Document v6kg8pDVZpbKGMdgxkkXR6Jnb

W. R. Bailey - Delaware City S. BrouMlar^ D. E. Frey V. Hehle/WT"u. Hutton - Pasadena R. Henderson - Independence D. L. Lull R. J. Sutch - Cleveland J. E. Zimmerman - Cleveland D. P. Tech. File 16.17.(b) File 712L May 24, 1978 Mr. Richard Miller Industrial Hygienist Occupational Safety and Health Adm. 2320 LaBranch Street Houston, Texas 77004 Dear Mr. Miller: Attached is the additional information you requested during your inspection of our Deer Park PVC Plant on May 18 and May 22, 1978. Exhibit numbers have been included for each reference: Exhibit I Exhibit I I Complete report of May 18, 1978, VCM spill. VCM releases for last nine (9) months involving personnel exposure. Exhibit i I I Exhibit IV Exhibit V Description of VCM monitoring system. Corrective action for missing valve handles. Personnel sampling data for last six (6) months in general area where spill occurred. Also, you asked about the source of our monitoring equipment. The vendor who supplied the equipment for our continuous monitoring system is Areas, Inc., 8500 Commerce Park Drive, Suite 110, Houston, Texas 77036, and their phone number is (713) 777"2392. If you have any additional questions or comments, please do not hesitate to contact us. Sincerely, (c^JLv^L P* RPB:Imr Enclosures Rodney P. Becker Plastics Plant Manager OCC 11097 Diamond Shamrock Corporation P O. Box 600, Deer Park, Texas 77536 Phone, 713476-2C00 EXHIBIT I INTRODUCTION Polyvinyl chloride is made by polymerizing vinyl chloride monomer. In the initial charging operation, water, catalyst, suspending agents and vinyl chloride monomer are manually charged through meters to an agitated pressure vessel where they are then heated to initiate the reaction process under controlled conditions. LOCATION The #4 Plant process area where the spill occurred contains ten (10) 2000 gal. reactors and allied equipment such as charge pumps, instruments, piping, and compressors. The #3 Plant process area just South of #4 Plant and adjacent to #4 Plant con tains the same inventory of equipment. The manpower required to operate these process areas include a total of nine (9) men. These men are engaged in the charging, dropping, cleaning of the reactors and for the drying of the finished product. The personnel responsible for the drying area are also required to monitor the operation of the charge pumps, compressors, and other equipment located in the ground level area since the charging operation takes place on the second level. INCIDENT On the morning of Hay 18, 1978, an operator who was in the process of charging #44 reactor had completed the addition of all of the raw materials except the vinyl chloride monomer and was pulling a vacuum on the reactor prior to the addition of the VCM. (The reactor evacuation process is a standard operating step in the reactor charge procedure.) When the desired vacuum was reached on #44 reactor, the operator proceeded to open the VCM valve and meter the VCM to the reactor. Standard operating pro cedure for this step is to close the evacuation valve and then open the VCM valve but for some reason the operator failed to -close the evacuation valve. EVACUATION Evacuation of the reactor is done via a Nash water sealed compressor that pulls the reactor vapors from the reactor and discharges them to a gasholder collec tion system where they are later condensed and returned to the process. The seal water for this compressor is recycled through a small tank which is an allied part on the Nash compressor. Since the VCM vapors that are being re moved from the reactor are laden with water, a level controlled dump valve s installed on the seal water pot to control the water level. When the water level gets high, the dump valve opens and discharges this water to a process sewer. SPILL When the operator failed to close the evacuation valve on the #44 reactor, the liquid VCM that was being charged was carried into the evacuation compressor and compressor seal water pot. The automatic dump valve then opened up to re duce the seal water pot liquid level and discharged the liquid VCM to the open process sewer. OCC 11098 SPILL (Cont'd) Operating personnel in the Number 3 and process areas immediately rushed to the compressor area to isolate the spill by closing the suction and discharge valves at the compressor. A diagram of the poly evacuation process is attached to this report. THG:lmr 5/19/78 Ted Guth OCC 11099 \ ] ! i :i I i o Q i Q O O i Diamond Shamrock EXHIBIT II bcc: L. G. .son N. F. Fahnoe T. 0. Isbell November 29, 1977 Mr. Ronald McCann Safety and Health Director U. S. Department of Labor 2320 LaBranch Street Houston, Texas 77004 (OSHA) . Dear Mr. McCann: At 11:51 A.M. on Novemher 26, 1977, a VCM release occurred at our Deer Park Poly Vinyl Chloride Plant as a result of metal fatigue to a screen pot stud bolt which allowed the screen pot lid to blow off and discharge water, PVC and residual amounts of VCM vapors to the atmosphere. The total time of the emergency was estimated to be 30 seconds and the highest reading recorded on the Personnel Monitoring System was 861 ppm of VCM. There were two (2) operating personnel who stated that they had smelled VCM during the release and they were sent to First Aid for medical examination. Neither one of the operators were wearing respiratory protection. Operators involved were Rudy Ybarra and Mike Mulkey. The VCM .release amounted to 184 lbs./VCM. Events leading up to the release are as follows: An operator, Rudy Ybarra was in the process of discharging a finished batch of PVC slurry from It51 poly (which is located in our It4 Plant Expansion Area) through the screen pot and into the blowdown tank. The screen pot lid blew off releasing water, PVC and VCM vapors to the atmosphere. Mike Mulkey who heard the noise caused by the release immediately rushed over and closed the drop valve on the poly. A VCM sensor located approximately six (6) feet from the screen pot detected a concentration of VCM and sounded an alarm located in the Poly Control Room. Corrective action to prevent personnel exposure from releases occurring at the screen pots will include the isolation or closing of the drop valve and the evacuation of the affected area by all personnel. Sincerely DIAMOND SHAMROCK CORPORATION RPB:lmr Rodney P. Becker Plant Manager OCC 11101 Diamond Shamrock D. E. Frey DA. Lull Rn ^^l. cS.u. +tc,,h D. P. Tech. File 16.03-b(1) May 18, 1978 Mr. Richard Miller Industrial Hygienist Occupational Safety and Health Adm. 2320 LaBranch Street Houston, Texas 7700^ Dear Mr. Miller: At 0511 A.M. on May 18, 1978, a VCM release occurred at our Deer Park Polyvinyl Chloride Plant and seven (7) of our employees were exposed to VCM. The highest level recorded by our monitoring sys tem during the release was 971-3 ppm/VCM. All of the employees exposed to VCM were examined by our First Aid Department and no ill effects were reported. The names of the employees exposed are as follows: L. Singleton J. Davis L. Verrette R. Corpus B. Byous E. Lujan J. Jonas The total amount of the release is estimated to be 380 lbs./VCM and was a result of an operator error. The operator involved was in the process of charging a reactor in our 8h process plant. During the charging operation he failed to close an evacuation valve on the reactor before commencing to charge the liquid VCM. The liquid VCM escaped through the open evacuation valve to the water sealed Nash compressor. The dump valve on the Nash seal water pot then discharged the liquid VCM to the process sewer. In their haste to isolate the spill, none of the employees wore respiratory protection although each employee is provided with approved respiratory equipment. Sincerely, RPB:lmr Rodney P. Becker Plant Manager OCC 11102 Diamond Shamrock Corporation P.O. Box 500, Deer Park, Texas 77536 Phone 713 476-2000 Diamond Shamrock October 21, 1977 Mr. Ronald McCann Occupational and Health Administration Room 2118 2320 LaBranch Street Houston, Texas 77004 Dear Mr. McCann: On October 21, 1977, at 0920 hours a VCM release occurred at our East Poly vinyl Chloride Plant in the monomer recovery area when a safety valve blew on an accumulator. The VCM release was caused by a mechanical failure of the high level alarm on the reclaimed monomer pump-back-tank normally referred to as the accumu lator. Two operators, Mr. Lonnie Follis and Mr. Melvin Eudy, who were near the scene, immediately shut down the reclaim compressor, but were exposed to an undetermined amount of VCM during the process. Neither one of the operators were wearing respiratory protection. Both of the employees reported to First Aid for medical examination with no ill effects reported. The VCM release was calculated to be 658 lbs./VCM and total time of the emergency was two (2) minutes. The highest concentration of VCM recorded by our continuous monitoring system was 38.9 ppm. The accumulator level alarm was repaired before the recovery system was put back in operation. The relief valve discharge stacks will be elevated to avoid future employee exposures in case of an emergency relief valve discharge. Sincerely DIAMOND SHAMROCK CORPORATION EZ:lmr bcc: L. G. Davison N. F. Fahnoe VJ. C. Hutton 'T't rt T -- L ~ 1 ^. ;r. teen, rile I6.03b(i) P"irr*n'^ ^mrr*r^ r n l* ^ E. Zinn Plant Manager Pc'.'' C'rvL Too' 7[H-. OCC 11103 -nnn Diamond Shamrock August 23, 1977 Hr. Roy Piggee Occupational and Health Administration Room 2118 2320 LaBranch Houston, Texas 77004 Dear Mr. Piggee: On August 22, 1977, at 2347 hours, VCM vapors were released to the atmos phere when a 3/4" plug blew out of a monomer recovery compressor. The monomer recovery compressor is operated in intermittent service and had just been put on-stream. The operator who was at the scene, immediately shut down the compressor, but was exposed to an undetermined amount of VCM during the process as he was not wearing respiratory protection. No ill effects to the employee occurred as a result of the exposure and the employee reported to first-aid for medical examination. The VCM vapor release was estimated to be 5 lbs./VCM and the total time of the emergency was two (2) minutes. An L.E.L. (Lower Explosive Limit) sensor detected the VCM vapors and tripped our recovery area sprinkler system as added protection. No high VCM readings were recorded on our continuous monitoring system during the time of this emergency. The plug was replaced in the compressor and normal operations were resumed. Sincerely, DIAMOND SHAMROCK CORPORATION EZ: lim bec : cof'i ^ L. G. Davison N. F. Fahnoe W. C. Hutton T. 0. Isbell B.rjp.' Tech File 16.03.b(l) E. Zinn Plant Manager OCC 11104 Diamond Shamrock Corporation PO Rr S00 Park 7753n Phnnr* 713 **76-?000 ARCAS VCM MONITORING SYSTEM The Areas System is basically a communications system. It sequentially analyzes 80 designated sample points strategically located throughout the Plant on five separate G.C. Units. The most recent analyses from the five systems (No. 1, 2, 3, & 5 Plants) are stored in the multiplexer. The multiplexer scans all data sending out the most recent information to the Environ mental Head Operators deewriter and to the remote warning stations if an exposure is imminent. Each time the next higher level is exceeded, a visual light is displayed. The primary function that the system serves is to feed back VCM concentrations and designate respiratory protection to be used by way of the remote exposure warning stations the operating areas and the personnel in those areas. Action levels displayed at the designated warning stations are 5 ppm (white), 25 ppm (blue), 1000 ppm (yellow), and 3600 ppm (red). If a warning light is displayed and respiratory protection is not available, you must IMMEDIATELY LEAVE THE AREA. TMG:lmr 5/11/78 OCC 11105 ANALYTICAL EQUIPMENT ARCAS INC. *>Ofi CQHMCnCE f'AHK DU., SUITE. I IO HOUSTON. ttXAS 1713) J7 PROGRAMMER DATA SHEET Customer Diamond Shamrock Date 'December 1D75 Address Deer Park, Texas Job 4^ 5X1054 Type of Mount: p.O. # H95368-7 ' Model 505D FID / / Panel / / Rack /x/ Field Electrical Classification: / / General Purpose /x/ Explosion Proof Cycle Time: Tuner: i minutes /x/ S. M. Digital seconds Count Rate one second No. of functions (slots)_______7 Function slots not used 2 / / Cramer Cam Motor Speed Gear Rack_ No. of Cams ______. No. of Cams Not Used / / Other ________________ Number of Streams_______^_________ / / Manual Switching /x/ Automatic Switching Detector Current No. of Attenuators^ Notes: _ma. (T.C. units only) / / Dual Range OCC 11106 * nmicirwi rC IMP Timer Functions 1A End of cycle - 2A Auto zero 3A Column switch 4A Peak One 5A 6A 7A 8A 9A 10A 11A 12A 13A 14A 15A loA 17A 18A 19A 20A inject Time 060 024 058 027 ` IB Sample block 2B 3B 4B 5B 6B 7B 8B . . 9B 10 B 11B 12 B 13B 14B 15B 16B 17B 18B 19B 20B Time 057 020 039 Components__________ Attenuator # Vinvl Chloride 1 Streams 1-16 Range %/ppm 0-3.6% Notes A DIVISION OF ANACON. INC OCC 11107 JOB # 5110 VALVE #1 Sample valve type 6 port s ,s .-l/8"-Arcas slider__________________________ Sample loop External_____________ Length 6" x 1/8" Volume Carrier gas Helium^ Bottle regulator 50. PS I Carrier pressure Reg 1 ^30 psi Reg 2 23FSX Column, configuration Precut with backflush to vent Precut column 1' chromosorb 102 80/100 Analytical column 2' chromosorb 102 80/100 Other Flows; measured with bubble tube Reference cc/m Column cc/m Backflush 45 cc/m VALVE #2 Sample valve type Sample loop ' Length _________________________________________ Volume ______________ Carrier gas Bottle regulatorPSI Carrier pressure Reg 1 PSI Reg 2 PSI Column configuration Precut column- _* Analytical column Other _. FI ows : measured with bubble tube Reference cc/m Column cc/m Backflush __________________________________cc/ii BOTES: _____________ ______________________ CC Uio8 Model # 905 Separation of Job #*511054 vinvl chloride from air Oven type Air Bath Field electronics /x/ Purged (check one) J Condulet Detector type_______FID F.I.D. Units only -- Bottle regulators supplied by customer- Zero hydrogen bottle; ;* Pressure setting 40 PSX Flow________________60___________ cc/rg Restrictor type fixed capillary Zero air bottle r Pressure setting 40 PSI Flow__ 300 cc/nt Restrictor type __________________variable needle valve Instrument air pressure:.. Source 50 PSI Oven air pressure 40 PSI setting Operating temperature 230 Temoerature controller zero crossing Check one / / Plug Card fa / Gup Mounted Temperature probe __________thermistor 1 meg 250 C_________ High Temp. Cut-off Switch standard on all units/set at 300F Carrier Protection standard on all thermal cond. units Power Switch / / yes .hJ no OCC 11109 EXHIBIT IV DACO Z7 t MEMORANDUM To /<>/ //______________________________________ Subject //U/. l/ZZ /-/zl/ZZZZ Date Z5~~ j3S- *7& V//-T /S T'O Z?0A//r//?sr7 -7-ZS/27' Z^t>2T/g^ i^ZlZ^ &/sZ /ZoZ <S ZAL___ ^ - 4- - 4r>Z___ ,4^Z___# AZ/P/ZZJZZr -Z77 - < /?7sOD<^ t~A//S ZTA/ZT/^tTcZT'/ZZsy /y^f^r/A"__________________________________ _________________________ occ lino M?}/33, /<?'/& '1 -7&. /_________^/r/Z 'i ______________ ,'Jv30/?7.^._______/-/?/?___ __________________ ,,________ ___________________ _______ ____r/oM_ (3-4- 4*^ j I___ ,,/Al--JMA/Lr- ^_____________________ k'tfJ- t/'---_///jA/0<L3. t ____ /A/S33C-T/&M /MC0/?ro/?& TcLD s/S ~T/43. ___ /77&/vr// .../,&/?/' fhr/z&t /a/3/30r/6W........................... ____ 0<0S ^rd:td>/j!3fc<Z-.....________ ____^r/A'^tyV^Z y/r/,2*7S,.. (4-) ........ tf/C/?. d?/?S3(0^________________ __ ___ occ mu DAH: \/2\//'7 2/1 4/ /7 tl /04/ /8 iR/09/ / 8 ).i/02/ /8 M/03/ / 8 DEER PARK PLASTICS VCM CEILING EXPOSURE J 08 3-4 DRYING 3-4 DRYING 3-4 DRYING 3-4 DRYING 3-4 DRYING 3-4 DRYING NAME J. VALENZUELA D. HERNANDEZ R. MURPHY T. CASKEY R. MURPHY D. HERNANDEZ TIME DESCRIPTION 15 15 15 320 15 1b OPEr. dryer ort ITCHED BIN.) HOU11 NE DUTI ES iiASHED DOWN routine dry. oAMPLED,Toner #s vcm 0. 49 0. o3 0. 7 4 0.28 i . 53 0. 54 DA; L i /os/ n 1 /' 3 0/ 1 7 11 /1 9/ i 8 18/09/ i 8 )// 1 5/ / 8 M/ ! 9/ M oao M b* N) DEER PARK PLAoTICo VCM TnA EXPOSURE JOB 3-4 DRYING 3-4 DRYING 3-4 DRYING 3-4 DRYING 3-4 DRYING 3-4 DR* 1 NG NAME R. MURPHY J. NARVAEZ D. hILL I AMS T. CASKEY J. VALENZUELA J. NARVAEZ TIME 320 320 320 320 320 32 U DESCRIPTION NORMAL OPER. SAMPLE VCM SAMPLING & DRY. WASHED GOWN OPER. urYER CAICH SAMPLE VCM O.oO 0.02 0. J3 0.28 0. 99 0. 26