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