Document 0J18rYgRRQzE6vR2D3j3mQGGk
EUROPEAN REGULATORY UPDATE
VCSA MEETING 1992 BALTIMORE
Author D.J. HART EVC International
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EUROPEAN REGULATORY UPDATE - SUMMARY OF THE KEY POINTS
National SHE legislation now becoming dominated by the increasing influence of the EEC
EEC developments of note are legislation concerning Safety Management in general and of specific topics with emphasis on RISK ASSESSMENT rather than prescription ; legislation concerning ENVIRONMENTAL AUDITING ; move towards INTEGRATED POLLUTION CONTROL (IPC)
TA Luft limit values becoming the "Bible" for air emissions (but some countries imposing tighter limits)
Key Figures :
-- Any vent of > 25 g/hrflow must be < 5 mg/m3 VCM
-- At transition from closed to open process : for mass PVC plant, must be < 0.01 Kg VCM/te PVC for susp. PVC plant, must be < 0.1 Kg VCM/te PVC for copoly. PVC plant, must be < 0.4 Kg VCM/te PVC for emulsion PVC plant, must be < 1.5 Kg VCM/te PVC
-- Dust must be < 50 mg/m3 for vent flows > 0.5 Kg/hr and < 150 mg/m3 for vent flows < 0.5 Kg/hr
-- In vents, HCL < 30 mg/m3, CL2 < 5 mg/m3 and EDC < 5 mg/m3
* EEC monthly average limit for EDC is 6 mg/I in 1993 and 2.5 mg/I in 1995. (but see detail in note) Tighter in some countries.
* VCM in occupational environment set by EEC limits
(or tighter)
i.e. 3 ppm annual or 7 ppm over 8 hours.
Excursion/Evacuation levels depend on
time between measurements
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e.g. 15 ppm for 1 hour, 20 ppm for 20 mins.
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EDC in occupational environment is variable. Most countries 10 - 20 ppm but some at 50 ppm and Norway/Sweden at 1 ppm. Increasing pressure
PVC Dust in occupational environment 5 or 10 mg/m3 depending on particle size. Proposals for significant tightening.
Dioxins in incinerator vents 0.1 ng/m3. Limits being considered for liquid effluents and sludges. Oxychlorination and dioxins Incineration is very much an issue.
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REGULATORY ISSUES CONCERNING EDC/VCM IN EUROPE
1. HIGHLIGHTS AND DEVELOPMENTS
EEC LEVEL
- General Safety Management "Framework" Directive and several "Daughter" Directives on a number of particular items have been issued. Implementation 1/1/93. Emphasis on RISK ASSESSMENT and POLICY/PROCEDURES i.e. move towards self-regulation by industry rather than legal prescription.
- Strong moves towards Environmental or ECO Auditing. Emphasis on the management system. Looking similar to Quality Assurance.
- Move toward Integrated Pollution Control (IPC)
- Vast amount of SHE legislation underway
BELGIUM
A new local regulation called "VLAREM" has been prepared by the Flemish authorities and only applying to the Flemish region. This regulation contains standards for VCM and EDC. These standards are since 1/9/91 used for Permits. The "VLAREM"-regulation is based on T.A.-Luft and EEC-Directives.
FRANCE
No national standards, only local regulations.
FRG
- New Regulation for EDC-concentration in occupational areas - expected value for EDC 10 mg/m3 air.
- EDC or VCM emission in waste gases shall not exceed 5 mg/m3
- National regulations are being prepared for VCM and EDC concentration in plant effluents.
Following limit concentrations are proposed : VCM :
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All volatile halogenated hydrocarbons e.g. VCM max 10 mg/1 waste water at each isolated plant boundary. S, mass and copo PVC 1 mg/1 or 5 g/ton prod. cap. daily av. from 1991 E, microsuspension PVC 5 mg/1 or 20 g/ton prod. cap. daily av. from 1993
EDC :
All adsorbable organic halogen compounds e.g. EDC 2 mg/1 waste water or 20 g/ton production.
ITALY
DPR203 now implemented specifying emission limits very similar to TA Luft. Mass emission limits (kg VCM/te PVC produced) as the same as FRG.
THE NETHERLANDS
- Expected lowering MAC-value for EDC from 200 mg/m.3 to 80 mg/m.3 at least.
- Authorities use TA-luft officially as reference but may go beyond.
- Much attention to Dioxin etc. formation in incineration processes.
- In the Dutch OSHA-train the report "Health based recommended occupational exposure limit for Polyvinylchloride (PVC) dust" is in discussion.
- Directive on emissions from waste incineration (old and new installation) will come into force by 30th November 1993. It will exceed the EEC guidelines in the following aspects :
total solids
5 mg/m3
total heavy metals (Sb + Pb + Cr + Cu + Mn + V + Sn + As + Co + Ni + Se
+ Te)
1.0 mg/m3
Cd 0.05 mg/m3
Hg 0.05 mg/m3
Sox 40 mg/m3 No* 70 mg/m3
PCDD' s + PCDF's
0.1 mg TEQ/m3
Argument is a.o. regional immission situation.
NORWAY
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No national standards. Each plant has got specific limits as a part of the permit to operate the plant and these are still under debate.
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U.K.
- Environmental Protection Act into operation legalising the concept of Integrated Pollution Control to water, air and land.
- Application for authorisation for all existing VCM- and PVC-manufacturing processes required before July 1993. Her Majesty's Inspectorate of Pollution will issue a process guidance note for each process including discharge standards. Authorisation of the process based on using the Best Available Techniques not Entailing Excessive Cost and the Best Available Environmental Option.
- Legislation enacted on the Duty of Care for waste management (cradle to grave type of responsibility)
2. REGULATORY STANDARDS CONCERNING VCM IN EUROPE
2.1. EMISSION LIMITS (AIR1 B Flemish VLAREM < 5 mg/Nm3 when mass flow > 25 g/h
F 0 or 15 ppmv (local regulations)
FRG - < 5 mg/m3 daily average, when massflow > 25 g/h (TA-luft, closed systems). Transition from the closed to the open system.
10 mg VCM/kg PVC maximum monthly average for mass-PVC
- 100 mg VCM/kg PVC maximum monthly average for suspension homopolymer
- 400 mg VCM/kg PVC maximum monthly average for suspension copolymer
- 1500 mg VCM/kg PVC maximum monthly average for microsuspenson and emulsion PVC
These regulations of the Federal Law TA-Luft (Technical instructions air) may additionally be tightened by the single states.
For example, in our microsuspension-PVC-plant in Cologne, WACKER has to observe the limit of 450 mg VCM/kg PVC from 1994.
It <5 mg/m3 when mass flow > 25 g/h (TA-luft). Also note that as both
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VCM and EDC are regarded as carcinogenic, their sum must be < 5 mg/m3.
Neth < 5 mg/m3 av. hour
Nor - < 20 kg VCM/h from old PVC-plant - < 1,5 kg VCM/h from new PVC-plant (max 3,2 kg/h) - < 25 kg VCM + EDC/h from VCM-plant
Sw < 0.5 kg/ton (S-PVC) and < 13 kg/ton (PVC Paste)
UK Proposed limits of 0.1 kg/te PVC for emulsion and 1.5 kg/te PVC suspension. Any vent must be below 5 mg/m3.
Switz The standard of < 0.2 kg/te PVC for suspension plant has now disappeared. Now all vents < 5 mg/m3 if total flow > 25 g/hr.
2.2. DISCHARGE LIMITS (WATER1
B Total halogenated organics 15 mg/1 CL (reference volume of water 1.1 m3/ton installed prod, capacity)
F Not specific, COD < 15 mg/1
FRG No legal standards at present, but expected to come
It Sum chlorinated hydrocarbons < 1 mg/1 (Venice lagoon <0.05 mg/1)
Neth Not in discussion
Nor New PVC-plant < 67 kg VCM/week (max 40 kg/h) < 1400 kg TOC/week
PVC/Suspended solids to be decided (max 2,5 kg/h)
Sw 300 kg/year
UK <1 mg/1 (expected)
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GR Sum chlorinated hydrocarbons < 2 mg/1 Switz <0.1 mg/1 VCM (as CL)
2.3. ENVIRONMENTAL QUALITY STANDARDS (AIR) B VLAREM : 10 micro g/m3 limiting value 1 micro g/m3 target (strive) value as 98-percentile of all measured half-hour values over 1 year
F Nothing at border of plant
FRG Nothing
It Nothing
Neth 0,38 ppb year average (strive value)
Nor Nothing
Sw 1 -2 ppb advise
UK Nothing (yet)
Gr Nothing
2.4. Standards for OCCUPATIONAL Environment
B 3 ppmv max. average year, evacuation when 15 ppmv max/1 hr av ; 20 ppmv max/ 20 min av. ; 30 ppmv max/2 min av.
F 3ppmv (old plants), 1 ppmv (new plants)
FRG 3 ppmv max TWA (8 hrs), old plants 2 ppmv max TWA (8 hrs), new plants evacuation. See B
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It EEC Limits i.e. Technical Long Term Limit Value (1 year) is 3 ppm. Remedial action if 1 reading over 15 ppm. Evacuation if over 30 ppm. (For continuous monitoring systems of 1 analysis every 20 mins., the annual limit of 3 ppm is considered respected if in the year there are less than 1314 readings of over 7.9 ppm.)
Neth 3 ppmv year average, 15 ppmv max/1 hr av ; 20 ppmv max/20 min av ; 30 ppmv max/2 min av.
Nor 1 ppmv (8 hour day)
Sw 1 ppmv TWA (8 hrs), 5 ppmv TWA (15 min)
UK 3 ppmv year average, 7 ppmv (8 hrs av), remedial action if 15 ppm/lhr or 20 ppm/20 min or 30 ppm/2 min i.e. EEC Directive
GR EEC Directive 78/610 as state law
Switz 2 ppm MAK (8 hrs) ; remedial action required if two consecutive readings above 10 ppm or one above 15 ppm
3. REGULATORY STANDARDS CONCERNING EDC IN EUROPE
3.1. EMISSION LIMITS (AIR1 B VLAREM < 20 mg/Nm3 when mass flow > 100 g/h
F
FRG < 20 mg/m3 av. daily concentration with a mass flow of > 0.1 kg/hr (TA Luft)
It <5 mg/m3 when mass flow > 25 g/h. Also note that as both VCM and EDC are regarded as carcinogenic, their sum must be < 5 mg/m3.
Neth < 5 mg/m3 av. hour
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Nor < 25 kg/h (VCM plant, VCM + EDC), < 1 kg/hr (offgases from incinerator EDC/EC/VCM), also a limit on dioxin
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Sw Incinerator required for all EDC-containing gases UK Proposed limit of 20 mg/m3 if mass flow above 100 g/hr. Gr
3.2. DISCHARGE LIMITS 1WATER)
B VLAREM : implementation now of EEC 1995 limits (see later). Reference volume of 2,5 m3 water/ton production capacity of EDC.
F 10 mg/1 monthly av.
FRG No legal standards at present, but expected to come
It EEC limits adopted (see below)
Neth EEC limit values have been adopted.
Nor < 1.75 kg/wk, 0.35 mg/1. Limits also on Fe, Cu, NaOCl, CO, N0X, pH and dioxins
Sw < 1.000 kg/year
UK Limits set locally based on EEC limits
Gr Sum chlorinated hydrocarbons < 2 mg/1
3.3. ENVIRONMENTAL QUALITY STANDARDS 1AIR1
B 10 ppm (40 mg/m3) Ref. Acceptable Limits for hazardous substances. TLV's 1991 - 1992 (C.E.D. SAMSON)
Neth 1 ppm advise
Sw 100 - 150 ppb advise
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Nor Proposal for total hydrocarbons 100 - 200 micro g/m3 (1 hour)
3.4. STANDARDS FOR OCCUPATIONAL ENVIRONMENT B 50 ppmv (TWA) F FRG 20 ppmv, in discussion, probably 3.5 ppmv TWA It 10 ppmv (TLV and TWA) Neth 50 ppmv (TWA) Nor 1 ppm TWA (8 hrs) Sw 1 ppmv TWA (8 hrs), 5 ppm TWA (15 min) UK 10 ppm (8 hrs av.), 15 ppm (10 min av.)
3.5. EEC GUIDELINES 119901 FOR AQUEOUS EFFLUEffTS Limit values for discharge of 1.2-dichloroethane
TvDe of Plant
Type of Averaae
Limit Values exoressed in : Weight Concentr. (9/ton) (mg/i)
a) Installation for Month production of EDC
4 2.5
2 1.25
Day 8 5
4 2.5
b) Installation for production of EDC and conversion of EDC into VCM on
the same site
Month Day
12 5
24 10
6 2.5
12 5
Ton = production - capacity of EDC incl. recycle EDC.
AddIicable from :
1.1.1993 1.1.1995
1.1.1993 1.1.1995 1.1.1993 1.1.1995 1.1.1993 1.1.1995
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4. PVC-UPDATES - PLASTIC WASTE MANAGEMENT
EEC LEVEL
A modified version of what was called the "final draft, dated 21.2.92" of the Council Directive on Packaging and Packaging Waste was presented by DG XI to the Commission and adopted on 15.7.92. It has now simultaneously been passed on to the European Parliament and the Council of Ministers to take the next step in the approval process.
Key elements are :
* 10 years after adoption (by year 2003 ?)
recovery
: 90 % per material
of which is recycling :
60 % per material
disposal of residues : max. 10 % per material
* "Intermediate targets" for those countries without fixed schemes
recovery
: 60 % per material
of which is recycling :
40 % per material
disposal of residues : max. 40 % per material
* "Recovery" = reuse, recycling and energy recovery "Recycling" = recovery for the original purpose or other purpose, excluding energy recovery
* If scientific research, such as ecobalances, prove that other recovery processes show greater environmental advantages, the target for recycling can be modified.
* No discrimination between competing materials, collection and recovery methods.
* No standstill in packaging waste output.
* Member states have to harmonise their individual schemes over the next 10 years towards the recovery targets mentioned above. Obligation to notify any proposed measure or voluntary agreement under other Community legislation.
AUSTRIA
- Industry taking legal action against Greepeace anti-PVC publicity - no ban on PVC-packaging expected for the moment - waste bill draft revised with emphasis on reduction and recycling - recycling companies started for PVC and expanded PS
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SWEDEN
- Pressure against use of PVC fairly moderate - Proposal to forbid use of PVC for foodpackaging has been withdrawn - Combustion of PVC in municipal waste is no longer an issue
UK
A senior official of the DTI presented at Davos 1992 the plans of the UK government for waste management, particularly on packaging. These are not yet "consolidated", but a target of 50 % by the year 2000 for recyclable household waste, of which used packaging is a major share, was put forward. A separate target for energy recovery is still to be fixed. Interestingly, it is the DTI = Department of Trade and Industry which deals with waste handling and the setting of recycling targets, and not the DOE = Department of Environment. Several plastics recycling plants are in operation.
FINLAND
Agreement within packaging industry to decrease PVC-consumption is difficult to put into practice. Minister of Environment accepted that substitution must mean an improvement in environmental performance.
GREECE
PVC waste is considered by Greek Law as normal industrial waste. The law requires disposal to be made in certain landfills for solid industrial wastes under state supervision/control. Above state landfills have not been arranged yet.
SWITZERLAND
Despite pressure from the EEC concerning violation of the "free trading agreement" and the spirit of the "European Economic Area", the Swiss Federal Government in its judgement of 7/7/92, have rejected the appeals of the PVC industry and have gone ahead with its ban on PVC for drink containers (as part of implementing their waste management act). As in Germany and Austria, some Swiss cantons are putting forward "PVC free" purchase lists. Recycling projects in progress.
Incinerator guidelines in EEC are for 0.1 ng/m3 of dioxins TEQ.
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- Mandatory deposit on plastic bottles
- Constitution of a committee of the Federal Government and the States (BLAU) with aim to prepare a policy towards PVC.
- Many new recycling projects including chemical recycling.
ITALY
- Public climate worsening
- Packaging waste management law (no 475) being implemented. Also new decree to allow certain wastes to be classified as secondary raw materials and recycled.
- National consortium of public bodies, industry and trade for collection and recycling of waste packs and for every type if recycling a minimum is fixed : for plastics 40 % min., in period 1990 - 1992. Financial resources 10 % of cost of raw materials. If target is not reached, containers will be taxed
THE NETHERLANDS
- Short product life application of PVC (a.o. packaging) under strong attack
- Recycling project developing
- Convenant on packaging between packaging industry and government :
. Packaging waste . Recycling in 1995 40 % . Landfill in 1995 40 % . Incinerator
in 2000 90 % of 1986 in 2000 60 % in 2000 0 % in 2000 max 40 %
NORWAY
PVC has been heavily debated, partly due to Norsk Hydro planning a new PVC plant. The Norwegian Ministry of environment has established a PVC policy. They have concluded that the main environmental problems related to PVC is waste and some of the additives. As a consequence of this they invite the industry to prepare plans for phasing out PVC-packaging. The Norwegian Environmental Agency will appoint a group to study the environmental impact of PVC products with long product life compared to alternative materials/products. Life cycle analysis, labelling and recycling. But environmental impact of production is also a strong issue. Norsk Hydro and Statoil have decided to build a plant for recycling of mixed plastic waste.
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BELGIUM
- Collection system for plastic bottles in operation (Flemish and Wallonian region!.
- Consortium of public bodies industry and trade for collection, separation and recycling of waste packs in Flemish Brabant (1.000.000 inhabitants).
- Collection and recycling of mixed plastics household waste in Limburg and the Campine (300.000 inhabitants).
DENMARK
Voluntary PVC-agreement between government and industry : . PVC-waste not incinerated together with ordinary waste ; . PVC-waste shall be recycled instead of dumped ; . Reduction in use of lead stabilisers and chloroparaffins in PVC ; . Environmental assessments according to "cradle to grave principle" ; . Targets for PVC-packaging, recycling of PVC-building products.
FRANCE
- Ecologist groups and industry worked together in collection scheme for (PVC-) bottles (operation Pelican, school program)
- Dunkerque : 80 % return of PVC-bottles
- April 1992 decree on the waste management of used packaging (reduced landfill, recycling, acceptability of thermal recovery, etc)
FRG
- Recycling scheme for PVC-flooring in action since December 1990 by PVCflooring producers ; target is to recycle 300 T till end of 1991.
- PVC less discussed than before, much attention for recycling but in some federal states pressure and action for total prohibition of
use/application of PVC (Green Party conservative party). PVC products increasingly threatened by purchasing policy of some states.
- Targets for plastics packaging officially approved :
. 01.01.93 collecting 30 % recycling 10 % . 01.01.95 collecting 80 % recycling 64 %
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PVC AND ENVIRONMENT
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BILL NANKERVIS
Bc IMech Engl Pr Eng MIMechE Operations Manager VCM PVC Business
Member of
AECI CHLOR-ALKALI AND PLASTICS LIMITED
MIDLAND FACTORY
REG. NO. 71/08069/06
P.O. 6ox 321 Sa.olburg 9S70 OFS RSA T.tafa*. (0161 703-2337 __Teletex: 75-0617 Telephone. IQifii 703*2345
CertairifeedH
Frank L. Conrad
Plant Superintendent
CertsinTeed Corporation Vinyl Building Products Group Mailing Address: PO Box 253 Pal# Manana Road Sulphur. LA 70664 318 882-1441 *xL 19
fax 318 882-1516
AKZO
Drs. H. Steegenga
Production Manager
Salt and Basic Chemical Division
Akzo Sait and Basic Chemicals Nederland t>v. Weipiaatweg 12, Postbus 7020 5000 HA Rotterdam Tel 1010) A 3Q 92 50 Fax 4389354 Telex 28871
ATOCHEM
Roland WEBER
R'ocess Manager PVC FiuO'Opofymers
bans qe SAint PONS Oua. coo'S Aulagne BP 35 - 6919! SAINT PONS Ceoe Te 72 73 9- u Pa. 72 73 90 06 Tele. 300 232 F
C. Arthur Gellner Vice President - Polymer Operations
CertainTeed Corporation Vmyi Building Products Group Pete Manena Road P.O. Box 253 Sulphur. LA 70664 318 882-1441 tax. 318 882-1516 voice mail 600 359-7296
box. 2749
CPC
COMPANHIA PZTROQUlMlCA At.AGOAS
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AWD
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A Subsidiary of The Dow Chemical Company
Boy A. DeGesera W9fer Technology program Director
AWD Technologies, Inc. 400 W Sam Houston Pkwv S Houston TX 77042 Tel 713 978 2544 Fa* 713 978 2959 Car 713 553 9370
COMPANHIA PETROQUlMICA CAMAQARI
LUIZ EDUARDO EMATNA Plont Monomer
CMA 02399-4
OFFICIi Ktrd Hldrop4nlo, 3342 . COPCC (Comptexo Idtlcol Como$df1 * IA Phone* (071) 832-3200/832-1748 Telex 7H1S4 CPCA 18
(SC. HO. Rue SAo Joa4, 73>A/9Q2 * Rio 4e Janeiro * RJ Phone* (021) 221-1490 Telex 2123612 CPCA
$. PAULO. Rue Poet Lente, 524 - 11st floor * Plnhelrot * S4o PoulO * SR Phone* (011) 6U4Q22 - Telex 1131610 CORC It
PETER N. GUAY
TfcCHWCAb MANAGE*
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Dow U.SJL
TOMMOWUS Technical Manager Chlorinated Ethane Products Technology Center
The Dow Chemical Company 2301 N. Brazosport Btvd., 001120 Freeport, TX 77541 -3257 Fax: 409-238-9694
jt. cr
DOW CHEMICAL U.S.A.
AN OffBATING UNIT !> TX( DOW CHIAHtAl COMPANY
WM (BILL) HUFF PRODUCTION SUPERINTENDENT EDC/NPA A-7001 Freeport TX 77541 409*238-3767 Home 409-297*0640 FAX 409-238-0478
DOW CHEMICAL U.S.A.
AN OPEBATING UNIT Of THE OOW CHtMICAt COMPANY
SAM SMOLIK
SUPERINTENDENT
Texas Operations &9401- OC.-- IO ( Freeport, Texas 77541 Office 409/238-5286 Home- 409/297-8607
JOHN MANDRAVEUS
PVC PROCESS SECTION HEAD
tXO - CMDRCALS Co. A-t P.O. BOA 10 044
OR .*41 10 THEMAUOMKI- GREECE TO.:T*0 412tTM>*12
TELEX: 41 2311 - TELEFAX 317708 ##7
ELECTROCHEMICAL tNDUSTRES (FRUTAftOM) LTD
E. SASSON
ORGANC AREA SUPERVISOR
P.O.8 2357 Act. 24102
Tel : 04-
Fax: : 972 (4) `US'TlS' Tbc : 972(4)471*19
Udm: 04-239940
BRIDGET G. WOOD
ADVANCED PQOOUCTION ENGINEER SOLUTION VINYL RESINS
(4091 9*8-3930 PAX (409) 9*8-5208
UNION CARBIDE CHEMICALS AND PLASTICS COMPANY INC PQ BOX 471 TEXAS CITY TX 77393-0471
R P,(Rudy) Sandau
Esso Chemical Canada
mperial Oil
European Vinyls Corporation International SA/NV
Bouteva'o cl Sduveram 360 B*n60 Bruxe'ies Belgium Tei (02) 674 09 i1
EVC
Dr. David J, HART
Group Safety Health and Environment Manager
Tel, (02) 674 09 23 (Direct) Fax (02) 674 78 35 (Direct)
Te'e* 24 200 EVC8 c3x (02)660 M 81
European Vinyls Corporation (Americas). Inc.
Licensing DeoartTiery
Wilmirgtor,
19897 USA
Telephone (3C2i 479 1504
Tele* 40113C
Fax (302) 479 1614
EVC
EngiTneeMrinSg nVoaw^ager
FORMOSA PLASTICS CORPORATION DEL
Louis J. LaCorte
regulatory affairs manager
SchoouhouSc Ho
P O Box 320
D 19706DELAWARE ClTV,
el
(302) 836-2213
yK\^ FORMOSA PLASTICS CORPORATION USA
Burley R. Melton, P.E.
COBrOIATI DIMCTOI (NVIlONMtNTAL / SA/tTY
9 PEACH TREE HILL tOAD LIVINGSTON. Ni 07039
TELi 12011 716-7387
TLX, 4764065 FPC USA
PAX: 12011 99WMI
7/fc ~ "72h ?
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02399J
Georgia Gull Coroorsnon PVC Tacnmeat Cantar Evergraan ftoao Post Offica 00* 629 Piaguamma. LA 70765-0529 fax ISM1685-1238
Jamas F Gabbatt Oir of Pofymer Q^vafooment PVC Division 50</$S5->25D
Georgia Guifj
Georgia Gulf Corporation Rn er Road Pom Office Bo\ 6/0 Delaware Cttw DE 19706 iJ02i 836-2110
fM2iR,U-l92l -fc/\
David A. DiPiero Plant Manager P\ C Division
Georgia Gulf
Georgia Gulf Corporation Post Office Bor 629 Plaquemine. LA 70765-0629 1502) 665-2670
(504)169-2670
A,T, Wafers PVC Production Manager PVC Division
Georgia Gulf
Georgia Gull Corporation Post Office Box 629 Plaquemme, LA 70765^)629 (504) 635-2653 (S04) 399-2653
W.O. Peepfei Techmca/ Services Supervisor
j 'Goodrich <3eon Vinyl DM*km
6100 Oak Tree Boulevard Cleveland. Ohio 44131 216-447-6498 216-447-6479 - Fax
Harm Waltemate, CSP Manager of Safety
((( HYDRO
tins HAST
Magnus Rdnnmark
Manager PVC Technology
Hydro Plast AB
S-444 83 STENUNGSUNO Telephone mt -46 303 876 54 Telex 2437 hydropl s Fax mt -46 303 811 81
((( HYDRO POLYMERS
David Middleton
Technical Services Director
Tel: 0336 300555 Telex: 58323 Fax: 0335 300215
Hydro Polymen Ltd Newton Aydlffe CoOurmm OL56EA
Chemicals & Polymers
Roger Furr EVC Section Manager
ICI Chemical* Polymer* Limited Merseyside Operations Casiner Kellner Site PO Box 9 Runcorn Cheshire wa 7-tj Telephone (0928) 512917 Telex 629655 iCimoh g Fax (0928l 560972
kevsob corporation
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CMA 023996
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US LUCKY
YUN-KYUNG
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YEOCHUN VCM PLANT
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LUCKY LTD.
HEAD OFFICE; 20, YOIDODONG, YONGDUNGPO-GU. SEOUL. KOREA
TEL; (02) 7B7-7950-3
FAX: (02) 704-4371
PLANTJ763. WOLNAI-DONG YOCHON-SHi, JONNAM-OO. KOREA
TEL:(0ee2)d0-lB30
FAX; (0462) 00*1004
LUCKY
JONG-HWOE
MANAGER safety section YEOCHUN PLANT
JUNG
LUCKY LTD.
Head Ollice 20 TcO'dociYanjdLr'C'o pi. S*e*J Korea Tel Q?'7B7.11!4
Plant 701 Hwaihi dnn^. Yeochun-City CNjnranarrvdo Korea Tel ,0662' 80-10*5-6
fa* 10662, 80-1553
& HYDRO
SiS2kHydra's
VCM Plant
Tor O. Aiisen
Process Supervisor
Private address Yngvesvei 30 N-3900 Porsgrunn Norway Pnone *47 3 55 16 98
N-3965 Herre. Norway Phone. *47 3 57 60 00
Online *47 3 57 65 37 Tele*: 21675 hydro n Telefax' *47 3 57 65 39
tfflt HYDRO
Ninni Heyerdahl
Proc Tech Manager
S2kHydroas
Petrochemical Complex
N-3965 Herre. Norway Phone: +47 3 57 60 00 Oir line. *47 3 57 62 63 Telex: 21675 hydro n Telefax: *47 3 57 62 98
Donald Goodman
Manager, Technical Protects
.OxyChem
Occidental Chemical Corporation
Vinyl* Division Armand Hammer 8lvd,. P.0 Bo* 699. Pottstown. PA 19464 215/327-6559. 24 Hour Message: 800/729-5666 Ext. 8707 FAX. 215/327-6776
OXY
William A. Higgins
Production Manager
___VCM
OxyChenu
Occidental Chemical Corporation
Electrochemical* 4 Specialty Products P O Box 500 Deer Park. TX 77536
713/476-2003 Pager 763-9025, Fax 713/476-2016
OXY
Bob Hartman
Technical Services Superintendent Corpus Christi Plant
OxyChem,
0$MA *T*A wOMSJtC
Occidental Chemical Corporation
Beeic Chemicals Group
P. O Drawer CC
Ingleeide, Texas 78362-0710 512/776-6165 FAX. 512/776-6150
OXY
Deborah M. Foster
Safety Manager
.___OxyChem
Occidental Chemical Corporation
Besic Chemicals P O Box 500 Deer Park Texas 77536
713/476-2675
James W. Kachtick, P.E.
Manager Environmental Southern Region
.____OxyChem
Occidental Chemical Corporation
Corporate Five Greenway Plaza. Suite 2400. Houston. Texas 77046 P O Box 27702. Houston. Texas 77227-7702 713/623-7602 Fax- 713/623-7666
Don Pearson
Operation* Area Supervisor. VCM-ll Oenvativea, Lak* Cherlea Complex Chemical Group
PPO Industrie*. Inc. Post Office Box 1000 Lake Chada*. Louiatana 70602-1000 USA Telephone. (318) 491*4930/4500 Fax: (318) 491-4415 Home' (318) 625-8182
CMA 023997
c nk
4
0
SHINFECH
SHfntftch Inc S618 Mignway 332 Eas: Freeport Teias 77541 Telecnone 409 233-786 FAX 7'.3 482-2140
E. E. (Erv) SetirOMter
v,ce`Pre$ioent Manufacturing
s SOLVAY i SOLVAY TECHNOLOGIES
George Gerliczy
V-ce Presiaeni
Soi.-s. Technologies Inc
5CC = IT Avenue New York New York 1Q110 C ` 2 35-i 858^ Fax 212 35-4-9032
Kenneth G. Akins Senior Environments! Coordinotor
Vista Polymers A Division of Vista Chemical Company
Post Office Box 91, New Highway 25 Aberdeen, Mississippi 39730*0091 Phone (601)369-3437
VISTA
WACKEII
Dr. Herbert Deuschl ProduKtion GesefiaftsOereieh V
Wackar-Ctwmt* QmbH Hanns-SeKJel-Piatz 4 D-8000 Munchen 83 Teleton (0 89)62 79-1494 Telefax (089) 62 79-14 05
JT M WALLACE 7. S'ZT LAKESMORE R>
R.R-X BRiQ+TS &R0YE ONTARIO A/ON ' cO CM1A&A c 5-19 - 869 - 432?)
J.A.KW& 550 6<WVY SRCOK AY
TPAPPE , PA. (?42&
(Zir-489 -4381)
02399^
U.S.A. REGULATIONS
1992 UPDATE
r
1
VINYL CHLORIDE SAFETY ASSOCIATION
OCTOBER 1-2, 1992 BALTIMORE, MARYLAND
CMA 0 2 3 9 9 ?
Burley R. Melton Formosa Plastics Corporation
Livingston, New Jersey
U.S.A. REGULATIONS 1992 UPDATE
1. OSHA's Process Safety Management Act 1910.119 2. EPA's Clean Air Act Amendments (1990) Update 3. Stormwater Regulations 4. RCRA - Hazardous Waste Identification Rule 5. SARA Title III Form "R" Reporting 6. Louisiana Air Toxic Regulations
o
3:
O 7. CFC's 8. Environmental Crimes Act of 1992
00
ELEMENTS PROCESS SAFETY MANAGEMENT
1. Written Plan of Action for employee participation
2. Process Safety Information
3. Process hazard Analyses
4. Standard Operating Procedures
5. Training Program
6. Contractor Safety Awareness & Performance Program
7. Pre-Startup Review Program
8. Mechanical Integrity Procedures
9. Hot Work Permits
10. Management of Change
11. Incident Investigation
12. Emergency Plan of Action
13. Compliance Audits 14. Trade Secrets
CM* 024001
CLEAN AIR ACT UPDATE
TITLE III: Air Toxics
Initial list of Categories of Sources - July 16, 1992
174 industries requiring control of emissions of HAP
10 Tons per year of any HAP 25 Tons per year of any combination of HAP's
Polyvinyl Chloride and Copolymers Production Synthetic Organic Chemical Manufacturing 189 Substances - HAP Maximum Achievable Control Technology
(MACT)
TITLE I: Provisions for Attainment and Maintenance of National Ambient Quality Standards
5 January 1993 - NJ Traffic Congestion & Air Pollution Control Act Companies with 100 plus employees at worksite 25% increase in average vehicle occupancy by November 1996 Approved plan by November 1994
24002
LZARDOUS WASTE
ENTIFICATION RULE (HWIR)
BACKGROUND
Haz Waste
1) 4 Characteristics 2) Listed F,K,U, or P
Broadened the universe of listed Haz Waste by:
"Mixture Rule" "Derived From Rule" "Contained-in Interpretation"
j^ample: K019/K020 Spill into waste water
Dec. 6, 1991 - Court Declared "Mixture Rule & Derived from Rule" unlawful
EPA temporarily reinstated Rule, April 1993
Proposed (HWIR) - EPA, May 1992 (CBEC) Concentration Based Exemption Criteria)
Tier 1
Soil EOC Soils
EDC lOmg/kg .005 mg/kg (detection limit)
VCM 0.6
Leachate .05 mg/L .02 mg/L
Tier 2
EOC Leachate Leachate
.0005 mg/L 0.5 mg/L (detection limit)
- 0.2 mg/L
CMA 024003
^,Uv' \iJ(l VA A
LOUISIANA AIR LAWS UPDATE
DEQ ADOPTED AN AIR TOXICS PROGRAM ON 12/20/91
MOST INDUSTRIAL FACILITIES TO MEET TECHNOLOGY AND RISK-BASED CONTROL STANDARDS
STATE DEADLINES OUTPACE FEDERAL DEADLINES
97 CHEMICAL, INCLUDING AMMONIA, ON STATE LIST
FACILITIES MUST DEVELOP AN MACT STANDARD APPROVABLE BY DEQ
10 TPY/25 TPY "MAJOR SOURCE" DEFINITION
DEQ MOST DETERMINE PERMIT APPLICATION COMPLETENESS WITHIN 110 DAYS OF SUBMITTAL
NO "PERMIT SHIELD" FOR SOURCES NOT NAMED IN PERMIT
MODIFICATIONS MAY TRIGGER MACT NEW SOURCE REVIEW
COMPLIANCE PLAN MUST BE SUBMITTED B
EMISSION STANDARDS APPLY FOR: - MERCURY - VINYL CHLORIDE - BENZENE EQUIPMENT LEAKS - TRANSFER OPERATIONS - BENZENE WASTE OPERATIONS - ASBESTOS - BERYLLIUM - BERYLLIUM ROCKET MOTOR FIRING - VOLATILE LTAP EQUIPMENT LEAKS
CMA 0 2 4 0 0 4
U.S.A. REGULATION 1992 UPDATE
Storm water Permit Application - October 1, 1992 CFC - July 1, 1992 CAA prohibits venting SARA Form "R" Reporting > Source Reduction and Recycling Activities > Energy Recovery > CFC's > RTKM > EPA Proposing to add 80 chemicals (RCRA Haz. Waste List)
o Environmental Crimes Act of 1992
>
> Death or serious injury through environmental offence $250,000 fine 15 years jail
> Environmental Audits by Court > $10,000 Rewards
24005
ASSOCIATION OF PLASTICS MANUFACTURERS IN EUROPE (APME)
VINYLS COMMITTEE REPRESENTS MANUFACTURERS OF VINYL CHEMICALS AND MATERIALS
i.e. PVC/VCM
VINYLS MEDICAL WORKING GROUP
VINYLS SAFETY WORKING GROUP
u*v*a2
CMA 024006
VINYLS SAFETY WORKING GROUP
REMIT WORK ON PROCESS SAFETY AND PLANT ENVIRONMENT ISSUES RELATED TO THE MANUFACTURE OF PVC AND ITS PRECURSORS
MEETS ANNUALLY
MEMBERSHIP COMPANIES IN APME
LAST MEETING - JUNE 11/12 1992 IN BRUSSELS
AGENDA
PVC MODEL PLANT AND BEST AVAILABLE TECHNOLOGY
DETECTION OF FUGITIVE EMISSIONS SHUT OFF VALVES AND UNLOADING SYSTEMS
- HAZARD REVIEW APPLICATION OF MASS SPECTROMETRY FOR
ATMOSPHERIC MONITORING ACCIDENT REPORTS (TRUE CONFESSIONS) ACOUSTIC EMISSION TESTS FOR STEEL
VESSELS REPLACEMENT OF ASBESTOS GASKETS HOW TO COPE WITH 2ppm EDC
OCCUPATIONAL EXPOSURE ON VCM PLANT A GUIDE TO SAFE HANDLING OF PEROXIDES EMERGENCY ACTIONS PROGRAMME
CMA 024008
APME VINYLS SAFETY WORKING GROUP PROPOSED 1993 AGENDA
ABSESTOS GASKET REPLACEMENT - RESULTS OF QUESTIONNAIRE
SHUT OFF VALVES AND UNLOADING SYSTEMS A GUIDE TO AVOID MAJOR SPILLS
HAZARD SUMMARY ON UNLOADING SYSTEM DETECTION OF FUGITIVE EMISSIONS CONCLUSIONS OF GASAFE PROGRAMME ACOUSTIC EMISSION TESTS ON STEEL VESSELS FURTHER DISCUSSIONS ON SAFE HANDLING OF
PEROXIDES PVC DUST EXPLOSION RISKS INCINERATOR UNITS DESIGN TRANSPORTATION SAFETY AND EMERGENCY
ACTION
'JSVCS35
024009
CMA
VCM CONTAINMENT
AN UPDATE
History Design Features Operation Highlights Benefits and Long 'ferm Results
L. LaCorte, FPC Delaware, October 1,1992
CMA 024010
DESIGN FEATURES
1. Combination of Automatic Early relief operation with VCM Recovery Operation
* Unreacted VCM is stripped off of polymerized batches, collect df condensed, and recovered to maximize VCM conversion efficiency
2. Computer controlled "Early Relief Valve"
* New emergency vent line on all VCM vessels
* ERV valves open when vessel pressure exceeds SOX of the rupture disc design
* High pressure conditions dissipated
* VCM released is directed to the Recovery System
3. Provides reliability against the possibility of equipment malfunction or human error
* Prevents abnormal conditions that can cause high pressure
* Provides a redundant backup if "All Else Fails"
4. Does not interfere with VCM recovery system*
* Integrates containment system with normal recovery operations
* Assures continuously operable and reliable equipment
* Help prevent polymer formation in dormant nozzles
CMA 024011
BENEFITS AND LONG TERM RESULTS
1. Improved Environmental Protection * There has been only one significant VCM release due to equipment failure since 2/10/87 (faulty weld)
2. Improved plant productivity * Reactor stripping process and VCM recovery efficiency has been greatly improved, at least a 277. productivity increase in the reactor areas
3. Reductions in variable cost and maintenance cost* * Savings on electricity, steam, and water * Virtually maintenance free
4. Long Term Benefits * Efficient plant operation * Effective maintenance * Environmental assurance
CMA 02-4012
yoiVA^R
FAST VENT HEADER "A1 I
NOTE: EACH BULLET HAS A VOLUME EQUAL TO 62.5%
OF THE TOTAL REACTOR VOLUME
8" (8 REACTORS @ 6,000 GALLONS EACH) j.
VCM VAPOR
<a
3-7 PSIG
TO NASH
COMPRESSORS
10"
CONTAINMENT SYSTEM GAS HOLDER (30,000 GALLONS EACH)
LOW PRESSURE SOURCES ARE
EITHER VENTED OR PULLED BY
n VACUUM PUMPS INTO THE BULLETS
3>: o
ro
o wi-*-
VCM VAPOR SLOW VENT HEADER
"B"
INLET - 10" Hg ABS
8"
75 Hp
NORMAL DOTY - PRESSURIZED GAS HOLDER FOR VCM RECOVERY
EMERGENCY DOTY -
PRESSURE RELIEF AND COLLECTION OF A POTENTIAL VCM RELEASE TO THE ENVTRflMNT
FIRST
STAGE SEAL WATER TANK
* BOTH BULLETS ARE IN SERVICE AT ALL TIMES * PRESSURE IS NOT ALLOWED TO EXCEED 15 PSIG TO
ALLOW ADEQUATE ROCM FOR AN EMERGENCY DISCHARGE (AS PRESSURE APPROACHES 15 PSIG, ALL FEEDS ARE
SHUT OFF EXCEPT EMERGENCY EARLY RELIEF)
FIRST STAGE SEAL WATER COOLER ( 2 REQUIRED @ 2.5 HM BTU EACH)
NASH VACUUM PUMP ( 3 REQUIRED @ 1,000 ACFM EACH) NORMAL liOTY - 2 PUMPS IN OPERATION (STOPPED/STARTED AUTOMATICALLY)
10 PSIG @ 80V
SEAL WATER TRANSFER PUMP ( 2 REQUIRED @ 60 GPM/80 FEET HEAD EACH)
PROCESS SAFETY MANAGEMENT OF HIGHLY HAZARDOUS CHEMICALS
OSHA 29 CFR 1910.119
VINYL CHLORIDE SAFETY ASSOCIATION October 1-2, 1992
Baltimore, Maryland
Burley R. Melton Formosa Plastics Corporation
Livingston, New Jersey
ACCIDENT HISTORY
30 Year Property Loss Loss Per Incident
$5,100,000,000 $ 34,000,000
1974 1976
1984
Cl
Flixhorough, England 28 Deaths $232,000,000
Seveso, Italy 1 KG Dioxin Release Contamination of Sq. miles/yr.
Mexico City, Mexico LPG Explosion 450 Deaths
1984 1989
Bhopal, India MIC Release 3,000 Deaths
Texas, USA Vapor Cloud 28 Deaths $500,000,000
DMA 0 2 4 0 1
U.S.A. REGULATORY INITIATIVES (State Level)
CALIFORNIA - 1985 f
"Hazardous Materials Management"
NEW JERSEY - 1986 "Toxic Catastrophe Prevention Act"
TEXAS - 1986 "TACR Disaster Review Program"
DELAWARE - 1988 "Extremely Hazardous Substances Risk Management Act"
OSHA 29 CFR 1910.119 - May 1992 "Process Safety Management Of Highly Hazardous Chemicals"
o
3:
* CLEAN AIR ACT AMENDMENTS "Prevention of Accidental Releases - November 1993
9rot,
APPLICATION
Processes which involve chemicals at or above the specified threshold quantities listed in mandatory appendix;
Chlorine Hydrochloric Acid Anhydrous Hydrogen Chloride Ammonia Anhydrous Hydrogen Peroxide (52% by weight) VCM - Not on list EDC - Not on list
1,500 lb.
5,000 lb. 5,000 lb. 10,000 lb.
7,500 lb.
Processes which involve flammable liquids or gases on-site in one location, in quantities of 10,000 lbs. or more; such as VCM
CMA 0 2 4 0 1 7
Purpose
This regulation contains requirements for preventing or minimizing the consequences of catastrophic releases of toxic, flammable or explosive chemicals.
ELEMENTS PROCESS SAFETY MANAGEMENT
1. Written Plan of Action for employee participation
2. Process Safety Information
3. Process hazard Analyses
4. Standard Operating Procedures
5. Training Program
6. Contractor Safety Awareness & Performance Program
7. Pre-Startup Review Program
8. Mechanical Integrity Procedures
9. Hot Work Permits
10. Management of Change
11. Incident Investigation
12. Emergency Plan of Action
13. Compliance Audits 14. Trade Secrets
CHA 024019
CMA 0 2 4 0 2 0
Employee Participation
Employers shall: o Develop a written plan of action regarding implementation of the employee participation
o Consult with employees and their representatives
o Provide to employees and their representatives access to process hazard analyses and to all other information
Formosa Plastics Corporation, U.S.
Safety and Health Policy and Procedures Manual
Safety Policy No.???
PROCESS SAFETY MANAGEMENT - EMPLOYEE PARTICIPATION & CONSULTATION
Date Issued: DRAFT
Revised: 08/11/92
Effective: 09/01/92
Page 1
PLAN FOR EMPLOYEE PARTICIPATION AND CONSULTATION PROCESS SAFETY MANAGEMENT - OSHA 29CFR 1910.119
1.0 POLICY
It is the policy of Formosa Plastics Corporation to encourage employee participation and to consult with employees in order to provide a safe and healthy workplace.
Below is a written Plan of Action regarding the implementation of the employee participation and consultation as required by OSHA'S Process Safety Management (PSM) Regulation. 29 CFR Part 1910.119.
2.0 SCOPE
Employees shall have the opportunity to be consulted with and are encouraged to participate in a number of activities that include, but are not limited to the following.
3.0 REQUIREMENTS 3.1 Safety Council
3.1.1 The purpose of the Council is:
a. To establish an advisory safety body representing maximum knowledge of the methods, process and conditions in the facility.
b. To bring together varying viewpoints for discussion so that agreement can be reached on the most effective solutions to safety problems.
c. To recommend corrective measures designed to permanently eliminate hazards caused by unsafe conditions and unsafe acts.
d. To review major accident(s) (injury and non-injury} experience.
e. To develop methods that will obtain maximum compliance with safety instructions.
CMA 024021
Formosa Plastics Corporation, U.S.
Safety and Health Policy and Procedures Manual
Safety Policy No.???
PROCESS SAFETY MANAGEMENT - EMPLOYEE PARTICIPATION & CONSULTATION
Date Issued: DRAFT
Revised: 08/11/92
Effective: 09/01/92
Page 2
f. to plan and promote programs for arousing and maintaining employee interest in Safety.
g. To review safety training methods and establish standard to insure that instruction standard are thorough.
h. To review Safety instruction, policy and procedures and implement necessary changes or additions as required.
l. To estabhsn sub-committees to study facility topics in aetaii.
3.1.2
Membership
Membership shall be composed of the site manager, all section/unit managers, the safety supervisor/manager, the primary employee representative(s), and maintenance contractor representative(s).
3.2 3.2.1
Hourly Employee Safety Meetings Purpose a. To review meeting minutes from the last Safety Council Meeting. b. To review safety topics for the month. c. To review accidents and injuries that have occurred during the last month.
d. To review safety suggestions and audits brought up at the previous month's safety meeting.
e. To discuss the minutes of the Supervisor Safety Meeting. f. To discuss at least one chemical per the hazard Communication Program. g. Examination of personal issue Safety Equipment (e.i. respirators, safety
alassesi.
Formosa Plastics Corporation, U.S.
Safety and Health Policy and Procedures Manual
Safety Policy No.???
PROCESS SAFETY MANAGEMENT - EMPLOYEE PARTICIPATION & CONSULTATION
Date issued: DRAFT
Revised: 08/11/92
Effective: 09/01/92
Page 3
3.2.2
3.2.3 3.2.4
3.2.5 3.2.6 3.2.7 3.2.8
Membership
There are several different groups that will need to meet separately. Each wage roll group is required to participate in a safety meeting once per month with their supervisor. It is the responsibility of each department head manager to ensure that each of his supervisors holds a safety meeting once, each month.
Process Hazard Analysis Team
During a process hazard analysis study at least one member of the team will consist of an hourly employee.
Operating Procedures
Employees required to follow the operating procedure will have an opportunity to review the procedure and a mechanism to make recommendations concerning the procedures.
Pre-Start-up Safety Reviews
Safety reviews are to be conducted with the employees prior to start-up.
Training Program Evaluations
Training program assessments and evaluations by employees will be encouraged.
Safety Suggestion Program
Safety Suggestion Program will be implemented.
Incident Investigation
Both applicable and appropriate, will be conducted with an hourly employee as a member of the investigation team. The results of the incident investigation will be made available to affected and potentially affected employees.
Formosa Plastics Corporation, U.S.
Safety and Health Policy and Procedures Manual
Safety Policy No.???
PROCESS SAFETY MANAGEMENT - EMPLOYEE PARTICIPATION & CONSULTATION
Date Issued: DRAFT
Revised: 08/11/92
Effective: 09/01/92
Page 4
3-2.9 3.2.10 3.2.11
Emergency Response Planning
Emergency Response planning and procedures will be discussed with employees for their information and input.
Compliance Audits
Compliance Audits of the Process Safety Management Program will be discussed with emplovees for their information and input.
Process Safety Information
Process safety information will be made available to employees for their review. MSDS books will be located in accessible locations.
The above plan covers the elements of the PSM employee participation and consultation requirements of OSHA's 20 CFR Part 1910. The individual plant locations should work out the details on how they implement and incorporate the various elements of this plan.
Process Safety Information
Provides the basis for: Safe design, operation, maintenance Hazard analysis/risk assessment Training Inspection and testing (mechanical integrity) Management of change
Process Safety Information Requirement
o The employer shall develop and maintain a compilation of written safety information to enable the employer and the employees operating the process to identify and understand the hazards posed by processes involving highly hazardous chemicajs.
o This safety information must be communicated to employees involved in the processes
ShoulcJ Include Information Pertaining to:
o Hazards of the highly hazardous chemicals used in the process,
o The technology of the process, and o The equipment in the process.
ox> o
to
o t'oO
Information Pertaining to Chemicals
& Toxicity information; o Permissible exposure limits; o Physical data; o Reactivity data; o Corrosivity data; o Thermal and chemical stability data; and o Hazardous effects of inadvertent mixing of different
materials, that could foreseeably occur.
Common Limitations of an MSDS Program
Missing in-process stream data (e.g., black liquor, NCG) Lack of data on incompatibilities (e.g., black liquor and
sulfuric acid; Composition data limited to less hazardous constituents Lack of physical data Lack of accurate data on behavior when exposed to l ire Recommendation: Audit MSDS data for all HHS and
major streams
Information Pertaining to Process Technology
'Slit'
o A block flow diagram or simplified process flow diagram
o Process chemistry; o Maximum intended inventory; o Safe upper and lower limits for such items as
temperatures, pressures, flows and/or compositions; and, o The consequences of deviations, including those affecting the safety and health of employees.
CMA 0 2 4 0 3 0
Common Limitations of Process Technology Information
PFDs out of date No description of process chemistry No single reference on maximum inventory No "mass balance block" showing T, P, flow,
composition, etc. on PFD No upper/lower limits on P&ID No equipment data sheets
Deviations never considered before
Information Pertaining to Process Equipment
sP' ------
o Materials of construction; o Piping and instrument diagrams (P&ID's); o Electrical classification; o Relief system design and design basis; o Ventilation system design; o Design codes employed; o Material and energy balances for processes built after
the effective date of standard; and, o Safety systems (such as interlocks and suppression
systems, etc.).
CMA 0 2 4 0 3 2
Equipment
o Document that equipment complies with applicable codes and standards (where they exist; or, recognized), such as the: American Society of Mechanical Engineers, American Petroleum Institute, American Institute of Chemical Engineers, American National Standards Institute, American Society of Testing and Materials, and Natior '! '"'re Protection Association,
o and generally accepted engineering practices.
CMA 0 2 4 0 3 3
Common Limitations of Process Equipment Information
P&IDs out of date No electrical classification diagrams (or comprehensive
facility drawing) Relief systems design basis unknown Design codes unknown or out of date Safety systems design basis unknown
When Must Process Safety Information be Completed?
Must be completed and up to date for: 25% of processes by May 26, 1994 50% of processes by May 26, 1995 75% of processes by May 26, 1996 100% of processes by May 26, 1997
This has been changed in the final OSHA rule to track the schedule for process hazard analysis
Why? Because it represents the single largest commitment of resources of any of the eleven PSM elements
0^30 VWO
Process Hazard Analysis
Perform an initial process hazard analysis (hazard evaluation) on processes covered by this standard
PHA shall be appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process
Determine and document the priority order for conducting PHAs. Consider: extent of the process hazards number of potentially affected employees age of the process operating history of the process
Why do Process Hazard Analysis?
The cornerstone of a PSM program is the recognition and understanding of process hazards. Hazard analysis can be used to: Prioritize efforts and expenditures to reduce risk Improve emergency planning Improve operating procedures and training Identify critical equipment for higher levels of maintenance, inspection, and testing
CMA 0 2 -4 0 3 7
Process Hazard Analysis
To identify the hazards of the process and for each potential event identify the: Cause Consequences Existing controls and protections Human factors Likelihood of occurrence given existing controls Recommended measures to reduce risk when warranted PHA must also address siting and previous incidents
CMA 0 2 4 0 3 3
PHAs shall address:
Process hazards Previous incidents which had a likely potential tor
catastrophic consequences Engineering and administrative controls
applicable to the hazards * their interrelationship such as appropriate application of detection
methodologies to provide early warning of releases
Consequences of failure of engineering and administrative controls
Facility siting Human factors
A qualitative evaluation of a range of the possible S&H effects of failure of controls
Process Hazard Analysis Requirement
XfjP
o The employer shall perform a hazard analysis for identifying, evaluating, and controlling hazards involved in the process, using at least one of the following methodologies:
(i) What-lf; (ii) Checklist; (iii) What-lf/Checklist; (iv) Hazard and Operability Study (HAZOP); (v) Failure Mode and Effects Analysis (FMEA); or, (vi) Fault Tree Analysis.
Hazop Risk Ranking Matrix For Formosa Plastics Corporation, Texas Using HAZOP2 software from Primatech Inc.
Table 1 Severity Category
Category 1. Catastrophic 2. severe
3. Moderate
4. Light
5. None or very light
Employe* Safety
Multiple deaths and/or serious injuries to employees Death and/or serious multiple injuries to employee
Serious Injury to employee
Slight Injury to Employee
No injuries
Public Safety and Environmental
Death or severe health effects to surrounding community
Severe Injuries and/or Health effects on surrounding Community
Major Health effects on community or Environmental Violationrelease above one pound (VCM)
Slight Health hazard to community or Minor Environmental violations. Under one pound (VCM).
Minor environmental risk, no violations
Equipment/ Facility Loss
Loss of Facility or Above $5 M in damages
Damage of Facility between 5.5 M and $5 M
Damage of Facility between $20,000 and $0.5 M Dollars
Damage of Facility Between $500 and $20,000
Minor damage possible Less than $500
Production Loss
More than six moths of Production
Loss of between 1 and 6 months of Production
Loss of between 1 and 4 weeks of production
Loss of between 4 hours and 1 week of production
Loss of less than 4 hours of production Possible
Table #2 Likelihood Categories
Category 1 2 3
4 5
Description
Expected to occur once every few months.
Expected to occur about once every 1-2 years.
Expected to occur several times in the life a the plant, which is 20 years.
Expected to occur once in the life of the plant.
Not expected to occur in the life of the Plant or within the next 100 years.
CMA 024041
Hasop Risk Rankin? Matrix For Formosa Plastics Corporation, Texas Using HAZ0P2 Software from Primatech Inc.
Table #3 Risk Ranking Matrix
Hazard Severity Cateaorv
1
2
3
4
5
Hazard Likelihood Category
12 3 4
5
2345 34 56 4567
6 7 8
5678
9
6789
10
Table #4 Risk Ranking Categories
Rank 2-3
4 5 6 7-10
category Completely Unacceptable and Immediate Corrective action required
Unacceptable
Undesirable
Acceptable with Controls
Acceptable as is
Description
Must correct with engineering and/or administrative controls or design to risk rank III or better immediately. For existing plant, must notify plant staff of danger and need of corrective action immediately
Must correct with engineering and/or administrative controls or design to risk rank III or better For existing plant, roust correct problem within six months
Should correct problem with engineering and/or administrative controls or design to risk rank III or better For existing plant, must correct problem within a year
Should be verified that procedures or controls are in place. Correct SOP's as required. Minor corrections can e used.
No corrections are required
~'4 04?
HAZARD ANALYSIS TEAM
> Shall be performed by a team with expertise in engineering and process operations, and
> Shall include at least one employee who has experience and knowledge specific to the process being evaluated
> Should involve employee participation
o33: O
Taking Action
Ifjgp mmmmm~mmmmim--m--m^--
o Establish a system to promptly address the team's findings and recommendations;
o document actions taken; o communicate them to operating, maintenance and
other employees whose work assignments are in the facility, and who are affected by the recommendations or actions; and o assure that the recommendations are implemented in a timely maimt..
trfO ^S O VWO
Hazard Analysis Schedule
o No less than 25% of the initial process hazards analyses shall be completed by May 26, 1994;
o No less than 50 percent of the initial process hazards analyses shall be completed by May 26, 1995;
o No less than 75 percent of the initial process hazards analyses shall be completed by May 26, 1996;
o Ail initial process hazards analyses shall be completed by May 26, 1997.
c.n
CMA 0 2 4 0 4
Previous PHAs
PHAs developed in the 5 years prior to this standard are acceptable if they meet the current requirements
They shall be updated and revalidated within 5 years of their completion date
CMA 0 2 4 0 4 6
PHA Retention
Retain process hazardous analyses and updates or revalidations as well as the documented resolution of recommendations for the life of the process
Operating Procedures Requirement
*MM
o jhe employer spall develop and implement written operating procedures
o Procedures should provide clear instructions for safely conducting activities involved in each process consistent with the process safety information
o Should include: Steps for each operating phase Operating limits Safety and health considerations
CHA 0 2 4 0 4 3
Steps for each Operating Phase:
o Initial start-up; o Normal operation; o Temporary operations as the need arises; o Emergency operations, including emergency
shutdowns, and who may initiate these procedures; o Normal shutdown; and, o Start-up following a turnaround, or after an emergency
shutdown.
6 b O trZ 0 VW3
Operating Limits
stJD'
o Consequences of deviation; o Steps required to correct and/or avoid deviation; and, o Safety systems and their functions.
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Safety and Health Considerations:
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o Properties of, and hazards presented by, the chemicals used in the process;
o Precautions necessary to prevent exposure, including administrative controls, engineering controls, and personal protective equipment;
o Control measures to be taken if physical contact or airborne exposure occurs;
o> Safety procedures for opening process equipment (such as pipe line breajqng);
o Quality control for raw materials and control of hazardous chemical inventory levels; and,
o Any special or unique hazards.
Other Procedure Requirements
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o A copy of the operating procedures shall be readily accessible to employees who work in or maintain a process.
o The operating procedures shall be reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment; and
0 changes to facilities.
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Training
o Initial Training o Refresher and Supplemental Training o Training certification
CMA 0 2 4 0 5 3
Training Applies to:
Employees presently involved in operating a process
Employees before being involved in operating a newly assigned process
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CMA 0240
Training Consists of:
Overview of the process and OPs Emphasis on:
specific safety and health hazards emergency operations including shutdow safe work practices applicable to the
employee's job tasks
Exemption from Training
For employees already operating a piocess written certification that the employee has the required knowledge, skills, and abilities to safely carry out the duties as specified in the OPs
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Training Documentation
Ascertain that each employee involved in operating a process has received and understood the training required by this paragraph
The employer shall prepare a record which contains the identity of the employee the date of training the means used to verify that the employee understood the training
Refresher Training
Provided at least every three years, and more often if necessary
To assure that (he employee understands and adheres to the current OPs
The employer, in consultation with the employees involved in operating the process, shall determine the appropriate frequency of refresher training
Contractors
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o Inform contractors performing work on, or near, a process of the known:
known potential fire,
known explosion or toxic release hazards related to the contractor's work and the process, and
any applicable safety rules of the facility
o Ensure that contract employees are trained in the work practices necessary to safely perform their job.
o Explain to contractors the applicable provisions of the | emergency action plan
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Application
Applies to contractors performing maintenance or repair turnaround major renovation or specialty work on or adjacent to a covered process
It does not apply to contractors providing incidental service., which do not influence process safety, such as janitorial work food and drink services laundry delivery or other supply services
Employer Responsibilities
Obtain and evaluate information regarding the contract employer's safety performance and programs
Inform contract employers of the known potential fire, explosion, or toxic release hazards related to the contractor's work and the process
Explain the applicable provisions of the emergency plan
Develop and implement safe work practices to control the entrance, presence and exit of contract employers and employees in covered process areas
Periodically evaluate the performance of contract employers in fulfilling their obligations
Maintain a contract employee injury and illness log related to the contractor's work in process areas
CMA 0 2 4 0 6 1
Contract Employer Responsibilities
Assure each contract employee is trained/instructed in:
the work practices necessary to safely perform his/her job the known potential fire, explosion, or toxic release hazards related in
his/her job and the process the applicable provisions of the emergency action plait
Document that each contract employee lias received and understood the training
Prepare a record which contains:
the identity of the contract employee the date of training the means used to verify that the employee understood the training
Other Contract Employer Responsibilities
Assure that each contract employee follows the safety rules of the facility including (he safe work practices
Advise the employer of: any unique hazards presented by the contract employer's work any hazards found by the contract employer's work
Pre-startup Safety Review
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o The employer shall perform a pre-startup safety review for: new facilities, and for modified facilities for which the modification necessitates a change in the process safety information.
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Pre-startup Safety Review (cont.)
o The pre-startup safety review shall confirm that prior to the introduction of highly hazardous chemicals to a process: Construction is in accordance with design specifications; Safety, operating, maintenance, and emergency procedures are in place and are adequate; Process hazard analysis recommendations have been addressed and actions necessary for start-up have been completed; and, Operating procedures are in place and training of each operating employee has been completed.
Mechanical Integrity - Topics
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o Written Procedures o Inspection and Testing o Equipment Deficiencies
o Quality Assurance
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Mechanical Integrity - Application
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o Apply to the following process equipment:
Pressure vessels and storage tanks;
Piping systems (including piping components such as valves);
Relief and vent systems and devices;
Emergency shutdown systems; and,
Controls (including monitoring devices and sensors), alarms, and interlocks.
CMA 0 2 4 0 6 7
Written Procedures
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o The employer shall establish and implement written procedures to maintain the on-going integrity of process equipment.
o The employer shall assure that each employee involved in maintaining the on-going integrity of the process equipment is trained in the procedures applicable to the employee's job tasks.
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Inspection and Testing
o Inspections and tests shall be performed on process equipment.
o inspection and testing procedures shall follow applicable codes and standards, such as those published by the ASME, API, AlChE, ANSI, ASTM, and the NFPA, where they exist; or, recognized and generally accepted engineering practices.
Training for Process Maintenance Activities
To assure that the employee can perform ihe job tasks in a safe manner
Train each employee involved in maintaining the on-going integrity of process equipment in an overview of that process and its hazards in the procedures applicable to the employee's job tasks
CMA 02-4070
Quality Assurance
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o The employer shall assure that equipment as fabricated meets design specifications.
o Appropriate checks and inspections shall be performed as necessary to assure that equipment is installed properly and consistent with design specifications and manufacturer's instructions.
o The employer shall assure that maintenance materials, and spare parts and equipment, meet design specifications.
CMA 0 2 4 0 7 1
Safe Work Practices
Develop and implement safe work practices to provide for the control of hazards during operations such as:
lockout/tagout confined space entry opening process equipment or piping control over entrance into a facility by maintenance,
contractor, laboratory, or other support personnel
Safe work practices apply to employees and contractor employees
CMA 02-4072
Hot Work Permit
Issue a hot work permit for hot worjc operations conducted on or near a covered process
The permit shah document:
that the fire prevention and protection requirements in 29 CFR 1910.252(a) have been implemented prior to beginning the |iot work operations
it shall indicate the date(s) authorized for hot work identify the object on which hot work is to be
performed the permit sjiall be kept on fije until completion of
the hotwork operations
Management of Change
Written procedures Procedure assures Other change requirements
Written Procedures
Establish and implement written procedures to manage changes (except for "replacements in kind") to process chemicals technology equipment procedures changes to facilities that affect a covered process
INCIDENT INVESTIGATION
> Investigate every incident which results in, or could reasonably have resulted in, a catastrophic accident in the workplace.
> Initiated as promptly as possible, but no later than 48 hours following the incident.
> An incident investigation team shall be established and consist ol persons knowledgeable in the process involved and other appropriate specialties as necessary.
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Incident Investigation (cont. m)
o A report shall be prepared at the conclusion of the investigation wfiich includes at a minimum: Date of incident; Date investigation began; A description of the incident;
The factors that contributed to the incident; and, I Any recommendations resulting from the investigation.
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Incident Investigation (corn #2)
o Report shall be reviewed with all operating, maintenance, and other personnel whose work assignments are within the facility where the incident occurred.
o Establish a system to promptly address the report findings ahd recommendations and implement the report recommendations in a timely manner.
o Incident investigation reports shall be retained for n five years.
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Emergency Planning and Response
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o The employer shall establish and implement an emergency action plan in accordance with the provisions of 29 CFR 19f 0.38(a).
o Note: 29 CpR 19)0.120 (a), (p) and (c|) may ajso be
applicable.
CMA 0 2 4 0 7 9
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o Certify that they have evaluated compliance with the provipjpps'of J)]js secfjop, af|easf every three years.
o Conduct the compliance safety audit and shall be compfjseq of af |easf ope pefsop Hpowjedgeable |n the process. Deve|pp a report of ffte fjncjings of f|ie auditPromptly determine and document an appropriate response {peach of the findings ofthecorripljance audit, apd cert fy that depcieppips have beep corrected.
o Retain the two (2) most recent compliance safety audit repoifs, ps we|| as fpe dpcunienfed corrective actions.
Trade Secrets
Make available all information necessary to comply, to:
those persons responsible for compiling the process safety information those assisting in the development of the process hazard analysis those responsible for developing the operating procedures those involved in incident investigations emergency planning and response and compliance audits
3o:
Without regard to possible trade secret status of such information:
t>*8 0f
MINUTES OF DENVER VCSA MEETING SEPT, 26-27/91
The conference was held at the Brown Palace Hotel and was attended by 57 persons from countries, corapanys and company sites as follows:
U.S.
Non-U.S.
TOTAL
N umber Number Number Number Number
of of of of 0f
* (Oxy
countries companies company sites
persons, paid persons, not
paying* and Dow speakers,
1 15 23 33
4 Wallace,
11 15 16 20
-- King)
12 30 -- .39. ........33
4
Officers
were:
Chairman Vice Chairman Program Chairman, U.S. program Chairman, non U.S. Treasurer Secretary Asst to SecretaryJ. King
J. Kachtick. Occid. R. Farr, ICI L, LaCorte, Formosa M. Ronnmark. Norsk Hvdn J. Gabbett, Ga. Gulf
K. Law, Keysor Century
Treasurers
Report;
Bank balance before conference
Expenses
Registration income
Bank balance after conference
.$2230.43 $3760.28
$3710.00 $2180.15
Business Matters:
A. Officers elected for 1992: Chairman Vice Chairman Program Chairman, U.S. Program Chairman, non U.5. Treasurer--Permanent Secretary Asst to Secretary
R. Farr, ICI L. Burmeier, Dow
L. LaCorte, Formosa D. Hart, EVC J. Gabbett, Ga. Gulf K. Law, Keysor Century J. King
B. 1992 Conference Site: Baltimore, MD After the second run-off the final vote was: Baltimore 14 Quebec ______ 10
C. Other Business:
Asst to Secretary
CMrt 024082
)
SUSPECTED VINYL POLYPEROXIDE EXPLOSION AT EVC's BARRY PVC SUSPENSION PLANT 6th APRIL 1992
024083
I
VA
DO/92/27 : SCHEMATIC DIAGRAM SHOWING LOCATION OF INCIDENT
EXPLOSION OCCURED AS PIPEWORK BOLTED TOGETHER AT THIS POIfTT
FROM RECOVERY COMPRESSORS
V2
TO nCFRIDGCRATiOi1'
CONDENSERS /VO VENT
CMA 0 2 4 0 8 4
INCIDE-NT
TANK D618A HAD BEEN TAKEN OFF LINE AND EVACUATED TO ALLOW A, BLOCKAGE TO BE REMOVED FROM THE VAPOUR OUTLET LINE.
ON 6 APRIL 1992 AMAINTENANCE TEAM WERE GIVEN A PERMIT TO REM OVE VALVE V635A TOGETHER WITH A SPOO L PIECE ABOVE THE VALVE.
BOTH WERE FOUND TO BE BLOCKED WITH POLYMER BUILD UP.
BUILD UP WAS REMOVED FROM SPOOL PIECE
mAND V635A REPLACED Wl A NEW VALVE.
FLANGES OF SPOOL PIEC E WERE SCRAPED AND WIPED CLEAN BEFORE REFITTING WITH NEW JOINTS.
AS THE FITTER WAS TIGHTENING THE BOLTS ON FLANGES CONNECTSG V635A AND SPOOL PIECE HE HEARD A LOUD BANG.
HE IMMEDIATELY STOPPE D WORK AND INFORMED HIS SUPERVISOR.
NO ONE WAS HURT OR ANY DAMAGE SUSTAINED IN INCIDENT
CM* 024085
DISCUSSION
ANALYSIS OF BUILC UP INDICATED THE PRESENCE OF VIN> L POLYPEROXIDE.
D618A HAD BEEN OFFLINE SINCE NOVEMBER 1991.
DURING THIS TIME VENT LINE BETWEEN VI3 AND V635A HAD BEEN ISOLATED BUT NOT DECONTA,MINATED.
ALTHOUGH TOPAN QL/EC180 AND CAUSTIC SODA WERE INJEC ED INTO ON LINE TANK THERE HAD BEEN NO INJECTIONS INTO OFFUNE TANK.
IT IS THUS LIKELY THAT VCM, OXYGEN, IRON AND HCL WOULD H AVE BEEN IN CONTACT WITH PIPEWORK ABOVE V635A FOR AN EXTENDED PERIOD OF TIME.
RATE OF POLYPEROXIDES WOULD HAVE BEEN SLOW DUE TO LOW AMBIENT TEMPERATURES.
NO CONTINUOUS OXYGEN ANALYSIS IS MADE OF GAS FLOW TO RECOVERY PLANT.
8 NO ROUTINE TEST FOR VINYL POLY-
CPEROXIDES WERE ARRIED OUT.
CM* 024086
CONCLUSIONS/RECOMMENDATIONS
1 VINYL POLYPEROXIDE FORMATION IN POLYMER BUILD UP WAS THE LIKELY CAUSE OF DETONATION WHILE PULLING UP FLANGE FACES.
DESIGN IS NOW IN HAN D TO INSTALL 02 ANALYSERS IN INLET L NE TO RECOVERY PLANT.
INJECTION OF INHIBITO>R INTO RECOVERY HEADER PIPEWORK AT RECOVERY COMPRESSORS.
COMMUNICATE INCIDE NT AND RAISE PROFILE OF DANGERS OF VINYL. POLYPEROXIDE.
ESTABLISH ROUTINE TIEST1NG FOR VPP AND PH.
MAKE RECOMMENDAT ONS FOR THE CLEARING OF, AND CLEANING DOWN OF EQUIPMENT AND PIPEWORK LIKELY TO CONTAIN VPP.
t 1 >
024087
EUROPEAN REGl LATORY UPDATE
VCSA ME TING 1992 BAI IMORE
Author : O.J. HART EVC International
CMA 02-4088
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