Document xjqmX5Rz7DGzKwXQZBweqX931

I UNION CARBIDE CORPORATION CHEMICALS AND PLASTICS fc \ V, < ' I v 1 . VAS / 7 5`JO December 14, 1976 Mr. Jim Tarr Texas Air Control Board Region VII Office 5555 West Loop, Suite 300 Bellaire, TX 77401 Dear Jim: SUBJECT: Leak Detection Program for Vinyl Resin Production Units, Texas City Plant In furtherance of our agreement to keep you informed of our reporting to EPA under the new VCM Regulation, attached is a copy of the Leak Detection Program report required within 45 days by subject regulation. If you have any questions, please call me. Very tr^j-ly yours, JFE/cew Atiacnment bcc: Mr. J. B. Leverton Mr. F. S. Provenzano j.', F, Erdmann, Coordinator ? Environmental Protection Dept. (713) 945-7411, Ext. 1126 UCC 060645 '-jy. I- SOUTH CHARLESTON PLANT ^^ ^Ji UNIOtf'c^^DE dO^POR^^N^^ CHEMICALS AND PLASTICS i* i>, nox noo-t, '.oiiim cn/vm i , 11 im, hi, v/v. to December 3, 1976 Mr. Abraham Ferdas Environmental Protection Agency Region III Curtis Building 2nd Floor 6th &'Walnut Streets Philadelphia, Pennsylvania 19106 Ref: Memo, J. L. Worstell to Abraham Ferdas, November 21, 1976 Dear Mr. Ferdas: In accordance with the recently promulgated emission standards for vinyl chloride, the attached description of the required leak detection and elimination program ( 61.65 (b) (8)) is submitted for approval by the Administrator. Very truly yours, fi J. L. Worstell Environmental Protection Coordinator JLW/pl Attachment UCC 060646 NATIONAL EMISSION STANDARD FOR VINL CHLORIDE 61.65 (b) (8) Leak Detection and Elimination Program * Union Carbide Corporation South Charleston, West Virginia Objectives 1. Prevent leaks by preventive maintenance and good work procedures. > 2. Discover and repair accidental leaks, i.e., leaks not controllable by preventive maintenance and good work procedures. 3. Keep adequate records to demonstrate to E.P.A. that Union Carbide Corporation is in compliance with the E.P.A. regulation. Program I. Prevent Leaks 1. All major equipment in vinyl chloride service is inspected by trained process safety inspectors on an annual basis. This inspection includes tests for metal loss, weld failure and structural integrity. Hydrostatic strength tests are made at regular intervals even in the absence of faults revealed by inspection. i 2. Faulty valves are removed, disassembled, work parts replaced, reassembled and leak tested prior to reinstalla tion. 3. Relief valves are inspected monthly. Relief valves are removed, cleaned, seats lapped, reset, tested for leaks and reinstalled on an annual basis. UCC 060647 Program (continued) Prevent Leaks (continued) 4. Relief valvds that have relieved are removed, cleaned, seats lapped, reset, tested for leaks and are reinstalled promptly. 5. Rupture discs are inspected regularly and are replaced at two-year intervals. 6. Disassembled pipe and equipment flanges are cleaned, regasketed with new gaskets and reassembled. 7. All pipelines in vinyl chloride service are inspected externally for evidence of corrosion failure on an annual basis, particularly in areas where the pipe is supported by hangers and structure and where flanged joints appear. This thorough inspection by skilled Process Safety Inspec tors is in addition to inspections by operating personnel. 8. Installed spare equipment such as pumps and compressors is provided so that leaking or poorly operating items can be removed from service promptly for repair. 9. Material in process inventories are managed so that vessels in vinyl chloride service can be removed from service and emptied promptly if leaks develope. 10. Equipment and pipelines are leak tested with inert gas after disassembly for cleaning and repair. 11. Operating personnel are trained in the hazards of vinyl chloride and in the methods and work procedures to minimize emissions. - 2- ucc 060648 * Program (continued) II. Discover and Repair Accidental Leaks A. Fixed vinyl chloride monitoring systems Union Carbide Corporation, after a thorough study of available monitoring systems, chose to build its own systems. The purchased systems generally did not meet internally developed selection standards for sensitivity, > precision, specificity, cost, maintenance and delivery time. The monitoring system in use is identified as a Union Carbide Corporation Model 1200 automatic chromatograph. The unit consists of a three-column chromatograph with a flame ionization detector requiring two minutes to analyze an air sample to a sensitivity of 0.05 ppm vinyl chloride. The system analyzes samples taken from 19 points and checks it calibration against a standard sample every forty minutes. Visible and/or audible alarms are auto matically actuated when the VCM concentration exceeds 5 ppm in any sample, when the calibration sample analysis fails to check, when sample flow is inadequate and when the unit is over ranged (>*25 ppm). Output data is collected and correlated by a computer and the results printed on an automatic typewriter. Three of these systems are used to monitor work space, leak and vent emission concentration at the South Charleston, West Virginia Plant. The automatic chromatograph system is routinely checked by the instrument mechanic daily (or more frequently) for - 3- UCC 060649 Program (continued) II. Discover and Repair Accidental Leaks (continued) A. Fixed vinyl Chloride monitoring system (continued) proper operation. Faulty parts are replaced promptly. Since the system checks itself each cycle, little or no manual testing is required to provide essentially 100% availability. These systems have been functioning since mid-1974. The output print from the automatic typewriter showing the individual analysis for each point, time and summary data are filed daily for the record along with appropriate information on point location, B. A "leak" defined in terms of the fixed monitor data is a significant departure from the average background vinyl chloride concentration in the plant. The average background concentration is less than 1 ppm and the standard deviation for the average is 2 ppm. Compensating for the skewed distribution curve requires the arbitrary use of a change of over four standard deviations to indicate a significant change, a leak is defined as two consecutive analysis of a single point showing 10 ppm or more vinyl chloride concen- ) tration. An analysis of 25 ppm or more requires emergency procedures. Leaks are also indicated by the sound of the emission, frosting at the leak point, visible gas emission and process controls. These other characteristics of a leak are obvious and presumably do not need formal definition. -4- UCC 060650 Program (continued) II. Discover and Repair Accidental Leaks (continued) C. Portable Lea*k Detector Two Century Organic Vapor Analyzers Model OVA98B are used for locating leak sources when leaks are indicated by the fixed monitor or area studies are made to check the integrity of operating, procedures and equipment. The % Century OVA analyzer has a sensitivity of approximately 1 ppm for organic vapors. Specificity, while desirable is not required since once the leak is located the source of the leak gives an indication of leak composition. The Century OVA operating procedure provides for routine tests of the battery and the indicator span and zero with each use. The Century OVA is tested with a standard air sample containing 100 ppm methane daily. Stable vinyl chloride air samples cannot be prepared and nitrogen vinyl chloride samples upset the instrument detec tor. Union Carbide Corporation, South Charleston Plant, utilizes a computerized preventive maintenance program (RM-1) to periodically recall a variety of electronic instruments, used for safety/environmental measurements, into the plant instrument shop for inspection, any necessary adjustments or repairs and calibration. The computerized program provides means for notification when inspections are due and for maintaining-individual his torical records related to accuracy, reliability, mainte- 5 ucc 060651 Program (continued) II. Discover and Repair Accidental Leaks (continued) C. Portable Leak Detector (continued) nance, etc. Portable hydrocarbon detectors (Century OVA's) used in the plant vinyl chloride leak detection/elimination program are on a three (3) month RM-1 schedule. In addition to the above program, weekly inspections .v of Century OVA's used in vinyl chloride leak detection/ elimination are conducted by trained instrument mechanics on duty in immediate areas where these instruments are stored and used. Thus, quick service is available in the event of a malfunctioning portable hydrocarbon detector. Weekly inspections include the following check list which is essentially the instrument start up procedure plus calibration. (This same procedure is the standard operating procedure in preparing the instrument for actual use.) STANDARD OPERATING PROCEDURE - CALIBRATION 1. Check instrument sampling pump by engaging pump switch. 2. Check indicator to assure that the battery is adequately charged. 3. * Turn instrument switch on and allow five (5) minute warm-up. 4. Check calibration with "low" and "high" calibration switch. 5. Check sample flow rate indicator (rotometer) to assure sample flow. -6- UCC 060652 Program (continued) II. Discover and Repair Accidental Leaks (continued) C. Portable Leak Detector (continued) 6. Check hydrogen tank pressure gauge (0-300 psi) to assure adequate supply. 1. Open hydrogen tank valve and the hydrogen supply valve. 8. Ignite the burner per instrument instructions. 9. Insert the portable hydrocarbon detector sample probe through the valve stem and into a 5-10 liter TEDLAR bag containing 100 ppmv methane in air to assure instrument response. (100 ppmv methane in air is prepared in cylinders per the procedure described in a previously submitted equivalency determination application.) D. Action Program for Accidental Leak Control 1. On indication of a leak or an alarm from the monitoring system, personnel are to put on respirators immediately or are to evacuate the area. 2. The source of the leak or the leak area will be announced over the public address system or the 1 radio telephone system by the foreman or his deputy. 3. The designated operator, protected by a respirator, will proceed immediately to the leak area for an audible-visible survey: 4. If the designated operator can locate the leak source, then he effects repair if possible or requests help from the foreman and takes the pipe- 7 UCC 060653 Program (continued) II. Discover and Repair Accidental Leaks (continued) D. Action Progr'am for Accidental Leak Control (continued) line or equipment item out of service, i.e., prepares it for opening. 5. The foreman, if required, provides assistance via other personnel or summons maintenance personnel and makes repairs. > 6. If the leak is not readily found by visible or audible means, the foreman sends the designated Century OVA operator to the area to survey the suspected area. 7. The Century OVA operator locates the leak and notifies the foreman who arranges for its repair. 8. On location and repair of the leak, the foreman or his deputy prepares a leak report noting the time of the leak, its location and its cause. He also describes the action taken to repair the leak and its current status. This report is signed by the foreman and filed daily as required by the regulation. 9. The manufacturing department head for the plant reviews leak reports regularly and takes further action if a * leak is repetitive or there is indication of an under lying problem. The department head also acts to ensure the availability of trained Century OVA operators and of trained repair personnel. 8 ucc * 060654 Program (continued) II. Discover and Repair Accidental Leaks (continued) E. Layout of Le'ak Monitoring System The vinyl chloride monitoring system at the South Charleston West Virginia Plant consists of three automatic chromatograph systems (See previous description) with a combined total of sample points of 57. accomplish three basic objectives. These are used to > (a) Monitor the work space atmosphere as required by the Occupational Safety and Health Standard. (b) Leak detection as required by the Environmental Protection Administration Standard for Vinyl Chloride [61.65 (b) (8)3- (c) Monitor vinyl chloride control equipment emissions as required by the EPA Vinyl Chloride Standard (|61.68 (aj. The location of the sample points was selected based upon Industrial Hygiene studies conducted by the plant and upon judgmental probability of emissions occurring at a specific location. Where vinyl chloride is frequently detected, or there is a high probability of VCM detection the sample point concentration is higher than areas where there is a low probability of a leak or an emission. The location of sample points is shown of Figures I and II which encompasses plant areas where vinyl chloride is transferred, stored or used. Figure I shows the unloading and storage /jcr 9 060655 Program (continued) II. Discover and Repair Accidental Leaks (continued) E. Layout of Loeik Monitoring System (continued) area. Figure II shows the resin manufacturing area. Shaded areas show the location of equipment in vinyl chloride service. A listing and description of the sample point loca tions is as follows*. Chromatograph No. 1 Sample No. Description 1 Outside south end of polymerization and stripping building (Building 153). 2 Inside south end of polymerization and stripping building (Building 153) . 3 Inside south center area of polymerization and stripping building (Building 153) . 4 Inside north center area of polymerization and stripping building (Building 153). 5 Outside north west corner of polymeriza tion and stripping building (Building 153). 6 Vent solvent scrubber area east of solvent recovery building (Building 154). 7 Inside north end of polymerization and stripping building (Building 153). 8 South end of polymerizer structure (Building 153). 9 South center area of polymerizer structure (Building 153). 10 UCC 060656 program (continued) II. Discover and Repair Accidental Leaks (continued) E. Layout of Leak Monitoring System (continued) Chromatograph No, 1 (continued) Sample No. Description 10 North center area of polymerizer structure (Building 153). 11 North end of polymerizer structure (Building 153). 12 Vinyl chloride unit storage tanks (south tank area Building 154). 13 Building 191 control room area. 14 Building 154 control room area. 15 Vinyl chloride metering and storage tank area (south tank area Building 154). 16 Dilute solvents storage tank area south of Building 153. 17 Lower level of stripping area, polymeriza- tion and stripping building (Building 153) 18 Upper level of stripping area polymeriza- tion and stripping building (Building 153) 19 South east corner structure, solvent recovery building (Building 154). 20 Calibration gas sample cylinder. Chromatograph No. 2 21 Resin slurry area, second level, resin processing building (Building 152) . 11 UCC 060657 ` <'4-- , Program (continued) U t Discover and Repair Accidental Leaks (continued) U. Layout of Leak Monitoring System (continued) Chromatograph No. 2 (continued) Sample No. Description 22 Supervisors offices, second level, resin processing building (Building 152). 23 Resin precipitation area, second level, resin processing building (Building 152). 24 Process control room, third level, resin processing building (Building 152) . 25 Resin precipitation area, third level, resin processing building (Building 152), 26 Resin slurry area, third level, resin processing building (Building 152). 27 Resin testing laboratory area, third level, resin processing building (Building 152). 28 Resin solution storage area, tanks south of polymerization and stripping building (Building 153). 29 Process control room, fourth level, resin processing building (Building 152). 30 Resin wet grinder area, fourth level, resin processing building (Building 152). 31 Stack sample vent incineration system (Building 151). - 12 - ucc 060658 * Program (continued) II. Discover and Kcpnir Accidental Leaks (eontLnued) V.. Layout of Leak Monitoring System (continued) Sample No, Description 32 North resin grinding area, fourth level. resin processing building (Building 152) 33 Center resin grinding area, fourth level resin processing building (Building 152) 34 Gel processing area, fourth level, resin processing building (Building 152) 35 Clarifier area, fifth level, resin pro- cessing building (Building 152). 36 No. 1 primary centrifugal area, fifth level, resin processing building (Building 152). 37 No. 1 secondary centrifugal area, fifth level, resin processing building (Building 152). 38 Batch precipitator area, fifth level. resin processing building (Building 152) 39 Batch precipitator area, fifth level, resin processing building (Building 152) 40 Calibration gas sample cylinder. Chromatograph No. 3 IN North fence of bulk storage area at west end of tank car unloading station. 13 UCC 060659 *' 'V Program (continued) II. Discover and Repair Accidental Leaks (continued) E. Layout of Leak Monitorinq System (continued) Chromatograph No. 3 (continued) Sample No. 2N South end of tank car unloading station in bulk storage area. , 3N North fence of bulk storage area at center of tank car unloading station. 4N Middle of tank car unloading station, bulk storage area. 5N North fence at east end of tank car unload ing station. 6N Pipe rack at south east end of tank car unloading station, bulk storage area. 7N Pipe rack at north west corner of tank No. 9030, bulk storage area. 8N Pipe rack at north east corner of tank No. 9020, bulk storage area. 9N Pipe rack at south east corner of tank No. 9020, bulk storage area. ION Pipe rack at south east corner of tank No. 9014, bulk storage area. 11N Pipe rack at south west corner of tank No. 9016 (VCM tank), bulk storage area. 12N Pipe rack at north-west corner df tank No. 9016 (VCM tank), bulk storage area. - 14 - ucc 060660 Program (continued) II. Discover and Repair Accidental Leaks (continued) E. Layout of Leak Monitoring System (continued) Chromatograph No. 3 (continued) Sample No. Description 13N Pipe rack at north east corner of tank No. 9016 (VCM tank), bulk storage area. 14N Pipe rack at south eat corner of tank No. 9016 (VCM tank), bulk storage area. 15N Pipe rack west of tank No. 9016 (VCM tank) refrigeration unit, bulk storage area. 16N Pipe rack east of tank No. 9016 (VCM tank) refrigeration unit, bulk storage area. 17N North side of tank No. 9016 (VCM tank) refrigeration unit, bulk storage area. 18N Underside of tank No. 9016 (VCM tank), bulk storage area. 19N Western portion of bulk storage area near tank No. 9997. 20N Calibration sample gas cylinder. NOTE: The foregoing layout and description of sample points was in effect December 1, 1976. Union Carbide Corporation will relocate these points for greater effectiveness as monitoring results indicate a need. 15 ucc 060661 Program (continued) II. Discover and Repair Accidental Leaks (continued) E. Layout of LeAk Monitoring System (continued) Major Plant Equipment in Vinyl Chloride Service 61.65 (2) Item Railway Tank Cars Tank Car Unloading Structure Volumetric Capacity 25 to 48,000 gallons NA Storage Sphere (No. 9016) 430,000 gallons No. 1 Polymerizer No. 2 Polymerizer 10,000 gallons 10,000 gallons No. 5 Polymerizer No. 6 Polymerizer Process Storage Tank (No. 2611) 10,000 gallons 10,000 gallons 8,200 gallons Process Storage Tank (No. 2613) Process Storage Tank (No. 2621) Process Storage Tank (No. 2623 Vent Recovery Tank (No. 2622) 8,200 gallons 4,200 gallons 4,200 gallons 4,200 gallons No. 2 Stripper Tank 2,000 gallons VCM Distillation Column NA 1 - 16 ucc 060662 060664 be: Mr 1. D. Epps Mr. C. E. Fry Mr. R- T. Kramer . Mr. W. C. Young Mr. R. N*. Wheeler Mr. H. L. Wise t ucc 060665 /> t SOUTH CHARLESTON l*LANT UNION CARBIDE CORPORATION CHEMICALS AND PLASTICS IVj, IlMX '.OtJIH CHAM } M< M, W VA. .**1* *0 > TO -> ^ WT66/tyJu/. +74-2*00#/ RECEIVED DEC 1 4 1976 J.EE. December 3, 1976 Hr. Abraham Ferdas Environmental Protection Agency Region III Curtis Building 2nd Floor 6th &'Walnut Streets Philadelphia, Pennsylvania 19106 te /A/fo - A* cJaaJu^, /faU'toXtlrd Ref: Memo, J. L. Worstell to Abraham Ferdas, November 21, 1976 Dear Mr. Ferdas: In accordance with the recently promulgated emission standards for vinyl chloride, the attached description of the required leak detection and elimination program ( 61.65 (b) (8)} is submitted for approval by the Administrator. Very truly yours, fi JV L. Worstell Environmental Protection Coordinator JLW/pl Attachment 1 1 1 4ij UCC 060666 NATIONAL EMXSSION STANDARD FOR VINYL CHLORIDE 61.65 (b) (8) Leak Detection and Elimination Program 'Union Carbide Corporation South Charleston, West Virginia Objectives 1. Prevent leaks by preventive maintenance and good work procedures. 2. Discover and repair accidental leaks, i.e., leaks not controllable by preventive maintenance and good work procedures. 3. Keep adequate records to demonstrate to E.P.A. that Union Carbide Corporation is in compliance with the E.P.A* regulation. Program I. Prevent Leaks 1. All major equipment in vinyl chloride service is inspected by trained process safety inspectors on an annual basis. This inspection includes tests for metal loss, weld failure and structural integrity. Hydrostatic strength tests are made at regular intervals even in the absence of faults revealed by inspection. 2. Faulty valves are removed, disassembled, work parts replaced, reassembled and leak tested prior to reinstalla tion. 3. Relief valves are inspected monthly. Relief valves are removed, cleaned, seats lapped, reset, tested for leaks and reinstalled on an annual basis. UCC 060667 Program (continued) I. Prevent Leaks (continued) 4. Relief valves that have relieved are removed, cleaned, seats lapped, reset, tested for leaks and are reinstalled promptly. 5. Rupture discs are inspected regularly and are replaced at two-year intervals. 6. Disassembled pipe and equipment flanges are cleaned, regasketed with new gaskets and reassembled. 7. All pipelines in vinyl chloride service are inspected externally for evidence of corrosion failure on an annual basis, particularly in areas where the pipe is supported by hangers and structure and where flanged joints appear. This thorough inspection by skilled Process Safety Inspec tors is in addition to inspections by operating personnel. 8. Installed spare equipment such as pumps and compressors is provided so that leaking or poorly operating items can be removed from service promptly for repair. 9. Material in process inventories are managed so that vessels in vinyl chloride service can be removed from service and emptied promptly if leaks develop^. 10. Equipment and pipelines are leak tested with inert gas after disassembly for cleaning and repair. 11. Operating personnel are trained in the hazards of vinyl chloride and in the methods and work procedures to minimize emissions. 2 ucc 060668 Program (continued) II. Discover and Repair Accidental Leaks A. Fixed vinyl fchloride monitoring systems Union Carbide Corporation, after a thorough study of available monitoring systems, chose to build its own systems. The purchased systems generally did not meet internally developed selection standards for sensitivity, precision, specificity, cost, maintenance and delivery time. The monitoring system in use is identified as a Union Carbide Corporation Model 1200 automatic chromatograph. The unit consists of a three-column chromatograph with a flame ionization detector requiring two minutes to analyze an air sample to a sensitivity of 0.05 ppm vinyl chloride. The system analyzes samples taken from 19 points and checks it calibration against a standard sample every forty minutes. Visible and/or audible alarms are auto matically actuated when the VCM concentration exceeds 5 ppm in any sample, when the calibration sample analysis fails to check, when sample flow is inadequate and when the unit is over ranged (> 25 ppm). Output data is collected and correlated by a computer and the results printed on an automatic typewriter. Three of these systems are used to monitor work space, leak and vent emission concentration at the South Charleston, West Virginia Plant. The automatic chromatograph system is routinely checked by the instrument mechanic daily (or more frequently) for 3 ucc 060669 Program (continued) II, Discover and Repair Accidental Leaks (continued) A. Fixed vinyl Chloride monitoring system (continued) proper operation. Faulty parts are replaced promptly. Since the system checks itself each cycle, little or no manual testing is required to provide essentially 100% availability. These systems have been functioning since mid-1974. The output print from the automatic typewriter showing the individual analysis for each point, time and summary data are filed daily for the record along with appropriate information on point location. B. A "leak" defined in terms of the fixed monitor data is a significant departure from the average background vinyl chloride concentration in the plant. The average background concentration is less than 1 ppm and the standard deviation for the average is 2 ppm. Compensating for the skewed distribution curve requires the arbitrary use of a change of over four standard deviations to indicate a significant change, a leak is defined as two consecutive analysis of a single point showing 10 ppm or more vinyl chloride concentration. An analysis of 25 ppm or more requires emergency procedures. Leaks are also indicated by the sound of the emission, frosting at the leak point, visible gas emission and process controls. These other characteristics of a leak are obvious and presumably do not need formal definition. 4 ucc 060670 Program (continued) II. Discover and Repair Accidental Leaks (continued) C. Portable Lealc Detector Two Century Organic Vapor Analyzers Model OVA98B are used for locating leak sources when leaks are indicated by the fixed monitor or area studies are made to check the integrity of operating, procedures and equipment. The Century OVA analyzer has a sensitivity of approximately 1 ppm for organic vapors. Specificity, while desirable is not required since once the leak is located the source of the leak gives an indication of leak composition. The Century OVA operating procedure provides for routine tests of the battery and the indicator span and zero with each use. The Century OVA is tested with a standard air sample containing 100 ppm inethane daily. Stable vinyl chloride air samples cannot be prepared and nitrogen vinyl chloride samples upset the instrument detec tor. Union Carbide Corporation, South Charleston Plant, utilizes a computerized preventive maintenance program (RM-1) to periodically recall a variety of electronic instruments, used for safety/environmental measurements, into the plant instrument shop for inspection, any necessary adjustments or repairs and calibration. The computerized program provides means for notification when inspections are due and for maintaining individual his torical records related to accuracy, reliability, mainte- 5 UCC 060671 Program (continued) II. Discover and Repair Accidental Leaks (continued) C- Portable Leak Detector (continued) nance, etc. Portable hydrocarbon detectors (Century OVA's) used in the plant vinyl chloride leak detection/elimination program are on a three (3) month RM-1 schedule. In addition to the above program, weekly inspections of Century OVA's used in vinyl chloride leak detection/ elimination are conducted by trained instrument mechanics on duty in immediate areas where these instruments are stored and used. Thus, quick service is available in the event of a malfunctioning portable hydrocarbon detector. Weekly inspections include the following check list which is essentially the instrument start up procedure plus calibration. (This same procedure is the standard operating procedure in preparing the instrument for actual use.) STANDARD OPERATING PROCEDURE - CALIBRATION 1. Check instrument sampling pump by engaging pump switch. 2. Check indicator to assure that the battery is adequately charged. 3. 1 Turn instrument switch on and allow five (5) minute warm-up. 4. Check calibration with "low" and "high" calibration switch. 5. Check sample flow rate indicator (rotometer) to assure sample flow. 6 ucc 060672 Program (continued) II. Discover and Repair Accidental Leaks (continued) C. Portable Leak Detector (continued) 6. Check hydrogen tank pressure gauge (0-300 psi) to assure adequate supply. 7. Open hydrogen tank valve and the hydrogen supply valve. 8. Ignite the burner per instrument instructions. 9. Insert the portable hydrocarbon detector sample probe through the valve stem and into a 5-10 liter TEDLAR bag containing 100 ppmv methane in air to assure instrument response. (100 ppmv methane in air is prepared in cylinders per the procedure described in a previously submitted equivalency determination application.) D. Action Program for Accidental Leak Control 1. On indication of a leak or an alarm from the monitoring system, personnel are to put on respirators immediately or are to evacuate the area. 2. The source of the leak or the leak area will be announced over the public address system or the 1 radio telephone system by the foreman or his deputy. 3. The designated operator, protected by a respirator, will proceed immediately to the leak area for an audible-visible survey: 4. if the designated operator can locate the leak source, then he effects repair if possible or requests help from the foreman and takes the pipe- 7 ucc 060673 Program (continued) II. Discover and Repair Accidental Leaks (continued) D. Action Progr'am for Accidental Leak Control (continued) line or equipment item out of service, i.e., prepares it for opening. 5. The foreman, if required, provides assistance via other personnel or summons maintenance personnel and makes repairs. 6. If the leak is not readily found by visible or audible means, the foreman sends the designated Century OVA operator to the area to survey the suspected area. 7. The Century OVA operator locates the leak and notifies the foreman who arranges for its repair. 8. On location and repair of the leak, the foreman or his deputy prepares a leak report noting the time of the leak, its location and its cause. He also describes the action taken to repair the leak and its current status. This report is signed by the foreman and filed daily as required by the regulation. 9. The manufacturing department head for the plant reviews leak reports regularly and takes further action if a ` leak is repetitive or there is indication of an under lying problem. The department head also acts to ensure the availability of trained Century OVA operators and of trained repair personnel. 8 UCC 060674 Program (continued) II. Discover and Repair Accidental Leaks (continued) E. Layout of Le'ak Monitoring System The vinyl chloride monitoring system at the South Charleston West Virginia Plant consists of three automatic chromatograph systems (See previous description) with a combined total of sample points of 57. These are used to accomplish three basic objectives. (a) Monitor the work space atmosphere as required by the Occupational Safety and Health Standard. (b) Leak detection as required by the Environmental Protection Administration Standard for Vinyl Chloride {j*61.65 (b) (S)H- (c) Monitor vinyl chloride control equipment emissions as required by the EPA Vinyl Chloride Standard {61.68 (a)]. The location of the sample points was selected based upon Industrial Hygiene studies conducted by the plant and upon judgmental probability of emissions occurring at a specific location. Where vinyl chloride is frequently detected, or there is a high probability of VCM detection the sample point concentration is higher than areas where there is a low probability of a leak or an emission. The location of sample points is shown of Figures I and II which encompasses plant areas where vinyl chloride is transferred, stored or used. Figure I shows the unloading and storage 9 ucc 060675 Program (continued) II. Discover and Repair Accidental Leaks (continued) E. Layout of Leak Monitoring System (continued) area. Figure II shows the resin manufacturing area. Shaded areas show the location of equipment in vinyl chloride service. A listing and description of the sample point loca tions is as follows: Chromatograph No. 1 Sample No. Description 1 Outside south end of polymerization and stripping building (Building 153). 2 Inside south end of polymerization and stripping building (Building 153). 3 Inside south center area of polymerization and stripping building (Building 153) . 4 Inside north center area of polymerization and stripping building (Building 153) . 5 Outside north west corner of polymeriza tion and stripping building (Building 153). 6 Vent solvent scrubber area east of solvent recovery building (Building 154). 7 Inside north end of polymerization and stripping building (Building 153). 8 South end of polymerizer structure (Building 153). 9 South center area of polymerizer structure (Building 153). 10 UCC 060676 Program (continued) II. Discover and Repair Accidental Leaks (continued) E. Layout of Le*ak Monitoring System (continued) Chromatograph No. 1 (continued) Sample No. Description 10 North center area of polymerizer structure (Building 153). % 11 North end of polymerizer structure (Building 153) . 12 Vinyl chloride unit storage tanks (south tank area Building 154). 13 Building 191 control room area. 14 Building 154 control room area. 15 Vinyl chloride metering and storage tank area (south tank area Building 154). 16 Dilute solvents storage tank area south of Building 153. 17 Lower level of stripping area, polymeriza tion and stripping building (Building 153) 18 Upper level of stripping area polymeriza tion and stripping building (Building 153) 19 South east corner structure, solvent recovery building (Building 154). 20 Calibration gas sample cylinder. Chromatograph No. 2 21 Resin slurry area, second level, resin processing building (Building 152). 11 ucc 060677 Program (continued) II. Discover and Repair Accidental Leaks (continued) E. Layout of Letik Monitoring System (continued) Chromatograph Mo. 2 (continued) Sample No. Description 22 Supervisors offices, second level, resin processing building (Building 152). 23 Resin precipitation area, second level, resin processing building (Building 152) 24 Process control room, third level, resin processing building (Building 152) 25 Resin precipitation area, third level, resin processing building (Building 152) 26 Resin slurry area, third level, resin processing building (Building 152). 27 Resin testing laboratory area, third level, resin processing building (Building 152) . 28 Resin solution storage area, tanks south of polymerization and stripping building (Building 153) . 29 Process control room, fourth level, resin processing building (Building 152) 30 Resin wet grinder area, fourth level, resin processing building (Building 152) 31 Stack sample vent incineration system (Building 151). 12 UCC 060678 Program (continued) II. Discover and Repair Accidental Leaks (continued) i;. Layout of I .oak Monitoring System (continued) Chromatograph No. 2 (continued) Sample No. Description 32 North resin grinding area, fourth level, resin processing building (Building 152) 33 Center resin grinding area, fourth level resin processing building (Building 152) 34 Gel processing area, fourth level, resin processing building (Building 152) 35 Clarifier area, fifth level, resin pro cessing building (Building 152). 36 No. 1 primary centrifugal area, fifth level, resin processing building (Building 152). 37 No. 1 secondary centrifugal area, fifth level, resin processing building (Building 152). 38 Batch precipitator area, fifth level, resin processing building (Building 152) 39 Batch precipitator area, fifth level, resin processing building (Building 152) 40 Calibration gas sample cylinder. Chromatograph No. 3 IN North fence of bulk storage area at west end of tank car unloading station. 13 ucc 060619 Program (continued) II. Discover and Repair Accidental Leaks (continued) E. Layout of Leak Monitoring System (continued) Chromatograph No. 3 (continued) Sample No. Description 2N South end of tank car unloading station in bulk storage area. , 3N North fence of bulk storage area at center of tank car unloading station. 4N Middle of tank car unloading station, bulk storage area. 5N North fence at east end of tank car unload ing station. 6N Pipe rack at south east end of tank car unloading station, bulk storage area. 7N Pipe rack at north west corner of tank No. 9030, bulk storage area. 8N Pipe rack at north east corner of tank No. 9020, bulk storage area. 9N Pipe rack at south east corner of tank No. 9020, bulk storage area. ION Pipe rack at south east corner of tank No. 9014, bulk storage area. UN Pipe rack at south west corner of tank No. 9016 (VCM tank), bulk storage area. 12N Pipe rack at north west corner of tank No. 9016 (VCM tank), bulk storage area. 14 ucc 060680 Program (continued) II. Discover and Repair Accidental Leaks (continued) E. Layout of Leak Monitoring System (continued) Chromatograph No. 3 (continued) Sample No. Description 13N Pipe rack at north east corner of tank No. 9016 (VCM tank), bulk storage area. 14N Pipe rack at south east corner of tank No. 9016 (VCM tank), bulk storage area. 15N Pipe rack west of tank No. 9016 (VCM tank) refrigeration unit, bulk storage area 16N Pipe rack east of tank No. 9016 (VCM tank) refrigeration unit, bulk storage area. 17N North side of tank No. 9016 (VCM tank) refrigeration unit, bulk storage area. 18N Underside of tank No. 9016 (VCM tank) , bulk storage area. 19N Western portion of bulk storage area near tank No. 9997. 20N Calibration sample gas cylinder. NOTE: The foregoing layout and description of sample points was in effect December 1, 1976. Union Carbide Corporation will relocate these points for greater effectiveness as monitoring results indicate a need. 15 UCC 060681 Program (continued) II. Discover and Repair Accidental Leaks (continued) E. Layout of Lehk Monitoring System (continued) Major Plant Equipment in Vinyl Chloride Service 61. Item Railway Tank Cars Volumetric Capacity 25 to 48,000 gallons Tank Car Unloading Structure NA Storage Sphere (No. 9016) 430,000 gallons No. 1 Polymerizer No. 2 Polymerizer 10,000 gallons 10,000 gallons No. 5 Polymerizer 10,000 gallons No. 6 Polymerizer 10,000 gallons Process Storage Tank (No. 2611) 8,200 gallons Process Storage Tank (No. 2613) 8,200 gallons Process Storage Tank (No. 2621) 4,200 gallons Process Storage Tank (No. 2623 4,200 gallons Vent Recovery Tank (No. 2622) 4,200 gallons No. 2 Stripper Tank 2,000 gallons VCM Distillation Column NA ucc 060682 ? Oto op o # 060684 0" ?CEO 5i; ' rNCH 91) & atr) : |C+r/ "j *7? 5 :-!Cf9 0* 1 * l* ** t IC . V j ; J_____ 1 0.6/ oe orS - : @f 96 0 3 2603 2709 ENGINEERING DEPARTMENT UNION CARBIDE CORPORATION jo* siw$t* jsit ifmok. IQHt C* i 2693 i T1 ^\ ~I ~ `J2661 *M 2709 i- 'I ! it; FIGURE II SOLVENT VINYL RESIN PLANT SOUTH CHARLESTON, W.VA. ii s X - -IT N rt ,s.-**?|a ____ ) *f i..rc c- c. *:. - i W.C.Y. { 4 be: Mr. T. D. Epps Mr. C. E. Fry Mr. R. T. Kramer , Mr. W. C. Young Mr. R. N*. Wheeler Mr. H. L. Wise i ucc 060685  /fldzs J? *. y . 4&U ^ .PxJ Atf/4^ /3&>fd / *A*~ds*yJ I I Jy 7%k/lj di $%*$/**" ! ucc 060686 J. T, Bouchier D. E. Deese J. F, Erdmann N. A. Gimber F. L. Keller T. L. Rapp File ucc 06068"? Te-i-epjione Conversation - Vinyl Chloride Abe E'erdas (EPA Recjion Til) to J. LJy Worstcll, 5/13/77 received 1) Good nows. returmneodd from Washinqgton, D.-Cc.- MMAAYY 22 31977 with decisiowg'on oquiva 1 oncios fo>'N514. 2) Abe says that everyth intj "Tooklr'qood,, . Wc will get the ' J* E. equivalencies, with some "qualifications". No details on the "qualifications", because Abe wants to review the info before forwarding it on to us. I hope that his definition of "looks good" is the same as ours! 3) Should get the info in about a week. 4) Apparently Abe is going to simplify some of the "qualificafcicns", e.q., he felt that some of the requests for additional data for the Method 106 equivalency were not really needed, and he was probably going to delete some of the requirements for extra data (! ! 1 j . 5) I explained that the equivalency for a standard check gas for the chromatographic monitoring systems was more important than appeared at first glance. Strict adherence to the EPA method for standard check gas would create a very awkward problem for ur. Abe pointed out that several changes had been made in this regard, and perhaps these changes would solve our problem. 6) n appears that wr should "sit tight" regarding the four equivalency i since.. 1 r, a week or so wo may |:ind that wc are in qo"'d shape, and perhaps many, if not. most, of our concerns will mil by the wayside. 7) T.onk Detection and Elimination: Abe said ho would review and approve this in aTont 6" tiEmths when he comes to 514 for a field inspection. He commented that, ho could see no problems: ours were aaong the best that lie had seen. d. L. WorsteJLl V16/7 7 W. T. GRAY, Jr. ucc 060688