Document re5zk2zM1rkyEBZ1Z1w4xZxLa

PPG INDUSTRIES, INC. INDUSTRIAL CHEMICAL DIVISION P. 0. BOX 1000 LAKE CHARLES, LA. 70602 May 1, 1984 Mr. Gus Von Bodungen Department of Environmental Quality Air Quality Division P. O. Box 44066, Capitol Station Baton Rouge, LA 70804 RE: VCM - SRV Discharge of 4/27/84 Dear Mr. Von Bodungen: In accordance with the provisions of Section 76.18 of the LESHAP vinyl chloride regulations, enclosed is a report of the emergency safety relief valve discharge which occurred at our facility on April 27, 1984. Respectfully,^ / / Kenneth S. Komoroski KSK/bh Attachment cc: Joe Withers received MAY 0 41984 W. B GRAYBILU SL 105208 SRV RELEASE REPORT 1. Date of Incident 4/27/84 2. Time of Incident (start/finish) 10:12 a.m./10:15 a.m. 3. SRV No. 46-2463 Location No. 91-699 4. Estimated Concentration of VCM (weight or yol-time) ______ 99.99 in the equipment 5. Quantity of VCM discharged (lbs) 4.3 6. Method of Calculation See Attachment 1_______________________ 7. Give a detailed description of the cause of the discharge ' See Next Page ____ _______________ _______ 8. Give a detailed description of all relevant corrective steps taken before and during each discharge. Upon learning of the release, operations personnel immediately shut down the product transfer. The trip system was reset again and the isolation valves opened automatically. Product transfer was resumed with no further problems occurring. __________________________________________ SL 105209 7. Give a detailed description of the cause of the discharge: The SRV- relieved due to hydraulic shock created by starting a transfer of VCM from VCM-11 to the storage spheres with the automatic sphere isolation valve (located on the transfer line at the spheres) in the closed position. Startup of the pump against the closed valve caused a momentary pressure surge which lifted the SRV. The purpose of the automatic sphere isolation valves is to prevent backup of VCM from the spheres into the transfer line during an emergency. These valves are normally open and remain in the open position until such time as the emergency trip system activates and automatically closes them (a fail close design). Prior to the product transfer under discussion, the emergency trip system had been manually activated for operator training purposes (caused sphere isolation valves to close) and then reset (should have caused sph re isolation valves to reopen). The reset operation causes a number of things to automatically occur and some of these were visible to the operator causing him to believe that the entire system had reset. However, for some reason, the sphere isolation valves had not reopened. SL 105210 SRV Release Report Page 2 9. Describe any d^/iations from SOP and explain why. None 10. Describe external conditions (if any), such as weather, utility upset, etc. that affected this release or the attention of the employee during this release. NA 11. If the incident was due to employee error, answer the following: A. Name and badge number of employee _______ NA____________________ B. Hours worked on the day of the incident NA C. Hours worked seven (7) previous days NA # D. Briefly identify employee's duties: ______NA E. Describe employee's training records NA SL 105211 SRV Release Report Page 3 F. Provide a copy of all the employee's personnel records and disciplinary actions. NA 12. If the incident was due to premature failure of a RD and/or SRV, NA A. Describe RD material _______ NA ___________________________ B. Describe manufacture of RD NA C. State length of time RD in service NA D. State rated burst pressure and % allowance NA______ NA % E. State pressure during discharge NA F. What was the cause of the RD failure? NA_______________________ G. What was the cause of the SRV failure? _____ NA H. Provide a copy of the last two SRV test reports. NA 13, State what actions will or have been taken to prevent this type of release from occurring again. Also note when these corrective actions will be completed. The trip/reset system is being checked for proper operation and repaired as necessary. A method hasJ Taeen discovered which will allow the operations personnel to detect if the valve has failed to respond to the reset of the system. This method has been implemented as SOP for the unit. 105212 Sh t Attachment 1 t,V 'FBOiT (-!<-'C. (V--"xT --vj- Lin------. it-------------- 41 .' / -/U ^-AL/O Vt. = C ro5 s seen'*/ o^a( area L_ " Le.r\a~tl\ . ^7 ~ <3> n = u/eir,t+ "(Va-c'fio^ ver^ VC I =* = (0. 05-1 -f !% 8 15^X7. vg ^'4^)(o.?m) ^ - 4.3 lbs VCM / SL 105213