Document pmVkV3d2gbdOGVVMnMxDRqdgE

To From INTEROFFICE MEMORANDUM R. Fleming J- T- Barr/ A. R. Adams L. Allen J. Balliker J. H. Body P. L. T. Brian A. F. Cantor R. E. Duggan R. E. Gilbert A. E. Greene B. Helm Subject Date 27 September 1979 Vinyl Chloride Safety Association Meeting Executive (UuIIoa, Organization, or 0OJrtmnt) Reg. Response (Location, Organization, or Department) J. D. Kramer J. H. McMakin A. K. McMillan J. C. Novak E. A. Primeau R. C. Sander R. H. Schenck J. M. Scigliano/W. Silowka J. H. Yaworski The annual m?eting of the Vinyl Chloride Safety Association was held at San Francisco on 13-14 September 1979. More than 90 persons from 10 countries attended. Air Products was represented by Larry Allen, Earl Primeau, and the writer. A complete attendance list will be available later. The officers for the next year will be: Chairman, 0. Gabbett (Georgia Pacific); Vice-Chairman, W. Clark (Dow); Program Chairman, R. Becker (Diamond-Shamrock). H. Olsen (Ethyl) and J. Hager (Stauffer) remain permanent Secretary and Treasurer, respectively. The next meeting will be held in Bermuda in October 1980. Summary of Proceedings Several of the subjects planned for the agenda were not presented because of problems getting input or leaders for the items selected in the summer survey, thus the original agenda was not followed exactly. See Attachment I. CUT R. Fleming This presentation provoked considerable discussion at later breaks, and several persons have asked for further information. Risk Analysis Don Wobser, Union Carbide The Union Carbide procedure for process risk analysis was illustrated by application to their solvent polymerization reactor. Their overall procedure i$ as follows: 1. Fault identification, individual and in all possible combinations, is prepared for use in an effects analysis. (320) AP00050504 2 2. Preliminary hazards review is prepared from process information, equipment specifications, process chemistry, and total energy inventory. This normally takes 1-2 man days by an experienced analyst with adequate help. 3. Failure mode identification and effects analysis follows, performed by a team of about 5 persons (not necessarily including persons from manufac turing - this caused some comment) and takes 2+ days for the first review, followed by a 11 few weeks" work by the analyst. They review each part of the process, disect the systems to identify hazards, and go through a uwhat-if" analysis to describe the s-ope of failures and their potential cause-effect relationships and to search for possible solutions. However, solutions are not the prime responsibility of this procedure, and are expected to be prepared by the process group. A criticality scale is used to prioritize information needs and along with a probability estimate in a matrix presentation to establish action timing for existing processes. For example if there Is a moderate or high probability for a- strong or severe effect, immediate response is required. A goal of less than once per thousand years is established for a severe effect. 3. Fault f'-ee analysis is applied, using a systems approach to examine interactions of various failure modes. A team critique is used wnich takes about one day for the group, followed by two weeks work by the analyst. A response diagram is constructed and computer simulation used. Integration is by the Ruge-Kutta approach. This example had 34 variables, and took 25-30 man days to examine. It was stated that after programming, each final "run" cost about $0.75. Results of the study were: 1. There were no major hazards that had not been anticipated in design. 2. Many minor changes were made to reduce the effects of process upsets. 3. More rapid emergency response was obtained. 4. Response systems were directed to treat the causes, and not just the symptoms of upsets. 5. Quality was improved and costs reduced. The completed program has been very useful in operator training and in research studies. They are convinced that paper studies can give a realistic and reliable picture of actual fault patterns. Their expe rience is that it normally requires 3 or more failure events to cause a major effect, and that about 90% of the time some type human failure is involved. AP00050505 3 They have used a combination of formal training and special short courses to prepare their specialists. Schools which have programs in this area include Texas A&M, Carnegie-Mellon, University of Washington, University of Tennessee, and George Washington University. They also hired consul tants at the beginning. The analysis is used only on major projects, and because this group is a service activity, only at the request of Process. A comment by ICI pointed out that they had used this procedure for more than 10 years, that it was mandatory in any high risk situation, and also before any process modification. It is not used as the basis for cost/benefit decisions, but to provide advice and analysis. A show of hands identified 10 companies which use some Mmilar type of procedure, three with computer simulation. Training for Safety Roy Henderson, Diamond-Shamrock The employee training program at the new D.S. monomer plant was used to illu strate their procedures and methods. Their principal effort is to give adequate information and guide in its inter pretation. This includes a good understanding of the properties and hazards of the materials used, and also of the equipment and processes. In preparation of the second quarter 1978 startup they began personnel assignments in late 1976. By early 1977 they had their 10 key supervisors aboard, by mid-1977 all salaried technical and supervisory personnel were assigned, and by Setpember 1977 all personnel had been located. Only 9 operators had prior chemical experience. The total work force is about 205. The first steps were to write a process training manual, that was used later as the operating manual, and to attend training seminars by the suppliers of major units. All exempt persons attended a key-man safety seminar. Then the group prepared their safety manual, emergency manual, spill prevention and lead detection programs, and hazards handbook. All potential operators were given a 4-week refresher course in basic math, physics, and chemistry, and fundamental manufacturing terminology. The total plant force went to the 4-day, Texas A&M fire fighting school. This developed a strong sense of interdependence as well as needed skills. During the latter construction period there was half-day schoolroom study and half-day field inspection and identification. There was also a 4-week school of half company procedures and half special skills. The operators then assisted in the final field checkout. AP00050506 4 The plant was completed by systems, not geographical areas. In January 1978 they started and operated the coaling water system, then air, then steam, and then purchased EDC and VC to operate portions of the distillation trains before the reactors were completed. Finally, all hazard information was brought into the Material Safety Data Sheets, compliance and enforcement procedures were prepared by those to whom each would apply. Safety meetings are used as refresher training and for detailed discussion of problem areas. Startup resulted in two recordable accidents - one tripped over a pipe, another fell from an improperly extended ladder. There has been one recordable acci dent so far in calendar 1979, They have one Safety and Loss Control Supervisor, primarily concerned with security, fire prevention and similar housekeeping chores, and one Environmental Engineer, responsible for industrial hygiene. It is more difficult to train operator additions to an existing plant. All of their Houston area plants cooperate in maintaining a 4-week school for new hires (see a later discussion). They have'validated once, and are now revalidating their preentrance exam, so that they can require minimum scores before hiring. It demands 7th grade arithmetic and reasonable reading skills. Their contract maintenance people are given the same training and safety programs as fulltime employees, despite the rapid turnover. Relief operators are used extensively for training when not actually relieving. Monomer Peroxide Explosion B. Terwlesch, C. W. Huls An explosion occurred 29 December 1978 in the monomer recovery and recycle section of the Huls 100 tpd PVC plant which was built in 1973. Their process used two screw compressors to condense vapor from a gasholder. The outlet pressure was 8 bars at 110C, and the noncondensed gases were water scrubbed before return to a monomer plant (ammonia was added to control the pH at above 6) in a tower where water was added to maintain a desired level. This tower previously had contained Raschig rings, but they had earlier been found to have polymeric peroxides on them, and so had been removed. Prior to the explosion a leak had been found in the tower, and it was bypassed and depressurized. Steam was applied to several pipe turns on the exterior to prevent freezing. The recovery section was destroyed with about 2 MM DM damage by the explosion. The principle causes of the explosion appear to be the heat-induced decomposi tion of a significant quantity of peroxide formed in the tower. Primary contributors were the unusually high allowable oxygen content of the gases, 6% or half the explosive limit as compared to the below 0.5% that is acceptable AP00050507 5 here, the high temperature at the compressors, and the probable presence of liquid monomer in the scrub tower resulting from, inadequate condensing capacity in the expanded condensing train. The prior finding of peroxide should have been adequate warning that the system was not being operated properly. Subsequent laboratory work confirmed the literature (primarily Kolenin, et al. Chem. Industrie. 27-28 (1966)) that acetaldehyde, iron salts, acid and water catalyze the formation of the peroxides, which polymerize to a gummy mass. See also ibid. , 3 172 (1970). The laboratory-made polymer has a molecular . weight of about 750-1400, averaging about 1000. The autodecomposition starts at about 40C, raising temperatures at about 2.5C/min and releasing about 2 Kj/g. Formaldehyde and CO are decomposition products, along with C0, water and HC1. 1 They have since reduced the allowable oxygen content to 2%, and use 3% NaOH as the scrub liquid. lodometric spot tests are used to check for peroxides, assisted by IR (-0H and -CO-bond absorption) and NHR. They find that 300 ppm phenol is adequate to control - lower values were not tested. A pH 8 is safe, 5 is not. Temperature and organic impurities increase the rate of formation. Oxygen concentration is important, iron salts are not a major influence. Decomposition of the peroxide by aqueous caustic is sometimes slow if large masses are not properly contacted, and addition of methanol or other bridging solvents is useful. They now use Topacol C, a substituted phenol (same as Iona!??) at low concen trations in their system, and do not redistill before reuse. A written version of their discussion is not generally available at this time. EIF stated that they had a similar explosion and now use caustic wash with no more difficulty. Others state that they assure quick reuse of the condensed material. Transportation Accident H. Waltemate, BFG The October 1979 derailment in Kentucky left two leaking and burning cars which persisted for several days and delayed repair and use of the track. The local fire marshall requested a squad from Ft. Campbell to place shaped charges on the cars to penetrate the shell and release the liquid for more rapid burning. The cars were diked to contain the spill, and secondary charges, placed to reignite the liquid. This was successful on the first try on one car, but the second had an ice layer on the heads, so another try was needed. Burnoff took less than 30 minutes. A copy of the video tape made by a local TV station is available on loan. Three other VC cars also derailed. One had the full DOT retrofit package, and two were double insulated. These were not punctured and were replaced on the track for delivery. Operator Training Programs D. Frey, Diamond-Shamrock This discussion was an extension of the earlier presentation by R. Henderson on pre-commissioning training. There are five D-S installations in the Houston area with a total Work force of about 1100, and they have a cooperative train ing program for employees. Prior to 1975 their average operator had 7 years AP00050508 (A 6 experience in their plant, and a head operator had 10-12 years. After the 1975 expansions the figures decreased to two and three years, respectively. Thus, they started a training program. The Gulf Coast Area Program employs full-time two former-supervisors that give two principal courses, a 4-week entry level program divided into equal parts of classroom and field study, and a 1-week "recycle" program given each employee yearly. The Plastics Operations has one full-time training em;loyee who gives all new employees a 4-day program on safety, company procedures, and process and quality assurance corrective action. He is developing a recycle program. Their experience has been that about two-thirds of emissions and release incidents involve operator error to some degree, but this training program has reduced release frequencies to one-third of the prior 2 year average. As environmental violations have dropped, product quality has increased. There has been no change in the rate of recordable OSHA injuries, which already was low. Their recommendations for a successful program included: 1. Go first class - provide adequate facilities and absorb the costs for overtime. 2. Employ a good trainer (rotate his duties). 3. Develop a positive attitude in the employees, which requires enthuastic management participation. Industry Emission Survey G. Schaaf, BFG Only about 40% of the members responded to the survey sent out earlier, so this report was delayed pending further answers. A part of the data are covered by the report of R. Laudrie, later. Monitoring Data Handling W. Clark, Dow This report described some of the critiera used to decide if plant data are to be stored in original form, as microfilm, in computer memory banks, or some other form. They have several process computer systems in the plant areas that gather data. These cost about $50 M, take 30 days or so to program, and have a 99.9%-on-1ine history since their earliest use in 1972. They have been in continuous use since 1974. Software has been the principal problem, and no back-up is provided. Management computers are used to process, sort, store, and report the data received from the field computers. These cost about $150 M, require 90 days to program, and have about 98% reliability. They are scheduled down 6 hr/month to create back-up storage files on floppy disks. AP00050509 7 Data which are to be reused in the original form, or which is kept only to meet a regulations is kept in the most convenient form - usually original or microfilm. If it is to be computer-processed it usually winds up on a floppy disk. Solvent Absorption as Final Control Device G, Schaaf, BFG Goodrich is offering to license their solvent absorption system for final control of vent streams. However, they were forced to admit that they are installing incinerators as stand-by backups at several of their plants, and Great American, the other solvent user, relies on its boiler for back-up. Their claim for the most economical process is based on the following table using the EPA standard 150 MM lb plant emissions of 0.4-8/100 lb of product: Solvent Incinerator C. Bed Capital, $M 475 425 600 Cost/hr, $ Utl pities Solvent Caustic 6.01 0.50 2.91 2.34 13.94 Credit, RVCM @ 174 13.96 - 13.97 Net cost/hr $ (7.46) 5.25 (0.03) It is apparent that a change in the basic assumptions will affect the net cost strongly. The advantages are given as: Safe Low operator attention Best economics (?) Low pol1ution Some impurity selectivity Disadvantages are: Releases some solvent Cannot be used on copolymer Some impurity build-up They have obtained 96% on-line time for the last 6 months, and expect 98% in the future, but are installing back-up incinerators. AP00050510 3 No precise figure on the VC content of the off-gas was given* but it was said to be well within the proposed 5 ppm. It was admitted that it was not as good as an incinerator. There was extensive discussion as to the fate of methyl chloride. John Floros sees a build-up at Great American, and burns off a purge when necessary. Scheff claimed not to have seen it at 8FG. However, a 4% downtime could well be the reason. A show of hands revealed; 3 companies have solvent systems (BFG, Great American, and Wacker) 5 have carbon beds (see 1978 report) 21 have incinerators 17 neutralize HC1 (2 use it elsewhere) 11 have back-up, 6 more planning. There is a great variety of response to loss of the primary abatement device. Several have a "few days gentlemens agreement," some go to gasholders, boilers, storage bullets, etc., others do nothing. Those with carbon beds that do produce copolymer have added a stripping column before the beds to remove vinyl acetate. Some use a small (disposable) carbon bed as a standby disposal system for their single incinerator. General Discussion Five companies have specific leak detection program approval, mostly in Region IV. Others have It indirectly through their permits. Several companies are concerned about assurance that the reactor is empty before recharging. A few, such as Tenneco and Huls have radioactive level devices. BFG has a sight glass in the dropheader. Only 8 claim to be in full closed-reactor mode as we are. For reactor opening 11 use the specified EPA instrument test to show compliance, 4 use bags, and many have approved equiva lent methods, usually random tests and record retention of a demonstrated procedure. For reactor purging 11 use steam, 3 water, and 2 nitrogen sweep to an incinerator. Stress Cracking J. Wallace, Esso Canada - Attachment II Seventeen companies, 7 of them foreign, participated in the survey for stress cracking of stainless vessels. See the attached handout for a summary of results, which seem to support his preliminary theory (see 1978 report). Temperature, pH, oxygen and chloride concentration appear to be the key vari ables. His survey included reports on 8 strippers, 4 reactor strippers, 5 reactors, 2 stripping towers, 3 centrifuges and several process pipe sections that have AP00050511 3 failed. Type 316 is somewhat better than 304 or 321, and confinement of acid by fouling or insulation is important. In general all failures have been within 0.4-3.0 service lives per his predictions. Microphotos show the failure to be intergranular, changing to transgranular, and originating in heat-sensitized areas near welds. Regulatory Activities J. Barr and R. Laundrie, General Tire The writer and Bob Laundrie used the attached outline (Attachment HI) to discuss regulaactivities of the past year. In addition, Bob reviewed the SPI survey on emergency discharges which, among other facts, showed that operator error was the single largest cause at about 30%, followed by "process upset." He also presented the attached emission and compliance data without the identifying company names from EPA semiannual reports which he obtained by FOI requests. This shows a spotty and incomplete reporting and compliance history. (Attachment IV) Discussion revealed 13 OSHA inspections during the last year. Only two cita tions of any consequence were given: Hooker was cited for not giving hazard training to workers in non-regulated work areas, and the citation was withdrawn at the Review Commission level; Pantasote was cited for not doing personnel monitoring in their Region II plant which is equipped with the E0C0M area monitor. T.'.is was despite a letter from OSHA approving this step. The cita tion is being challenged. Four companies in the northeast have received the "cease and desist" administra tive orders from EPA on emergency releases for which SPI recently voted to join in the judicial review. We and Conoco received show cause orders from Region IV, and Goodrich had an informal conference on the same subject. Region VI has not acted on this, except for one general letter earlier this year. True Confessions There were no major accidents reported again this year. Several companies discussed near-misses and minor accidents. Georgia-Pacific had established a very competitive situation between shifts during a production push. All men were on 12 hour turns and management encouraged trying to outdo the previous record. In trying to rush the appli cation of an antifouling spray through their 36" center head nozzle an operator who was working alone forgot to turn off the ventilation fan and the partial vacuum pulled the temporary rig into the reactor. The man also fell in, while the agitator was on slow speed. He suffered a compound fracture of one leg and severe burns from the hot (18BF) reactor walls. Management attitude was given as the primary cause. Shell was loading 7 cars from a header using two pumps with a combined flow of about 2000 gpm. The relief on one car lifted several times, with the release igniting on the third lift. The fire went out when the pump was stopped. The m AP00050512 10 automatic meter shutoff on that car had failed, while the meters on 4 other cars had activated. The cars were grounded. One suggestion as to the ignition source was static developed in the liquid spray. Goodrich had one employee badly burned when he fell into a tank of 200F tempering water at a compound plant. He had climbed on the edge of the tank to reach the plastic ribbon. They added a safety bar to reduce clearance to 12". ICI reported that the casing on a Ourco monomer pump shattered while being checked in a blocked-in situation. They surmise that the housing bulged, reducing the internal clearances, which increased the pump pressure to over 1000 psi, which caused the casing to bulge further, etc., etc., and parts were scattered more than 20 feet. All 8 casing bolts failed by tensile failure. This happened within 2-3 minutes of pump startup. Borden and Air Products commented on similar but less catastrophic events, and Premex reported hydrau lic hammer damage in monomer lines. A Mexican company discussed a sudden unexplained pressure surge in a charged reactor, which they thought might be due to excessive light ends in the charge. No one else had had a similar experience. Goodrich asked if anyone had experience with surge accumulator in incinerator fuel lines that might operate in the explosive range. There was no construc tive response. Miscellany Stauffer paid Kema Nobel for a look-see at their antifouling technology. They got a maximum of 15 batches between cleanings even after extensive electro polishing, and found it too time consuming. They realize that EDC will be declared a carcinogen and thus must develop a new reactor cleaning process. The question of personal tape recorders came up again, and again it was the wish of the majority that they not be used. This brought up the question of the "official" recorder that was instituted originally to protect against potential anti-trust problems. It was decided for each company to ask its law department for counsel on this subject, for a vote at the next meeting. I have since discussed this with Ray Schenck,and he advises that, so long as we do not have an independent observer such as a staff member or lawyer, that we continue the practice. Kema Nobel has tried the Diamond-Shamrock technology for low-gel resins (types 35 and 40) in their laboratory reactors, and find it to be low gel, but of undesirable PSD. They do not have adequate small test equipment to evaluate the system properly. sjs Attach. AP00050513 --0.//3 /t / 7?! Cl'JJ / VINYL CHLORIDE SAFETY ASSOCIATION MEETING^AGENDA---------- SEPTEMBER 13 & 14, 1979 HYATT ON UNION SQUARE, SAN FRANCISCO, CALIFORNIA 94108 y September 13, 1979 Time A.M. 8:00 - 9:00 9:00 - 9:30 9:30 - 10:15 10:15 - 10:30 10:30 - 11:15 11:15 - 12:00 Subject Registration & Coffee Social Hour Chairman's Welcome Official Business CIIT - Its contribution to business which handles toxic chemicals. Coffee Break Risk Analysis of Runaway Reaction Occurring in a Solvent Autoclave Training New Plant Forces for Safety Discussion Leader Art Gellner CertainTeed Dick Fleming Ex. Vice President Air Products D. C. Wobser Union Carbide Roy Henderson Diamond Shamrock P.M. 12:00 1:30 . 2:15 1:30 2:15 2:45 2:45 3:00 3:00 - 3:45 3:45 - - 4:15 4:15 - 4:45 4:45 Lunch Explosion in VCM Recovery Compressor Placing Explosive Charge on a Burning Tank Car Coffee Break Major VCM Excursions & How They are Handled Data Reporting on VCM Monitoring Equipment Solvent Absorption as a Final Control Device Adjourn B. Terwiesch Chemische Werke Htfls H. Waltemate B. F. Goodrich Doug Frey Diamond Shamrock W. Clark G. Schaaf B. F. Goodrich / AP000505I4 (2) September 14, 1979 Time A.M. 8:00 - 8:30 8:30 - 10:15 10:15 - 10:30 10:30 - 12:00 12:00 Sub.ject Chloride Stress Cracking (Update) An Update of Regulatory Agencies Activity & Their Effect on Our Industry. Including: New Regulations Present Reporting Required Present Reporting Results Other Agencies, et*'. Coffee Break True Confessions Adjourn Meeting Discussion Leader J. Wallace Esso J. T. Barr Air Products 8c R. Laundrie General Tire i AP000505I5 WORKING HYPOTHESIS THE MAJORITY OF THE DATA COLLECTED OR REASONABLY ASSUMED, PLUS THE OBSERVATION OF STRESS CRACKS ORIGINATING AS INTERGRANULAR CRACKS IN HEAT AFFECTED ZONES, LEAD TO THE FOLLOWING HYPOTHESES. 9 AT pH <4 A REASONABLE GUIDE TO LIFE EXPECTANCE MAY BE OBTAINED FROM THE COMPUTATIONS PRESENTED AT THE LAST MEETING. '9 AT pH >4 LIFE EXPECTANCY IS GREATLY INCREASED. 9 IN THE CASE OF STRIPPING TOWERS, OPERATION ABOVE ATMOSPHERIC PRESSURE MAY ALSO EXTEND THE LIFE EXPECTANCY BY PREVENTING OXYGEN ENTRY. 9 FOULING WAS USUALLY PRESENT, BUT ITS EFFECT WAS NOT CLEARLY RESOLVED. THE IMPLICATIONS OF THESE HYPOTHESES ARE IMPORTANT AND VERIFICATION OR CORRECTION IS EAGERLY SOUGHT. YOUR INPUT IS AGAIN REQUESTED, ESPECIALLY TO FIND: 9 HAVE YOU EXPERIENCED ANY CRACKING AT pH >4 OR AT DISSOLVED OXYGEN CONTENTS <0.5 PPM (NOT TO BE CONFUSED WITH OXYGEN IN THE CHARGE, WHICH IS CONVERTED TO HC1)? 9 CONVERSELY, HAS THE LIFE OF A GROUP OF VESSELS GREATLY EXCEEDED THE PREDICTED LIFE EXPECTANCY UNDER THESE CONDITIONS? 9 HAVE YOU ANY OTHER DATA RELEVANT TO THE LIFE EXPECTANCY? COPIES OF THE ORIGINAL HANDOUT AND QUESTIONNAIRE ARE AVAILABLE FOR GATHERING RESPONSES. ANONYMOUS RESPONSES ARE BETTER THAN NONE. JRW/cdr 79 09 13 AP00050516 ' ' 1) 2) NUMERICAL ESTIMATES OF PROBABLE C.S.C.C. FAILURE DATES ARE ESSENTIAL FOR DECISION MAKING. FROM DATA IN A REVIEW BY E. HOXIE^ THE "KICKING TEST" 50% FAILURE TIME t0>5 IS ESTIMATED AS to,5 = ANTILOG10 (yBc+273 ' *7586 10910 tC1" ppm3 " 6-045) H0URS F0R AISI 304> 3) ACTUAL STRIP DRUMS AND MIX TANKS OF AISI 304 BADLY FAILED IN 5 TO 7 TIMES t0,5. 4) - MOST PROBABLE FAILURE TIME t, ESTIMATED AS 3 x t,, s FOR AISI 304 `304 i.e. tf = ANTI LOG jo (^*73*- 0.75B6 log10 [C1` ppm] - 9.5105] YEARS 5) NOTE (a) FIGURE 13 SUGGESTS FOR AISI 316, t- * 4 xtf .NO ACTUAL FAILURE FOUND OR PREDICTED. *316 T3o4 6) RESULTING PROBABLE FAILURE ESTIMATES ARE PLOTTED IN THE ATTACHMENT. I I 7) FOR REGULAR EXPOSURE OF DIFFERING SEVERITY, E.G. P , P. , P X OF TIME AT TEMPERATURES a d c V V Tc "ETC- f tfa Vb Vc ETC. a) FAILURES WERE AT PH 3-4: EFFECT OF PH'UNOER INVESTIGATION. ZERO OXYGEN INHIBITS, BUT LOW LEVEL HAS NO EFFECT. 9) CORRELATION WITH ONE OTHER PLANT HAS BEEN GOOD. MORE CORRELATIONS NEEDED FOR GOOD RISK MANAGEMENT. YOUR INPUT IS REQUESTED WHERE EQUIPMENT HAS GREATLY EXCEEDED THE PREDICTED FAILURE TIME. AP00050517 (a) E.C. Hoxle - Some Considerations In the Selection of Stainless Steel for Pressure Vessels and Piping A.S.M.E. Talk 1975 copies from International Nickel Corp,, 1 New York Plaza, New York, N.Y. 10004. J.R. WALLACE:caw ESSO CHEMICAL CANADA PLASTICS TECHNOLOGY LABORATORY P.O. BOX 69, SARNIA, ONTARIO N7T 7H8 OCTOBER 25, 1978 TEL.(519)339-2284 V LIFE EXPECTED - fOTM. tEAAS OF A-TUtL EXPOSURE AP00050518 10 20 30 40 50 SO }ft BO 90 100 '10 20 M -------- 4ft S b '~ S (T ) 0 : '& !'& 1 b 0 These p re d ic tio n s are "C1 ,0 W"1 th e b e s t we can make, based la rg e ly on th e la b o ra to ry Cl- ion ppM results of o th e rs .p lu s our fie ld "experience w ith Type 304 s ta in le s s s te e l. No guarantee can be g iv e n o f performance in any s p e c ific c1 -im stances, duo to th e e ffe c t o f o th e r v a ria b le s , as y e t not q u a n tifie d .  CHLORIDE STRESS CORROSION RISK MANAGEMENT FAILURE QUESTIONNAIRE # HAVE YOU EXPERIENCED CHLORIDE STRESS CORROSION CRACKING IN ANY OF THESE MATERIALS - 0STAINLESS STEEL TYPE 304 0304L 0316 0316L OTHER IF,SO* PLEASE INDICATE THE CONDITIONS, AS FAR AS THEY ARE KNOWN TO YOU. TYPE OF EQUIPMENT STEEL TYPE 304 304L 316 316L 1. MAXIMUM TEMPERATURE USED 2. X OF TIME AT THIS TEMPERATURE 3. YEARS OF SERVICE 4., 1 IONIC CHLORIDE CONTENT PPM 5. pH 6. OXYGEN CONTENT 7. WERE CONCENTRATING CONDITIONS PRESENT 8. EXTERNAL OR INTERNAL (MARK E OR I) 9. IF INTERNAL, LIQUID OR VAPOUR (L OR V) 10. WAS FOULING PRESENT' 11. SPECIAL CONDITIONS* OTHER SPECIAL CONDITIONS INCLUDE STRESSES FROM GRINDING OR WELDING, TEMP, CYCLING, PRESENCE OF CHELATOR. PLEASE RETURN TO: J^R. WALLACE ESSO CHEMICAL CANADA PLASTICS TECHNOLOGY LABORATORY P.O: BOX 69, S. CHRISTINA STREET SARNIA, ONTARIO N7T 7H8 AP000505I9 RECENT REGULATORY ACTIONS OSHA Enforcement - New Manual 4 June (unlawful?) - Relies more heavily on General Duty Clause, including criminal charges. - Will enforce ACGIH guidelines, NIK,-etc. - Employee representatives must be included. - More difficulty with blank warrants - exparte. Rate Retention - Included in Lead Standard - Part of standard remanded, but not rate retention. - Limited term, depends on suitability for employment. Carcinogen Policy - In Draft - Said to issue this fall but perhaps not until after \ benzene case is settled. - Fifth District has said that incremental cost/benefit must be considered. Appealed. Fire Brigades - Now Proposed - Would allow employee to refuse hazardous jobs EPA Carcinogen Policy - Draft Released - Possibly to appear in FR soon, - Requires generic leak reduction program at once, BAT as a minimum later, with decreasing goals based on residual risk. One test of one species adequate to list, if pollutant. Vinyl Chloride Revisions - After Policy - No change in agency attitude that overall policy will be established before any further action on amendments. If present draft stands, June 77 proposal will be consistent. - Office of Enforcement also wants changes. - EOF may not accept delay. - Companies in Northeast have filed for Judicial Review. AP00050520 2- - Water Quality Criteria - Used Old Risk Analysis - Proposes 52 ppb for lifetime 10"^ risk. - No aquatic life criteria proposed. - Very bad job. Waste Disposal - RCRA likely to impact PVC - Waste streams from VC, PVC operations listed as hazardous. FDA PVC Packaging Sanction - No further action - Awaits results of SOM policy, that will use acceptable risk calculations to establish residuals. - Memo of understanding with EPA on potable v/ater finally written. Identification System - HM - 171 - Proposes 4-digit international identification system on all containers of hazardous materials. IRLG Identification of Carcinogens - For Comment - First step toward uniform governmental policy. - Uses risk assessment as tool. - Many good features, but generally too pessimistic in approach. IRIG/TSCA Extensive and detailed test methods. Protocols. fda/hew/tsca' Good laboratory practices, etc. AP00050521 SUSPENSION STRIPPED SLURRY DATA (March - 1979 Reports) Page 1 Company and Location Area Borden Leominster, Mass. X Great American Chemical Fitchburg, Mass. I Goodrich Pedricktown, N.J. II Pantasote Passaic, N.J. II Tenneco Burlington, N.J. II Tenneco Flemington, N.J. II Goodyear Niagara Falls, N.Y. II Hooker ~ Burlington, N.J. n Stauffer Delaware City, Del. nr Diamond Shamrock Delaware City, Del. hi Pantasote Point Pleasant, W.Va. Union Carbide S, Charleston, W.Va. \ hi hi Firestone Perryville, Md. in Firesonte Pottstown, Pa. m No. Reported 124 Over 400 .8$ Oct. 94 PPM Average Nov. Dec. Jan. 129 84 116 Peb. 98 160 8.7$ 266 106 334 236 218 181 28.1 1.3 8.6 4.0 2.8 172 2-3$ 119 155 125 164 117 124 8.8$ 136 189 144 147 188 83 12$ 301 156 137 229 ` 288 Did not submit report to EPA Did not submit report to EPA 1 < 181 2.7$ 259 215 234 183 197 181 6$ 52 70 101 128 387 156 10.8$ 227 255 267 218 236 142 19-7$ Not reported 491 59 112 64 59 -- 553 240 268 150 Not reported -- 273 254 247 306 AP00050522 SUSPENSION STRIPPED SLURRY DATA (March - 1979 Reports) Page 2 Company and Location Area No. $ Reported Over 400 Oct. PIM Average Nov. Dec. Jan. Feb, Goodrich Louisville, Ky. IV 90 0 -- -- 95 72 55 Air Products Pensacola, Fla. IV l8l 18.8$ 342 655 93 210 190 Conoco Aberdeen, Miss. XV l8l 20.4$ 326 215 332 344 506 Air Products Calvert City, Ky. Borden Illiopolis, 111. IV Closed old plant - new plant not started till after 3/1/79 V 173 1.1$ 84 55 44 164 25 B. F. Goodrich Avon Lake, Ohio V 151 2.6$ 119 185 44 20 30 B. F. Goodrich Henry, 111. V 131 3.8$ 86 79 78 52 134 General Tire Ashtabula, Ohio V 151 9-9i 240 326 `311 248 223 Diamond Shamrock Deer Park, Texas VI 164 5.5$ i4i 154 234 134 91 Union Carbide Texas City, Texas VI 168 3.656 24 42 75 76 6.8 Ethyl Baton Rouge, La. VI Did not receive from EPA Georgia Pacific Plaquemine, La, VI Confidential Conoco Oklahoma City, Okla. VI Claimed confidential Certaintecd Lake Charles, La. VI ' Did not submit report to EPA B. F. Goodrich (Goodyear) VI Plaquemine, La. Did not submit report to EPA' Tenneco Pasadena, Tex. VI Did not receive from EPA Sbintech Freeport, Tex. VI Did not receive from EPA AP00050523 Company and Location Goodrich Long Beach, Cal. Keyser Saugus, Cal. Stauffer Long Beach, Cal. Union Carbide Torrance, Cal. SUSPENSION STRIPPED SLURR* DATA. (March - 1979 Reports) Page 3 Area rx No. $ Reported Over U00 179 IX 173 Oct. PPM Average Nov. Dec. Jan. 5.6 fc.5 6.0 Feb, -- 227 179 161 161 197 IX 151 M 166 llt-9 168 13^ 9^ IX None reported \ # G. E. Brumbaugh:em 8/30/79 AP00050524 Company and Location Great American Chemical Fitchburg, Mass. Borden Leominster, Mass. Tenneco Burlington, N.J. Goodyear Niagara Falls, N.Y. Pantasote Passaic, N.J. Tenneco Flemington, N.J. Hooker Burlington, N.J. B. F. Goodrich Pedricktown, N.J. Fireatone Perryville, Md, Firestone Pottstown, Va.. Union Carbide S, Charleston, W.Va. Pantasote Ft. Pleasant, W.Va, \ Stauffer Delaware City, Del. Diamond Shamrock Morristown, N.J. B. F. Goodrich Louisville, Ky. Conoco Aberdeen, Miss. Air Products Calvert City, Ky. Air Products Pensacola, Fla. fvc plants only VENT GAS DATA (March - 1979 EPA Reports) Area I Hours over 10 ppm 72 hours I 5-1/2 hours Page 1 T.yr>e of Control Device Some type of incinerator May be dryer Incinerator II 29-lA hours One incinerator installing second unit II Did not submit a report to EPA II None mentioned II None mentioned No mention of control device Two incinerators II Did not submit a report to EPA II 125 hours III None mentioned III None mentioned Vent gas absorber i Carbon adsorption Incinerator III None mentioned Incinerator III None mentioned Incinerator III No mention of vent gas III -0- IV 14 hours IV 1 hour -- ' ' Incinerator IV -0- Incinerator IV -0- Incinerator AP00050525 Company and location B. P. Goodrich Avon Lake, Ohio B. P. Goodrich Henry, 111. General Tire Ashtabula, Ohio Borden Illiopolis, 111. Georgia Pacific Plaquemine, La. Ethyl Baton Rouge, Ta. Certainteed Lake Charles, La. Conoco Oklahoma City, Okla. Goodyear Plaquemine, La. Diamond Shamrock Deer Park, Texas Tenneco. Pasadena, Tex. Union Carbide Texas City, Texas Shintecb Freeport, Texas B. F. Goodrich Long Beach, Cal. Keyser Saugus, Cal. Union Carbide Torrance, Cal. Stauffer Long Beach, Cal. P/C PLANTS ONLY VENT GAS DATA (March - 1979 SPA Reports) Bag 2 Area V V Hours over 10 ppm 724 hours plus 80 hours bypassed 87 hours Type of Control Device Vent absorber Vent absorber V 2 hours Incinerator V No data sent to us Incinerator "Confidential?" VI 1/2 hour Carbon adsorption unit vented to gas fired steam generator VI 2 hours Incinerator VI Did not submit a report to EPA VI Claimed confidential ! VX Did not submit report to EEA VI -0- Incinerator VI Did not receive from EPA VI Tests made in March Solvent absorption 1976 below 1 ppm5 no other mention of vent gas stream VI Did not receive from EPA IX 4l hours Incinerator IX 2 hours IX None reported IX. No mention of vent Incinerator gas stream AP00050526 Company and Location Great American Chemical Fitchburg, Mass. Borden Leominster, Mass. Tenneco Burlington, N.J. B. F. Goodrich Pedricktown, N.J. Goodyear Niagara Falls, N.Y. Tenneco Flemington, N.J. Hooker Burlington, N.J. Pantasote Passaic, N.J. Diamond Shamrock Delaware City, Del. Firestone Ferryville, Md. Firestone Pottstovm, Pa. Union Carbide S. Charleston, W.Va, Pantasote Point Pleasant, W.Va. Stauffer Delaware City, Del. B. F. Goodrich Louisville, Ky. Air Products Pensacola, Fla. Union Carbide Tucker,Ga. Air Products Calvert City, Ky.. REACTOR OPENING LOSS (March - 1979 Reports) Area Number Reported r 377 Number Over Limit 10 ruge j. $ Over Limit .7$ 1 556 556 10036 11 39 1 1.1# 11 296 17 5.7$ 11 Did not submit a report to EPA 11, 54 6 U# 11 Did not submit a report to EPA 11 I.o mention of reactor losses in report in 195 110 i 56$ hi hi hi hi m IV IV Have approved alternate method of steam purging - - did not report individual reactor openings Have approved alternate method of steam purging - - did not report individual reactor openings No mention of reactor opening losses in the report Operating under an alternate method of tasting Reported results in PPM -- cannot tell if out of compliance 10,802 332 3.0 (9*9% of large reactors were ever standard) Closed reactor technology -- no data reported IV Run other products before opening no data reported IV Closed old plant - new plant not started till after 3/l/79 AP00050527 Company and Location B. F. Goodrich Avon Lake, Ohio B. F. Goodrich Henry, 111. General Tire Ashtabula, Ohio Borden Illiopolis, 111. Diamond Shamrock Deer Park, Texas Conoco Oklahoma City, Okla. Certainteed Lake Charles, La. Goodyear (B.F.Goodrich) Plaqueniine, La. Ethyl Baton Rouge, La. Tennaco Pasadena, Texas Georgia Pacific Plaquemine, La. Shintech Freeport, Texas Union Carbide Texas City, Texas \ Stauffer Long Beach, Cal. Keyser Saugus, Cal. B. F, Goodrich Long Beach, Cal. Union Carbide Torrance, Cal. 'REACTOR OPENING IOSS (March - 1979 Reports) Area Number Reported V 232 Number Over Limit 7 Page 1i Over Limit 0.3# V 1U02 110 7.836 V 101 22 11.8$ V 479 479 10C$ VI 122 47 38.556 (Use statistical reactor sampling program) VI No March 1979 report VI Did not submit a report to EPA VI Did not submit a report to EPA 1 VI No data sent with this report VI Did not receive from. EPA VI All data labeled as confidential VI Did not receive from EPA VI Used a calculated procedure -- no data XX 10 0 IX 302 1 0.316 IX 978 25 2.5556 IX No data reported AP00050528