&L--- Q\--f s/jIaJ-<a2xfcy EMPLOYEE SUGGESTIONS AND PLANNED CORRECTIVE ACTION: Adit/- J* 2) flo ^ 3) ______^ TRAINEES UsOxA*. jLu^e- LD. fr*sycn- Instructor/Supervisor DEPT. YMa cl i1 1i i w CLOCK NO. /hS# y {2*\ !c! Jj /," ^ / i l NAME (Print,) 1 CLOCK | DEPT. ! NO. ! '7ZZo U-L-W 1 4 ''l^/ /fay 4/ sT)* -JFttT\ n^- fli yy-^sy i ' / 1fitiLO----. /f I i l i 1 i 1 1 __________ !_________ !___ 1 1 NAME ____ (Print1) ! i 1 >1 1 1 1 1 1 1 II 1 II 1 il ! n1 11 II 1 11 1 1 II 1 1 ABDOO185860 F-2 Interoffice Communication to Milton Threadgill prom : Dean Honeycutt Da November 9, 1981 Subject : Inattention to Operations & With Holding Information Disciplinary Lay Off On October 13th, you were given a written warning for inattention to operations. This resulted from your not properly cleaning a railcar prior to loading. On October 16th, you hooked up two VCM railcars for unloading. You incorrectly lined up the valving which resulted in the compressor operating under a "dead head" condition which subsequently lifted the relief valve at the compressor discharge, burst the rupture disc on surge tank T-201, and lifted the relief valve on T-201 releasing VCM to the atmosphere. When you were asked about your side of the story. You stated you did not see any VCM released from the surge pot, T-201 and you did not check both of the valve lineups because of two (2) nitrogen bottles tied off to piping. Later the following week you changed your account of the incident and stated you did see VCM coming from T-201 and esti mated the release at about 2% minutes. Your inattention to operations in properly lining up the valving for off loading VCM cars and with-holding information relevant to the inci dent are considered quite serious. This incident was reportable to the United States Environmental Protection Agency and your account of the incident was critical in determining the proper plant action steps in this regard. Because of the seriousness of this incident and the short time period since your written warning of October 13th, I am suspending you for two (2) days, November 10thand lTth. You are to return to your regular shift schedule on November 13th at 7:00 p.m. Any similar or future incidents will result in more severe disciplinary action up to and in cluding termination of your employment. A L. D. Honeycutt Yard Supervisor mdp c: PEM, CRM, JF, RAM(2) & JS ABDOO185861 '.lOp*' A. VALVE SETUP CHECKLIST FOR UNLOADING ye;j * F-2 VALVES THAT MUST BE OPENED FOR UNLQAQINC: ______ 1. Main liquid valve to sphere "r}J______ 2. Main vapor valve from sph (located under sphere) 3 Check sphere level ___ Feet nches 4. Both valves on liquid and vapor lines hooked to car 5. Valves inside car dome for vapor and liquid. 6. Vapor and liquid going to stations between railroad track 7. Vapor and liquid valves under sight glasses on each station being unloaded from 8. Sphere liquid and vapor valve on main headers on west side of compressor shed 9* 4-way valves on each compressor being used must be in vertica position (handle) VALVES THAT MUST 8E QPENEO FOR RECOVERING VAPOR FROM RAILCAR: _______ 10. Same as above except,4-way valves on compressor being used in horizontal position (handle) WHAT TO CHECK FOR UNLOAQIKG: 1. Pressure gauges on compressors: a. Inlet Side - 20 to 50 pounds. If 0, compressor is full of liquid. b. Outlet Side - SO to 110 pounds. If over 120, compressor is dead headed. 2. Sight glasses on liquid lines (flow of liquid). 3. Jamesbury valves on knockout pots closed to evacuation system. 4. No valve mentioned above partially closed. CAR NUMBERS BEING UNLOADED: ABDOO185862 Appendix G ABDOO185863 APPENDIX G ITEM NO. G-l TABLE OF CONTENTS DESCRIPTION Letter, R. A. Frohreich (Conoco Inc.) to Charles R. Jeter (Environmental Protection Agency), January 14, 1982 ABDOO185864 G-1 ABDOO185865 ml* i a V G-1 Conoco Chemicals Company Conoco Inc. P 0- Boi 9 1. New Highway 2 5 Aberdeen. MS 39730 January 14, 1982 Mr. Charles R. Jeter Regional Administrator Region IV United States Environmental Protection Agency 345 Courtland St., N.E. Atlanta, GA 30308 Dear Mr. Jeter: At approximately 4:30 p.m. on January 11, 1982 our plant experienced a minor relief valve discharge. Pursuant to the National Emission Standard for Vinyl Chloride (40 CFR, Part 61, Subpart F, paragraph 61.65a) we are reporting this incident to your office. This release has been reported to the National Response Center under the Comprehensive Environmental Resonse, Compensation and Liability Act of 1980. The vessel involved was the east recovered monomer condenser in reactor module No. 2. The vessel relieved through a 1" x IV' relief valve which has a 2" diameter rupture disk between it and the condenser. The relief valve setting was 150 psig and the rupture disk was rated at 150 psig at 150F. Prior to the release an unusually cold front moved through the area resulting in some freeze problems in the plant. At the time of the release operators were in the process of thawing out the recovery system. Steam was being used to warm up the condenser. As this procedure was being done the relief valve on the condenser discharged for about three seconds and then reseated. The outlet valve on the condenser was open at the time of the release but the inlet valve to the condenser was closed. Apparently the outlet line was plugged due to freezing and as the condenser heated up the vessel overpressured and the relief valve momentarily discharged. Heating of the condenser was stopped immediately to assure the condenser would not be overpressured again. The manual valve between the condenser and the relief valve was also closed. The in let valve to the condenser was then opened and the recovery system was thawed out without further incident. The amount of VCM discharged to the atmosphere from the relief valve was esti mated to be 3.7 pounds using a calculational procedure provided by the relief valve manufacturer. Teledyne Farris. A copy of the discharge calculation is attached. The relief valve discharge stack is 48 feet above grade and no personnel were overexposed to vinyl chloride. ABDOO185866 Hr. Charles R. Jeter United States Environmental Protection Agency January 14, 1982 Page 2 A The weather conditions at the time of the release according to the plant weather station were as follows: Barometric Pressure Temperature Wind Direction Wind Speed - 30.24 inches of mercurv 19F WNW Trace To minimize the liklihood of future discharges of this type,operators will be instructed to have both inlet and outlet valves open on vessels in vinyl chloride service prior to applying external heat to them. The reporting requirements of the Standard pertaining to relief valve discharges are summarized below for this release: Source: East Recovered Monomer Condenser, Reactor Module No. 2 Nature: Discharge through relief system on the east recovered monomer condenser, reactor module no. 2 Cause: Overpressure of the condenser caused by steaming the condenser to thaw it out. The inlet valve was closed and a plug due to freezing apparently existed in the outlet line. Date: January 11, 1982 Time: 4:30 p.m. Approximate Discharge: 3.7 pounds VCM Method of Determining Discharge: Relief valve discharge calculation Action Taken To Prevent Release: 1. Steam heating of the condenser was stopped immediately; 2. The manual valve between the condenser and the relief valve was closed. Measure Taken To Prevent Future Discharges: Operators instructed to have both inlet and outlet valves open on vessels in VCM service if unusual circumstances in the future should require external heating or steaming. ABD00185867 Mr. Charles R. Jeter United States Environmental Protection Agency Jauuary 14, 1982 Page 3 If there are any questions concerning this report, please contact me at (601) 369-8111, extension 2239. Sincerely, R. A. Frohreich tap c: Jerry Banks, Bureau of Pollution Control - JF, CRM, PEM, SJV, DLM, JJH ABD00185868 Relief Valve Discharge Calculation East VCM Condenser Relief Valve - Reactor Module No, 2 Vapor Discharge 4:30 p.tn. - January 11, 1982 From: Teledyne Farris Catalog No. FE-80-1000, page 3.01, Safety Relief Valve Sizing A= W VT " Kd P fl Kb Where: A* W T 35 Z= C* Kd= M= Kb P* Effective Orifice area, in. 2 * 0.280 in. 2 Relieving Rate, pounds per hour Inlet Temperature, R 460 + 151 = 611 Compressibility Factor ** 1.0 Gas Flow Constant = 315 Coefficient of Discharge a 0.953 Molecular Weight * 62.5 Backpressure Correction Factor * 1 Relieving Pressure, psia, = 164.7 psia Then: W = (0.280) (315) (0.953) (164.7)^6275 (1) y-jy- \|lt0 W * 4433 pounds per hour Vinyl chloride discharged in 3 seconds = 4433 pound X 1 Hr. X 3 Sec. hr. 3600 sec. 3.7 pounds ABDOO185869 Appendix H appendix h ITEM NO. H-l ABDOO185870 TABLE OF CONTENTS DESCRIPTION Letter, Veldon E. Messick (Conoco Inc.) to Jerry B. Banks, P.E. (Mississippi Department of Natural Resources), June 18, 1982 ft ABDOO185871 ABDOO185872 June 18, 1982 Conoco Chmlciii Company Conoco Inc. P. O. Box 91. New Highway 25 Aberdeen. Mississippi 39730 (601) 369-6111 CONFIDENTIAL Mr. Jerry B. Banks, P.E. Mississippi Department of Natural Resources Bureau of Pollution Control P. 0. Box 10385 Jackson, MS 39205 Dear Mr. Banks: At approximately 10:45 a.m. on June 10, 1982, our plant experienced a minor emergency relief valve discharge from two relief valves. Pursuant to the National Emission Standard for Vinyl Chloride (40 CFR, Part 61, Subpart G, paragraph 61.55 (a)) we are reporting this incident to your office. This release has also been reported to the National Response Center under the Comprehensive Environmental Response and Liability Act of 1980. The vessels involved were the East and West Recovered Monomer Condensers in reactor module No. 2. Each condenser is protected by a 1" x 14" relief valve with a 2 inch diameter rupture disc between it and the condenser. The relief valves were both set to relieve at 150 gsig and rupture discs both had a rated burst pressure of 150 psig at 150F. At approximately 10:45 a.m. on June 10, 1982, an operator noticed a liquid leak coming from the second floor of the VCM recovery system structure in reactor module No. 2. Upon investigation the operator found that liquid vinyl chloride was coming from the weepholes in the discharge piping of the east and west recovered monomer condenser relief valves. The operator notified his supervisor for help and instructed the panel operator to shut down the monomer recovery system. The relief valves on the East and West Recovered Monomer Condensers were isolated at approximately 11:00 a.m. There were no vapors observed coming from either of the relief valve stacks. No personnel were overexposed to vinyl chloride. Reactor module #2 was then shut down to find the source of the overpressure to the condensers that caused the relief valves to discharge liquid vinyl chloride. The line from the discharge of the condensers to the recovered monomer receivers was taken out of service and evacuated. This line was found to be plugged with polyvinylchloride resin, which is believed to be the cause of the overpressure of the condensers. This line was thoroughly cleaned before reactor module if 2 was started up again. This is the first time this line has ever plugged with polymer since startup in early 1978. Mr. Jerry 6/18/82 Page 2 ABD00185873 H-1 CONFIDENTIAL The estimated amount of vinyl chloride discharged is approximately 57 pounds. This amount is estimated from the accounts of those who observed the discharge. The accounts ranged from a quart of total liquid discharged to a pint of liquid every 30 seconds. The most conservative account was used to calculate the discharge. Attached are the calculations used to estimate the amount of the discharge. This amount differs from the amount reported to the National Re sponse Center shortly after the Incident. The estimated amount reported to the National Response Center was in the low hundreds of pounds. To minimize the possibility of future discharges of this type, the plant has Instituted a procedure to check, the pressure drop using pressure gauges between the discharge of the condensers and the recovered monomer receivers during re actor recovery. This check will be made weekly. If an abnormally high pressure drop is experienced between the discharge of the condensers and the recovered monomer receivers, the line will be taken out of service and cleaned. As a long term measure, the plant will install a high pressure alarm on the dis charge of the recovery system compressors. Upon high compressor discharge pressure, the source the high pressure will be found and corrected. When the high pressure alarm is installed, the weekly check of the pressure drop between the condensers and the receivers will be discontinued. The reporting requirements of the Standard pertaining to the relief valve discharge are summarized below: Source: Cast and West Recovered Monomer Condensers, Reactor Module No. 2 Nature: Discharge through relief systems on the East and West Recovered Monomer Condersers Cause: Overpressure of Recovered Monomer Condensers which is believed to be caused by pluggage of the liquid discharge line Date: June 10, 1982 Time: 10:45 a.m. Approximate Discharge: 57 pounds of vinyl chloride Method of Determining Discharge: Calculation based on account of personnel who observed the discharge. Action Taken to Prevent Discharge: 1. Monomer Recovery System shut down, 2. Relief valves isolated. 3. Module No. 2 shut down 4. Liquid line from the discharge of the Recovered Monomer Condensers was evacuated and cleaned. ABD00185874 Mr. Jerry Banks 6/18/82 Page 3 CONFIDENTIAL Measures Taken To Prevent Future Discharges: 1. Weekly pressure readings will be taken to determine pressure drop between the discharge o the Recovered Monomer Condensers and the Recovered Monomer Receivers. If an abnormally high pressure drop Is observed, the discharge line of the condensers will be taken out of service and cleaned. 2. A high pressure alarm will be installed on the compressor discharge. Upon high compressor discharge pressure, the source of the high pressure will be found and corrected. The weather conditions at 11:00 p.m. on June 10, 1982 were: Barometric Pressure Wind Wind Speed Temperature Clear 29.88 inches of mercury From Northwest 0 - L miles per hour 83F If there are any questions concerning this report, please contact me at (601) 369-8111, extension 2331. Sincerely, Veldon E. Messick Senior Process Engineer tap bcc: JF, CRM, PEM, RAF, DLM, JCL ABDOO185875 H-l A RELIEF VALVE DISCHARGE CALCULATION EAST AND WEST RECOVERED MONOMER RECEIVERS 10:45 A.M. - JUNE 10, 1982 Discharge 1 pint 30 seconds jc. 60 seconds 1 minute x 15 minutes x 2 stacks x gallon 8 pints 7.5 gallons 7.6 pounds gallon 57 pounds of vinyl chloride