Document wrKNxZ4pEKgQdB4Bz92nzQEkQ

1 August 1, 1978 Mr. Rric Cohan Chief, Air Compliance Section Region V, U.8. HA 230 South Dearborn 8t. Chicago, Illinois 60604 .n Dear Mr. Cohen 1 The General Tire and Rubber Co^any, in compliance vltb the National alssion Standard for Vinyl Chloride, Section 61.65# is reporting an aaergency relief valve discharge. On July 28, 1978 at 10:00 a.m., the rupture disc blew and the relief valve opened on Reactor 301. The cause was poor temperature control due to a polymer buildup on the temperature probe and operator failure to realize the rupture disc was ready to blow while there was still tine to take corrective action. The estimated loss of vinyl chloride to the atmosphere was 2,77*+ pounds. This loss was estimated by measuring the amount of vinyl chloride recovered in the gasholder, the change in level in the Reactor, and the conversion of the batch at the time the relief valve opened: . a. Vinyl chloride charged to the reactor 10,500 lbs. b. Rlyvinyl chloride formed at the time the relief valve opened (2.25 brs. x 8900 lbs./batch) (8 hrs./batch ) 2,503 lbB. c. Bounds vinyl chloride in reactor when relief valve opened (lbs. charged - lbs. reacted) 7,997 lbs. d. Change in level in the reactor as a result of relief valve discharge and venting to gasholder 50^ e. Bounds vinyl chloride vented to gasholder and atmosphere (0.50 x 7997 lb.) 3,998 lbs. GENC 004237 -2- f. Rwwds vinyl chlorite vented to p>holder (6600 ft.3 X 0.1855 lb./ft,- 1.224 lbs. g. Pounds Vinyl chloride lost to ataosptoere (3996 lb. - 3224 lb.) 2,774 lbs. A polyaer operator u attempting to add a chealaal terlstcp to the reactor when the relief valve opened. Bnedlatclr after the relief valve opened the reactor wi vented to the gselwl^er la on tffbrt to redace the ealasloa of vinyl chloride. the polyaer operator* Involved have been re-instfaetod as ta the asst probable causes of relief valve discharges, how to recognise conditions leading to these discharges* sd what corrective action anst be taken to avoid than. Very truly yours. ,v\*l at G. X. Broabeagh Technical Superintendent GXB:sa cc: A. S. Jeffrey X. V. Laundrle GENC 004238 1 i December 27 > 1977 Mr. George Hurt Chief, Air Compliance Section Region V, U.S. EPA 230 South Dearborn Bfc. Chicago, Illinois 6060U Dear Mr. Hurt, Attached is a copy of our procedure for unloading vinyl chloride f.nnV cars and our calculations for vinyl chloride emitted to the atmosphere from the opening of the unloading lines. The calcula tions are based on opening to the atmosphere five (5) feet of two (2) inch Schedule 40 pipe that has been vented to the gasholder to less than one (l) pound pressure. This procedure emits less than the .14 cubic feet of vinyl chloride vapors at standard conditions. He have assumed the temperature of the vinyl chloride to be at 32* F while in ast cases the temperature would be closer to 70 F. This completes the requirements for Waiver Number 17 to furnish the procedure and calculations for unloading lines. Yours very truly. G. E. Brumbaugh Technical Superintendent GEB:sm attach, cc: R. W. Laundrie A. D. Jeffrey GENC 004239