Document zb0VrwGB09gZMmEyJy26ZKBr3
DERIVATIVES PEL
PROJECT
(OSHA RULE 1910.1000)
LEGAL REQUIREMENTS FORCING AIR EMISSIONS REDUCTIONS IN DERIVATIVES
OSHA RULE 19KU0OO
Regulates permissible exposure limits (f^)itfae workplace.
EPA CLEAN AIR ACT & LDEQ AIR TOXIC REGULATIONS
Restrict emissions of many Derivatives compounds to a minimum level. The objective is to guarantee a minimum concentration of the chemical at the plant fence lines.
(Note: Compliance with MACT can be delayed up to year 2001 if we achieve 90% reduction from 1987 levels by end of 1993.)
EPA STANDARDS FOR HAZARDOUS WASTE TREATMENT STORAGE AND DISPOSAL FACILITIES (TSDF)
LDEQ VOC EMISSIONS REGULATIONS
Regulate emissions from hazardous waste facilities.
Regulate emissions of volatile organic compounds to the atmosphere.
SL 072001
OSHA Rule 1910.1000
- Effective date of promulgation March 1, 1989 - Compliance date for new limits using any control
method (i.e., ppe) September 1,1989 - OSHA to issue regulation on revisions to method
of compliance December 1991 - Employers to comply with new PEL limits using
engineering controls December 1992 - If OSHA did not complete revisions by 12/31/91
then compliance dates would be delayed one year December 1993
Vinyl Institute challenges the regulation
SL 072002
AIR CONTAMINANTS -PERMISSIBLE EXPOSURE LIMITS (PEL)- PPM
CHEMICAL NAME
EEL (TRANS)
ETHYL CHLORIDE 1,1 DICHLOROETHANE 1,2 DICHLOROETHANE
1,1,1 TRICHLOROETHANE 1,1,2 TRICHLOROETHANE
1,1,2,2 TETRA HEXACHLOROETHANE
1,1 DICHLOROETHYLENE TRICHLOROETHYLENE P ERCHLOROETHYLENE
METHYLENE CHLORIDE CHLOROFORM CARBON TETRACHLORIDE
HCL CL2 DOWTHERM OIL:
PHENYL ETHER BIPHENYL
2600 100 50 350 10 5 1
100 100 500
50 10
5 1
1
STABILIZERS GDL (P/T) NPL (P/T) DOX (TE2) SBL (TE2)
TLE (TE2) NRE (TE2) NTE (TE2)
MLE BTE DME (TE2) EPN (P/T)
50 200 100 150 200 100
25
20 200
1000 5
in
o
CM
O
EEL (TWA)
1000 100 1 350 10 1 1 1 50 25
2 2
i 0.2
25 200
25 100 100 100
25 20 200 1000
2
L (STEP
2600 400 2 450 10 1 1 1 200 25
2 2
1
1 0.2
25 250
25 100 375 100
25 20 200 1000
2
IPEL (PPG)
200 10 1
350 5 5 1 1
50 25 50
2 2 5 0.5
1 0.2
5 200
25 100 100 100
25 20 200 1000
2
SL 072003
Project Evolution
- 3/89 to 7/89 Operations made a preliminary assessment of the problems in meeting the new PEL limits for EDC. Determined we could have several hundred violations.
- 7/89 Operations formally requested Engineering help (wrote an RES).
- 7/89 to 7/90 Operations and Engineering surveyed activities that caused overexposures or over standard conditions. Major changes needed throughout Derivatives.
SL 072004
DERIVATIVES POINT SOURCES WITH POTENTIAL EEC OVEREXPOSURE
UNIT
WTU-TETRA WTU-TETRA WTU-TETRA WTU-TETRA WTU-TETRA
DESCRIPTION
LSB-II (all stream* into 6302/6303) DH STILL BOTTOMS BOTTOMS PRODUCT AFTER DRYER DH PRODUCT TANK DH FEED TANK
WTU-BTMS WTU-BTMS WTU-BTMS WTU-BTMS WTU-BTMS WTU-BTMS WTU-BTMS WTU-BTMS
WTU-BTMS
PURCHASED BOTTOMS TRUCKS BOTTOMS PLANT PRODUCT WASTE RECOVERY REFLUX CLEAN-UP REFLUX BOTTOMS PLANT VENT BOTTOMS PLANT VENT SCRUBBER SLUDGE BOX NORTH CLASSIFIER EFFLUENT, ORGANICS AND SOLIDS
LAB SAMPLE BOX
WTU WTU WTU WTU WTU WTU
WTU WTU WTU
NO. 1 WTU STEAM STRIPPER NO. 2 WTU STEAM STRIPPER NO. I CSS STEAM STRIPPER NO. 2 CSS STEAM STRIPPER 301 SEWER BAT METAL STRIPPER FEED TANK NO. 1 BAT METAL STRIPPER NO. 2 BAT METAL STRIPPER SOUTH CLASSIFIER EFFLUENT, ORGANICS
AND
SOLIDS
PER/TRI PER/TRI
PER/TRI PER/TRI
REACTOR FEED REACTOR VENTS
REACTOR VAPORIZER BLOWDOWNS LAB SAMPLE DRUM
EDC EDO EDC EDC EDC EDC EDC EDC EDC EDC EDC EDC EDC
EDC PRODUCT #2
NO. 1 EDC STRIPPER FEED NO. 1 EDC STRIPPER REFLUX NO. 2 EDC STRIPPER FEED NO. 2 EDC SRTIPPER REFLUX NO. 2 EDC STILL BOTTOMS EDC PRODUCT BEFORE THE NEUT. EDC PRODUCT AFTER THE NEUT. RECOVERY STILL FEED RECOVERY STILL PRODUCT RECOVERY STILL BOTTOMS EDC NO. 1 REACTOR LIQUOR EDC NO. 2 REACTOR LIQUOR
SL 072005
EDC NORTH DOCK STORAGE EDC SOUTH DOCK STORAGE EDC LAB SAMPLE BOX
IE- 11 TE-II te-ii TE-II TE-II TE-II TE-II TE-II TE-II TE-II TE-II TE-II TE-II TE-II
TE-II/MC TE-II/MC TE-II/MC TE-II/MC TE-II/MC TE-II/MC TE-II/MC TE-II/MC TE-II/MC TE-II/MC TE-II/DCE
FURNACE FEED L/P EDC OHC EDC MAKE-UP HEAVY STILL BOTTOMS VC STILL BOTTOMS OHC REACTOR CRUDE LIGHT STILL BOTTOMS STEAM STRIPPER BOTTOMS REACTOR PHASE SEPARATOR EDC AFTER CHLORAL TREAT LIGHT STILL OVERHEADS DH STILL BOTTOMS LIGHTS STORAGE TANKS LAB SAMPLE DRUM
RECYCLE STILL REFLUX PRODUCT STILL REFLUX PRODUCT STILL BOTTOMS RECYCLE STILL BOTTOMS MC PRODUCT VINYL STRIPPER BOTTOMS VINYL STRIPPER BOTTOMS VINYL STRIPPER FEED MC REACTOR CRUDE TCE TETRA TANK DCE STORAGE
VC-II/FURN VC-II/FURN VC-II/FURN VC-II/OHC VC-II/OHC ' VC-II/OHC VC-II/OHC VC-II/OHC VC-II/OHC VC-II/OHC VC-II/EDC VC-II/EDC VC-II/EDC VC-II/ST VC-II/ST VC-II/NT VC-II/NT
FURNACE FEED EDC HEAVY STILL REFLUX HEAVY STILL BOTTOMS LIGHT STILL REFLUX LIGHT STILL BOTTOMS DH BOTTOMS CHLORAL TREAT. PRODUCT OHC REACTOR CRUDE EDC RECYCLE OHC REACTOR VENT L/P REACTOR REFLUX L/P REACTOR LIQUOR L/P REACTOR VENT SOUTH TERMINAL II SOUTH TERMINAL CARBON BED NORTH TERMINAL CARBON BED SAMPLE DRUM
EC/HCL SHIPPING
HEAVY STILL BOTTOMS SUMP AND FLUSH TANK
1990 EDC OVERSTANDARD
(210)
SL 072007
Results of Survey
PEL Problem Areas - Sources of Exposure
Everyday Qperational activities
- Sampling - Stabilizing - Catalyst Addition - Fugitive Sources
Maintenance Activities
SL 072008
List of Fugitive Exposure Sources
- WTU Classifier operations - Open lift station sumps - Open tanks - Pump seals (especially in EDO service) - Tank Pressure relief devices leaking - Removing solids from WTU Central Steam Strippers - Transporting material using vacuum trucks or drums - Dumping and cleaning tar buggies - Phasing water from organics - Cleaning kettles in various units
SL 072009
Clearing for Maintenance Activities
Clearing Equipment problems
- Draining and purging with cold nitrogen was not clearing sufficiently well to meet PEL levels for most compounds in Derivatives.
- When we attempted to get to the new PEL levels the clearing was taking several times longer. For most compounds the work area surrounding the equipment showed concentrations significantly higher than the required PEL levels.
SL 072010
Develop Project Strategy - Mid '90
- Initiated projects and project team to deal with issues that required significant research and development and potentially large amounts of capital. Items such as:
- Classifier operation - Tarbuggy dumping - Tarbuggy cleaning - Removing solids from CSS stripper system - Minimizing vacuum truck usages and determine ways to
control emissions from vacuum trucks
SL 072011
Develop Project Strategy - (cont.)
-Assigned a multi-functional (12 member) team to work on the remaining PEL problem areas.
- Divided the PEL project into two phases; Phase I and Phase II
SL 072012
Phase I
For non-solvent areas and simple tasks - Double mechanical seals & pump clearing Closed-loop sampling Tank relief devices & clearing small pressure
vessels An ACT for Phase I was submitted 8/91
- Note: 4/91 Three members of the team attended a Vinyl Institute meeting (requested by PPG) to discuss what companies are doing to meet the new PEL requirements
SL 072013
MINUTES OF MARCH 27,1990 PEL MEETING WTTH VCM INS'lTiUTE MEMBERS
(Meeting requested by PPG)
SL 072014
INTEROFFICE MEMO
PPG CHEMICALS
LAKE CHARLES
Conclusions
1. The three other companies at the meeting are already steaming columns, reboilers, and storage tanks, m effect establishing an industry standard. PPG should match this level of performance by using a steam clearing procedure, or by use of vacuum if the feasibility proves out. No other company has tried a vacuum system, but all seem interested.
2. PPG should do followup STEL monitoring on the current closed loop sampling systems. If the average level i3 not < 1 ppm, PPG should consider testing the Dow quickconnect fittings. PPG may also consider trying the monel STECO sampling system.
3. All companies at the meeting are working under the assumption that engineering controls are required for all tasks. Dow already concludes that strict compliance with the rules is not and will not be possible, and wants the Vinyl Institute to communicate this to OSHA, and find out what happens when the best engineering controls fail to meet the IPELs.
4. PPG should test the Dow rotajet (or equivalent) procedure for clearing EDC storage tanks.
5. The fixed point EDC monitoring system appears to be very valuable in identifying EDC exposure problem areas. The Dow people asked a lot of questions about the fixed point system; they seemed won over. PPG should install fixed point monitoring systems in the three EDC process areas.
6. Double mechanical seals are favored by all companies, except in some applications where "seal less" is preferred. PPG should proceed to install double seals on EDC pumps (Phase I of IPEL project).
7. EDC exposure while connecting and disconnecting hoses during loading operations is a severe problem for PPG. The OFW dry disconnect system used by Dow is worth trying.
8. PPG should follow up on the closed sampling and gauging systems mentioned by Dow, not only to reduce EDC exposure, but also to maintain the integrity of the dry EDC barges.
9. The swapover from Garlock to Gylon gaskets is not going to be a snap. Maintenance will be required to do a better job of aligning gaskets, cleaning flange surfaces, and torquing bolts. We need to start developing these good work habits now, before we make the switch.
-- 5 --
SL 072015
'SROFFICE MEMO
PPG CHEMICALS
LAKE CHARLES
10. Some very large gaps exist m the PPG EDC exposure monitoring program. Very little sampling has been done on hydroblasters and vacuum truck operators. More maintenance monitoring is needed, particularly STEL rhecks on first breaks into reboilers and pumps. Not all the tasks identified by the EDC IPEL team have been monitored - this program should be completed, as some tasks may require more protection than the COMFO-II half mask. To avoid this problem, other companies have chosen not to use air-purifying respirators.
11. PPG lags behind BFG and Dow on secondary containment for sumps and underground piping. Also, to meet the industry "standard", PPG should incinerate or otherwise eliminate the vents from sumps that handle phase organics.
12. PPG should set a high priority to purchase some HNU's that are modified to be EDC-specific. These are needed to verify that equipment is adequately cleared for maintenance (pumps, lines, etc.)
SL 072016
Phase II
All Derivatives units and more difficult tasks - Clearing for maintenance (columns, reboilers,
reactors, piping, large storage tanks, filters, dryers, etc.) - Implement some items from the vacuum truck emissions reduction plan Catalyst addition Stabilization Sampling
SL 072017
THE TOOLBOX
I. HOT NITROGEN ii. VACUUM
in. STEAM
IV. WATER WASH V. HOTAIR
SL 072018
1. There are over 1000 pieces of equipment in Derivatives 2. There are many miles of piping to clear.
SL 072019
Page No. 1 7/30/91 15:30:04 CLEARING METHODS REPORT BY UNITS P=Nitrogen Purge,V*Vacuum,S=Steaming,HaHot Nitrogen, W=Water Washing,X=None
SAC: NO. DESCRIPTION
PRESS TEMP VAC? METHOD
59 40
59 41
59 42 60 330 60 347
60 407 60 1098 60 1759
60 1761 60 1763 60 1764 60 1765 60 1766 60 1767 60 1768 60 1773 60 1775 60 1776
60 1781 60 1782 60 1799 ,0 1803 60 1804 60 1805 60 1806 60 1807
60 1809
60 1810
60 1811 60 1812
60 1813
60 1814
60 1815 60 1819 60 1820 60 1824 60 1828 60 1835
60 1836 60 1837
60 1838 60 1839
60 1840 60 1841
60 1842 60 1843 60 1863 60 1880
60 1898 60 2171
60 2220 60 2221
60 2340
60 2406
OHC Reactor #5 OHC Reactor t6 LIQUID PHASE EDC REACTOR North Dock 1, EDC Storage North Dock 2, EDC Storage LIGHT STILL CONDENSATE TANK EDC Stg Tank, ST-2 (Old Butadiene)
#5 Catalyst Charge Pot Intermediate Crude EDC Drum
Aqueous surge drum Reactor Degasser - SPARE #6 RX COND ENTRAINMENT SEPARATOR
PLASHER CHLORAL TREATMENT PHASE SEPARATOR STEAM STRIPPER PHASE SEPARATOR
*6 CATALYST CHARGE POT #6 REACTOR DEGASSER 15 RX COND ENTRAINMENT SEPARATOR DRYING STILL PEED TANK HCL SEPARATOR LP-EDC REACTOR GAS SEPARATOR
LP-EDC VENT KNOCK-OUT DRUM H.S. REPLUX DRUM L.S. REPLUX DRUM LP-EDC KETTLE TAR TRAILER EDC BTMS DOPP KETTLE QUENCH LIQUOR DRUM #1 QUENCH DOPP KETTLE (W) VC DOPP KETTLE TAR BUGGY QUENCH DOPP KETTLE O.H. SURGE DRUM
PRODUCT STILL PEED DRUM
PRODUCT STILL REPLUX DRUM EDC RECYCLE REACTION DRUM QUENCH DOPP KETTLE ENTR. SEPARATOR HCL KNOCK-OUT DRUM #2 QUENCH DOPP KETTLE (E) EDC VERT COMP. SUCTION DRUM tl DRYING STILL BTMS TANK 2 DRYING STILL BTMS. TANK #3 DRYING STILL BTMS TANK #1 CRUDE EDC STORAGE TANK #2 CRUDE EDC STORAGE TANK 13 CRUDE EDC STORAGE TANK fl FURNACE PEED TANK #2 FURNACE PEED TANK #3 FURNACE PEED TANK NEUTRALIZER MIX TANK (REPLACEMENT) TANK VENT COMPRESSOR SUCTION *6 DEGASSER #5 DEGASSER 11 VCMII INCINERATOR KO POT 12 VCMII INCINERATOR KO POT LP-EDC CATALYST ADDITION DRUM VENT HEADER KNOCK-OUT POT
150 150
50 0 0
50 0
150 30 14
75 75 50 30 30 150
75 75
0 175
50 50
50 50 150 170 175 170 150
150
175 135 150 150 160 170
50 2 2 2 2 2
2 2
2 2 20
NA 75 75 30 30 150 20
500 500 280 100 100 300
0 300 A22A 5 200
225 150 225 200 200 300 225 150 100 300 300
ISO 300 300 400 430
300 430 400
300
300 150 300 350
60 430 200 200 200 200 200 200
200 200 200 200
200 NA
225 225 180 180 300 200
NX NX Y VHS Nw Nw N tH* 5
Nw
NX Y V uw Nw
Nw
Yw
Yw Y wS Y wS
NX Nw Yw
Nw Y VH Y VHs Y VHs Y VHs Y VHs Y VHs Y VHs Y VHs Y VHs Y VHs Y VHs Y VH Y VHs Y VHs Y VHs Y VH Y VHs Y VHs
Nw Nw
Nw
Nw
Nw
Nw Nw
Nw
Nw
Nw Np
Nw
Nw Np Np Y VHs Np
SL 072020
PEL SCOPE
LEGEND -*
|
C - CLEARING;
DESCRIPTION
F - FUGITIVES;
R - ROUTINE:
PER/TRI
VDCM
TEII/OHCII
I ACT:
Q C - Hot Nitrogen Systems | C - Clearing Utility Header*
C - Vacuum Systems C - Organic Vapor Clearing C - North Dock* | C - Portable Pump* | C - Quench Tower Steam Condenser | C - Quench Tower/Still Line
\ C - Kettle Wash System
| C - Column Clearing System | C Wet Transfer Header
XX XX XX X X
X
X X X
X
X
C - EDO Vent Header C - Steaming Condenser System C - DH Still Area F - Process Sumps F,R - Ash Liquor Mix Tank R - Catalyst Addition System R - Stabilizer Addition System R - Tetra Feed Tanks
MAINTENANCE: C - Pump Clearing C - Miscellaneous
XX X
X X
X XX
X X
VCM II X X X X X X
X
X
EDC X X X
X X X X
X
EC X X X
X X
X
WTU
I
X X X
X
X X
X X
SL 072021
Options considered & not recommended
- Closed-loop sampling in some areas - Install facilities to deal with large storage tanks - Double mechanical seals in some areas - Collection of vents from some tanks - Additional I.C. Tank at TE-2 - Fixed air monitors
SL 072022
CLEAN AIR ACT (with PEL Benefits)
1 DESCRIPTION
ACT:
9
P/T Vent Compression Systems including Aren Shipping Tanks
Tank Vent Control Systems
Old Stab Farm Area
Tanks 63011 6302 Sl 6303
MAINTENANCE: Closed Loop Sampling
Double Mechanical Seals
PER/TRI | VDCM
TEII/OHCI1
VCM II
EDC
EC
X X XX
X
XX X
X X
X
WTU
f
X
|
SL 072023
APPENDIX
SL 072024
MINUTES OF MARCH 27,1990 PEL MEETING WITH VCM INSTITUTE MEMBERS
(Meeting requested by PPG)
SL 072025
INTEROFFICE MEMO
PPG CHEMICALS
LAKE CHARLES
TO: Distribution
DATE: April 2, 1991
FROM:
Don Pearson Nelson Perez Art Reinhardt Johnny Stephenson
SUBJECT: VI Meeting on OSHA EDC Rules
On March 27, Art Reinhardt, Nelson Perez, Johnny Stephenson, and Don Pearson attended a meeting with other VCM-EDC producers to discuss action taken to meet the OSHA IPEL rules.
The other attendees were: Vinyl Institute - Meredith Scheck; Vista - Graham Bacon; B.F. Goodrich - David Hinson and Joel Lindahl; Dow - Bill Huff, Larry Burmeier, and Willie Myles.
9i.E.j- Goodrich
For personnel monitoring, Goodrich uses 3M badges, rather than the pump method. The principle is the same; the activated carbon in the badge absorbs contaminants which are later extracted and analyzed. An outside firm performs the analysis, which results in a very slow turnaround time on the sample.
For 1990, BFG ran 142 personnel samples, of which 31 were over the 1 ppm limit, with an average of 1.2S ppm. The highest result was 30.3 ppm. BFG improved during the year, with only four overstandards occurring in the fourth quarter out of 35 samples. All of the overstandard results were at or near the tar stills during clearing and hydroblasting. BFG also did 32 area monitor samples with badges in 1990 around the tar still area. EDC levels exceeded the 1 ppm limit 14 times.
BFG clears EDC equipment to 50 ppm before opening. The LaPorte plant was designed (1978) with closed loop sampling, using SS bombs. The original design also included equipment for steaming out columns and collecting the condensate. Drying is a problem; BFG once used the EDC azeotrope, which took 1-2 days to dry. BFG now uses hot N2 first; they purchased some portable N2 heaters. Large storage tanks are also cleared by steaming and N2 purging.
BFG also uses steam and nitrogen to clear low pressure storage tanks, usually over a period of several days. They have seen severe internal corrosion in the lower part of the tanks, possibly as a result of this method, particularly where solids are present.
The portable meter that BFG uses picks up all volatile organics; it is not EDC-specific. The meter is used to decide if hydroblasters need to wear personnel protection when cleaning reboilers.
1
SL 072026
NTEROFFICE MEMO
PPG CHEMICALS
LAKE CHARLES
BFG performs lab analytical work under ventilated hoods.
New loading arms with N2 purges were installed for truck loading and unloading. A 3.5 mile double-wall pipeline was installed to transfer material from the ITC terminal. The line will be cleared by pigging, with pressure vessels installed to catch the pigs. BFG seems to have a lot of pigging experience, and apparently uses a variety of pigs: high density, low density, and soft pigs were mentioned.
BFG will have double mechanical seals installed by the end of 1991.
BFG identified the process rainwater sump as an exposure problem, and plans to install enclosed tanks within all sumps for $1.04 MM. The existing sump will serve as secondary containment. The vent will be piped to a stack. A second sump called the decommissioning sewer tank is used for clearing organics from pumps and tanks. The vent from the decommissioning sewer tank is incinerated. BFG spent $465 M to install double-walled or trenched decommissioning piping in the cracking/quench tower area. BFG plans to replace existing decommissioning piping in all EDC/VCM areas in 199192.
BFG installed a fixed, ambient air monitoring system at a cost of $325 M. This GO system operates on a 15 minute cycle. They also spent $100 M on portable analyzers, respirators, and training.
Goodrich plans to spend $5.2 MM to replace their tar stills with a different type of technology.
BFG prefers AMRI TFE-lined butterfly valves for EDO service. BFG has huge, 20-24" valves on reboilers, which have given problems due to solids in the valve seats. For reboiler service, BFG tried several valves: Posiseal, Hills-McCanna, and Rockwell. BFG is using Goretex gaskets to replace Garlock, and found that the surface must be clean to get a good seal.
BFG commented that they use an on-line analyzer to monitor carbon tet and chloroform on their lights column.
Dow
Dow presented a graph of 8-hour EDC TWA annual averages which showed 2.4 ppm in 1988, 0.23 ppm in 1989, and 0.28 ppm in 1990. The improvement in 1989 was the result of closed loop sampling. A similar graph for STEL monitoring showed 3.3 ppm in 1989, 1.9 ppm in 1990, and 0.5 ppm YTD 1991. Dow has also spent considerable effort educating workers on EDC toxicity,
2 --
SL 072027
INTEROFFICE MEMO
PPG CHEMICALS
LAKE CHARLES
and emphasizing personal responsibility for avoiding exposure.
Cow uses pumps for personnel monitoring. They investigated the 3M badges, but determined that the results were biased on the low side, particularly for volatile compounds.
Dow showed their current sample system, which consisted of an 1.5" O.D. x 18" sample bomb, with small globe valves on each end. The bomb was attached to the sample panel with quickconnect fittings. Three-way valves were mounted on the panel to allow N2-purging through the tubing. Dow presented data from 4 tests that showed much less exposure using quickconnect fittings rather than Swagelock fittings. The four tests were: 1 vs 3.5 ppm; 0.5 vs 21 ppm; 1.0 vs 6.5 ppm; and 3.5 vs 3 ppm. Dow is using viton O-rings on the quickconnects, and has experienced some problems. Dow uses Steco samplers in clean EDO service. Dow specifies monel parts to get the needles to last longer.
Dow feels that sample collection contributes most to STEL exposure, and will probably use more on-line analysis. Dow presented a graph comparing lab analysis and vs. Servomex analyzer results for moisture. The on-line analyzer showed considerably less variation. (Note; the Dow moisture averaged 5 ppm)
Dow has seen some overexposures during outages.
For portable EDO monitoring, Dow uses an HNU equipped with a special lamp, and the OVA (not EDC-specific). Dow does not have a fixed point monitoring system.
Dow attempts to clear equipment to 1 ppm before making a flange break. Dow requires positive pressure respiratory protection if the EDO content is > 1 ppm. Dow is installing an extensive breathing air system to facilitate this, with outlets near every pump, every vessel (all levels), etc.
Dow has closed loading systems for tank cars and tank trucks, but still sees high exposures when connecting and disconnecting. They now use OPW dry disconnects.
Dow is using some mag drive and canned pumps, but is moving toward double-seals for EDC pumps.
Dow has gone to API 620 code on new storage tanks, with a 12.5 psig design pressure. The foundation has a solid concrete cap with a polyethylene barrier. Dow was interested in the new PPG foundation design (spoked channels).
Dow uses polyethylene secondary containment on its rainwater system.
-- 3 --
SL 072028
NTEROFFICE MEMO
PPG CHEMICALS
LAKE CHARLES
Dow steams columns for entry. For drying, Dow says that cold N2 will never work; they use hot N2 (Dowell trucks) and EDC -.0 dry equipment.
Dow described a procedure that was used to clear an 40' x 40' API tank. The tank was first steamed, then a rotajet was used to blast the walls with water. The rotajet was supplied by Dowell Schlumberger, and was hooked to 5000 psig water. The rotajet washes in 3 directions. Dow pumped the oncethrough water to steam stripping, then used Allwaste to vacuum the solids out, dewater the solids, and finally to drum the solids. Despite all this effort, the EDC content was still > lppm.
Dow showed some literature on systems to sample and gauge barges without exposure. A Swiss company, Tanksystem, makes the equipment, which is marketed in the U.S. by Lombard Sales and Marketing (617) 592-5500.
Dow is using both Gylon and Goretex gaskets to replace Garlock, and claims that clean gasket surfaces, proper alignment, and proper torqumg is necessary to avoid problems. Dow says that leaks from poor installation show up quickly.
Dow does not use valves on reboilers, because they could not find any that worked.
Vista
vista uses the 3M badges for personnel monitoring. Vista also has a fixed point monitoring system, and has found it helpful in identifying leaks and problems. Each fixed point excursion is documented, along with corrective action. One problem that was identified was vents from process analyzers (going to atmosphere).
Vista is using closed loop sampling for EDC.
Vista clears columns and reboilers by N2-purging, then steaming. Storage tanks are also steamed; problems have occurred with Fe and rust forming an emulsion that causes problems in the steam strippers. The vent from the tank goes to a condenser to condense the steam. Any vent from the condenser goes to a blower which sends the vent to the incinerator.
vista will complete installation of EDC pump double seals in Apri1.
-- 4 --
SL 072029
INTEROFFICE MEMO
PPG CHEMICALS
LAKE CHARLES
Conclusiona.
1. The three other companies at the meeting are already steaming columns, reboilers, and storage tanks, in effect establishing an industry standard. PPG should match this level of performance by using a steam clearing procedure, or by use of vacuum if the feasibility proves out. No other company has tried a vacuum system, but all seem interested.
2. PPG should do followup STEL monitoring on the current closed loop sampling systems. If the average level is not < 1 ppm, PPG should consider testing the Dow quickconnect fittings. PPG may also consider trying the monel STECO sampling system.
3. All companies at the meeting are working under the assumption that engineering controls are required for all tasks. Dow already concludes that strict compliance with the rules is not and will not be possible, and wants the Vinyl Institute to communicate this to OSHA, and find out what happens when the best engineering controls fail to meet the IPELs.
4. PPG should test the Dow rotajet (or equivalent) procedure for clearing EDC storage tanks.
5. The fixed point EDC monitoring system appears to be very valuable in identifying EDC exposure problem areas. The Dow people asked a lot of questions about the fixed point system; they seemed won over. PPG should install fixed point monitoring systems in the three EDC process areas.
6. Double mechanical seals are favored by all companies, except in some applications where "seal less" is preferred. PPG should proceed to install double seals on EDC pumps (Phase I of IPEL project).
7. EDC exposure while connecting and disconnecting hoses during loading operations is a severe problem for PPG. The OPW dry disconnect system used by Dow is worth trying.
3.PPG should follow up on the closed sampling and gauging systems mentioned by Dow, not only to reduce EDC exposure, but also to maintain the integrity of the dry EDC barges.
9.The swapover from Garlock to Gylon gaskets is not going to be a snap. Maintenance will be required to do a better job of aligning gaskets, cleaning flange surfaces, and torquing bolts. We need to start developing these good work habits now, before we make the switch.
-- 5
SL 072030
t
INTEROFFICE MEMO
PPG CHEMICALS
LAKE CHARLES
10. Some very large gaps exist in the PPG EDC exposure monitoring program. Very little sampling has been done on hydroblasters and vacuum truck operators. More maintenance monitoring is needed, particularly STEL checks on first breaks into reboilers and pumps. Not all the tasks identified by the EDC IPEL team have been monitored - this program should be completed, as some tasks may require more protection than the COMFO-II half mask. To avoid this problem, other companies have chosen not to use air-purifying respirators.
11. PPG lags behind BFG and Dow on secondary containment for sumps and underground piping. Also, to meet the industry "standard", PPG should incinerate or otherwise eliminate the vents from sumps that handle phase organics.
12. PPG should set a high priority to purchase some HNU's that are modified to be EDC-specific. These are needed to verify that equipment is adequately cleared for maintenance (pumps, lines, etc.)
PigtrifryLioh:
Attendees Dick Holliday / Lamar White Donna Magi11 Jim Wyche Richard Andersen Clark Graybill Jim Rock Billy Salter A1 Grabert Leon Zeringue Francisco Ortiz Vern Morgan Ron Williams Charles Parnell
-- 6 --
SL 072031
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The Vinyl Institute A nivninn
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industry, me
Maredith N. Scheck
Assistant Director
floun 4 neyna imtrentngt Plars II mu Mr*, nj o?4?o /201) 890-9299
Don K. Peareon
Operations Area Suparvtsor-vCM II Oenvativei Lake Charles Compiea Chemicals Group
PPG industries, me. P 0 Boa 1000 Lake Charles. Louisiana 70602 (319) 491-4930/491-4500
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John W. Stephenson, P.E.
Senior Proiect Engineer ,ake Charles Plant Chemicals Group
CG industries, ine P O Box 1000 Lake Chanes. Louisiana 70602-1000 C'l'ce 13181 491-4839 cax (3181 491-4766
Nelson E. Perez
Senior Process Engineer Lake Charles Pimt
Chemicals Group derivatives
pPG Industries, me p O Boa iqoq
i3*i)
7080*-,oo
vrt Reinhardt Area Foreman. OHC Oerrvatrves/Tri-Elhane II Laaa Charlea Plant Chemicaia Group
PPG induatriet, Inc P O Boa 1000 Laaa Charles. Louisiana 70602-1000 (318) 491-4744 Otliee (318) 491-4766 Fas
BFGoodrich
Joel H. Lindahl
Engineering Supervisor
BFQ Intermediates Company, Inc LaPone Plant 2400 Miller Cut-Off Road
LaPone, TX 77571
713-476-8023
BFGoodrich Chemical Group
2^00 Miller Cutotl Rd La Pone. Texas 77571 7i 3-476-8025
David J. Hinson
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DOW CHEMICAL U.S.A. - :=!=4T!s; ,v,t := i:.-. :-ivncii ;pvvv
L. J. (LARRY) BURMEIER UNIT MANAGES
Vinyl/EDC - Unit Ovsier Creek Sue F-eeoon TX 77541
-'-095 238-5231
LjJtLLt, MYLES -- .
Grohom W. Bocon Sr Process Engineer
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4*0 Pott,
Vista Chemieol Company
Lose Chorles VCM Plon* osi Office Boa 60S Westlake. Louisiana 70669 Phone (318) 494-5025
V1S1A
DOW CHEMICAL U S.A.
ik pkfaaTiNO uvt O' 'n PCiv e(Mie*i. C0Mvv
WM (BILL) HUFF
PRODUCTION SUPERINTENDENT
EDC/NPA A-7001 Freeport. TX 77541 409-238-3767 Home *09-297-0640 FAX 409-238-0*78
SL 072032
PSuTE& 57
c. \oob<LiCM :
OTHER TOPICS
INSTALLING ENCLOSED TANKS WITHIN ALL EDC PROCESS RAINWATER SUMPS. (S1.04MM)
INSTALLED STRAPPING SYSTEM FOR EDC TANKS FOR INVENTORY GAUGING. ($30M)
EDC AMBIENT AIR MONITORING SYSTEM INSTALLED. ($325M)
* DOUBLE-WALLED/TRENCHED DECOMMISSIONING PIPING INSTALLED IN CRACKING/QUENCH AREA. ($465M)
* PLAN TO REPLACE EXISTING DECOMMISSIONING PIPING IN ALL EDC/VCM AREAS IN 1991-1992.
* PURCHASED ADDITIONAL EQUIPMENT (I.E., PORTABLE ANALYZERS, RESPIRATORS AND TRAINING). ($100M)
* REPLACING TAR STILLS ($5,2MM)
SL 072033
