Document zRBvEDQvy2JbDo65B43aLV2z

PURPOSE: To establish a written plan to ensure the safety of our employees from any hazards arising from the production, storage, and shipment of Vinyl Chloride Monomer l VCM) SCOPE: 'Hus plan applies to the VCM [1. fn-II, VCM Tank Car Loading Rack, and VCM Ship Loading ('A1 Dock) RESPONSIBILITIES: The responsibilities for compliance are as follows, 1) VCM-II -- Area Supervisor' mTn-II ~Area Supervisor ill) VCM Tank Car Loading Rack -- Area Foreman Derivatives Shipping iv) 'A' Dock - Aiea Foreman-Docks Shipping Hie iesponsibiiity tor ensuring that this plan is reviewed every 0 months belongs to Derivatives' Safety Supervisor CON fROLS: ENGINEERING CONTROLS DOUBLE SEALS OR SEALLESS EQUIPMENT All Equipment (pumps, agitators, compressors) in Vinyl Chionde service' have double seals or are sealless (sealless equipment have magnetic drives) FLXED POINT MONITORING SYSTEM Tn-(I, VCM-II, and the Vinyl Shipping rack have fixed point morutonng systems that continually check the atmosphere for high concentrations of Vmvl Chionde Ihese systems alarm when they detect eurueiitraUons of? ppm or gieater ;n the air The computei is set up to benchmark its calibration three limes a day (all three in die morning), and it it has gicater than 5% deviation (plus or minus) the analyzer group is called to calibrate the machine Each unit has SOPs for the follow-up investigation to an alarm. Tn-11 6904-00-2001 VCM-II 5t>frljS)09SOP S-o)- a VCM Tank Car Loading Rack1 I l0.T00-2009.00 VCM Ship Loading ('A1 Dock) 1164-00-2002,00 SRV DISCHARGES TO PROCESS Where possible SRVs on streams or equipment in Vinyl Chionde service* relieve back to the system. RUPTURE DISKS All Vinyl Chionde service* SRVs that relieve to the atmosphere have Rupture Dusks underneath to prevent fugitive VC emissions Ope.utoi make a SRV rupture disk round at least quarterly to determine which rupture disks, if any, are blown, and make all possible attempts to repair those that are INCINERATOR STACK MONITORING The Incinerator stacks are equipped with a continuous monitoring system to verify that all Vinyl Chionde entering the incinerator is burned completely 10 ppm exhaust) There are unit and Derivatives-wide SOPs [Greenback SOP til ?) that outline what the response should be to Vinyl Chionde incineration bypasses * Vmvl Chionde service is defined as equipment used on process streams with a VCM concentration of -> 10% SL 088667 VALVE STANDARDS PPG has valve specifications that prevent the use of gate valves m Vinyl Chloride service* "TuxV CLOSED LOOP SAMPLING All samples of streams in Vinyl Chloride service' are collected by operators ui closed-loop sample systems, with nitrogen he-ms provided to purge sample connections before removing the sample cod CLOSED DOME LOADING Ail VCM tank cars and water vessels are loaded in a closed-dome system with all vents incinerated Nitrogen and vent header tie-ms are provided to purge loading hoses to the incinerator before disconnecting j4- WORK PRAC11CE CONTROLS VCM EQUIPMENT CLEARING Each unit has its own SOPs outlining the proper way to clear equipment or pipelines in Vinyl Chlonde service* Shipping also has an SOP for cleanng VCM tank cars for maintenance Tn-11 6004-00-7002 VCM-II 5601-0)12 (60 VCM Tank Car Loaning Rack 1163-00-7001 00 VCM Ship Loading 1,'A' Dock) 1 lo4-00-2001 00 SAMPLING VINYL CHLORIDE STREAMS Each unit that samples Vinyl Chlonde has SOPs explaining the proper way to collect samples using the closed-loop system vcm-ii ssewetrsn? VCM Tank Car Loading Rack 103-00-2007 00 LOADING'RANK CARS The Shipping department has SOPs for loading VCM tank cars properly, including monitoring tank car fittings for leaks VCM Tank Car Loading Rack 1103-00-2001 00 VCM Ship Loading ('A1 Dock) 1164-00-2000 00 YEARLY VALVE MONITORING Once per year VCM-II and Tn-II must check 200 random valves in Vinyl Chlonde service* Hus is usually done by an operator with an HNU meter that was calibrated the day of the inspection. The operator logs the VC concentration nght at the valve Regulations define a leak as a concentration oi 10,000 ppm or nioic at die valve PPG has defined a leak as 1 500 ppm or more nght at the valve An immediate attempt to ri\ us made on those valves that aie proven to be leaking, if the valve is unable to be repaired while in service, it is to be changed at the next available tune HNU ROUNDS A weekly round is conducted with the HNU meter of all equipment in Vinyl Chlonde service* The logsheet provides a place to log the leakage and comments ' \myl Chlonde service is defined as equipment used on process streams that have a VCM concentration of - 10% 83668 DOUBLE VALVE/PLUG RT.F.PDS Ail bleed valves in Vinyl Chloride service'* must be plugged or valved past the first valve. Both lire first and second valve must be closed if the bleed is double valved If it is not double valved it must have a closed valve on the process and a plug/cap at the end A weekly round is made through file VC unit at TE-1I to determine which bleeds need plugs or valves and immediate action is taken accordingly SRV/Rl; PTURED1SK INSPECTION S A round is conducted through the units be 'he operators!at least quarterly) to determine and log the status ot tlie rupture disks ibiown1'). gauge' operable'"';, and file bleed (double blocked',') EQUIPMENT INSPECTIONS Operators uispect equipment and piping externally on a quarterly basis and document any problems Hie PPG inspection group also makes external and internal inspections periodically and documents problems PERSONAL PROTECTIVE EQUIPMENT - RESPIRATORY Safety procedures specify that self-contained breathing eqtupment must be worn when responding to leaks ot unknown concentrations ot VC M When VCM concentrations are shown to be less that 10 ppm by fixed point monitors, or portable meters, use of an approved organic cartridge half-mask respirator is permitted Both the Supervisor and file wearer have the responsibility to ensure that the correct protection is selected and used properly Safety procedure ft 12 - Respiratory Protection Program -- provides general information on the use of respiratory' protection and the operation of the program and is reviewed annually Contents include responsibilities, medical review and approval, training, fit testing, selection, cleaning, inspection, and storage Mao included is a list of PPG IPELs and NIOSH IDLHs ANNUAL VC TRAINING Training is conducted annually by qualified instructors The training is documented and kept in the PPG Training department Training inciud.es die hazards associated with vinyl, first aid, handling, physical and chemical pioperties, acute and Gironic signs and symptoms, and a review of the additional information nr tire MSDS VINYL CHLORIDE MONITOR ING_PR OCR AM The purpose of the PPG Lake Charles Vinyl Chloride monitoring program is to evaluate potential employee exposures to vinyl chlonde and assess the need for engineering, administrative anchor personal protective equipment controls The annual Industrial Hygiene Monitoring strategy contains file sampling frequencies established for each job class potentially exposed to vinyl chlonde These frequencies are based upon a statistical analysis of past monitoring results and all samples are randomly acquired from different shifts on different days over the time period of interest. Investigative samples are obtained on an as needed basis. In the event that any sample taken shows an exposure level in excess of the 1PEL of 1,0 ppm, a second, follow-up sample is collected within 7 working days of receipt of the analysis If the second sample verities an exposure problem or potential problem, the Area Supervisor is notified that corrective actions are necessary If any sample taken shows an exposiue level m excess of the Action level but below the IPEL, a second follow-up sample is collected within 3 months from receipt of the analysis. Additional monitoring is also conducted whenever there has been a production, process or control change resulting m the possibility of employees be exposed above file action :evel * * Vinyl chloride service is defined as equipment used on process streams that have a VCM cone ..nation of 10% SIj 088669 To- Allen Pride From: Steve Hellen Date: 5/5/93 Subject: VCM Safety Compliance Procedure A meeting was held on 4/5/93 to discuss the existence of a wntten VCM Safety Compliance Program, In attendance were John Cobb, Bobby Chiasson, Don Pearson, and myself It was a general consensus that our program to ensure the safety of those who work around Vinyl Chlonde was not wntten down in a centralized location, but incorporates items from various sources. Enclosed, please find a list and bnef explanation of what we feel is Operations' and Plant 'B' Technical's contnbution to this program. If you have any questions, call me at 4742 cc. Dick Holliday Clark Graybill Don Pearson John Cobb Mike Guidry SL 088670 ENGINEERING CONTROLS DOUBLE SEALS OR SF.AT.T.F.S.S F.OI nPMENT AH Equipment (pumps, agitators, compressors) m VCM service* have double seals or are sealless (sealless equipment have magnetic drives). FIXED POINT MONITORING SYSTEM TE-I1, VCM-II, and the Vinyl Stripping rack have fixed point monitoring systems that continually check the atmosphere for high concentrations of Vinyl Chlonde. These systems alarm when they detect concentrations of 5 ppm or greater in the air. The computer is set up to benchmark its calibration three times a day (all three in the morning), and if it has greater than 5% deviation (plus or minus) the analyzer group is called to calibrate the machine. Each unit has SOPs for the follow-up investigation to an alarm, SRV DISCHARGES TO PROCESS Where possible SRVs on streams or equipment in VC service* relieve back to the system. RUPTURE DISKS We make a SR V rupture disk round atleast quarterly to determine which rupture disks, if any, are blown, and make all possible attempts to repair those that are. INCINERATOR STACK MONITORING The Incinerator stacks are continuously monitored to verify that all Vinyl Chlonde entering the incinerator is burned completely (--10 ppm exhaust) There are unit and Denvatives-wide SOPs that outline what the response should be to Vmyl Chlonde incineration bypasses. VALVE STANDARDS PPG has valve specs that limit die types of valves allowed in Vinyl Chloride service*. l_.iT/Y-7VtM_ v-Art-'Jtr that Art-t. , CLOSED LOOP SAMPLING All samples of streams in Vinyl Chlonde service* are collected in closed-loop sample systems, with nitrogen he-ins provided to purge sample connections before removing the sample coil. CLOSED DOME LOADING All VCM tank cars and water vessels are loaded in a closed-dome system with all vents incinerated. Nitrogen and vent header tie-ins are provided to purge loading hoses to the incinerator before disconnecting. WORK PRACTICE CONTROLS VCM EQUIPMENT CLEARING Each unit has its own SOPs ouduung the proper way to clear equipment or pipelines in Vinyl Chloride service* Shipping also has an SOP for clearing VCM tank cars for maintenance. SAMPLING VINYL CHLORIDE STREAMS Each unit that samples Vmyl Chlonde has SOPs explaining the proper way to collect samples using the closed-loop system. * Vinyl Chloride service is defined as equipment used on process streams with a VCM concentration of >10% SL 0886?i LOADING TANK. CARS The Shipping department has SOPs for loading VCM tank cars properly, including momtonng'tank car fittings for leaks. YEARLY VALVE MONITOR IMP, Once per year VCM-1I and Tri-II must check 200 random valves in Vinyl Chloride service* This is usually done by an operator with an HNU meter that was calibrated the day of the inspection Tile operator logs the VC concentration nght at the valve Regulations define a leak as a concentration of 10.000 ppm or more nght at the valve PPG has defined a leak as 1500 ppm or more nght at the valve. HNU ROUNDS A weekly round is conducted with the HNU meter of all equipment m Vinyl Chloride service* . The logsheet provides a place to log the leakage and comments. (OHo MAi/jc^ iUmk/O? Afecitzji? WHAT DOUBLE VALVE/PLUG BLEEDS ACT10 tmUS fUVC, If tl/iOtri* id MtLH? Ah bleed valves m Vinyl Chlonde service* must be plugged or valved past the first valve. Both the first and second valve must be closed if the bleed is double valved. Ifit is not double valved it must have a closed valve on the process and a plug/cap at the end. A weekly round is made through the VC urut at TE-1I to determine which bleeds need plugs or valves and immediate action is taken accordingly, SRV/RUPTURE DISK INSPECTIONS A round is conducted through the units (atleast quarterly) to determine the status of the rupture disks (blown?), gauge (operable?), and the bleed (double blocked?). WHAT AcrvOrJ EQUIPMENT INSPECTIONS Operators inspect equipment and piping externally on a quarterly basis and document any problems. The PPG inspection group also makes external and internal inspections penodically and documents problems. PERSONAL PROTECTIVE EQUIPMENT - RESPIRATORY Safety procedures specify that self-contained breathing equipment must be worn when responding to leaks of unknown concentrations of VCM, When VCM concentrations are shown to be less that 10 ppm by fixed point monitors, or portable meters, use of an organic cartridge half-mask respirator is permitted. Both the Supervisor and the wearer have the responsibility to ensure that the correct protection is selected and used properly. Safety procedure #12 - Respiratory Protection Program ~ provides general information on the use of respiratory protection and the operation of the program. Contents include: responsibilities, medical review and approval training, fit testing, selection, cleaning, inspection, and storage. Also included is a list of PPG IPELs and NIOSH IDLHs. ANNUAL VC TRAINING Training is conducted annually by qualified instructors. The training is documented and kept in the PPG Training department Training includes the hazards associated with vinyl, first aid, handling, physical and chemical properties, acute and chronic signs and symptoms, and a review of the additional information in the MSDS, * Vinyl Chloride service is defined as equipment used on process streams that have a VCM concentration of > 10% 88 6 72