Document wr437px3184MzxwKagaJMqeR3

Interoffice Correspondence To: From: Date: R. P. Becker T. M. Guth May lb, 1378 Subject: QSHA Inspection - Closing Conference cc: S. Broui11ard W. R. Bailey - Delaware City D. Frey V. Heble/W. C. Hutton - Pasadena D. Lull R. Henderson - Independence R. Sutch - Cleveland D. P. Tech. File 16.17. (b) o iib-c On May 22, 1978, Mr. Richard Miller, Industrial Hygienist with OSHA, arrived at the plant at 0530 A.M. to interview the employees that were exposed to VCM during the spill which occurred on May 18, 1978. The employee interviews ranged from 15 to 30 minutes each and employees were allowed to leave after the interview since they had worked the night shift. All of the employees who had stayed over for the inter views were instructed to fill out overtime cards. After the interviews Mr. Miller requested a conference with Rod Becker and myself to discuss the results of the interviews and of his in spection . Mr. Miller informed us that he was surprised that our employees were so concerned about the spill and of their responsibility to prevent spills from occurring. Mr. Miller stated that he could understand how a spill of this nature could occur even though the employee's error was unacceptable. Mr. Miller stated that we would be expected to install a handle on the reactor evacuation valve that was involved in the release, but he had no other requests. Mr. Miller stated that his recommendation to the Dallas office would be to not issue anv citot inns as a result of his inspection and that no additional sampling be conducted. Mr. Miller was informally asked his opinion of our plant. Mr. Miller stated that he was impressed by the attitude of our people and by our monitoring program. Mr. Miller was asked how frequently disciplinary action was taken to prevent employee errors. Mr. Miller stated that normal procedures were to address letters to the employee's file. The conference adjourned andjflr. Miller was bid farewell. Diamond Shamrock TMG:1mr Ted Guth OCC 10008 1 * \ Diamond Shamrock bcc: W. R. Bailey - Delaware City S. Brouillard D. E. Frey V. Heble/W. C. 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 2k, 1378 Mr. Richard Miller Industrial Hygienist Occupational Safety and Health Adm. 2320 LaBranch Street Houston, Texas TJQOk 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 1 Complete report of May 18, 1978, VCM spill. Exhibit 1 1 VCM releases for last nine (9) months involving personnel exposure. Exhib i t 1 1 1 Description of VCM monitoring system. Exhib i t IV Corrective action for missing valve handles. Exhib i t V 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) 777~2332. If you have any additional questions or comments, please do not hesitate to contact us. Sincerely, P6 RPB:lmr Enclosures Rodney P. Becker Plastics Plant Manager OCC 10009 Diamond Shamrock Corporation PO Box 500. Deer ParK. Texas 77536 Phene. 713 476-2000 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 jfk 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 h Plant and adjacent to ffh 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 May 18, 1978, an operator who was in the process of charging #hh 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 jfhh 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 is 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 s ewe r. SPILL When the operator failed to close the evacuation valve on the 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 10010 SPILL (Cont'd) Operating personnel in the Number 3 sod If 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. TMG:1mr 5/19/78 Ted Guth OCC 10011 Diamond Shamrock wm i i U I i ii bcc: L. G. Davison N. F. Fahnoe T. 0. Isbell C0PYFOR --'5- F* Tech- File l&*03.b(l) 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 November 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 #51 poly (which is located in our #4 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 loly 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. Becke Plant Manager OCC 10013 N Diamond Shamrock bcc: L. G. Davison D. E. Frey D. L. Lull R. J. Sutch : ... D. P. Tech. File I6.03.b(l) May 18, 1978 Mr. Richard Hiller Industrial Hygienist Occupational Safety and Health Adm. 2320 LaBranch Street Houston, Texas 77004 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 Hk 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 y Rodney P. Becker Plant Manager OCC 10014 Oiartinriri ^hamfnrk r.nfnnralinn P <"> Prw f'aar Trw-*~ 77CTC PhflT'ft 71*1 T/'An A Diamond Shamrock October 21, 1977 Nr. Ronald NcCann Occupational and Health Administration Room 2118 2320 LaEranch 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 te 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 L. G. Davison N. F. Fahnoe W. C. Hutton Tj. ,* Isbell s). A. Metelko ^- `P. Tech. File 16.03b(i) n;-* .rSrl f' E. Zinn Plant Manager I* . OCC 10015 Diamond Shamrock August 23, 1977 Mr. 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:lmr bcc: COF' ^ L. G. Davison N. F. Fahnoe W. C. Hutton T. 0. Isbell P.` Tech File 16.03.b(l) E. Zinn Plant Manager OCC 10016 EXHIBIT I I I 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/M/78 OCC 10017 .............. 1 ' idiiis ANALYTICAL EQUIPMENT ARCASlNC. *00 COMMIltCt AAA* JUlTC >19 HOWAIOH. Ux* PROGRAMMER DATA SHEET Customer Diamond Shamrock Date 'December 1975 Address Deer Park, Texas #jot, 511054 P.O. # H95368-7 Model #"'505D FID Type of Mount: / / Panel / / Rack A/ Field Electrical Classification: - / / General Purpose Cvcle Time: A/ Explosion Proof * 1 minutes 0 seconds Tuner: /x/ S. M- Digital Count Rate one second No. of functions (slots)______ Function slots not used u. Cramer Cam 2 Motor Speed __ Gear Rack No. of Cams No. of Cams Not Used , . / / Other_____________________________________ Number of Streams____________________ / / Manual Switching A/ Automatic Switching Detector Current ma. (T.C. units only) No. of Attenuators^ Notes: / / Dual Range a vi acavj nor OCC 10018 analytical equipment ARCA5 INC. t00 COMMERCE PARK DH< SUITE 110 Job # 511054 HOUSTON. T 171 Timer Functions ______Time 1A End of cycle - inject 060 2A Auto zero 024' 3A Column switch 058 4A peak One 5A 027 r 6A 7A 3A 9A 10A 11A 12A 13A 14A 15A ISA 17A ISA 19A 20 A _______________________ ____Time IB Sample block 057 2B 3B 020 4B 039 5B SB 7B 8B 9B 10B 11B 12 B 13B 14B 15B 16B 17 B 18B 19B 20B Components__________ Attenuator # Vinvl Chloride 1 Streams 1-16 ~ Range %/ppm 0-3.6% Notes A DIVISION OF ANACON, INC. OCC 10019 JOB 511054 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 PSj Carrier pressure Reg 1 23 PS3 Column configuration Precut with backflush to ye nt Precut column 1* chromosorb 102 80/100 Analytical column 2' chromosorb 102 80/100 - Other Plows : measured with `bubble tube Reference cc/m Column cc/m Backflush 45 cc/n VALVE #2 * Sample valve type k Sample loop Efength Volume Carrier gas Bottle regulator Carrier pressure Req 1 PSI Req 2' Column configuration Precut column- % z Analytical column Other - Plows; measured with bubble tube Reference cc/m Column cc/m Backflush NOTES r OCC 10020 ps: ps: cc/i Model # 905 FID Job * 511054 Separation of vinyl chloride from air Oven type Air Bath Field electronics /x/ Purged (check one)_ J Condulet Detector type ' FID F.I.D- Units only -- Eottle regulators supplied by customer. Zero hydrogen bottle: Pressure setting ______40 P5X Flow_________60 cc/ir Restrictor type fixed capillary Zero air bottle: Pressure setting 40 PSI Flow __ 300 cc/m Restrictor type __________________variable needle, valve Instrument air pressure:. Source 50 PSI Operating temperature 230 Oven air pressure 40 PSI setting Temoerature controller zero crossing Check one / / Plug Card fa f Gup Mounted Temperature probe High Temp- Cut-off Switch __________thermistor 1 meg d> 250 C standard on all units^/set at 300F Carrier Protection Power Switch standard on all thermal cond; units / / yes hJ no 0CC 10021 LA n I D 1 I IV DAT! dp or OCR DATE RCOUfRCO piv, rur. -22-73 -23- 7S ISCmPYTQN OP WOMKHAMC OR HUMBKH OP EQUIPMENT--RCABDN POR WORK 33716 1 .=v"( k*\i Jffiff/AUlfl frfcjfthflfnft ihW ii? g f f r r t lA . CENTRAL CONTROL. V DACO 287 MEMORANDUM To______/-3> 7-^ir/ / /-/_____________________________ Subject f/U/. !/" /-M/VZ)^ Date Aj~- 13-- 323 77//y /s mo s?k>a//=v.?s?7 -7~7S/?r <____/a/ 3 - 4- - 4-X /V^7< .<C?A/ /7T~____________________ _______ y /??s30^ -ry-//s ts&zi/g' o/\/ /7 S//?sA/J<C y'/^^y /--x'&sA*' /??/ <r occ 10022 3/9^ ASt /<?7& A~ro / ______________________ \/y?o/??. - 33e/9A/3 /Qyy/s ____ __________ ______ _ __________ .....-02/33^3;... pOsLt/3_ ///3A/Dt<--J^5'J^r/&A/. (3-4-4x^ ______ /y/~s;/yyy/yyy3 /a/ 3~c/a/3^. 3j_ t/&_L u'3._/-//Ja/oL 3 _. _____ /A/S36TC. T/&A/.. y3/<C3 ... 33,^ /MC03/?o3A> T3jD '3 T33. _____ S?7<?/V7-//l 9^ ... Z^/?3^shr3&L ,,_ysj353/Tc: 7/C>sS._______ _____ ______ CCrJL^ Akjfi. ^SzTfTZ ______________ ______ _.__ Jy/y'//<?/>?c^y/r/?^ //aC &&-. 09 ______ ______ /F/c3.. 0?s^33L______________________ OCC 10023 UAL I: 1t/21/ ( 7 1^/1 4/ / 7 J1 /04/ t 8 J2/U9/ i 8 JJ/02/ /8 U4/03/ /8 DEE! < PARK PLASTICS VCM CL: I LING EXPOSURE JOB 3-4 DRYING 3-4 DRYING 3-4 DRYING 3-4 DRYING 3-4 DRYING 3-4 DRYING NAME J. VALENZUELA D. HERNANDEZ . II. MURPHY T. CASKEY R. MURPHY D. OERNANDEZ TI ME DESCRIPTION 15 OPEN. DRYER 15 oWITCHED B IN .j 15 ROUIINE DU LIES 320 BASHED DOWN L 5 ROUTINE dry. 15 SAMPLED,TOWER It3 'j' CN O rOH u o o VCM MA gK 0. 49 0. o3 0. 74 0.28 l. 53 0. 54 t DAi t: 11 /0B/ n 1 1 / 3l)/ i 7 J! /1 9/ ( ti J//09/ i ti JO/ I 5/ /B Jo / l 9/ f ti t DEER PARK P LAS'IT Co VCM TuA EXPOSURE JOB 3-4 DRYING 3-4 DRYING 3-4 DRYING 3-4 DRYING 3-4 DRYING 3-4 DRYiNO NAME R. MURPHY J. NARVAEZ I). t* I LIT AMS T. CASKEY J. VALENZUELA J. NARVAEZ - TIME 320 320 320 320 320 320 description NORMAL Op Eli. SAMPLE VCM SAMPLING & DRY. WASHED DOWN OPLli. uHYEU CAl'CH SAMPLc VCM 0. 00 0.02 0. J3 0.28 0. 99 0.26 "MASK I l