Document r6BNdyDMrny6OdmnVbzQajD30

Telecopy to J. T. Barr ( >ages) and C/bmca&- CSCAM9IA PLANT INC. INTEROFFICE MEMORANDUM To: Mr. E. A. Ray From: *W. C. Wilde Re: Personal Monitoring for VCM Exposure at Pace Plant Dote: 12 March 1974 Copies: J. T. Barr T. L. Carey R. Fleming J. D. Kramer A. K. McMillan E. A. Primeau / G. B. H. Speed^ R. R. Spiegelhalter M. Sterman Three portable sampling systems have been received and are now being used for personal monitoring of VCM levels at the Pace Plant. After an initial period of debugging, it was found that the battery life was only 3 to 4 hours before a 16 to 20 hour recharge was needed. This is the same battery life experienced at Calvert City with, identical equipment. To increase the utilization of these instruments a purchase order has been placed for 6 more batteries and 3 more chargers. It was expected that the operators exposed to the highest VCM levels would be the utility, recovetyand solutions operators. The utility operators clean reactors, blind and unblind them, and do most of the washing out; therefore, we expected them to experience higher exposure levels than other operators. The initial round of samples showed; Utility Operator Solutions Operator Recovery Operator 27 ppm VCM S ppm VCM 6 ppm VCM This data confirmed our expectations, and it was decided that the initial testing program should concentrate on the utility operators. The next two samples taken on the utility operators showed 14 ppm and 180 ppm. The 180 ppm reading was taken during a three-hour reactor cleaning period. As a result of this unexpected high reading, the following steps were taken; 1) The man's supervisor was questioned and he said that normal entry procedure was followed. 2) It was impossible to contact the employee directly, he walked off the job without giving notice. His final paycheck is being withheld until he is questioned about possible unusual conditions. ! AP00050378 Mr. E. A. RayPersonal Monitoring for VCM Exposure 12 March 1974 Page 2 3) - Based on this one high (180 ppm) analysis, our entry procedures were modified to require the shift supervisor to check each reactor prior to entry with the Century portable analyzer. We have been reluctant to require this since the Century has not yet received UL approval for use in hazardous areas. The monitoring of utility operators has continued and the results have ranged from 5 to 88 ppm. The average for all utility operators to date (including the 180 ppm) is 51 ppm. Our program is to continue to monitor the exposure levels of the reactor cleaners to the exclusion of the other operators. We expect to have a good set of base data for the cleaners within one week. At that time our monitoring program will be extended to include the other operators. <L W. C. Wilde WCW:bp Enclosure AP00050379 Opra*h,,, r*> ToW T;t)e jfov- VC A\ Exposure Qptnfrf'pr's Mo** 5 _________________ S*Wt! .DaI* T^e *i - . SWf^ TMA. TVVU* . Vca\ Sa* j>W \ e*j $\ _Sol '. ov3 J-, 5uW^fv-U^______3/4>/7f _jo;3oA* i:3op^,,7;3./`d'.l.......... 8 ^ 4 -5- ?. .<J?_V_*V^___________ Aa--^ o.lliJi _. ^rdo(^\ 7.OP PM 3"///* 6pfM ,L_JA_iulii^F. Kfaj^orSoA 2 ft]74- A:ao 7:of^ 3 -11 /"a "______________ 2? ff `A i.UAilii* JlfHFv Hev\A.tr r_oa__ 3. 4--3aPM 7.-OofM 3-11 /"a 1 ' l^ ppws m;l,^ *__________MrL 3/a/7+ /2.:aoM>J 3:o^m ;|-7/`b' |80ppw |____ LlVSiiiy .----- s- 1U1 i.i'U\ ' iii. v .* / H a^ _Sj?t r IL_irHTjTiiTi-_' i^ _j* ^ U4,' I,' -* HeAtfsov\ Tb*rr ; r**o y\. UUVic* 3/s/ 74 &:ao pm U'OQ 3-lP/^".J_7. ppw, 1 3/5>/74 no pm 7-3/c" '--i" ?* 3-n/V 3 iaqAm '.so ** 11*7/ k ,,i4_ fp*\ 4? pp>. I -.1 88 lE&L'tv** ;.`jo pk7*^/'c". ,,._74- pp^, 1/1 o/? 4 3/ //7~r~ . __ _ i P* 7.ao f/^ 3~-f ppv^ 1 * A~Tl~7~/itVr *3 pp*s r* * sfrt +,a-v uia S i-K reactor ' .' Jk u v 1 ia. 9 --j l>Kk 6<vjJl AP00050380 CALVERT CITY PVC EXPANSION PROCESS HAZARDS ANALYSIS (PART I) Date: 12-16 September 1977 Committee: A. ]. Santay W. Silowka G.B.H. Speed T. N. Sreenivasan 0. O. Stango t* m AP00050381 CONTENTS * Executive Summary Introduction Methodology Analysis Figure 1; Reactivity Grid Conclusions and Recommendations Appendix I: Fault Tree Symbols Appendix II: PVC Hazards Analysis Fault Trees Appendix III: Status Report A Page i 1 2 3 4 5 - AP00050382 1 Executive Summary Part I of the Calvert City PVC Expansion Hazards Analysis was done on 12-16 September 1977. Major hazards and corresponding recommendations are summarized in the following: HAZARD RECOMMENDATION Overpressurize gas holder, possibly rupture Install control valve at scrubber which closes on high gas holder level. Install pressure relief inside gas holder membrane area. Runaway reaction Install agitator shaft zero-speed alarm. Provide strict maintenance of "short stop" system. Flammable mixture inside reactor Provide adequate N2 purge. Install flow alarm on N2 supply line. Operator exposed to "short stop" chemical while filling tank* Install check valve on drum fill line. VCM pipeline rupture from hydraulic hammer Overfill VCM charge tank Ensure that all JV ball valves are slow-closing. Install JV valve on VCM feed line after metering station. Install high level alarm in control room for level transmitter on charge tank. The status of all recommendations appears in Appendix III of this report. AP00050383 INTRODUCTION The scope of the Calvert City PVC Expansion includes increasing the plant's capacity to 210 mm Ib/year. New polymerization, stripping, drying, and product storage facilities will be provided, as well as incorporating portions of the existing plant. The process hazards analysis of the Calvert City PVC Expansion project was divided Into two parts. This report covers the items included in Part I of the review, done on 12-16 September 1977. Specifically, the reactor and stripper areas, raw material storage, and some of the monomer recovery area were examined. The objectives of this review were to: * identify major hazards in the PVC Process * generate recommendations to minimize the hazards * ensure that the recommendations were implemented into the design as soon as possible. Chemicals' Group Project Management is responsible to answer to all recom mendations of this hazards review. Team members for the PVC Expansion Hazards Analysis - Part I were: A. J. Santay - Corporate Safety W. Silowka - Chemicals' Group Engineering - Process Design G. B. H. Speed - Calvert City Manufacturing J. N. Sreenivasan - Plastics R & D J. J. Stango - Chemicals' Group Engineering - Mechanical Design AP00050384 METHODOLOGY Fault Tree analysis was used for this hazards review of the PVC Expansion. In some cases, the "What if" method was tried but abandoned because of the complexity of the systems and difficulty in documentation. For Part I, nine systems were defined, a system performing a single unit operation. They include the: reactor blowdown tank continuous stripper monomer charge tank raw material storage, including DMF freon condenser recovered monomer receiver methyl chloride splitter gas holder Vessel rupture, external fire, and internal fire were the undesired events examined in these systems. The development of a fault tree for any system begins with the undesired event at the top of the page. The analysis proceeds using specific logic symbols (Appendix I) until all basic causes are defined. The biggest advantage of this method is that it allows the team to identify those causes and all possible relationships. Since most major industrial accidents are the result of two or more simultaneous failures, these interactions are important in analyzing a system. A reactivity grid of the raw materials used In the PVC process was developed. This matrix provides a graphical means of determining what effect the mixing of any two materials might have. With vinyl chloride monomer a known carcinogen and under strict regulation, the potential for employee exposure was also investigated. The purpose of this discus sion was to highlight the health hazards associated with the process. -2- AP00050385 ANALYSIS The fault trees generated for the various systems in Part I are shown in Appendix II. Most of the systems were analyzed for vessel rupture or explosion, stressing the need for adequate relief protection. External fires in the process, monomer recovery, and storage areas were developed, as well as a fault tree for a runaway PVC reaction. A major portion of these main undesired events also appear within other fault trees as subevents. The reactivity grid for the PVC Process is shown in Figure 1. Fifteen major and supplementary raw materials were included in this analysis. Most of the combinations will result in rapid temperature and pressure increases, as shown on the key to the grid. Operator exposure to vinyl chloride monomer was briefly examined. Basically, a "closed-system" approach was used In the design of the PVC plant. Those areas specific to the plant which will minimize exposure were highlighted. A summary of this discussion appears in the Conclusions and Recommendations section of this report. -3- AP00050386 1. WATER I 2. METHOCEL K-90 (METHL CELLULOSE 3, METHOCEL K-35 {METHL CELLULOSE) F i. HIRE 1 PVC PROCESS 5 REACTIVITY GRIO 2 34 5 670 b 9 10 II * 12 13 14 a bb 15 4. MBCP 5 ULTRAWET -60L & ESPEROX 33M 7 VAZO 64 a VINYL CHLORIDE 9. VINYL ACETATE 10. SODIUM BICARBONATE II. VERSENE 12. PHOSPHORIC ACID 13. LUPERSOL 223 14. LUPERSOL 228 15. DREW 475 (ANTIFOAM) b 0 b b ed h ch 4 f t 9l c <1 f c df 9 cc dd 1 ff 99 fl 0 AP00050387 1 KEY TO REACTIVITY GRIO may react to produce heat in closed systems, can generate temperature and pressure increases through auto-acceleration decomposition 90oF) in confined non-diluted state will lead to temperature and pressure build-up in confined non-diluted state will lead to heat generation in confined non-diluted state will lead to heat generation will lead to rapid base hydrolysis, possible pressure build-up, and temperature rise will lead to rapid acid hydrolysis, possible pressure build-up, and temperature increase in confined non-diluted state will lead to heat release and pressure build-up in closed containers, can generate temperature and pressure increase through heat of neutralization # AP00050388 Conclusions and Recommendations Major hazards were identified with this analysis, and recommendations to minimize them have been generated. HAZARD RECOMMENDATION Overpressurize gas holder, possible rupture 1. Install a control valve at scrubber (DA-8301) before maintenance bypass. Reactor vent and blowdown lines will be tied in upstream of valve; all other vents are to be located down stream. Valve will close on high level in gas holder. 2. Install pressure relief on gas holder (within membrane area). Methyl chloride splitter ruptures 3, Install relief valve on MeCl splitter reboiler (EA-8317). 4. Install high-temperature, high-pressure, and high-level alarms on MeCl splitter. Evaluate a feed Interlock with pressure alarm. 5. Check that relief vent size on splitter is adequate to handle vapor from thermal polymerization of vinyl acetate. Freon condenser plugs from water freezing 6. Install a differential pressure loop on freon condenser (EA-8308). Have DP alarm to activate bypass loop. 7. Install level alarm. Gas blows back through condensers 8. Provide liquid seal legs or sufficient slope to allow liquid seal on both primary and both secondary condensers. Exchanger shell ruptures 9. Install relief valves on shell side of all exchangers. Vessel or safety equipment failure 10. Establish procedure for periodic inspection of vessel integrity. -6- AP00050389 HAZARD Runaway reaction Flammable mixture inside reactor Runaway reaction initiated by impurities Wrong charge pot filled with initiator VCM leaks in condensers, baffles, etc. Wrong initiator used Operator exposed to "short stop" while filling tank "Short stop" feed system blocked Leaks in "short stop" system RECOMMENDATION 11. Ensure that design provides means of relieving any pressure buildup between rupture disc and relief valve. 12. Evaluate rupture disc design to ensure that liquid cannot be extruded past it. 13. Consider the installation of an agitator shaft zero-speed alarm switch or equiv alent. 14. Have plant establish strict procedures for maintaining a fully operable "short stop" system. 15. Provide adequate nitrogen purge on reactor when emptying DMF, rather than relying on N~ from DMF tank displacement. Same recommendation applies for emptying of displacement water. 16. Install flow alarm on N supply line to reactor. 17. Install on-line analyzer for recovered monomer. 18. Install signal lights on charge pots. Lights should be computer-controlled. 19. Install VCM monitoring points in cooling tower and chilled water systems. 20. Provide means to identify different types of initiator. 21. Install check valve on drum fill line of "short stop" tank. 22. JV-0425 and JV-0428 on "short stop" system should be "fall close", not "fail open". 23. "Short stop" tank level gauge should be armored and equipped with ball check valves. AP00050390 HAZARD Process upsets Overpressurize blowdown tank VCM pipeline rupture from hydraulic hammer Overfill VCM Charge tank Thermal expansion in VCM piping Excessive vibration in VCM pumps from bearing failure Miscellaneous VCM leaks Thermal expansion in DMF, VAM, and TCE piping Raw material supply pumps fail RECOMMENDATION 24. Provide an indication and analysis of stream that is sent to the incinerator, 25. Evaluate failure mode of control valve between blowdown tank and gas holder system. 26. All JV ball valves on VCM line runs (i.e., from BF Goodrich, between existing storage and new monomer charge tank) should be slow-closing. 27. Relocate JV-0324 from BFG side of metering station to line VCS-601-3'1 CM, which services existing storage bullets. Install a manual valve in its place for maintenance access to PSV-0330. 28. Install a JV valve on line to new charge tank after metering station. This valve should be tied in with JV-0324 for emer gency shut-off of VCM feed from BFG. 29. Install high level alarm in control room for level transmitter on charge tank. High level switch should close LCV-0322. 30. Use rupture disc with PSV-0330, vent to atmosphere. 31. Review VCM piping to install thermal expansion reliefs wherever there is a possibility of a line segment being closed off (either manually or automat ically). 32. Establish preventative maintenance pro gram for all VCM pumps. 33. All level gauges on storage tanks should be armored and have ball check valves. 34. Review thermal relief requirements for DMF, VAM, and TCE piping. 35. Evaluate need for pressure relief valves on raw material supply pumps. -8- AP00050391 * HAZARD RECOMMENDATION VCM leaks into DMF storage 36. Add VCM monitor to DMF storage tanks. Certain features of the new PVC plant will aid in reducing operator exposure to vinyl chloride monomer. These are: Computer control of reaction system. Double mechanical seals on rotating equipment. Closed reaction through recovery system, gas holder, and incinerator. Reactor Building open on all sides for better wind dispersion. Reactors will be opened less often and water displacement will be used to reduce any emissions that occur if the reactor is opened. Fugitive emissions system evacuates VCM from equipment for maintenance purposes. Breathing air system. Reducing emissions by adding a continuous stripper. This de-regulates the drying/centrifuge system. Water streams will be stripped to less than 10 PPM VCM; therefore, there will be very little emissions of VCM from process used water. Laboratory Sampling Procedures are modified to reduce exposure. Number of sample points are reduced. Final product will have a lower VCM content than present final product. AP00050392 AP00050393 OR11 GATE The output of this gate results if at least one of the inputs is in the failed state. "AND" GATE The output of this gate results only if all inputs are simultaneously in the failed state. SUBEVENT Describes the output of a gate. PRIMARY CAUSE Represents either a system component primary failure, or an independent basic fault. SECONDARY CAUSE Represents a basic fault which cannot be or is not developed further because of a lack of information or its low probability of occurrence. NORMAL OPERATION Represents an event of element which occurs because of design or normal conditions. AP00050394 *A TRANSFER Transfer one part of a tree to another location on the same tree or to a separate page for more elaborate development. AUXILIARY SECONDARY CAUSE Describes an event which is beyond the scope of the review. RESTRICTION OR CONDITION Stipulates those circumstances under which the output would result from the inputs. AP00050395 AP00050396 F a u ll Troc of PVC Reactor AP00050397 AP00050398 fO * rcvw-- AP00050399 1 # AP00050401 F a u lt Tree o f PVC R eactor Set-Up F a u lt Tree o f Blowdown Tank AP00050402 AP00050403 * I F a u lt Treo ul Hooonor C lionio Tank Fault Tree o f DMF Storag AP00050405 Fault Tree o f Freon Condenser AP00050406 ['uu_l t l_r^p _J__iw-:ovm od Mo^iotnoi' l<oco iytir ftocovored l-boomer R&CtjJver txplodos AP00050407 0*0rPressurization flfil ief System Inadequate Read Ion ExternaI FIro in Area 10 A~ External Fire In Area Fuel i<)flit|on Source AP00050408 116 fiiull 1 ri>a ol Ik;Iliy 1 SplHtor i*iii>r< Ciiiorltn Sfillllur tK|ilcKki\ Ym! HiUl Falluro I OrarPtumtJ >< Ian Va&Mi Ruptura fellol Sywtoa ln<iofMU &-- AP00050409 I # Idutl free of Oil*j II<1 :r AP00050410 J39 140 i AP00050411 INTEROFFICE " MEMORANDUM. To DISTRICUT LOT* From Silov/ka Distribution: J. T. Ball 0. T. 3arr Vi. E. Crawford C. V. Hildenbrand V. L. Hcekssna J. D. Kramer R. C. Lietzau Subject Date I? January 1973 Disposition of Hazards Ravi Recommendations for Calvert PVC Plant (Location, Organisation, or Oapartirent) Chemicals Group Engineer!nr (Location, Organisation, or Ooarrm*nt> G. L. Miller E. A. Primeau Jin 0. CunLjj J. fl. Scigliano G. B. H. Speed J. 0. Stango C. M. Tronolone The following thirty-six recommendations were developed during a hazards review of the expanded PVC plant at Calvert City. For each recommen dation, I have indicated the status and disposition of each in the current plant design, and a brief explanation of the item when needed. 1. INSTALL A CONTROL VALVE AT SCRUBBER (DA-8301) BEFORE MAINTENANCE BYPASS. REACTOR VENT AND BLOWDOWN LINES WILL BE TIED IN UPSTREAM OF VALVE; ALL OTHER VENTS ARE TO BE LOCATED DOWNSTREAM. VALVE WILL CLOSE ON HIGH LEVEL IN GAS HOLDER. Flow control valves have been added to the lines between blowdown tanks and gas holder. Valves will close on high level in the gas holder. 2. INSTALL PRESSURE RELIEF ON GAS HOLDER (WITHIN MEMBRANE AREA). This suggestion cannot be implemented. Catalytic has been unable to obtain a pressure relief valve system which can operate at 0.4 psig, which Is the operating pressure of the gas holder. Of course the gas holder is protected by a mechanical relief which opens on high level. 3. INSTALL RELIEF VALVE ON MECL SPLITTER REBOILER (EA-3317). A PSV has been added to the reboiler. The splitter is now protected on top and bottom by relief systems - in the event that the column packing should plug from polymerization products. 4. INSTALL HIGH-TEMPERATURE, HIGH PRESSURE, AND HIGH-LEVEL ALARMS ON MECL SPLITTER. EVALUATE A FEED INTERLOCK WITH PRESSURE ALARM. Lev/ level alarm and indication and high temperature alarm on the reboiler, and DP unit on column to slow pressure build-up have been added to the MeCl splitter system. 1320) AP00050412 2- - 5. CHECK THAT RELIEF VENT SIZE 0N SPLITTER IS ADEQUATE TO HANDLE VAPOR FROM THERMAL POLYMERIZATION OF VINYL ACETATE. Catalytic is currently checking the basis for relief in the entire monomer recovery area. 6. INSTALL A DIFFERENTIAL PRESSURE LOOP ON FREON CONDENSER (CA-3303) TO DETECT PLUGGING FROM WATER FREEZE-UP. HAVE DP ALARM TO ACTIVATE BYPASS LOOP. A DP loop (DPT-1083) v/i 11 be installed, but enough time exists for an operator to manually activate the bypass loop on the exchanger. 7. INSTALL LEVEL ALARM ON FREON CONDENSER TO DETECT A POSSIBLE PLUG IN LIQUIO BOTTOMS LINE. A high-level switch and alarm (LSH-1082 & LAH-1082) have been added to the freon unit. 8. PROVIDE LIQUID SEAL LEGS OR SUFFICIENT SLOPE TO ALLOW LIQUID SEAL ON BOTH PRIMARY AND BOTH SECONDARY CONDENSERS TO PREVENT GAS BLOW-THROUGH. Complete. 9. INSTALL RELIEF VALVES ON SHELL SIDE OF ALL EXCHANGERS. Completed, where necessary (the thermal relief system had not been completed at the time of the hazards review). 10. ESTABLISH PROCEDURE FOR PERIODIC INSPECTION OF VESSEL INTEGRITY. To be established by Plant Management. 11. ENSURE THAT DESIGN PROVIDES MEANS OF RELIEVING ANY PRESSURE BUILD-UP BETWEEN RUPTURE DISC AND RELIEF VALVE. Standard procedure will be to install tell-tales with a PI. 12. EVALUATE RUPTURE DISC DESIGN TO ENSURE THAT LIQUID CANNOT BE EXTRUDED PAST IT. At the time of the hazards review, the rupture disc selected for the reactors could be hydraulically overpressured by QMF liquid during the reactor cleaning sequence. Since that time, BS&B has come back to APCI with a design which avoids this problem. 13. CONSIDER THE INSTALLATION OF AN AGITATOR SHAFT ZERO-SPEED ALARM SWITCH OR EQUIVALENT. A zero speed indicator (ST 1141) has been added to each reactor agitator shaft. AP00050413 -3- 14. HAVE PLANT ESTABLISH STPsICT PROCEDURES FOR MAINTAINING A FULLY OPERABLE SHORT STOP SYSTEM. To be completed by Plant Management. 15. PROVIDE ADEQUATE NITROGEN PURGE OH REACTOR WHEN EMPTYING DMF, RATHER THAN RELYING OH U9 FROM DMF TANK DISPLACEMENT. SAME RECOMMENDATION APPLIES FOR EMPTYING OF DISPLACEMENT WATER. DMF and air can develop explosive mixtures in the reactor. As such, nitrogen blanketing will be employed during the cleaning cycle on a reactor. Dy JV-11Q7, an operator can add positively 1J2 from the header to the DMF tank and reactor, and ensure through low flow alarm that nitrogen is indeed available and being used. 16. INSTALL FLOW ALARM OH i<2 SUPPLY LINE TO THE REACTOR. Complete (see 15) 17. INSTALL ON-LINE ANALYZER FOR RECOVERED MONOMER. LAD TESTS HAVE BEEN DISCONTINUED AT THE PLANT. A chromatograph has been added to sample the monomer pumped to and the recycle line around, the RVCM tank. The analysis will be used by the computer to determine, for a given recipe, the amount of RVCM which can be charged to the reactor. IS. INSTALL SIGNAL LIGHTS ON CHARGE POTS TO INDICATE WHICH CHARGE POT IS TO GE CHARGED WITH INITIATOR. LIGHTS SHOULD BE COMPUTER-CONTROLLED. The computer will indicate with a green "running1* light which charge pot the operator should fill with initiator. This technique should avoid double-charging or mischarging of a reactor batch. 19. INSTALL YCM MONITORING POINTS IN COOLING TOWER AND CHILLED WATER SYSTEMS TO DETECT LEAKING CONDENSERS, CRACKED BAFFLES, ETC. Area monitor has been added to the cooling tower cells and to the chilled water return tank. 20. PROVIDE MEANS TO IDENTIFY DIFFERENT TYPES OF INITIATOR TO ENSURE THAT CORRECT INITIATOR IS ALWAYS USED. By Plant Management. Must distinguish between binary initiators (to be used for homopolymer production only) and azo-type initiator {for copolymer production only). Both types come in same sort of container. Only the label gives away the bottle contents, APCI will investigate color-coding of caps, etc. AP00050414 -4 21 INSTALL CHECK VALVE ON DRUM FILL LIME OF SHORT STOP TA'ilC TO PREVENT 2 BlONBACK DURING AN EMERGENCY WHILE OPERATOR IS FILLING TANK The short-stop tank is always pressurized with 'U (for emergency purposes). During refilling of the tank, a check valve wilrkeep N2 ^rom blowing-back tc the short-stop drum. 22. JV-0425 AND JV-0423 ON SHORT STOP SYSTEM SHOULD BE "FAIL CLOSE", NOT "FAIL OPEN", TO ISOLATE PUMP UNDER EMERGENCY CONDITIONS. This recommendation has not been enacted. Closing these JV's only closes off a pump, which is normally used to add short stop on a routine basis. The OV's will fail-open to allow short stop to blew through the pump network as well as through the pump bypass line. 23. SHORT STOP TANK LEVEL GAUGE SHOULD BE ARMORED AND EQUIPPED WITH BALL CHECK VALVES. Done. 24. PROVIDE AN INDICATION AND ANALYSIS OF STREAM THAT IS SENT TO THE INCINERATOR. This recommendation was found to be unnecessary and expensive. Normally the flows to the Incinerator will range from very rich in VCK to very high in inert.gas. Losses of monomer are easily determined by pressure and temperature in the condensation train. 25. EVALUATE FAILURE MODE OF CONTROL VALVE BETWEEN BLOWDOWN TANK AND GAS HOLDER SYSTEM. These valves will fail close to prevent an overpressure in the gas holder/ recovery sections. 26. ALL JV BALL VALVES ON VCM LINE RUiiS (I.E., FROM BF GOODRICH, BETWEEN EXISTING STORAGE AND NEW MONOMER CHARGE TANK) SHOULD SE SLOW-CLOSING TO PREVENT HYDRAULIC HAMMER WHICH COULD RUPTURE LINES. Agreed. 27. RELOCATE JV-0324 FROM BFG SIDE OF METERING STATION TO LINE VCS-601-3" CM, WHICH SERVICES EXISTING STORAGE BULLETS. INSTALL A MANUAL VALVE IN ITS PLACE FOR MAINTENANCE.ACCESS TO PSV-0330. JV-0324 was left on the BFG side to give renote/positive shut-off of VCM from BFG in event of PVC plant emergency. Also a new JV was added to the. VCM line from the metering station to the existing storage bullets to remotely allow VCM to the bullets in event that main charge tank cannot take VCM directly from the BFG line. AP00050415 * # 28. INSTALL a jv VALVE 0,'i LINE TO NCI I CHARGE TANK AFTER METER IMG STATION. THIS VALVE SHOULD CE TIED IN WITH JV-0324 FOR EMERGENCY SHUT-OFF OF VCM FEED FROM 3FG LINE. Agreed. See above. 29. INSTALL HIGH LEVEL ALARM III CONTROL ROOM FOR LEVEL TRANSMITTER OH CHARGE TANK. HIGH LEVEL SWITCH SHOULD CLOSE LCV-0322. Agreed. 30. USE RUPTURE DISC WITH PSV-0330, VENT TO ATMOSPHERE. Rather than vent to atmosphere, we chose to put relief back to the low-pressure side of the charge tank. 31. REVIEW VCM PIPING TO INSTALL THERMAL EXPANSION RELIEFS WHEREVER THERE IS A POSSIBILITY OF A LIME SEGMENT BEING CLOSED OFF (EITHER MANUALLY OR AUTOMATICALLY). v Completed. P?*ID`s were incomplete at time of hazards review. 32. ESTABLISH PREVENTIVE MAINTENANCE PROGRAM FOR ALL VCM PUMPS, PARTICULARLY FOR VIBRATION ANALYSIS (BEARING FAILURE). By Plant Management. 33. ALL LEVEL GAUGES ON STORAGE TANKS SHOULD BE ARMORED AND HAVE BALL CHECK VALVES. Agreed. 34. REVIEW THERMAL RELIEF REQUIREMENTS FOR DMF, VAM, AND TCE PIPING. Catalytic is currently investigating the need for thermal relief for the above services. 35. EVALUATE NEED FOR PRESSURE RELIEF VALVES ON RAW MATERIAL SUPPLY PUMPS. Instead of PSV's, flow control loops were added to VAC, VCM, RVCM, and DM H2O. In addition, a PIC circuit was added to VCM and DM H^O lines with set points at 275# and 290# respectively. These lines relieved each storage tank. 36. ADD VCM MONITOR TO OMF STORAGE TANKS TO DETECT VCM LEAKING THROUGH VALVE FROM REACTOR. Agreed. WSrpaj W. Silowka w f AP00050416