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ATTACHMENT 5 INDUSTRIES PPG INDUSTRIES. INC. CHEMICAL DIVISION U.S. P. 0. BOX 1000 LAKE CHARLES. LA. 70602 August 30, 1982 Mr. Dick Whittington Administrator U.S. EPA, Region VI 1201 Elm Street Dallas, Texas 75270 Dear Mr. Whittington: In compliance with the provisions of 61.65(a) of the NESHAP vinyl chloride regulations, enclosed are two reports of safety relief valve discharges which occurred on August 24, 1982. Sincerely, PPG INDUSTRIES, INC. PST/cp CC : Mr. Gus Von Bodungen Mr. Joe Withers bcc: R. P. Byars/J. A. Hart B. D. Reynolds CF. Cn . Dehri/R.n _ i___ ftt% J* . Samel______ i son W. J. Peard/J. E. Wyche E. J. Tullier File 11103.1.02 Philip S. Trew Environmental Control Specialist RECEIVED "iv i 71985 LAW DEPARTMENT SL 068498 RELIEF VALVE DISCHARGE REPORT VCM PLANT (Send completed form to Coordinator Environmental Systems within 5 days of discharge.) 1. Date of Discharge: August 24, 1982___ 2. Time of Discharge: 11:00 A.M, to It: 30 A.M. 3. Source: SRV #46-2459. Location #90-259 -- Certain-Tenri Tank Fill I inp (Name of Vessel and SRV Number) 4. Nature and Cause of Discharge: This SRV release was due to the Certain-Teed Tank Fill Line being blocked-in without the pressure equalization ling hping_____ in service. 5. Approximate Quantity of VCM Discharged: 303 lbs.__________________________ 6. Method of Calculation of Line (5): See Attachment_____________________________ 7. Action Taken to Prevent This Discharge: When the release wat riicrnvpror) at 11:30 A.M. the alternate SRV was placed into service. 8. Measures Adopted to Prevent Future Discharges:^ Five measures have been adopted to insure against the reoccurrence of this SRV from discharging 1) On 8/24/82. the VCM-il Storage /Transfer Operator rwni^ ^ri+tan instructions to leave all equalizing lines open. 2) On 8/24/82, a tag was Placed on the equaliratinn lin* stating that thp lino must remain open. O / M / O^ _________________ ml SL 068499 i 4) On 8/25/82, the SOP was revised to state that equalization lines must remain open. 5) By 9/3/82, a sign will be posted in the vicinity of the equalization line reminding the operators to leave the equalization lines open. SRV Release Of 8/24/82 at 11:00 A.M. Method Of Calculation 1. Estimate of pounds of vinyl released 1. 30 feet of 10" pipe 1/3 full of vinyl 2. 36 feet of 2" pipe full of vinyl 3. Total Volume: A) -JtLD12 = TC (30) (.833) 2 = 16. 36 ft3 4o5f 6the 10" pipe 44 1/3 of the 10" pipe filled so V = (0. 252315) ( 16.36) = 4. 13 ft3 B) 7T LD2 = 7T(36){0. 172) 2 = 0.8365 ft3 44 C) Total Volume of VCM released = 4.97 ft3 4. Assume VCM liquid at 4F and atmospheric pressure 5. Density = 8.1584 lb/gal- . .. 6. lbs. released = (4.97 ftJ)(7. 48052 ) {8. 1 584 ) = 303 lbs. SL 068500 RELIEF VALVE DISCHARGE REPORT VCM PLANT (Send completed Form to Coordinator Environmental Systems within 5 days of discharge.) 1. Date of Discharge:______ August 24, 1982 2. Time of Discharge:5:15 P.M. 3. Source: SRV #46-2464, Location 90-260 -- Certain-Teed Tank Fill Line (Name of Vessel and SRV Number) 4. Nature and Cause of Discharge: This SRV release was due to the rupture disc having a pin hole leak and the SRV leaking. The transfer line was operating at only 110-120 psi with the RD/SRV rated for 275 Dsi. 5. Approximate Quantity of VCM Discharged: 51 lbs._________________________ 6. Method of Calculation of Line (5): See Attachment___________________________ 7. Action Taken to Prevent This Discharge: Maintenance personnel immediately changed out the rupture disc between the transfer lioe and the SRV.. which stopped the release. _______________________________________________8 8. Measures Adopted to Prevent Future Discharges: The SRV was removed______ from service and tested with no noticeable problems observed.--The.SRV. qualified test mechanic assumes that the SRV seat had been fouled which prevented the SRV from seating properly. --------- SL 068501 SRV Release of 8/24/82 at 5:15 P.M. Method Of Calculation 1. 36 feet of 2" pipe full of liquid vinyl 2. Total Volume = 0.8360 ft^ V = -TT LD2 = -fC (36) (0.172)2 = 0.8360 ft3 44 3. Assume VCM at 4F and atmospheric pressure 4. Density = 8. 1584 Ib/gal 5. lb. VCM = = (0.8364 ft3) (7.48052 gal/ft3) (8. 1584 Ib/gal) = 51 lb. SL 068502