Document rkZGeErXm9aeVx0zN531rdJ

conoco RECEIVED Interoffice Communication To Di j;r r i hu t i on Rout From Dare J . H. McCu ] ].ey , Jr. March 16, 1984 Copy: Subject 1983 Vinyl Chloride Safety Association Meeting Report,. X-F: ------l- A report on the 3 983 Viny.l Chloride Safety Association meeting is attachedAs usual, the meeting was well worth attending. Several major incidents from the past were reviewed to prevent their lessons from being lost. Also a number of interesting audience surveys were made on various safely issues. The results from an industry questionnaire on controlling runaway PVC reactors were of particular interest. The RFC VCM storage tank safety standard and maintenance work standard that were developed as a result of a large (1 1/2 MM pound) VCM release from a sphere need to be evaluated. Please contact Dick, Steve, or John if there are any questions. R. A. Frohreich Chief Process Engineer Aberdeen Plant Steve Ashby Safety Director VCM Plant Chief Process Engineer Chemicals (Vista) Division Process Engineering Department PJC Enc CC : J F:CRM:PEM:RAF:AHS:HDC:AWS:CWT:JPW: RC:RAC:JWW:SA:SSP:VCL:ELK:RLP:DRW:WLM PVC Croup File SAL 00024093 INDEX 1 . Thompson Chemical Explosion, 1964 2. Hooker Burlington Plant Fire, 196b 3. Goodyear Pacquemine Fire, 1972 4. PPG Oxychiorination Explosion, 1977 5. BFG Altona, Australia VCM Sphere Release 6. Formosa Plastics, Baton Rouge Plant VCM Railcar Loading Rack Explosion and Fire 7. Occidental High Pressure Water Fatality 8. Exxon Canada Resin Transport Trailer Rupture 9. Exxon Canada Failure of a VCM Line* 10. PPG VCM [.(jading Putnp Housing Failure 11. Conoco VCM Railcar Derailment 12. Solvay VCM Tank Car Explosion 13. Angio Update 14. Simularities of Plants with Multiple Cases of Angiosarcoma 15. PVC Dust Inhalation Studies 16. Dow Area Monitoring and Leak Detection System 17. BFG Plant Evacuation Planning and Training 18. ICI Safety Performance Assessment 19. Controlling Runaway Reactions and Emergencv Power-Questionnaire Results 20. Updates on EPA Court Action Page No . I 3 4 5 8 9 10 10 !I 13 14 15 15 16 17 18 18 20 24 002<t 0 94 Index Page 2 21. Handling VCM Waste from Small Pilot Reactors Questionnaire Results 22. Valve Position Indicator Switches Questiutmaire Results 23. Miscellaneous Comments Attachments 1. Valve Position Switch Survey Tables 2. Angiosarcoma Information 3. BFG Vinyl Chloride Storage Tank Safety Standard A. BFG Maintenance Work Order Standard Page No. 28 29 SO sal 00Z4095 `4 OLD CASK HISTORIES 1. Thompson Chemical Explosion, 1964 -- John ISnrr, Air Products The evening January 12, 1964, a reactor was taken out of service and a new sight glass installed. The reactor sight glass was a Pinudler type using tempered glass, an envelope CRT typo gasket, and flange fastened. When the reactor was returned to service and charged, the sight glass leaked. Someone tightened the flange bolts to stop the leak causing the glass to break. The VCM cloud that was released ignited and burned several hours. The reactor building and aLl the reactors were destroyed. Seven people were killed and 22 Injured. The plant was shut down permanently after the lire. The problems were: a. The reactor was not hydrotested after the new glass was Installed. b. An old type sight glass was used. c. They attempted to tighten the sight glass bolts under pressure. d. Plant facilities were inadequately separated. Process equipment was closely packed. There was a school across the street. e. Poor crowd control. Some of the public entered the plant during the fire. f. The building construction was not adequate to withstand a fire. The accident, coupled with a Tenneco plant explosion several years later, led the industry to form the Vinyl Chloride Safety Association. The following audience survey questions were asked. a. Does everyone hydrotest after service (excluding quick opening manheads)? Yes. b. How many use in-line blank flanges? 3 They said it saves about half the blinding time. They are used on vapor lines and some slurry lines (to avoid cross contamination of resin). The reactor is hydrotested after swinging the blinds. c. How many do not use sight glasses on PVC reactors? 20 d. How many do use sight glasses on PVC reactors? 9 All of these use a "pressure products" type sight glass which uses laminated glass compressed from the side. Air Products finds the sight glasses useful for preventing overfilling the reactors and for other purposes, too. e. Any problems with sight glasses? No response. Barr mentioned that heat from a light can increase risk of chloride stress cracking if no heat circulation is provided. ^ 000<*096 Old Case Histories Page 2 2. Hooker Burlington Plant Fire, 1968 -- Joe King, Occidental The fire occurred during the initial start-up of the first hulk (mass, no water used) polymerization plant in the l).S. The process (Pechiney) goes to 10 percent conversion in n prepo 1ymerizatjon reaction (prepo) and then is completed in a post polymerization reactor (pope). The prepo reaction pressure is 180 to 190 psig. The prepo is rinsed with VCM to the popo. The transfer from the prepo to the popo is controlled by a hydraulic operated valve. The plant was in the third week of start-up. Several French engineers were assisting with the start-up but the day of the f f re they were sightseeing in New York City. Fire water was supplied from one 400 M gallon tank. The Delaware River was near the plant. There was a calendaring unit next to the FVC plant. Also there was a gypsum plant nearby. At 11:00 p.m. on a day in March, 1968, operations was getting ready to transfer the second prepo batch. The remotely operated transfer valve was opened. An operator saw a flash in the reactor area. He immediately started the deluge system. Power was lost briefly and then restored. The fire water pumps, one diesel and one electric, were started. At first the operators were not sure there was a fire, but after seeing smoke for several minutes, they called for outside help. A fireman went in the process area and found the lower flange of the transfer valve (4") leaking. It became apparent that they would run out of water after two hours. The fire water tank was only 1/3 full at that point. Water was added to the fire water tank at 1,000 GPM by two wells but the fire water pumps pumped 6,000 GPM. A procedure of running the fire water pumps for 15 minutes, then shutting them down for 15 minutes was started. Nine fire departments were called involving a total of ]00 men and 16 pumpers. The fire water runoff ditch was dammed. Two putnps were used to circulate water back to the tank. Two pumpers in series were used to transfer water from the river to the tank. Two other pumpers were used to transfer water from the gypsum plant. Foam was tried to the point foam was three feet deep in the reactor area. Then they decided it was better to let the VCM burn. For some reason the plant could not stop the leak. Both the prepo and popo reactors continued to depressure through the leak. Probably 20,000 pounds of VCM. were burned in total. SAL 0C0C24097 Old Case Histories Page 3 The plant called the New York police to ask for help finding the French engineers. The police found them and returned them to the plant at 12 noon the next day. The engineers found the nitrogen system intact and only 7 psig of VCM pressure on the reactors. With a combination of nitrogen and (JO^ , they were able to kill the fire and stop the leak. Damage was estimated at $200 M, mainly to L beams, piping, instrumentation, and HC3 corrosion. Downtime after the lire was estimated at four to six weeks. There were no Injuries. The leak was caused by faulty maintenance. After the first prepo batch was transferred, the transfer valve was found to have a damaged seal. The valve was removed, repaired, and replaced. Its flanges were of a tongue and groove design with a hard asbestos gasket. The downstream flange was not properly refjtted. Operations hydrotested only the upstream side of the valve. They were not sure what Ignited the VCM. required them to: Their insurance company a. Install a second 400 M gallon fire water tank. b. Overhaul their pressure testing procedures. c. Prepare contingency plans. d. Plan for fighting fires like this in the future (use methods of the French engineers). Apparently there were no isolation valves around the transfer valve at the time of the fire. Isolation valves were installed afterwards. 3. Goodyear Plaquemlne Fire, 1972 -- Dan hanglois, BFG (formerly of Goodyear) This fire occurred on the popo of Goodyear's bulk PVC plant. The reactor was charged and the pressure brought to 128 psig. Three minutes later the dome blew off releasing 19,000 pounds of VCM. The VCM cloud ignited, perhaps from a spark caused by the dome hitting a pipe. Three people were seriously burned but there were no fatalities. The fire burned for three hours. SAL 0OOO2AOSB Old Case Histories Page k The dome slipped out of the locking ring and broke a three-inch nozzle on the dome (or maybe vice versa) . Perhaps the dome had not been tightened completely. Or the broken nozzle could have caused the dome to twist out of the locking ring. They don't know which happened first. A steel wedge was made to insert in the locked dome flange to prevent it opening accidentally. A proximity switch was installed to confirm that the wedge was in place before charge would start. Alarms sound if the wedge is removed during operation. This has worked well. A Dow engineer in the audience reported that a similar thing happened in a Union Carbide licensed PVC plant in Japan he was helping to start-up. He requested a second hydrotest on the plant reactors because they used the same type of twist locking manway flange. One manhead twisted off during the hydro and blew through the roof. They decided to replace the manheads with Lcnape manheads. OOOOZ^9 03d Case Histories Page 5 4. PPfi Oxychlorinat ion Explosion -- Ben Reynolds, PPCI The explosion occurred in early 197 7. oxychiorination since the late 60's. I'I'O has used oxygen based The oxychiorination reaction area was started up around noon. Operation was normal. At 6:00 p.m. an ethylene fiow adjustment was made. At 10:00 p.m. there was an explosion in the vent scrubber. Five minutes later there was a second explosion. A fire started and burned for 25 to 30 minutes. The deluge starLed after the first explosion. Mutual Aid responded. State police helped control traffic. No one was injured. The scrubber was destroyed and 13 other vessels were damaged. Losses were $1 MM of repair costs plus business interruption. The No. 1 reactor was down 10 weeks and the 2 adjacent reactors were down 6 weeks. The explosions were caused by a feed imbalance in the ethylene and oxygen streams. Normally the oxygen concentration (in the vent scrubber T assume) is about 3 percent. At the time of the explosions it was 30 percent, well within the flammable region. They had ethylene and oxygen analyzers at the time but they were not working. The process was modified as follows: a. Dual Modicons were used to monitor feed streams and oxygen concentra t j on. b. They have sequenced the start-up with programmable controllers. Start-up can be advanced only if the prior condition is satisfied. c. Shut down is done under automatic control. d. Instrument voting (redundancy) was used. e. Shutdowns and other safety instrumentation are checked every six months. 5. BFC Altona, Australia, VCM Sphere Release -- Henn Waltemate, HFG A four-inch liquid line off the bottom of a large VCM sphere was being replaced due to corrosion. There were seven other smaller lines connected to the bottom of Lhe sphere. Only the four-inch line had a remote operated valve at the tank. None of the lines had excess flow check valves. SAL 0C00241CC Old Case Histories Page 6 The valve was closed. The pipe fitter was not allowed to remove the expanded mesh cage around the valve or the operator. However, he did remove the operator's U--bolts, freeing it from the pipe. In the process of trying to move the unbolted line the line flange hooked the valve operator, partially opening the valve. Liquid VCM began to blow out. Operations could not close the valve with air pressure because the operator was only connected to the valve stem; it did not have anything to push against. They tried to use a long 2x4 to pry the valve operator and close the valve. However, the 2x4 snapped. Apparently the recoil caused the valve to go wide open. One and one half million pounds of VCM (the entire contents of the tank, were lost over a six-hour period. There was no fire or explosion. This incident was investigated thoroughly by BRI. They concluded that the accident was caused by a breakdown of their maintenance work order procedure. A new companywide maintenance work order standard was prepared (attached) which requires that the release by operations of hazardous equipment must be done at the .job situ in the presence of the craftsman, among other things. The release is valid Lor that shift only and must be repented for the next shift. This helps to insure that both operations and maintenance understand the status and hazards of the work. SAL 000C24101 Old Case Histories Page 7 Also a companywide VCM storage tank standard was prepared which is also attached. It requires: a. Liquid valves must be: 1) Quick opening and closing, fail closed. 2) Remote operated, from two local points outside the dike and one remote (usually the control room). 3) Valve must pass fire testing. 4) Valve must not be top entering. This eliminates ping valves. b. Relieving system must be sized correctly. Some of theirs wenfound to be undersized due to inlet block valve losses. c. Automatic deluge sprinkler system is required. Some of their tanks were protected with fire water monitors only. d. Continuous LEL monitors are required. When 50 percent of the LF.l. is reached, all liquid valves on the storage tank are closed. They found some BFG plants like excess flow valves, others did not. They decided to make excess flow valves optional. Air operated valves are required even if excess flow valves are used. Page 8 NEW CASE HISTORIES 6. Formosa Plastics, Baton Rouge Plant -- Jim Fields, Formosa lMnstics Explosion and Fire at VCM Railcar Loading Rack On July 30, 1983, an explosion and fire occurred at Formosa Plastics' Baton Rouge VCM plant railcar loading rack. The loader was severely burned and is still hospitalized. They have.* not been able' to talk to him to find out what he knows about the cause of the iIre. Five railcars were being loaded. Two cars wore loaded before midnight. The three remaining cars were loaded next. After loading, the lines are blown with nitrogen. The. plant nitrogen pressure was "up and down" and not high enough to blow the lines. While waiting for the nitrogen pressure to increase, the loader sampled the cars. The second loader (the one burned) came on duty at 3:00 a.m. The first loader explained the situation, then took the samples to the. lab. The second loader apparently disconnected one car that was partially loaded, disconnected the second car, and started to disconnect the third card. There was anexplosion and fire. They don't know what the source of ignition was. The relief valve on a second car started releasing due to the fire. The relief discharge caught fire 4.5 minutes later. The fires burned four or five days. They hot tapped a car to drain its VCM to a pit to burn it to end the fire quickly. The found all three angle valves open on the car involved in the initial release. The loading hoses were burned off but the hose/tank car connections were still connected on one liquid hose and one vapor hose. The second liquid hose was not connected. Either the loader opened the hose with the valve open on the car or the hose connection failed when he tried to blow the hoses with nitrogen. The railcar excess flow valves never did work. Formosa has made the following changes since the fire. a. All the Kam-Loc couplings were replaced with Hammerloek couplings. b. Check valves are screwed into each (liquid only?) railcar valve hefore the loading hoses are connected. c. A remote operated valve has been installed in the loading line. It can be closed locally or in the control room. d. Railcar loading hoses are tested every six months at 260 psig. They used to be tested to 150 psig annually. New Case Histories Page 9 e. A loading cheek list has been prepared. Koch loader must show the loading status correctly on the check oil sheet at shift change. f. Loading procedures were updated. g. Loading placards are displayed on the curs being loaded. 7. High Pressure Water Fatality -- Joe King, Occidental A hydroblast system of German design was used to clean PVC fouled exchanger tubes. The hydroblast system used a special nozzle having six forward and one backward facing holes. It was designed to pull itself through the tube. The water pressure used was 4,200 p.sig. The nozzle was attached to an 18-foot 1/4-inch stainless steel rod. However, the nozzle was directly connected to a hose; there was no flow through lance. The mechanic using Che hydroblaster controlled the water flow stepping on a foot valve at the exchanger. A second mechanic positioned at a pump motor shutdown switch six feet away. by was Both mechanics were experienced and had operated the hydrobiast equipment many times before. The mechanic using the nozzle signaled to the second mechanic to start the pump. He then cleaned seven tubes. The hose bucked quite a bit during the cleaning which indicated the exchanger tubes were badly fouled. Just after the mechanic started to clean the eighth tube, his helper saw him jump, then slowly turn and fall . The helper immediately stopped the pump. The nozzle hod broken free ol the rod, jumped out of the tube and struck the mechanic in the neck. It then entered his chest. He was killed from lacerated lungs and a lacerated esophagus. They have taken the following steps to avoid a recurrence. a. Exchanger tubes are drilled out some predetermined distance before the water lance is used. The eighth tube had only been cleaned for two inches of its length. b. They are considering using a short section of rigid pipe between the hose and nozzle. c. Outside contractors are now used for hydroblasting. New Case Histories Page 10 Someone in the audience said that Haliburton can hydroblnst exchangers under remote control. Goodyear, BFG, and Conoco all use a rigid lance. RFC has had people cut their hands with the blast water when they pull the lance out of the tube. They now mark the lance near its no/?. Jc end so the operator knows when it's about to come out. 8. Resin Transport Trailer Rupture -- Jim Wallace, Kxxon Canada On June 28, 1982 , a rented 1,800 cubic foot PVC transport trai.Ler blew up while being unloaded. No one was hurt. However, the trailer failure was quite violent. A large section of the trailer opened up and peeled back. Resin was blown over a TOO foot area. The unloading line had plugged twice during the unloading but the pressure only reached 14 psig. The trailer was tested when new at 25 psig. It had two relief valves set at 15 psig but they did not relieve. Subsequent investigation showed that the trailer had been rolled over and damaged three months after it was made in 1977. The trailer was straightened and repaired. However, the welding was not done correctly. The weld had a lot of porosity and poor penetration. The rupture occurred at that weld. They are not sure if the car was pressure tested after the repair or if the relief valves were checked. 9. Failure of a VCM Line -- Jim Wallace, Exxon Canada The fixed point monitors indicated a Leak. They found the flange to pipe weld was leaking. They blocked in the leaking section of the line quickly. There was no fire or major release. SAL 0000241C5 New Case Histories Page 11 Afterwards someone kicked the Line and the leaking flange to pipe wold completely failed. The flange was monel. The 304 stainless steel line had suffered galvanic corrosion at the weld. Cross Section of the Weld 304 Mo n e 1 The flange had been installed by a contractor. He did not have a two-inch flange so he used a monel flange figuring that it would be even better than stainless steel. Esso is now using more stringent inspection procedures to make sure the right metallurgy is used. Wallace said Esso has always used stainless steel for wet RVCM. In an audience survey eight companies (including Conoco) said they do not use stainless steel in this service. Fight companies do use stainless steel. One company reported they had had failure of stainless steel hoses on an RVCM tank mounted on load cells. L0. VCM Loading Pump Housing Failure -- Ben Reynolds, PPG A blocked in loading pump in their VCM tank farm failed due to overpressure from thermal expansion of the VCM. The pump's parts in contact with VCM were steel, but the back of the pump was steel clad cast iron. The back failed 360 around its circumference. The force of the failure sheared the pump base and motor mounting bolts and bent the pump shaft. The pump seal did not blow out. The pump is located in a VCM storage area that contains two 2,500 ton spheres and 8 bullets. See the sketch below. SAL 0C0C2-41C6 New Case Histories Page 12 Thermu1 Rel L of VCM In Small Equal i/.at ion Lino, Both Valves Were Sleeked Y To Tank Car f Vi-m Stark * !) i d C I ose C I osed Be to re Aceideni Kai 1 nl to l No Cheek Va I Vi'S I ^------ Soleno i d Vent ------------D>C} VCM 1 Y>p----------- ^-----------Bypass was open --------- i. M r SAL 0C0G24107 < New Case Histories Page 13 The pump was not running at the time. Normally the pump and left liquid full but the valves to the sphere are left open. the pump suction valve was closed this time. lines arc However, A shipping loader heard a loud bang and saw VCM spraying 30 to 40 feet around the pump. The 40 percent l.EI, tripped deluge started automatically. The shift supervisor arrived within three to five minutes. The leak was Isolated within LI minutes. The all-cLear was sounded within 23 minutes. Approximately 4,000 pounds of VCM were released from the pump. When the sphere liquid inlet isolation valve was closed, it created a hydraulic shock that popped the thermal reliei valve;. It stuck open and released 1,200 pounds before being isolated. Five minutes after the release started a fixed point monitor 1,000 feet away registered 44 ppm VCM. The sphere isolation valves suction isolation valve did bypassed. are not tested routinely. close because its However, solenoid the had pump been PPG is checking the tank farm piping to make certain that it is protected against thermal expansion. All solenoid bypasses have been removed. They are reconsidering the use of cast iron in VCM pumps. 11. VCM Railcar Derailment -- Steve Ashby, Conoco On April 22, 1982, Conoco was notified by Chemtrec of a derailment at Pittsburg, Texas involving Conoco VCM railcars. At the Railroad's request, Steve Ashby and Sid Pitts left Immediately. Upon arrival they found the railroad (KCS) had 75 people at the site. The Conoco safety representatives provided information on exposure limits, potential health effects, and flammability. The superintendent asked them to approach the wreck and appraise the situation. They found one car had been punctured and emptied. One car was leaking below the creek water level. Another car was slowly leaking. A dairy herd one mile downstream was drinking creek water. railroad was concerned about the herd. The The VCM from the car leaking below creek leveL could not be salvaged. The Railroad decided to vent it. Tt was vented from 3:00 p.m. to the next morning. There was a strong wind the second morning which dispersed the vapors in the area. Venting was stopped. Three cars were transferred with a contractor's compressor. The two empty cars were purged. They were able to save 500,000 pounds but 500,000 pounds was lost. SAL 000024103 New Case Histories Page 14 The railcar coupling shields did work. The car that was punctured was holed from the side. The first day an KPA contractor arrived. lie was interested In creek water contamination primarily. The second day the Regional Administrator arrived. He took two drager tube samples. He was concerned about hydroquinone in the VCM. lie left when he was convinced there was no hydroquinone in the VCM. The VCM concentration in the creek was 3 percent 30 feet downstream and 10-20 ppm 150 feet downstream. No injuries occurred. 12. Solvay VCM Tank Car Explosion In April of 1983 VCM railcars were loaded at a German VCM plant for shipment across Italy to a PVC plant in Austria. One of the railcars was rejected by Italian customs officers. German officials decided the car should be unloaded at the PVC plant rather than returned to the VCM plant. Both groups of officials thought the car had a brake problem. The car was left on the PVC plant's main track meters from the reactors and over 100 meters from electrical generator. upproxima t e 1 y steam boilers 300 and Several days later the car exploded. A plant technician saw a cloud around the car, smelled the VCM gas in the air, then ran to the main entrance to sound an alarm. He them came back into the plant to shutdown the steam boilers and turbine. Two PVC reactor workers heard the explosion and saw a 1 1/2 meter thick cloud around the car and a 10 meter high liquid stream jetting from the car. The plant area was isolated and everything was shut down. There were no PVC reactors in polymerization. A few minutes after the explosion the VCM "leak" had stopped, apparently due to autorefrigeration. There was still VCM in the car but there was no pressure on the car. They found a 150 mm slit that was 20 mm wide in the top of the car. The VCM concentration in the air near the split was 1 ,200 ppm. The air outside the plant area never exceeded 10 ppm. There was no fire. The railcar was pushed to the VCM unloading station manually. Approximately 10 cubic meters of liquid VCM was recovered from the car which contained 50 cubic meters filled, One worker fainted due to VCM inhalation but was recovered. He was hospi ta 3 ized for two days and was found to be all right. SAL 00C24io9 New Case Histories Page 16 c. In some plants reactor cleaning was an entry level job which often resulted in relatively short-term exposures. In other plants reactor cleaning was a permanent job. 1) Air Products, Pensacola - Reactor cleaning was an entry level j ob. 2) Firestone - Service and utility groups did the cleaning in all Firestone plants. 3) BFG, Niagra - The reactor operator <1 id not clean the reactor. The dryer operator rotated regularly through a reactor cleaning assignment. 4) Union Carbide, Texas City - A labor pool did the cleaning. The bulk resin reactors were cleaned every 140 hours. They had two workers that cleaned reactors every week oi their work life (about 20 years) without breathing protection, and apparently they did not get angiosarcoma or AOL. The VCM concentration in the reactors during cleaning was around 200 ppm. 5) Animal studies have shown a synergism with alcohol consumption. A person from Air Products said they had some operators at their Pensacola plant that would leave after a hoot owl shift, drink beer all day, get a little sleep, and then go back to work. Then they would purposely sniff VCM to cure their hangovers. 15. PVC Dust Inhalation STudies -- John Vaughan, 1CI ICI's first PVC dust inhalation study was done around tour years ago. They surveyed 818 of their people who had worked with PVC. The workers were checked for lung function and with chest x-rays. The survey concluded that exposure to PVC dust was associated with respiratory disfunction. The effect on the lungs was on the same order as the effect of smoking and about 1/7 that of the changes brought about by old age. Increased breathing protection control was recommended. A second IC1 survey was made two years later with 229 workers from the original group re-examined along with 127 others from another plant. That survey reached the same conclusion. ICI has now prepared Internal guidelines on exposure to respirable dusts. Dust masks are mandatory in dusty areas. Respirable dusts are those Mi or smaller in size. SAL 000024110 3 New Case Histories Page 17 In their dust monitoring they have found resplrabJe dust to be invisible to the naked eye. John described a PVC paste resin bag and box filling area that had a high respirable dust concentration yet the air did not appear dusty. However, when a beam of high intensity light was shone through the work area, the nir looked Jike cigarette smoke. They used the light to determine that the dust was coming from pinholes in bags and from emptied bag flattening. They now are more careful about inspecting bags and have installed a special wedge shaped bag flattener to slowly force nir from empty hag.*;. Their monitoring has shown virtually no respirable dust problems associated with handling suspension PVC. John Barr of Air Products said their dust monitoring sometimes shows high total dust levels but never respirable dust problems. 16. Area Monitoring System, Leak Detectors, etc. -- Mike Nevlll, VCM Plant Superintendent, Dow Chemical Dow uses Beckman 6700 or 6710 flame ionization detectors to monitor VCM concentration. Their system can be summarized as follows. a. Four 10 stream analyzers are used with there being some overlap. b. Samples are pulled continuously with water jets. c. They calibrate the detectors at 5 ppm. The measured span Is 0-25 ppm. d. Cycle time is 50 minutes depending on the number of things monitored. e. The monitoring data is managed by a computer. f. Their action level is 5 ppm. They wear Scott Air Paks above that. g. The detector span is checked daily. h. Full calibration is done weekly. i. Once a year they field calibrate each sample point. Likewise for leak detection they: a. Use HNU' s to respond to high VCM concent ra t ion alarms and for .leak patrol. b. Calibrate the HNU's before each use with a calibration gas mixture of VCM in N . SAL 000C2A1H New Case Histories Page 18 c. Survey one-fourth of the plant each week on leak patrol. Their response level (definition of a leak) is a concentration of 10 ppm six inches away from the leak source. They check every valve packing, pump seal, etc. Personnel monitoring is done with a Du Pont portable air sample pump using charcoal adsorption. Medical exams are offered to contractor employees as well as plant employees. The need to save area monitoring Air Products is debating whether Conoco do not save them. results to save for 30 years was discussed, them or not. DOW, I5FG, and Eleven companies use badge monitors and 19 use air pumps. When questioned said 5 ppm at 6 inches. about the definition of inches, one 10 ppm at 12 a leak used, two companies inches, and one 25 ppm at 6 17. Plant Evacuation -- Planning and Training -- T. M. Jones, BFC Convent Chlor-Alkali Plant Jones said it was important to explain to the plant workers how report a problem and when to do it. Recognize that it takes guts pull a switch that shuts down a plant and causes an evacuation. to to They try to drill twice a year. There was a suggestion from the floor that plants include press handling training in the emergency drill. Several people who can be obnoxious should he chosen to play the part of the press. 18. Safety Performance Assessment -- John Vaughan, 1CI r ICl became concerned about their workers getting a blase attitude toward safety. They decided to let floor people from one plant review the safety program of another plant. Their objective was to cross fertilize safety ideas and increase safety awareness. They do this by forming a team consisting of a manager, engineer, supervisor, safety representative, shop steward, and tradesmen. The team is limited to a maximum of 12 people. People are selected that have no technological experience with the area being inspected. A plant is inspected once a year. The inspection takes one full day. The team functions in an advisory mode only. \ 0<NO.0V >v `j New Case Histories Page 19 A form w^^s prepared to evaluate and rank safety systems such as ione worker situations, general chemical hazards and toxicity, and safety manuals. Where changes are needed, the team works to get plant commitment, then reviews whether the changes were made in the next annual inspection. They have found this to be a good program. employees look forward Lo the annual harangue they go through in their plant ami their participation in reviewing other plants. Ten or 12 companies use or have used a similar program developed by Du Pont called STOP. Their experiences are outlined below. a. Georgia Pacific They use contract maintenance people. They had the contract maintenance employees use STOP. They found the workers enjoyed it for around three months, then safety awareness dropped. Georgia P.'icific concluded it was not successful because it did not get the attention it needed. b. BFG They have used .STOP in some plants, in particular when plant supervision is set in their ways. They use it ior 12 to 24 months only to increase safety awareness. They think it loses effectiveness if used continually. They do think it is an excellent program however. c. Tenneco They started using STOP five or six months ago. They have had to require each person submit X safely idea cards per month. They do intend to keep it going. d. Union Carbide They have used it but found its usefulness declined quickly. initial training results were good. The formality of filling cards was a problem and the number of cards submitted fell quickly. The out off e. Another company uses STOP when an employee is relocated or transferred. In response to a question, 15 companies said they have safety incentive schemes such as gifts (jacket, knives, etc.) for good safety ideas. Ten of those companies felt they were ettective. SAL 000024113 `4 New Case Histories Page 20 19. Controlling Runaway Reactions and F.mergencv Power -- Adoll Peterson, Georgia Pacific and Jim Wallace, hsso Canada (Results of Questionnaire) Peterson started by reviewing Georgia Pac'j. lie's procedure. Ho defined a runaway reaction as any reaction that requires abnormal action to control. a. Preventive Measures 1) Use proper initiator and the correct quantities. 2) Check the jacket profile of the last hatch -- heat transfer, instrument problems. Operators are given guidelines to help decide when a reactor needs cleaning or instruments need repair. 3) Check type and quality of other ingredients -- VCM, water, and colloid. Check variation from set charge level. 4) Confirm agitator and jacket circulation pumps are operational and alarms are working. 5) Check other things -- colloid system, etc. b. Guidelines for Action to be Taken 1) Agitator shut down and cannot restart in 1-3 minutes. a) Kill batch with large quantity of short stop. The short stop is water soluble, but it does not completely kill the reactor. If reaction continues and better killing is needed, an oil soluble inhibitor is added. b) Vent to recovery. c) Maximize cooling on jacket. water. Flood the jacket with chilled d) Check for available empty reactors or an empty blow down tank. 2) Jacket circulation pump fails. a) Maximize cooling from chilled water pump. b) Add water soluble short stop. c) Vent to recovery. 000zAllA SM- New Case Histories Page 21 3) Gradual temperature rise above big!) alarm point. a) They have a Small amount of Ingredient injection into their reactors (implied that it was continuous). They stop that, b) Stun the batch with several gallons <>l water soluble short stop . c) Follow with the oil soluble inhibitor. 4) Gradual pressure and temperature rise above the first high alarm point. The first high pressure alarm point is set b psig above normal operating pressure. a) Check jacket cooling, block in steam valve if it is open. b) Maximize cooling. c) If it occurs at the end of a batch, cooling is not very effective so they would stun the batch. d) Vent to recovery. e) Kill with oil soluble inhibitor if in tiie first half of poly . 5) Second pressure or temperature high high alarm--10 psi above normal pressure. a) Stun with the water soluble inhibitor. b) Follow with the oil soluble inhibitor. c) Maximize cooling. d) Vent to recovery. e) Equalize to empty available vessel, c. Equipment Available 1) Take chilled water supply pumps to maximum cooling. 2) Recovery system has excess capacity. 3) Kill pots with high pressure water and nitrogen flush .are loaded and available at all times. Can remotely input. oC002i'il5 SA'- i New Case Histories Page 22 4) Backup generators for power to agitators and jacket circulation pumps. The generators start automatically after a specified time delay. The generators "save them" once or twice a year. 5) Normally there is an empty reactor or blowdown tank available. 6) Have a vessel in their recovery system (a foam trap) that is always under full vacuum and available for venting. The following surveys were made. There was one vote per company. a. How many plants manually charge initiator? 25 b. How many automatically charge initiator? 7 (l'enneco, Kema Nord) c. How many have back-up generators? 15 d. How many do not have back-up generators? 14 e. Agitator alarm -- Is it monitoring shaft rotation? Yes, 15 (Borden, Tenneco) f. Agitator alarm -- Does it monitor the motor drive? Yes, 12 Georgia Pacific docs not encourage the operator to transfer a complete batch to a blowdown tank. They are supposed to transfer only enough to control the batch. They are concerned about n resin chunk being caught in the transfer valve preventing the valve from closing and overpressuring the blowdown tank. Most companies have several remotely operated valves in the dump line. Are short stops effective without agitation? Georgia Pacific said they have not lost a batch rupture disc due to failure of the short stop system for three years. They said BFG uses a gas (NO?) to kill the reactor when agitation fails. Georgia Pacific reactors have a manual vent valve in addition to the relief valves. However, they do not manually vent in an emergency. The last VCSA relief area survey indicated that they had plenty of relief capacity in comparison to others so they do not think manual venting should be required. John Barr said that the EPA VCM standard does permit manual venting but it must be reported. In response to his question seven companies said they have written procedures that allow manual venting as a last resort. Two PVC companies have flare systems that can handle a venting reactor. 000C2-A New Case Histories Page 23 RESULTS OF QUESTIONNAIRE Twenty-seven companies completed the questionnaire. sent to ail companies that participated. Survey results wj1] be 1. When is the initial, action taken on controlling a runaway, when the normal controls are not controlling? Mean Range a. Temperature 4 .5 UC 1-8 C b. Pressure 10.7 psi 3-25 psi c. Auto Response 5 yes, 22 no What causes runaways? 1st Selected 2nd 3rd Charge Error 85 1 Mechanica1 Failure 1 35 Instrument Failure 2 A 3 Agitator Failure A 1 7 Cooling Loss 2 6V Formulation A 23 Condenser Plugged 2 l l and Other Causes What control, technique is used f irst, second, and then third Selected 1 Ft 2nd 3rd Increase Cooling 19 - - Liquid Phase Inhibitor ] 59 Vapor Phase Inhibitor 1 1 - Dump 123 Vent to Recovery 2 11 h Vent to Atmosphere - - 2 Vent to Flare -2- Vent to Blowdown Tank - - - A. Are inhibitor systems used to control or kill reaction? Control - 3 Kill - 17 SAL CC0C2A117 4 New Case Histories Page 24 Results of Questionnaire (Continued) 5. Number of back-up inhibitor systems. One - LI Two - 4 Three - 4 Six - l 6. Where is improvement needed? Reliability 7. Backup Power Frequency of power supply interruptions ranged from negligible to six per year. Is back-up power available? Yes, 12 No, 15 8. Do you burp a reactor after injecting Inhibitor? Five do if power has been lost. BFG is one of the five. None ol the five have had bad results. They do it be venting for just a few seconds. Kthyl vents through a ball valve for 5 seconds, waits 20 seconds, then repents. The ball valve, is four-inch and it is opened wide. 9. What is the frequency of runaway batches per year? Answers ranged from 0 to 250. 10. Whet percent of the runaways result in emissions? Answers ranged from 0 to 62 percent. 20. Update on EPA Court Action -- W. C. Holbrook, BFG a. Air Products -- John Barr Their compliance plan for the Calvert City plant was to essentially build a new plant. For- a $25,000 payment to the RPA they were able to extend the compliance period for two years. The plant start-up was in March, 1979. They had 20 releases after start-up. They received a show cause order in 1980. The 1CPA liled a civil suit against Air Products in 1981. Management decided to settle out of court. The KPA agreed to a payment of $120,000 which essentially bought forgiveness for everything up to the time of the settlement. The F.PA accepted Air Products' defense on about one-third of the releases. They reached an informal agreement not to contest emissions below 100 pounds. The settlement was based on $12,500 per release. In the settlement Air Products agreed to a compliance program that includes more training, an annual review of past releases, and lots of "nit picking" record keeping. Operators and mechanics have to be trained for 90 hours before being assigned to the vinyl area. Also every vinyl worker must receive 24 hours of annual SAL 000024113 New Case Histories Page 25 training. The consent period is three years calendar time or two years total operating time. There is provision for automatic payment Lor violations of the consent agreement during that period. However, tiiey still have the opportunity to argue that a release was not preventable. b. Ethyl -- Herb 01 sen Ethyl was brought to court by the ERA for 98 releases. The EPA filed suit for $2.45 MM. A Judge Parker dismissed the suit based or. an interpretation of the regulation as a work practice standard. c. Rorden Three suits have been filed by the ERA against Borden plants. 1) Leominster, Massachusetts PVC Plant The plant had four emergency releases in 1982. They used the Judge Parker decision to argue for dismissal. Their judge disagreed with that however. He said the standards "no relief valve discharge" meant zero emissions, which makes the standard an emission standard. He also argues that the regulation says it cannot be contested after it has been in effect for 60 days. Their case is still being litigated. They have not gotten to the point of deciding whether the releases were preventable. 2) Mono-Chem Acetylene-Based VCM Plant in Louisiana The Mono-Chem plant is now wholly owned by Borden. In 1979 and 1981 the plant had two releases. Since Borden has acquired it, they have had three releases. Some were not discovered or reported. The EPA argues that they were preventable. The EPA also alleges that the plant's VCM incinerator exhaust exceeded 10 ppm at times and was not monitored continuously. A hearing was scheduled for early November. They planned to use the Parker decision as the argument for the releases. Their judge is not Judge Parker. 3) An Ethylene-Based VCM Plant Across from the Mono-Chem Plant That plant had 34 relief valvedischarges from 1979 through 1983. Eighteen were not reported within 10 days. The EPA is asking for $25,000 per release plus injunctive relief. Borden will file a motion to dismiss the EPA suit using the Parker logic. SAL 000024119 * New Case Histories Page 26 d. Oxy -- Joe King 1) Their Louisiana large reactor PVC plant received a Section 114 letLer followed by an KPA suit in July. As best I can interpret my notes, the KPA asked Lor $1 MM lor violations during the period when Firestone owned the plant and $11)0 M for violations that occurred since Oxy acquired it. Half oi the $1 KM was a penalty for failure to report releases within 10 days. On October 11 Judge Parker dismissed the suit. appealed that decision. The LPA lias 2) Burlington, New Jersey PVC Plant This plant received a Section 114 letter in April, However, the F.PA lias not done anything further. Since the state has gotten enforcement authority. 1981. then, The plant had a had record of releases for a number of years, then its performance got much better. However, in 1983 they had five releases in two months. The plant uses rupture discs without relief valves. Their management became nervous about their situation and decided to approach the state and the MPA. The KPA elected not to participate and are not involved in the insuing negotiations. The state contracted a review of the plant records to a law firm which subsequently concluded that the releases were not preventable and recommended they be forgiven. The plant then received a cease and desist order which forgave the past releases hut questioned the plant's authority to operate the vent incinerator. Apparently the state thinks a separate permit is required for the incinerator and that the permit must covet anything (even reactors) that are connected to the incinerator. The plant has asked Lor a formal hearing. 3) Pottsdam PVC Plant Up to August of 1982 that plant had 22 stripped resin excursions. They settled with the state and paid a fee of $1,500. Their next semi-annual report listed 17 stripped resin excursions. In the interim the state had developed guidelines, based on a formula plus a judgement allowance, that were much more costly. The fine per excursion would range from $9,000 to $30,000. Oxy is trying to get information on the guidelines through the Freedom of Information Act. They planned to meet with the state, in November. SAL 0000241?C 4 New Case Histories Page 27 The state is also investigating releases at that plant. There were none until four occurred this year. One release involved less than 100 pounds of VCM and the state is not interested in pursuing it. e. BEG -- W. C. Holbrook 1) Calvert City VCM Plant The FPA filed suit against the plant In August, 1982, following four Section 1 14 letters. They had a show cause hearing and plant inspections. They had not heard anything from the EPA for two years before the suit was filed. The suit alleges harm to public health. BEG challenged that. In RFG's opinion the EPA has no facts to support that. Total VCM emissions from the plant are 33 percent below what the standard would allow. Eighteen releases are involved. Sixteen are partial bypasses of the incinerator and 14 involve releases below 100 pounds. Since the suit, there have been three EPA plant visits and two conferences. EPA attorneys and engineers participated in the plant visits. A trial date was set for mid-December. BFG tiled a motion to dismiss the suit, referencing the Parker decision. The EPA filed an amendment saying that the releases also violated the 10 ppm emission requirement. 2) Louisville Plant A suit was filed in April, 1983 after several Section 114 letters were issued. Again the KPA alleged harm to public health. The plant's emissions were 74 percent below what the standard allowed. There were 17 releases of which 12 were below 100 pounds. One was a manual vent. The plant has not had a significant release in two years. BEG plans to file a motion for dismissal. 3) Their California plant has to comply with a 10 ppb standard that is enforced by the local district. They have been sued three times. Any time they report exceeding the 10 ppb limit in a semi-annual report, they get a suit. Two suites have been settled for $3,500 or less. The one pending involves 11 issues. These include one relief valve discharge, one small leak found by an inspector, a couple of reactor opening losses, and one ambient air high concentration (above 10 ppb). The local district is asking for $10,000. SAL 00QC24121 New Case Histories Page 28 4) P lncqueir.ine Plant (ox Goodyear) The plant has received several Section 114 letters. They hove had 19 releases with about one-hall being manual vents. Total emissions are 15 5 percent below what the standard would require. They expect to be sued. 15 FC is arguing that releases covered and where possible .limitations defense. From rupture discs .are are using the statute not of f. Conoco -- Reviewed by Joe hedvlna g. Georgia Pncific They received a Section 114 letter in t lie Summer of 1982 hut haven't heard anything else from the Kl'A. They had 70 releases including manual vents, relief discharges, and significant leaks. h. PPG Their hake Charles VCM plant received a Section 114 letter in May, 1982. Since then, they have had one phone call, from an KPA hired consultant. They have had around 30 releases with most of them being relief valve discharges. i. Shell Their Norco, Louisiana VCM plant received a Section 114 letter last Spring. The plant was shut down in June. The KPA was concerned that their enforcement action may have been a factor in the shu t down. Their Deer Park, Texas VCM plant lias had releases but had not been contacted by the Texas Air Control Board (TACB) yet. j. Tenneco The EPA has required the TACB to notify their Pasadena, Texas PVC plant of an emission violation any time a VCM relief valve is vented to the flare. 21 . Handling VCM Waste from Small Pilot Reactors -- Jim Wallace, F.sso Canada Jim reported on the results of a survey of pilot reactor operators. Eighteen companies participated in the survey. Probably most of these were U.S. companies since the survey was mailed only six or so weeks before the meeting. SAL 00002^*122 li New Case. Histories Page 2y Fifteen of the companies had small K&1> pilot reactors. Three companies had the pilot reactor located in the PVC plant end directly connected to the plant VCM recovery system. Several {.about three) companies had pilot reactors in a PVC plant that were not connected to the plant recovery system. Seven companies had pilot facilities remote from the plant. Only one of those (Conoco) had .a recovery system. Four of Lite seven said they did rot recover unreactud VCM because their pilot reactors are small (1 liter to 10 gallons). Nine companies vent RVCM to the atmosphere. Some use vent stacks. The average stack height is 40 feet with the maximum being H5 feet. One company vented VCM at ground level hut used steam to help disperse the VCM. Two companies incinerated vented RVCM and scrub the exhaust. incinerator There was some confusion about whether local regulations governed pilot reactor RVCM venting. Companies with pilot facilities in New York, Oklahoma, and the United Kingdom reported that local regulations did control venting. 22. Valve Position Indicator Switches -- J. H. McCuiley, Conoco Results of a questionnaire on plant experience with valve position indicator switches were reviewed. Most plants have found valve position switch reliability to be low. It was disturbing to see some of the plants with high failure rates rank, the reliability as acceptable. Most of the failures were caused by water penetrating the switch or by mechanical damage from plant personnel (during maintenance, etc.). Reliability did not seem to depend on frequency of use. The survey results are summarized below, a. Survey Participation Total Number of Companies Responding Total Humber of Plants Responding Total Number of Forms Returned 15 14 + 42 Types of Switches Used Capacitance Proximity 1/44 Electromechanical - 28/44 Inductive Proximity 9/44 Hall Effect Proximity 5/44 Other (Pneumatic) 1/44 2% 65% 20% 11% 2% SAL CO 002 A12 3 New Case Histories Page 30 c. Mean Time Between Failures (Months) Type Switch Elect romechan ical Inductive Proximity Hall Effect Proximity Min I l 2 Avg IB 10 7 Max 60 24 10 d. Cause of Failure Shifting Mechanical Failure Water Damage by Personnel Vibration Bent Indicator Arm Electrical Failure Total Electro mechanical 4 3 15 10 ') 2 36 Inductive Proximity 1 6 1 1 9 Hall Effect P roximity 3 3 1 1 2 12 e. Maintenance Performed Realign or Replace. A listing of the survey results, based on questionnaires returned before the meeting, is attached. 23. Miscellaneous Comments a. ETF, Israel Earlier in the year EIF approached Conoco to ask if we would license them reactor condenser technology. At the VCSA meeting we were told that they found a way to greatly shorten their reactor turnaround time and no longer have a need for additional suspension resin production. They are using reflux condensers on paste reactors with success. They said BASF, Shin-Etsu and others use external condensers. Some producers use reflux condensers. They said BASF and Shin-Etsu are removing 50 percent of the heat of reaction via condensers. They also said that they knew that we removed Less beat than that! SAL New Case Histories Page 31 They have problems with static on the dried resin. They have tried steam and ammonia injection without much success. Steam worked but they got wet resin. Ammonia water worked also hut it was difficult to control. A foreman discovered that placing a bucket of ammonia water next to the inlet to the transfer air compressor would help control static. They have not been able to correlate resin static with humidity. They have measured the resin static charge and find it positive sometimes and negative at other times. .John Barr suggested that they move their transfer air intake to just downwind of the cooling towers. K1F had already tried that but it did not work. They had an incident with their fluid bed dryer. The double lock valves on the dryer outlet developed problems so they shut off slurry feed. They left resin in the dryer and kept the air blowers on but shut off steam to the heating coils. Just prior to this the speed of the air blowers had been reduced to save energy but that bad dropped air flow to the point where they were not getting good fluidization. The steam valve leaked enough steam to start the resin degrading. They were not aware of this until the dryer walls became so hot the insulation on the outside of the dryer caught lire. They estimate the temperature reached several hundred degrees Centigrade. The resin in the dryer did not fuse but did turn dark gray. b. Exxon Canada Jim Wallace said their PVC plant expansion had just started operation. It included large reactors of their own design and a NIRO fluid bed. The reactors have performed well. However, they are having problems controlling the fluid bed. c. Shintech Shintech has found a way to increase their reactor productivity and plan to install an additional fluid bed dryer. The Texas Air Control Board had not issued them a permit for the dryer because with the increased capacity, air emission modeling of the plant showed some fence line concentrations of VOM to be greater than ten parts per billion, the California Standard. Texas does not have this standard, but still, did not want to issue the permit. JHM-pjc 3/16/84 QOOC SAL 'i ATTACHMENT 1 1 983 VCSA MEE'IINC VALVE POSITION SWITCH SURVEY TL:CFKCMECHANICAL LIMIT SWITCHES Manufacturer f'ro>: its: c y Microsvitch Mode 1 Number V3L-3-D8 V 3 L--139--0 8 RX21 and 3R021 No. of Switches 2l+ 21* 21* 21 + Cycles per Day 10 20 2 4 Bettis F isher C _ r. t r c I s Jamesburg M.icrcswitch Microsvitch M.;c rcsuit ch 5oc:is Switch 3R 3D4 069-0072-00 EXAR and EXAR.30 31ML1-7646 1CX42-7714 2CX3-7904 3S321AFC 3R021AFC 21 + 21 + 21 + 21 + 21 + 21+ 2;* 6 8 4 8 6 8 1t" He r.6*."Vc 11 1 LX 5001 VCX5001 21 + <20 y.i c rc sw itch Bettis Microsvitch LSXA - 21 + 6-20 21 + 2 5 3-30 Mean Time Between Failures Cause of Failure Maintenance Performed 3 Years X Years 2 Years Shifting of switch Shifting of switch Mechanical failure Cam indicator shifting and armature failure 3 Years 10 Months 1 Year 6 Months 3 Months 10 Months 6 Months Broken spring (rare) Uater in switch Shifting of switch Water in switch Mechanical damage by personnel Water in switch Bent indicator arm Water in switch Mechanical damage by personnel Bent indicator arm Water in switch Mechanical damage by personnel 5 Years Water in switch (2 or 3,Year) Mechanical damage (2 or 3/Year) by personnel 1 Month Water in switch Vib rat ion 2 Months (v/o failure) 6 to 8 Months Water in switch Shirting due to vibration Alignment Alignment Replacement Cam alignment and rep!acenenc Armature repair occasionally Alignment Alignment Replace switch Alignment Replacement of switch Alignment Replacement Replacement cf feedback arm Alignment of cams and indicaccr arr Replacement cf switches re p laceme rit Replacement " Repair (replace internals) Realign L'nu sua 1 Arabient Conditions V ibration V lbration No No Coranents on Performance Excel lent Very Good Fair Fair No Good No Good N J Good No Gc-cd No Good No Good No Good, cost prohleirs caused by water ar.J personnel Coed Deluge Fair V ibra c i on Vibration High Humid ity Installed for only two months Good. Some m service fer eight years with no failure SAL OCOC24126 ATTACHMENT I Page 2 1983 VCSA MF.ETING VALVE POSITION SWITCH Sl'RVEY KALL EFFECT PROXIMITY SWITCH (MAGNETIC SENSING) Manufacturer In house Wesco Wesco Wesco Model Number MS2A, MS2B MS2AAOO MS2-BB-00 No. of Switches 21t 21 + Cycles per Day 2 16 21 + 21 + 5 ,max 15/day 12 In house 21 + 12 Mean Time Between Failures -- 8 Months 2 to 3 Months 10 Months 8 Months Cause of Failure Maintenance Performed Slipped magnet Mechanical damage Water in switch Slipped magnet or loss of magnet Slipped magnet Water in switch Vibration Mechanical damage 30Z Electrical failure 70Z Bent indicator am 10Z Mechanical damage Alignment or replacement Replacement of switch Alignment of magnet Alignment or replacement Replacement Alignment of magnet arms and magnets ctrical failure I'nusual Ambient Conditions No No Comments on Performance Good on automatic valves Fair on manual valves Cood Vibracion and deluge water Fair. Performance improved with new magnet bracket design. Average Fair performance, requires excessive maintenance SAL 3CJC24127 ATTACHMENT 1 Page 2 1983 VCSA MEETING VALVE POSITION SWITCH SURVEY HALL EFFECT PROXIMITY SWITCH (MAGNETIC SENSING) Manufacturer In house Wesco Wesco We sco Model Number MS2A, MS2B MS2AA00 MS2-BB-00 No. of Switches 21 + 21 + Cycles per Dav 2 16 21 + 21 + 5, max 15/day 12 In house - 21 + 12 Mean Time Between Failures Cause of Failure Maintenance Performed -- 8 Months 2 to 3 Months 10 Months 8 Months Slipped magnet Mechanical damage Water in switch Slipped magnet or loss of magnet Slipped magnet Water in switch Vibration Mechanical damage 301 Electrical failure 702 Bent indicator am 102 Mechanical damage Alignment or replacement Replacement of switch Alignment of magnet Alignment or replacement Replacement Alignment of magnet arms and magnets ctrical failure .01 Unusual Ambient Conditions No No Comnents on Performance Good on automatic valves Fair on manual valves Good Vibration and deluge water Fair. Performance Improved with new magnet bracket design. Average Fair performance, requires excessive maintenance </ r o o o o w K* 7*0 ATTACHMENT 3 Page 3 1983 VCSA MEETING VAIA'E POSITION SWITCH SURVEY INVECTIVE PROXIMITY SWITCH (METAL SENSING) Manufacturer Pepperl and Fuchs (Germany) Model Number N7-2-12-GR-N No. of Switches 21 + Cycles per Day 2 General Equip 211117 ment and Manufacturing, Co. Inc. (GO ) Microsvicch 6FRI-6 General Equipoer.t ar.d Manufacturing Co. Inc. General Equip ment and Manufacturing Co. Inc. General Equip ment and Manufacturing Series 20 and 40 257126 and 13929 2115' C 21 + 2 21 + 21 + 16 5, max of :5/day 8/year 21 + 12 Mean Time Between Failures X Years +6 Honths Cause of Failure Maintenance Performed Bent indicator arm (2/Year) Mechanical damage by personnel (1/Year) None yet, Installed 6 months ago Alignment Unusual Ambient Conditions None None Comments on Performance Sacisfied Good 3 Months I Month Mechanical damage by personnel Vibration Mechanical damage Alignment or replacement Alignment or replacement Only in service a few months 2 Years Mechanical damage by personnel Physical damage 95S Shifting of switch 55 Alignment Replace due to excessive dead band Replacement None Good Vibration and deluge water Fair Dead band has been a problem. Difficult to adjust position of the switches. Works well and is the most reliable position switch used in the plant. SAL 0CG02A12 ATTACHMENT ANGIOSARCOMA INFORMATION FROM JOHN MARK The angiosarcoma tumor is rare. A review of all cases reported in the United State.s for the period from 1964 to 1974 revealed 167 cases, of which L9 were ascribed at that time to occupational VC exposure, 26 to Thortrast given medically, and 9 to arsenic in Fowler's solution, also vised medically. The remainder were of unknown etiology, with no connection to VC. There are references in the literature to one case thought to be associated with hair spray use. The high level of interest in this specific tumor is such that any subsequent cases would most certainly have been reported, and none have. For a time N10SH published a summary of VC-related cases, but this task was taken over by John Stafford of TCI, England. His most recent compilation shows a total of 30 cases in the U.S., and 101 worldwide. A summary of the number of cases by countries and of the U.S. cases by company and by date of death as given in Stafford's reports are shown in Tables 1-LI1, respectively. The average latency period in the U.S. has been 25 years, but with a mode of about 22 years. There is an unusual clustering of cases in relatively few plants (Table II). All of the U.S. occupational cases, and almost all of the cases in the rest of the world, are closely associated with the job of reactor cleaning, which was once done manually at the end of the polymerization cycle. It may be speculated that differing work programs and job progressions have had some effect on the rates at various plants. Ten cases of ASI. have been reported in one plant In Canada, the last in 1976, with no new cases since that time. These cases are completely typical, both ns to the clustering and the medical symptoms. It is also worthy of note that there is, at most, one case of both AOL and ASL in the same person, although both of these diseases are associated with VC exposure as a reactor cleaner. An industrv-sponsored epidemiological survey of workers in the VC/PVC industry covered 8,384 men with at least one year of exposure before 1973. The expected excess of ASL was found. There were also suggestions of an excess of cancers in the brain, respiratory, and at unknown sites, and of lymphoma. This study was expanded to 10,173 workers, where the excess of brain and respiratory cancers continued to be seen without, however, an association between the brain cancer and exposure. In addition, most of the lung cancer cases come from the same facility, with many plants having no cases. A follow-up study of this cohort to determine the status of the workers as of the end of Ly80 is underway. SAL QC0024130 TABLK I ANGIOSARCOMA CASKS TN THK VC/PVC INDUSTRY BY COUNTRY AS OK APRIL 1983 United States West Germany France Canada United Kingdom Sweden Yugoslav!a Ltaly Czechoslovakia Japan Norway Belgium Total 30 21 14 10 B 5 4 3 2 2 1 1 101 Includes two U.S.A. coses still alive. Adapted from Stafford. 0024I3Z i tabu: ti ANGIOSARCOMA CASKS LN THE UN HKD STATES BY COMPANY AS OF JANUARY 1983 Goodrich, l.ouisviLle Union Carbide, S. Charleston Goodyear, Niagara Five Others Total 13 8 A 3 30 00, *33 TABLE ill CHRONOLOGY OF U.S. DEATHS FROM ANGIOSARCOMA Deaths Year ot First Exposure 1961 1 1946 1962 0 1963 1964 0 1 1944 1965 0 1966 0 1967 0 1968 3 1944, 1951, 1952 1969 2 1949, 1950 1970 1 1946 1971 1 1955 1972 0 1973 3 1945, 1948, 1958 1974 1 1942 1975 4 1945, 1947, 1954, 1962 1976 3 1943, 1947, 1955 1977 1 1946 1978 2 1941, 1944 1979 0 1980 4 1942, 1951, 1955, 1964 1981 0 1982 Total 1 28 1946 Two cases liv j ng (first exposures 1954 and 1955). Data from Stafford. SAL 00002A133 ATTACHMENT 3 SA - 132 Date: 11/15/82 BFGOODRICH CHEMICAL GROUP SAFETY STANDARD Hazardous Material Storage Tank Standard Vinyl Chloride Storage Tanks (Non-Process) Tank Valves and Nozzles I. All tank nozzles must have one of the following: 1. If Not In Use - Blank on the tank nozzle flange. 2. Vapor Service Nozzles - Ball valve mounted on tank nozzle flange. Valves in conjunction with relief valves will be covered in the relief valve section. 3. Liquid Service Nozzles (usually on bottom of tank, but would also include top entering dip pipes) - Remote air actuated ball valve mounted on tank nozzle flange. The following exceptions apply: (a) Tank nozzles with thermowells. Thermowells must be welded to the tank flange. (b) A manually operated ball valve that meets criteria in Appendix I, mounted between the tank nozzle flange and the air actuated ball valve is optional. (c) Fill lines into the VCM spheres at the VCM plants. These lines require a check valve that is inspected annually and an air actuated valve that is activated only by a remote air switch. Air actuators must include the following features: (a) Air to open, spring to close. (b) Contain section of burn-through tubing. (c) Valve, with air actuators mounted on them, bench tested for leaks before installed on tank and during vessel turnaround. vp8/1.551q-l 6/9/83 3* 0* `i SA - 132 Bite! 11715/82 4. All tank nozzles must be a minimum of 1-1/2" pipe size. 5. No threaded connections should be attached to the tank. II. Valve requirements for Section I and a list of valves that meet these requirements are in Appendix I. III. Air actuated valves are required to have two local and one remote manual air switch. The two local air switches will be 180 apart and located just outside the tank contain ment system. A LEL vapor detector, discussed later, will also operate these valves. 6 IV. It is required that all air actuated valves be cycled every two weeks. V. Excess flow valves may be used in conjunction with air actuated valves. Vapor Detectors I. LEL type vapor monitor with continuous sampling that alarms at a maximum of 25Z and closes air valves and activates deluge system at 50% are required. II. Three LEL detectors will be located below tank and one at pump. It is not required that the LEL detector at the pump activate the deluge system. III. Vapor detectors should be tested and calibrated every four months. Fire Protection I. An automatic deluge fire water system is required for each tank. II. Vessel supports need either a deluge system or fire proofing with a 2 HR rating. Relief Valves I. One of the following two, (a) or (b), may be used for vessel pressure relieving systems: (a) A three-way valve with two relief valves. wp8/1551q-2 6/9/83 SAL 0CQ024135 r< SA - 132 Dace: 11/15/82 (b) Two-way valves, multi-nozzle with "Castell" locking system. See Appendix II for relief valve design and installation requirements. II. Manual valves below relief valves must be mounted on tank nozzle flange. Valves for this service must meet the requirements in Appendix I. III. Each relief valve will be bench tested every three years. IV. Rupture discs will continue to be used per the EPA Regulations. V. Sizing of relief valves must adhere to BFG Policy ST-1317. Tank Internal Inspection I. Storage tanks will be inspected a minimum of once in five years; tanks in rework VCM service every two years. II. The minimum inspection requirements are: (a) Visually inspect for internal corrosion, especially around flange welds, thermowells, level indicators, etc. (b) Ultrasonically test wall thickness in several representative locations. TTT ^ (c) Record results of each inspection and thickness measurement and compare with previous inspections. Connecting piping will be inspected at the same time tank is insnected. wp8/1551q-3 6/9/83 SAL 000024136 4 ADDENDUM HAZARDOUS MATERIALS STORAGE TANKS SAFETY STANDARD SA-132 To be used for existing installations and specific applications only. (1) Existing high performance butterfly valves, manufactured by Posi-Seal, may be used in vinyl chloride service at Calvert City in p.lace of the ball valves required by the standard. When these valves are replaced, however, they must conform to the standard. (11/15/82) (2) Existing six inch pipe elbows may remain between the tank nozzle flange and the air actuated valve on the butadiene tanks at Port Neches. These elbows must be inspected every year, however. (11/15/82) wr>8/1551a-4 11/9/82 ` cai 0CGC24137 i ATTACHMENT 4 SA - 130 Date: 8/10/82 BFGOODRICH CHEMICAL GROUP SAFETY STANDARD MAINTENANCE WORK ORDER STANDARD Purpose The objective of this standard is to eliminate personnel injuries, chemical spills, chemical exposures, and equipment damage which may result as a consequence of maintenance work being performed by persons who are not always familiar with the particular equipment or facility and the inherent related hazards. Definition Maintenance Work - is any activity to install, adjust, repair, test, inspect, remove or re-install workplace equipment or facilities, when performed by persons not directly responsible for the operation of such equipment or facilities. Maintenance Work Order - A permit which is used to define in written form: (a) A description of the maintenance work. (b) Safety related information. (c) Authorization for the maintenance work to begin. (d) Acknowledgement of work completion. Procedure Each plant/facility shall prepare and maintain a written procedure for authorizing maintenance work. This procedure must require the fo1 lowinot I The transaction of releasing equipment involving hazardous chemicals to mainte nance personnel must occur at the equipment site. Th e fo'reman/operator who author izes the maintenance work to commence in his area must re lease the equipment in the pr esence of the craftsman. wp8/0 55 9q-1 8/10/82 sal 00oa<u3 b -2- II. III. IV. wp8/0559q-2 3/10/82 The foreman/operator who signs the Maintenance Work Order, authorizing the work to begin, must determine that: (a) The craftsman is working on the correct piece of equipment* (b) The equipment is safe to work on. (c) The craftsman has been advised of the potential hazards and any special tools or protective equipment that is required. (d) The appropriate personnel are aware of the maintenance work that is in progress. Note: Many jobs performed by maintenance craftsmen require the following additional procedures: hot work., vessel entry, lockout and others required by the specific plant. It is the responsibility of the maintenance craftsman that these procedures are followed. However, the production foreman and the maintenance foreman must be held accountable* The maintenance foreman will assign a craftsman to a job after determining that the necessary preparations have been made and will give him a copy of the maintenance work order. Communication with the production or operating area is required to determine whether equipment or systems have been made ready for maintenance. The maintenance foreman must make certain that the work order accurately describes the work to be performed. The production foreman/operator releases the the craftsman by describing in written form, equipment has been safed-out and signing his date and shift must also be included. equipment to how the name. The This signature assures the maintenance craftsman that the equipment has uu mdue au-Ce, Lhe operators have been informed of the work to be performed, and if more than one department uses the equipment, each of the other department operators have been informed. The craftsman must be satisfied that the release is complete and conditions are safe prior to commencing work. SAL 00024139 `4 V The release of equipment is only valid for one shift. The ^.craftsman must obtain another signed release whenever there is a personnel shift change (this includes a personnel . shift change by either the craftsman or production or both). The release requirements for subsequent shifts are identical to item #11. The possibility that conditions could change makes this duplication of the release procedure as .important as the original. When the equipment has the potential for a large chemical spill or release and cannot be drained or isolated by using a blank or locking a block valve, the foreman/operator must be present at the equipment site until the job has been completed by the craftsman. VI. A Maintenance Work Order is used to authorize maintenance work. It must provide: (a) A description of the maintenance work to be done. (b) The location or job site. (c) The date and estimated duration of the maintenance work. (d) A section on safety that will accommodate a written description of how the equipment has been safed-out. This should include any permits, safety equipment, or activities that are required for the job to be performed safely. (e) A signature from the foreman/operator for the release of the equipment to the craftsman. The craftsman must countersign the foreman/operator*s release signature. (f) A signature from the foreman/operator signifying that the maintenance work has been approved. Before approval is given, however, the maintenance work, housekeeping conditions, and tool/equipment storage must be acceptable. If the maintenance work requirements are satisfactory, then the foreman/operator must sign the MWO, including the date and the time, indicating the acceptance of the work. (Those plants that use a Hazardous Work Permit or a Permission to Start Work permit m.iy substitute these for the safety requirements of this v'< i. n tenance Work Order Standard). wp8/0559q-3 8/10/82 SAL 0c024l40 -4- VIII. A system must be established for monitoring the release and approval process for Maintenance Work Orders. This can be ". accomplished by having the person who is responsible for charging the craftsman's hours verify the proper authorizations. Also, routine audits by line management and staff personnel should be used to monitor the release and approval process. A thorough investigation must be conducted if a Maintenance Work Order is found without the proper release and approval signatures. wp8/0559q-4 8/10/82 Oc DSC."IIB6 MOW THE EQUIPMENT HAS BEEN SAFEO-OUT JC B AUTHORIZATION OESCRtBE HOW THE EQUIPMENT HAS BEEN SAFEO-OUT AUTHORIZATION CRAFTSMAN SIGNATURE OESCHIBE HOW THE EQUIPMENT HAS BEEN SAFED-OUT OATE SHIFT AUTHORIZATION CRAFTSMAN SIGNATURE OCSCRIBt HOW THE EQUIPMENT HAS BEEN SAFEO-OUT. |DaTI |jSHlfT . AUTHORIZATION CRAFTSMAN SIGNATURE A 1 ALARM A3 ANALYZER A3 ARMATURE bi BASE ez SATTERY S3 BEARING 64 BELLOWS IBOUROON-MELICALI as BELTS as 8LAOE S7 BOLTS ISCREWS. STUOSI u BUSHING CI CABLE C2 CASING C3 CATALYST C4 CHAIN CS CIRCUIT C6 CLUTCH C7 COilS-HEaTER cs CONDUIT cs CONTROLLER ISTARTER) 01 DIAPHRAGM El ELECT. SUPPLY FI FAN 2 FILTER (SCREEN. STRAINERI '] FLOAT F4 FUSE Cl GASKET CJ GAGE G3 GEAR Ml HOSE ATE SHIFT AUTHORIZATION CRAFTSMAN SIGNATURE COMPOtalNT REPAIR MM* jur cooes M7 11 3 3 LI L2 L3 Ml M? M3 KM N1 1 FI P7 P3 F4 PS 01 ai 03 04 R1 R1 R3 R4 RS R6 HOUSING OR FRAME iBOOl IMPELLER IMPULSE LINE INSULATION LAMP LEADS LINKAGE MAGNETS METER MOTOR MOUNTING NOZZLE OIL PACKING PIPE piston iplungeri POSITIONER POWER SUPPLY PROBE PUMP 1COMPR ESSORI COOLANT COUPLING IF LANGE . JOINT) CUP CYLINDER RECORDER REGULATOR RELAY RELIEF RING ROO RJ RB AO S< SI S3 S4 SB M S7 SB SB T1 T7 T3 T4 T5 TB T7 TB T9 VI V? V3 W1 X1 XI X3 X4 IS Zi ROLL ROLLER ROTOR SEAL LIP SEAL MECHANICAL SEAT SHAFT SMELL SHEAR PIN SHEAVE SLEEVE SOLENOID TERMINAL THERMAL SYSTEM THRUST BEARING TRACING TRANSFORMER TRANSMITTER TRAYS TRIM TUBES VALVE VENT VESSEL WIRING OR WINDINGS SPRING SPROCKET STATOR SUPPORT STRUCTURE SWITCH (BREAKER) TUBING OR FITTING * CaT? SHIFT CONDit'ON 81 B3 83 Cl c? OI 1 E2 FI FI Gl Jt L LI L3 Ml M3 M3 Nt N3 N3 N4 Ol 02 PI SI Tl VI w> w? W3 BENT BROKEN BURNT CALIB NEEOFO COAAOOEO OIRTY EMPTY EROOCO FAILED FAULTED GROUNDED JAMMED LEAKING LOOSE LUBE NEEDED MISALIGNED MISAPPLICATION MISSING NEEOEO NEW NOISY NOTHING FOUND OFF OVERHEATED PLUGGEO SHORTEO TIGHT VIBRATING WET WORN WRONG SIZE ! ACTION A1 A7 ei Cl c? C3 F1 11 12 L< L2 Ml M2 N1 PI P? P3 P4 Rl R2 R3 R4 RS R6 AT RB R9 SI Tl U> Wl AOJUST t D ALIGNED BALANCED CALIBRATED CHECKED ITESTf CLEANED FABRICATED INSPECTED INSTALLED LOOSENED LUBRICATED MACHINED MODIFIED NONE PAINTEO PICKLED PLUGGEO PURCHASED REBUILT REINSULAIEO RELOCATEO REPACK E 0 REPAINTED REPLACED RESET (STARTED REWIRED REWOUNO STRAIGHTENED TIGHTENEO UNPLUGGED WELDEO 'I FURTHER EXPLANATION (OPTIONAL) SAL C002i42