P.1 

OAR Box 1107 

Prepped by Ollie Stewart 

Document Number: 

55) IV-B-5 

Docket Number: 

A-81-21 

Printed 4/11/2008 3:03:47 PM Sheet 55 of 90 
P.2 

A-81-21 

CORPORATIO N 

IV-B-5 

MEMORANDUM 

DATE: July 17, 1985 

TO: Vinyl Chloride File 

FROM: Karen K. Fidler 

SUBJECT: Receipt of Compliance Information for Formosa Plastics in 

Delaware City, Delaware, from Region III 

Attached are 10-day compliance reports for relief valve discharges 

submitted by the Formosa Plastics PVC facility in Delaware City, Delaware, to 

Region III. Copies of these reports were received from Mr. Ron Patterson of 

Region III. 

Attachments 

Progress Center/3200 E. Chapel Hill Rd./Nelson Hwy./P.O. Box 13000/Research Triangle Park, N.C. 27709/(919)541-9100 
P.3 

. £ £ " FORMOSA PLASTICS CORPORATION DELAWARE 

V

 " P.O. BOX 320 • DELAWARE CITY, DELAWARE 19706 • TEL (302) 834-4575 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

March 20, 1935 M[>r "•

 ;" "'* " 

Robert R. French, P.E. **!\. 

Manager, Air Resources Section .AL;.> 

State of Delaware 

Department of Natural Resources 

and Environmental Control 

P. 0. Box 1401 

Dover, Delaware 19903 

RE: EMERGENCY RELIEF DISCHARGE OF VINYL CHLORIDE 

MONOMER FROM RELIEF VALVE, FORMOSA PLASTICS 

CORPORATION, DE 

Dear Mr. French: 

In accordance with the State of Delaware Regulations Governing the Control 

of Air Pollution, Chapter XXI, Section 13, Subsection 3.2a.l, Formosa 

Plastics is submitting this written report of an emergency relief discharge of vinyl chloride monomer from a relief valve. 

NATURE AND CAUSE 

At 1500 hours on 3/10/85, an emergency relief discharge of vinyl chloride 

monomer (VCM) occurred from VCM accumulator DT-303, part of the recovery 

system at the E-2 emulsion plant. The discharge, actually two, onesecond discharges from the relief valves on DT-303, was caused by an 

automatic v^lve which leaked VCM into the recovery system at E-2 plant 

from the tank farm (VCM storage area). The cause of the rising level 

of VCM in the accumulator was not immediately found, and operations 

charged recovered monomer to reactors from the accumulator to reduce 

pressure and level. Without the knowledge that the automatic valve was 

at fault, the pressure and level in DT-303 continued to rise leading to 

a relief valve discharge. The second relief valve (spare) on DT-303, 

was put into service immediately, at which time it relieved also. Doth 

discharges were observed to be one second duration. 

APPROXIMATE TOTAL VINYL CHLORIDE MONOMER LOSS DURING DISCHARGE 

The approximate total VCM loss to the atmosphere was 36 lbs. 
P.4 

Robert R. French, P.L. Page 2 

3/20/85 

METHOD USED TO DETERMINE VCM LOSS 

Orifice calculations were made as shown in the attachment, based on a 

two second observed discharge. 

ACTION TAKEN TO PREVENT DISCHARGE 

When the accumulator level was observed to be increasing without good 

reason, operators immediately began preparing a reactor for charging 

and looking for the source. Additionally, the liquid line from the 

recovery condensers to the accumulator was closed. Charging of a reactor 

from the accumulator was initiated within seconds of the release, thus 

preventing a larger release. 

MEASURES ADOPTED TO PREVENT FUTURE DISCHARGES 

In addition to changing the faulty valve, an analysis of the system 

indicated that additional interlocks on the recovery system may have 

prevented the incident. Therefore, an interlock system will be designed 

and installed to help prevent future discharges from the VCM accumulator. 

Sincerely, 

H. Allen Wrigley, Vr-^H 

Environmental Manager 

HAWjr/AB 

Attachments: 

cc: Ronald Patterson 

Joseph J. Hardman, P.E. 
P.5 

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,,-r- FORMOSA PLASTICS CORPORATION DELAWARE 

s*dS P.O. BOX 320 • DELAWARE CITY, DELAWARE 19706 • TEL (302) 834-4575 

October 3, 1984 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

Robert R. French* P.E. 

Manager, Air Resources Section 

State of Delaware 

Department of Natural Resources 

and Environmental Control 

P.O. Box 1401 

Dover, Delaware 19903 

RE: Vinyl Chloride Monomer Release 

Formosa Plastics Corporation DE 

Dear Mr. French: 

In accordance with the State of Delaware Regulations Governing the Control of 

Air Pollution, Chapter XXI, Section 13, Subsection 3.2a.l, Formosa Plastics 

is submitting this written report of a relief valve discharge of vinyl chloride 

monomer. 

Nature, and Cause 

At 1030 hours on 9/30/84, an emergency relief valve discharge of vinyl chloride 

monomer (VCM) occurred from CT-211, the knockout pot for the wastewater stripping columns. The cause of the discharge, lasting for approximately 15 seconds, 

was operator error. A valve on a drain hose from CT-124 VCM tank to the wastewater filter pot upstream of the VCM-ladcn wastewater tanks CT-200 A and B was 

left open, allowing backflow of water into CT-124, filling the system with 

water. Upon restart of the system, CT-211 overpressured, causing a rupture 

disc failure and the relief valve discharge. 

Approximate Total Vinyl Chloride Monomer Loss During Discharge 

The approximate total VCM loss to the atmosphere during discharge was 1.2 lbs. 

VCM. 

fccnVm 
P.7 

... -v-j._.c—P:J 

Robert R. French, P.E. -2- October 3, 1984 

Method Used to Determine VCM Loss 

Orifice calculations, based on a 15 second discharge resulted in 56 scfm as air, 

which, with a 9/30 0230 hours waste gas analysis of 55.4 mole percent VCM represents a discharge of 1.16 lbs. or 1.2 lbs. VCM. 

Action Taken to Prevent Discharge 

Upon learning of the system having backfilled with water, nitrogen sparging of 

the water gas line to the incinerator was initiated to strip VCM out of the 

line. The incinerator was restarted to burn the VCM stripped from that line, 

shortly after which time the pressure on CT-2H reached 15 psig, and the relief 

valve opened. After the waste gas line to the incinerator was cleared, a hose 

was connected to CT-210 and the waste gas line to control pressure until operations were resumed. 

Measure Adopted to Prevent Future Discharges 

Operators were instructed to shut both valves on the water transfer line 

when draining of CT-124 has been completed. Further, a check valve to prevent backflow on that line has been installed. 

A work order has been initiated to move the existing high pressure alarm 

from the carbon treatment bed to the wastewater treatment plant control 

board. 

If you have any further questions, please do not hesitate to contact me. 

Sincerely yours, 

H; Allen Wrigley, tfx, 

Environmental Manager 

HAW:11 

cc: Ronald J. Patterson 

Joseph J. Hardman, P.E. 
P.8 

"H^p^ FORMOSA PLASTICS CORPORATION DELAWARE 

^<~y p o B0 X 320 . DELAWARE CITY, DELAWAFPE 19706 • TEL (302) 834-4575 

September 12, 1984 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

Robert R. French, P.E. 

Manager, Air Rosouices Section 

State of Delaware 

Department of Natural Resources 

and Environmental Control 

P. 0. Box 1401 

Dover. DE 19903 

RE: VINYL CHLORIDE MONOMER RELEASE 

FORMOSA PLASTICS CORPORATION DE 

Dear Mr. French: 

In accordance with the State of Delaware Regulations Governing the 

Control of Air Pollution, Chapter XXI, Section 13, Subsection 3.2a.l, 

Formosa Plastics is submitting this written report of a relief valve 

discharge of vinyl chloride monomer. 

NATURE AND CAUSE 

At 09C0 hours on 9/8/84, an emergency relief v?lve discharge of vinyl 

chloride monomer (VCM) occurred from S-T. reactor PR-410. The cause of 

the discharge, lasting only for approximately cne second during unseating and immediate reseating of the relief valvf-. is unknown. The attached batch chart indicates that the reactor came up to normal temperature 

and pressure of 166°F and 180 psi;;*, respectively at approximately 0600 

hours, dropped back to 164°F and 178 psig where the conditions held virtually constant for three hours. At approximately 0900 hours, well below the pressure rating of the rupture disc, and relief valve setting, 

the rupture disc failed with only a momentary release. Past experience 

has shown this type of behavior to be associated with vortex formation 

which can cause direct contact of liquid batch contents against the rupture disc, resulting in rupture disc failure v/ell below raned value, with 

or without an accompanying relief valve discharge for short duration. Thin 

discharge ir. very unusu.:]. in t:hai; all conditions were in steady-state for 

an extended period of time prior I.o tlie rupture disc failure. 

APPROXIMATE TOTAL VINYL CHLORIDE .MONOMER LOSS DURING DISCHARGE 

The approximate total VCM loss to the. atmosphere during discharge was 17 lbs. 
P.9 

Robert R. French.. .E. 1\ 2 of 2 

H. Allen Wrigley, Jr. September 12, 1984 

METHOD USED TO DETERMINE VCM LOSS 

Orifice calculations were made as shown in the attachment, based on a 

one second observed discharge. 

ACTION TAKEN TO PREVENT DISCHARGE 

Immediately upon discharge, batch stripping was commenced, with no other 

action required, since the relief valve immediately reseated. 

MEASURES ADOPTED TO PREVENT FUTURE DISCHARGES 

This discharge could not be attributed to a known cause with certainty. 

All associated systems with PR-410 were found to be normally functioning. 

HAW:jcc 

Attachments 

Sincerely, 

H. Allen Wrigley, W . 

Environmental Manager 

•••af-'-
P.10 

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~£; ~ FORMOSA PLASTICS CORPORATION DELAWARE 

w

 ' P.O. BOX 320 • DELAWARE CITY, DELAWARE 19706 • TEL (302) 834-4575 

September 5, 1984 

CERTIFIED MAIL OfST^^"^^^" ! 

RETURN RECEIPT REQUESTED ^ fi» ^ ^"j v; - ^ * 

,^H \ 

7^ SEP 15 W Robert R. French, P.E. 

Manager, Air Resources Section T ,...-

State of Delaware. ENFORCE^, Ujjt 

Department of Natural Resources ACTlVHttS SECuON 

and Environmental Control 

P. 0. Box 1401 

Dover, DE 19903 

RE: VINYL CHLORIDE MONOMER RELEASE 

FORMOSA PLASTICS CORPORATION DE 

Dear Mr. French: 

In accordance with the State of Delaware Regulations Governing the 

Control of Air Pollution, Chapter XXI, Section 13, Subsection 3.2a.l, 

Formosa Plastics is submitting this written report of a relief valve 

discharge of vinyl chloride monomer. 

NATURE AND CAUSE 

At 2315 hours on August 29, an emergency relief valve discharge of • 

vinyl chloride monomer (VCM) occurred from S-I reactor PR-401. The 

cause of the discharge was directly caused by a failure of the pressure 

alarm due to a plugged pressure pic, and indirectly through an unnoticed, accompanying temperature rise which had occurred fcr a period of 

45 minutes prior to the discharge. 

APPROXIMATE TOTAL VINYL CHLORIDE MONOMER LOSS DURING DISCIL\P.GE 

The approximate total VCM loss to the atmosphere during discharge was 

1102 lbs. 

METHOD USED TO DETERMINE VCM LOSS 

Orifice calculations were made as shown in tlie attachment, based on a 

1.5 minute disdiarge. 

ACTION TAKEN TO PREVENT DISCHARGE 

Upon discovery of tho discharge, tlie hatch was killed and stripping 

commenced using the recovery system. 
P.13 

Robert R. French, P.E. 

H. Allen Wrigley, Jr. 

September 5, 1984 

Page 2 of 2 

MEASURES ADOPTED TO PREVENT FUTURE DISCHARGES 

Investigation has been initiated into the feasibility of providing temperature alarm common to the pressure alarm systems on all 31 reactors, which 

if implemented would provide alarm redundancy in the event of occurrances 

similar to that described above. 

If you have any further questions, please do not hesitate to call me at (302) 

836-2219. 

Sincerely, 

Xj,Gte&^ 

H. Allen Wrigley, 

Environmental Manager 

HAW:jcc 

Attachment 
P.M 

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P.15 

Consolidated® Conventional Safety Relief Valve 

3-2 Formula Valve Sizing o 

Formula Symbols 

At Calculated orifice area, sq. in., as determined by 

formula 

A Valve orifice area, sq. in., Table A page 3-4 

Gcm.Q Required gas capacity SCFM @ 14.7 psia and 

G0°F 

V,.i,,W Required vapor capacity, Ibs/hr 

L«„, L Required liquid capacity, gpm at 70°F 

SG Spccilic gravity of gas (with reference lo air = 

1 at G0°F and 14.7 psia) or of liquid (with reference to water at 70°F, compressibility of liquid 

is usually ignored) at actual discharge temperature. 

M Molecular weight (average) 

Pi Flowing pressure, psia = Set pressure + overpressure + 14.7 

P. Set pressure of valve, psig 

Pb Flowing back pressure, psig 

Ti Inlet temperature absolute, °F + 460 

Ti Flowing temperature absolute, °F + 460 

7 Compressibility factor 

Ratio of specific heats, C,./C. under inlet 'flow 

condition 

ASME Nozzle gas constant, page 3-23 

Ui API Nozzle gas constant, page 3-5, 3-10, or 3-23 

P Density, lbs/ft J Air = 0.0763 lbs/ft3 at 14.7 

psia and 60°F 

B Vapor or gas correction factor for constant back 

pressures above critical pressures, page 3-6 

Vi Vapor correction factor applies to bellows 

valves only, page 3-7 

l.i Liquid correction factor applies to bellows 

valves only, page 3-7 

K. Viscosity correction factor, page 3-30 and 3-31 

Si Superheat correction factor, page 4-12 

K.. Napier factor, for dry saturated steam at set 

pressures, is listed in the Table shown below. 

Sect. 

I 

VIII 

Ace. 

10'o 

IIP. 

ler.s thnn 

1*i-1 

V-! 2-1 

K„ 

y.o" 

To" 

P. Range, 

pr.iq 

1521 to 3100 

1-i2-fto"?'*03 

K„ 

C.-JIC. 

TTk-" 

p, 

Ahovc 

N/A 

2303t " 

1 

K „ j 

1.0 | 

„ _ -190GP 

Kr — — ; 

1000 

2292P. - 10G1 

tSco Srclion VIII, Appendix XI, (oi equivalent ste.ini capacity 

•or cnll the t;tcloiy. 

Nozzle Gas Constant (C.) — A value obtained by combining the r;as constant shown in the ASMi" Code with 

the .050 No.-.*le Flow Coelliciont of the Consolidated 

Valve, Ure C, with the API fomuiki and C with the ASWC 

formula. 

The r..*ifv'ty iclicf valves aro designed, constructed, and 

tested in accordance with ASMI- Code Section I or VIII 

and Ihe capacities aro coililiod by the N.ilional Board. 

Tho AIM osilieo ,iioas shown ato the minimum areas 

designated lor the specihed lettoi orifice. Since the 

no.'./le HUMS aio nol in |!v t'V.ict same pi oner tion lor 

Formula Notes 

1. CAUTION: Use only API letter orifice areas in the 

API formula and only the actual (ASME) areas In the 

ASMI: formula. 

2. Apply factors Sr, Kn, B, Vf, K. L, and Z when 

applicable; if not applicable use factor of 1. 

For SRV's with back pressure: 

I) non bellows with constant b.p., apply "B " and 

V, = 1 

li) bellows with constant or variable b.p., apply "Vi" 

and B = 1 

3. Compressibility factor, Z applies to light hydrocarbons, see Code Section VIII, Appendix XI. 

4. API liquid formulas are stated as the ASME Code 

does not cover liquid capacities. 

5. Liquid capacity correction factors for overpressures 

other than 25% are shown on page 3-8. 

6. Gas Specific Gravity - —^ - ' • 

28.97 

O 

o 
£=£ ^ FORMOSA PLASTICS CORPORATION DELAWARE 

P.O IJOX 320 • DELAWARE CITY, DELAWARE 1970G • TEL (302) B34-4575 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

P 

September 5, 1984 

CP 0* { 

Robert R. French, P.E. 

Manager, Air Resources Section 

State of Delaware 

Department of Natural Resources 

and Environmental Control 

P. 0. Box 1401 

Dover, DE 19903 

* ** iM» 

S i ^ 

\$A 

^-

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RE: VINYL CHLORIDE MONOMER RELEASE 

FORMOSA PLASTICS CORPORATION DE 

Dear Mr. French: 

In accordance with the State of Delaware Regulations Governing the 

Control of Air Pollution,-Chapter XXI, Section 13, Subsection 3.2a.l, 

Formosa Plastics is submitting this written report of a relief valve 

discharge of vinyl chloride monomer. 

NATURE AND CAUSE 

At 0909 hours on 8/30/84 and at an unknown time during the 12 to 8 

shift on 9/2/84 the S-1 weigh tank PT-303 was overfilled due to faulty 

calibrated weigh cells, causing hydrostatting and emergency relief 

valve discharges cf vinyl chloride monomer (VCM). 

» •nypy.rvv —\f A ?PRp ••IATE TOTAL VINYL CHLORIDE MONOMER LOSS DURING DISCHARGE 

The approximate total VCM loss to the atmosphere, during the respective 

discharges was as follows: 

8/30/84: 

9/2/84: 

4 M lbs <2oc b 

Unluiowi-r^auration evidently far less than 8/30 

release, as evidenced by small amount of frost on 

relief valve which had reseated and was holding 

when discovered. 

METHOD USED TO DETERMINE VCM LOSS 

The 8/30 release of 444 lbs was based on discharge of 60 gallons by 

eyewitness estimate. The determination that the relief valve, unseated 

and a discharge, occurred on 9/?. was based on presence of small amount 

of frost on the relief valve. 
P.17 

Robert R. French, P.E. September 5, 1984 

H. Allen Wrigley, Jr. Page 2 of 2 

ACTION TAKEN TO PREVENT DISCHARGE 

Weigh cell recalibration was immediately scheduled on a priority basis, 

as is removal of extraneous piping. 

MEASURES ADOPTED TO PREVENT FUTURE DISCHARGES 

Extraneous piping which may have been interfering with weigh cell 

operation will be disconnected, and as described above, the weigh 

cells will be recalibrated before and after removal to determine 

if piping was interfering with weigh cell operation. 

If you have any further questions, please do not hesitate to call 

me at (302) 836-2219. 

Sincerely, 

{Q&£ 

H. Allen Wrigley ^/fr. 

Environmental Manager 

HAWrjcc 
P.18 

.. „__ FORMOSA PLASTICS CORPORATION DELAWARE 

\_H£ ^ PO BOX 320 • DELAWARE CITY, DELAWARE 19/06 • TEL (302) 834-4575 

August 13, 1984 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

Robert R. French, P.E. 

Manager, Air Resources Section 

State of Delaware 

Department of Natural Resources 

and Environmental Control 

P. 0. Box 1401 

Dover, DE 19903 

RE: VINYL .CHLORIDE MONOMER RELEASE 

FORMOSA PLASTICS CORPORATION DE 

Dear Mr. French: 

In accordance with tlie State of Delaware Regulations Governing the 

Control of Air Pollution, Chapter XXI, Section 13, Subsection 3.2a.l., 

Formosa Plastics is submitting this written report of a relief valve 

discharge of vinyl chloride monomer. 

NATURE AND CAUSE 

At 0045 hours on August 5, seven rupture discs on tha following equipment 

in the S-I vinyl chloride monomer (VCM) recovery system failed due to hydrostats which occurred throughout the system: 

PT300B - Vacuum pump seal water tank 

PT301A - Knockout pot 

PT301B - Knockout pot 

PT310A - Compressor seal water tank 

PT310B - Compressor seal water tank 

PT313 (west) - VCM accumulator 

PT315 - Wastewater tank 

Relief valve discharges occurred on PT300B and PT315, with fugitive 

emissions following reseating of the valves. The immediate telephonic 

report to the State of Delaware was that discharges occurred from all 

seven, but. later interviews with plant personnel indicated that the relief valves did not unseat from the other five vessels, nor did fugitive 

emissions occur from them (valves did not weep). 

The cause, of the above emissions was transfer of recovered VCM from the 

E-11 plant, to the S-I recovery accumulator (PT313) which was already nearly 

full, due to a faulty level indicator (L/l) signal, which indicated a false 

20% level. 
P.19 

Robert R. French, P.E. Augus 3, 1984 

VINYL CHLORIDE MONOMER PLEASE Page 7 

H. Allen Wrigley, Jr. 

APPROXIMATE TOTAL VINYL CHLORIDE MONOMER LOSS DURING DISCHARGE 

(• The approximate total vinyl chloride monomer (VCM) loss to the atmosphere 

during discharge was.as follows: 

PT300B vacuum seal water tank - 193 lbs 

PT315 waste water tank - 242 lbs 

METHOD USED TO DETERMINE VCM LOSS 

Orifice calculations were made as shown in the attachment, based on a four minute 

discharge. 

ACTION TAKEN TO PREVENT DISCHARGE 

Upon discovery, the waste water tank was immediately blocked in, and upon shutoff of the automatic sprinkler system, the remaining rupture discs which had 

failed were found. The entire S-I recovery system was thereupon shut down, and 

the inlet line to PT313 accumulator from E-II plant RVCM pump station (DT303) 

was blocked in. After all the remaining S-I recovery system tanks were blocked 

in, and the "all clear" signal sounded, the area was inspected and maintenance 

crews immediately began repair. 

MEASURES ADOPTED TO PREVENT FUTURE DISCHARGES 

A detailed investigation was begun immediately by management who was in the plant 

at the time conducting another investigation. It was confirmed that the L/l on 

PT313 accumulator was faulty and this will be replaced. To preclude a discharge 

from occurring in the event the L/I at PT313 should fail again, an interlock is 

being placed on the system instrumentation, which will shut the accumulator off on 

high pressure, in addition to the high pressure shutoff which already exists on 

the transfer pump. As an additional measure, the accumulator pressure indicator 

is being relocated to a position which is closer to the operator's normal field of 

vision on the main control panel, and the transfer procedure will likewise include 

monitoring of the accumulator pressure as a cross-check. 

If you have anv further questions, please do not hesitate to call me at (302) 836-

2219. 

Sincerely, 

H. Allen Wrigley, Jt 

Environmental Manager 

HAW:jcc 

Attachments 
P.20 

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APPENDIX XI 

CAPACITY CONVERSIONS FOR SAFETY VALVES 

P.21 

* UA-230 

The capacity of a safety or relief valve in terms of a 

gas or vapor other than the medium for which the 

valve was officially rated shall be dclcnnincd by application of the following formulas: ' 

For steam.• 

W,= S\.SKAP 

For Air: 

/A? 

w. CKAP^/H 

C=356 

M =28.97 

T= 520 when Wa is the rated capacity 

For any gas or vapor: 

/M W^ CKAP A/Y 

wherc 

W,~ rated capacity, pounds of steam per hour 

Wc= rated capacity, converted to pounds of air 

per hour at 60 degrees Fahrenheit, inlet temperature 

W= flow of any gas or vapor, pounds per hour 

C— constant for gns or vapor which is a function 

of the ratio of specific heats, k — cf/cv (see 

Fig. UA-230) 

A'= coefficient of discharge (sec UG-J31 (d) and 

(c)) " 

A— actual discharge area of the safety valve, 

square inches 

P~ (set pressure x 1.10) plus atmospheric pressure, pounds per square inch absolute 

A/= molecular weight 

T~ absolute temperature at inlet (degrees Fahrenheit plus 460) 

Knowing ihe onici:il ratint; capacity of a safely valve 

which is MampcJ on ilic valve, il is possible lo ilcicrniiuc 

(lie nvnall valin- of K.t in either of ihe followinp foumilas 

•n cases where ihe value of Ihcsc individual terms is not 

known: 

Ollieial Killing in Steam . 

51.51' 

Official Rating in Air 

_•_ - "'• / " 

KA

 - cfr Tt 

i'.k,i ,;,''"

 Xi,,"r fo r

 K'l is then sulv-iiiuicd in the ahovc for-

>*\ to lU-icdiiine t[,e capacity of the wfety valve in Icnns 

"""••* *l-a\ or \aivr. 

These formulas may also be used when the required 

flow of any gns or vapor is known and it is necessary 

to compute the rated capacity of steam or air. 

Molecular weights of some of the common gases 

and vapors arc given in Tabic UA-230. 

For hydrocarbon vapors, where the actual value of 

k is not known, the conservative value, k = 1.001 has 

been commonly used and the formula becomes, 

Jr = 315 KAP T 

When desired, as in the case of light hydrocarbons, 

the compressibility factor, Z, may be included in the 

formulas for gases and vapors as follows: 

W=CKAP 

Example 1: 

Given: A safety valve bears a certified capacity 

rating of 3020 lb of steam per hour for a pressure 

setting of 200 psi. 

Problem: What is the relieving capacity of that 

valve in terms of air at 100 F for the same pressure 

setting? 

Solution: 

For steam: 

W,= 51.5 KAP 

3020= 51.5 KAP 

For air: 

WB=CKAP V 

-3S6KAP V. 28.97 

460+100 

= (356) (58.5) y ^ 97 

560 

= 4750 lb per hr 

Example 

Given: It is required to relieve 5000 lb of propane 

per hour from a pressure vessel through a safety valve 

set to relieve at a pressure of P„ pounds per square, 

inch, and with an inlet temperature of 125 F. 0 

327 
tion of the system may be aulotr • or manual. 

Vent stack—A vent stack is the elevated vertical 

termination of a disposal system which discharges 

vapors into the atmosphere without combustion or 

conversion of Hie relieved fluid. 

Types of pressure relief valves 

GENERAL 

Several designs of pressure-relief devices can be 

certified and approved under Section VIII of the 

ASME Boiler and Pressure Vessel Code covering unfiled pressure vessels. These include spring loaded 

direct acting, pilot operated, and rupture disks. When 

the governing code is ANSI B31.8, USA Standard 

Code for pressure piping, gas transmission and distribution piping systems, many types of pressure entiling devices are permitted, such as monitoring regulators, series regulators, weight-loaded relief valves, 

liquid seals, etc. The discussion below is limited to 

A.SME Section VIII types of devices. 

CONVENTIONAL SAFETY RELIEF VALVES 

In a conventional safety relief valve the inlet 

pressure lo the valve is directly opposed by a spring 

closing the valve, and back pressure on the outlet 

of the valve changes the inlet pressure at which the 

valve will open. 

BALANCED SAFETY RELIEF VALVES 

Balanced safety relief valves are those in which 

the back pressure has very little or no influence on 

the set pressure. The most widely used means of balancing a safety relief valve is through the use of a 

bellows. In the balanced bellows valve, the effective 

area of the bellows is the same as the nozzle seat 

area and back pressure is prevented from acting on 

the lop side of the disk. Thus the valve opens at the 

same inlet pressure even though the back pressure 

may vary. 

• PILOT OPERATED SAFETY RELIEF VALVES 

A pilot-operated safety relief valve is a device 

consisting of two principal parts, a main valve and 

a pilot. Inlet pressure is directed to the top of the 

main valve piston, and with more area exposed to 

pressure on the top of the piston than on the bottom; 

pressure, not a spring, holds the main valve closed. 

At the set pressure the pilot opens reducing the 

pressure on top of the piston and the main valve 

goes fully open. 

At extremely low set pressures, pilot-operated 

safety relief valves are available in frietionlcss lightweight diaphragm construction in place of heavy 

pistons. 

RESILIENT SEATED SAFETY RELIEF VALVES 

When metal-to-metal seated conventional or bellows type safety relief valves are used where the 

operating pressure is close to the set pressure, some 

leakage can be expected through the scats of the 

valve (Refer to API Standard 527, "Commercial Scat 

Tightness of Safety Relief Valves with Metal-toMctal Scats"). 

Resilient scat- afety relief valves with either 

O-Ring seat seal <». plastic scat such as Teflon provide seat tightness belter than API Standard 527. 

Limitations of temperature and chemical compatibility of the resilient material must be considered when 

using these valves. 

RUPTURE DISK 

A rupture disk consists of a thin metal diaphragm 

held between flanges. The disk is designed tu rupture and relieve pressure within tolerances established by ASME Code. 

Sizing of required orifice areas 

GENERAL 

It is not the purpose of this section lo discuss determination of individual relieving rates of safety 

relief valves. An excellent reference for detennining 

individual relieving rates is contained in Section 3 

of API RP521, "Guide for Pressure Relief and Depressuring Systems". After the required relief capacity of a safety relief valve has been determined, 

it is necessary to calculate the minimum orifice area 

that the relief valve must contain. Methods of performing these calculations are outlined in this section. 

The safety relief valve manufacturers have 

standards for orifice designation and area and the 

valve body sizes which contain these orifices (API 

Standard 526, "Flanged Steel Safety Relief Valves 

for Use in Petroleum Refineries). The standard orifices available, by letter designation and area -re: 

D Orifice 

E Orifice 

F Orifice 

G Orifice 

H Orifice 

J Orifice 

K Orifice 

L Orifice 

M Orifice 

N Orifice 

P Orifice 

Q Orifice 

R Orifice 

T Orifice 

However, inar.y small safety relief valves are 

manufactured with orifice areas smaller than "D", 

and many pilot-operated types contain orifice areas 

larger than "T". 

SIZING FOR GAS OR VAPOR RELIEF. 

SONIC OR CRITICAL FLOW 

Safety relief valves in gas or vapor service may 

be sized by use of one of these equations: 

0.110 

0.196 

0.307 

0.503 

0.785 

1.287 

1.838 

2.853 

3.60 

4.34 

6.38 

11.05 

16.0 

26.0 

sq 

sq 

sq 

sq 

sq 

sq 

sq 

sq 

sq 

sq 

sq 

sq 

in 

in 

in 

in 

in 

in 

in 

in 

in 

in 

in 

in 

sq in 

sq. in 

A = 

A = 

W y/~T^ZT 

CKP , Kb y/W 

V ,/T\fW\/T 

6.32 C K P, K„ 

(3.1) 

(3.2) 

O 

o 

o 

3 

o 

\, 
A = 

VV'TVGVZ -

(3.3) 

1.175 CKP , K„ 

W = flow through valve, lb/hr 

V = flow through valve, scfm 

C — coefficient determined by the ratio of the 

specific heats of th^ i*as or vapor at standard conditions. This can be ained from Fig. 3-1 or Fig. 3-2 

K = coefficient of discharge, obtainable from the 

valve manufacturer 

A — effective discharge area of the valve, sq in. 

P, = upstream pressure, psia. This is set pressure plus overpressure plus the atmospheric pressure 

tc, n 

0.41 

0.42 

0.43 

0 4 4 

0.45 

0.46 

0.47 

0.48 

0.49 

0.50 

0.51 

0.52 

0.53 

0.54 

0.55 

0.56 

0.57 

0.58 

0.59 

0.60 

0.61 

0.62 

0.63 

0.64 

0.65 

0.66 

0.67 

0.6S 

0.69 

0.70 

c 

219.28 

221.59 

223.86 

226.10 

228.30 

230.47 

232.61 

234.71 

236.78 

238.83 

240.84 

242.82 

244.78 

246.72 

248.62 

250.50 

252.36 

254.19 

256.00 

257.79 

259.55 

261.29 

263.01 

264.72 

266.40 

268.06 

269.70 

271.33 

272.93 

274.52 

' Intcrpololed values 

Acetylene 

Air 

Ammonia 

Argon 

Benzene 

Carbon 

Carbon 

Corbon 

Chlorine 

Cyclolw 

Elhone 

Ethylene 

Helium 

Hcxanc 

disulphide 

dioxide 

monoxide 

Kane 

k, n 

0.71 

0.72 

0.73 

0.74 

0.75 

0.76 

0.77 

0.7? 

0.79 

0.80 

0.81 

0.82 

0.83 

0.B4 

0.85 

0.86 

0.87 

0.88 

0.89 

0.90 

0.91 

0.92 

0.93 

0.94 

0.95 

0.96 

0.97 

0.98 

0.99 

1.00 

, since 

c 

276.09 

277.64 

279,18 

280.70 

282.20 

283.69 

285.16 

256.62 

288.07 

289.49 

290.91 

292.31 

293.70 

295.07 

296.43 

297.78 

299.11 

300.43 

301.74 

303.04 

304.33 

305.60 

306.86 

308.11 

309.35 

310.58 

311.80 

313.01 

314.19* 

315.38* 

C becomes 

Mol wt Cp/Cv 

26 1.28 

29 1.40 

17 1,33 

40 1.66 

78 1.10 

76 1.21 

44 1.28 

28 1.40 

71 1.36 

84 1.08 

30 1.22 

28 1.20 

4 1.66 

86 1.08 

FIG 

Values of 

k, n 

1.01 

1.02 

1.03 

1.04 

1.05 

1.06 

1.07 

1.08 

1.09 

1.10 

1.11 

1.12 

1.13 

1.14 

1.15 

1.16 

1.17 

1.18 

1.19 

1.20 

1.21 

1.22 

1.23 

1.24 

1.25 

1.26 

1.27 

1.28 

1.29 

1.30 

c 

316.56* 

317.74 

318.90 

320.05 

321.19 

322.32 

323.44 

324.55 

325.65 

326.75 

327.83 

328.91 

329.98 

331.04 

-332.09 

333.14 

334.17 

335.20 

336.22 

337.24 

338.24 

339.24 

340.23 

341.22 

342.19 

343.16 

344.13 

345.08 

346.03 

346.98 

indeterminote as ci 

FIG. 

3-1 

Coefficien t C' 

k, n 

1.31 

1.32 

1.33 

1.34 

1.35 

1.36 

1.37 

1.33 

1.39 

. 1.40 

1.41 

1.42 

1.43 

1.44 

1.45 

1.46 

1.47 

1.48 

1.49 

1.50 

1.51 

1.52 

1.53 

1.54 

1.55 

1.56 

1.57 

1.58 

1.59 

1.60 

her n or k 

3 - 2 

c 

347.91 

348.84 

349.77 

350.68 

351.60 

352.50 

353.40 

354.29 

355.18 

356.06 

356.94 

357.81 

358.67 

359.53 

360.38 

361.23 

362.07 

362.91 

363.74 

364.56 

365.39 

366.20 

367.01 

367.82 

368.62 

369.41 

370.21 

370.99 

371.77 

372.55 

approaches 

Values of C for gases 

c 

345 

356 

351 

377 

327 

338 

345 

356 

352 

324 

339 

337 

377 

324 

C/3S6 

.969 

1.000 

.986 

1.059 

.919 

.949 

.969 

1.000 

.989 

.910 

.952 

.947 

1.059 

.910 

3 

Hydrochloric ocid 

Hydrogen . 

Hydrogc n sulphide 

Iso-butanc 

Methane 

Methyl 

Methyl 

alcohol 

chloride 

N-butane 

Natural gos 

Nitrogen 

Oxygen 

Pentone 

Propone 

Sulphur 

- 3 

dioxide 

k, n 

1.61 

1.62 

1.63 

1.64 

1.65 

1.66 

1.67 

1.68 

1.69 

1.70 

1.71 

1.72 

1.73 

1.74 

1.75 

1.76 

1.77 

1.78 

1.79 

1.80 

1.81 

1.82 

1.83 

1.84 

1.85 

1.86 

1.87 

1.88 

1.89 

1.90 

1.00. 

c 

373.32 

374.09 

374.85 

375.61 

376.37 

377.12 

377.86 

378.61 

379.34 

380.08 

380.80 

381.53 

382.25 

382.97 

383.68 

384.39 

385.09 

385.79 

386.49 

387.18 

387.87 

388.56 

389.24 

389.92 

390.59 

391.26 

391.93 

392.59 

393.25 

393.91 

Mol wt Cp/Cv 

36.5 1.40 

2 

34 

58 

16 

32 

1.40 

1.32 

1.11 

1.30 

1.20 

50.5 1.20 

58 

19 

28 

32 

72 

44 

64 

1.11 

1.27 

1.40 

1.40 

1.09 

1.14 

1.26 

k, n 

1.91 

1.92 

1.93 

1.94 

1.95 

1.96 

1.97 

1.98 

1.99 

2.00 

2.01 

2.02 

2.03 

2.04 

2.05 

2.06 

2.07 

2.08 

2.09 

2.10 

2.11 

2.12 

2.13 

2.14 

2.15 

2.16 

2.17 

2.18 

2.19 

2.20 

c 

356 

356 

348 

328 

346 

337 

337 

328 

345 

356 

356 

325 

331 

342 

c 

394.56 

395.21 

395.86 

396.50 

397.14 

397.78 

398.41 

399.05 

399.67 

400.30 

400.92 

401.53 

402.15 

402.76 

403.37 

403.97 

404.58 

405.18 

405.77 

406.37 

406.96 

407.55 

408.13 

408.71 

409.29 

409.87 

410.44 

41 1.01 

411.58 

412.15 

C/356 

1.000 

1.000 

.978 

.921 

.972 

.947 

.947 

.921 

.969 

1.000 

1.000 

.913 

.930 

.961 

Rev. 1976 
P.24 

ConsolidatedH) 

z-i Formula Valve

 c 

V>CP1 

bIZ 

fety Relief Valve 

ing 

'or 

Formula Symbols 

A, 

A . 

Gc„„Q 

V„„W 

Un,, L 

SG 

M 

P. 

P. 

Pb 

T. 

T, 

2 

k 

C 

C. 

P 

K. 

Sr 

Calculated orifice area, sq. in., as determined byformula 

Valve orifice area, sq. in., Table A page 3-4 

Required gas capacity SCFM @ 14.7 psia and 

60°F 

Required vapor capacity, Ibs/hr 

Required liquid capacity, gpm at 70°F 

Specific gravity of gas (with reference to air = 

1 at 60°F and 14.7 psia) or of liquid (with reference to water at 70C

F, compressibility of liquid 

is usually ignored) at actual discharge temperature. 

Molecular weight (average) 

Flowing pressure, psia — Set pressure- + overpressure + atmospheric pressure 

Set pressure of valve, psig 

Flowing back pressure, psig 

Inlet temperature absolute, °F + 460 

Flowing temperature absolute, °F + 460 

Compressibility factor, page 3-21 

Ratio of specific heats, CP/Cv under inlet flow 

condition 

ASME Nozzle gas constant, page 3-23 

API Nozzle gas constant, page 3-5, 3-10, or 3-23 

Density, lbs/ft-1 Air = 0.C763 lbs/ft1 at 14.7 

psia and 60°F 

Vapor or gas correction (actor for constant back 

pressures above critical pressures, page 3-6 

Vapor correction factor applies to bellows 

valves only, page 3-7 

Liquid correction factor applies lo bellows 

valves only, page 3-7 

Viscosity correction factor, page 3-30 and 3-31 

Superheat correction factor, page 4-12 

Napier factor, fcr dry saturated steam at set 

pressures, is listed in the Table shown below. 

Sect. 

I 

V!!! 

Acc. 

3% 

10% 

If P. 

less than 

1521 

1<!24 

K„ 

1.0 

1.0 

P, Range, 

psig 

1521 to 3100 

"i424 •72903 

K„ 

Calc. 

Calc. 

P, 

Above 

N/A 

_903f 

K„ 

/•»•*• 

1.0 

• 1906P, - 1000 

.2292P, - 1061 

tSco Section VIII, Appendix II for equivalent steam capacity 

or call the factory. 

Nozzle Gas Constant (C.) — A value obtained by combining tho gas constant shown in tho ASME Code with 

the .9;i0 Nozzle Flow Coefficient of the Consolidated 

Valve. Use C, with the API formula and C with the ASME 

formula. 

The safety relief valves are designed, constructed, and 

tested in accordance with ASME Code Section I or VIII 

and the capacities are certified by the National Board. 

The API orifice areas shown arc the minimum areas 

designated for the specified loiter orifice. Since tho 

nozzle areas arc not in the exact same propottion for 

all sizes, the calculated API capacity will vary slightly 

from tho ASME figure. 

Formula Notes 

1. CAUTION: Use only API letter orifice areas in the 

API formula and only the actual (ASME) areas in the 

ASME formula. 

2. Apply factors St, K„, B, Vr, Lt, and K. when applicable; if not applicable use factor of 1. 

For SRV's with back pressure: 

i) non bellows 'with constant b.p., apply "B " and 

Vr = 1 

ii) bellows with constant or variable b.p., apply "Vr" 

and B = 1 

i. Compressibility factor, Z applies to light hydrocarbons, see Section VIII, Appendix II. 

4". API liquid formulas are stated as the ASME Code 

does not cover liquid capacities. 

5. Liquid capacity correction factors for overpressures 

other than 25% are shown on page 3-8. 

o 

Refer to page 3-1 for Valve Sizing Sequences para. -2 . 
P.25 

f:' ^ FCmMO.'-j/. PLASTICS CORPORATION DELAY/ARE 

^H^ v.c. no>: :i?o • DEI.AWAH_ CITY. DELAWARE 19705» TEL (302) 834-1575 

August IL, 1984 

CERTIFIED MAIL 

RETURN RKCK11'T REQUESTED 

, -7-

7 "i 

Robert R. French, P.E. '•' . ... •', 

I'lHiiji^jy, Air Rer.om res Section f. '. "'\ \^> 

State of Delaware ^L 

Department of Natural. Resources V. QJ^- . 

an,-.! Environmental Control 0\P • ' ' 

P. 0. Box 1401. 

Dove?-, DE 19903 

RE: VINYL CHLORIDE MONOMER RELEASE 

FORMOSA PLASTICS CORPORATION DE 

Dear Mr. French: 

In accordance with the State of Delaware Regulations Governing the 

Control, of Air Pollution, Chapter XXI, Section 13, Subsection 3.2a.l 

Formosa Plastics is submitting this written report of a relief valve 

discharge of vinyl chloride monomer. 

MATURE AND CAUSE 

At 0100 August.4, 1984 batch S-4064 was to be transferred from S-II 

reactor SR-406 into degassing tank ST413 for stripping. The operator 

who vas to perform this instead transferred the batch in error to 

another reactor, SR41.0, which was being readied for CRT cleaning, and 

therefore open to the atmosphere via the manway on top of the reactor. 

The entire batch was transferred before the error was discovered and 

corrected. The loss of vinyl chloride monomer to the atmosphere which 

occurred was entirely through the manway as a direct result of operator 

error, and did not involve an emergency relief valve discharge or rupture disc failure. 

APPROXIMATE TOTAL VINYL CHLORIDE MONOMER LOSS DURING DISCHARGE 

2»rvl2 lbs. of vinyl chloride monomer was lost during the discharge. 

METHOD USED FOR DETERMININC THE VINYL CHLORIDE LOSS 

The vinyl c.lilorlde loss was based on a loss of all vinyl chloride in the 

vapor spare bo Tore, durin;*, and after transfer, based on initial VCM 

charged and per cent conversion durin;*', polymerisation. Since there 

war. no rupture- disc failure or relief valve discharge, the above basis 

was used with a vapor pressure calculation to determine the average 

volume fraction of VCM in solution remaining in the converted batch 

al'U'.!' livis at one at.'-ospherc pressure. Calculations and batch information a i* i! attached. -n 

• ^ 
P.26 

Robert R. French., <W. 

VINYL CHLORIDE Mi li'R RELEASE 

Augur- 1.4, 1984 

Pap.e 

ACTION TAKEN TO MINIMIZE THE RELEASE 

Immediately upon discovery, the batch was isolated by securing the 

open manway, thus preventing further atmospheric contact by the batch. 

MEASURES ADOPTED TO PREVENT FUTURE RELEASES 

The above discharge of VCM to the atmosphere was entirely one of operator error in which valve positions were incorrectly set. The operator involved was disciplined and retrained. 

In the event you have any questions, please do not hesitate to call. 

Sincerely, 

H. Allen Wrigley, Jr. 

Environmental Manager 

llAW:jcc 

Attachments '^ 

*-,H 

CC: Joseph J. Hardman ,•- <'i' <\*r.jX r ^J-" 

Ronald J. Patterso n 2*3 ' J>' fisV 

& 

j0±> 

x-4 -

5t__-*i*9 

R6.METER 

1512037 

ilWUMUB 
P.27 

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o 

it* 

VC-*-
i . }• t in vi i,|pji;i ,i.'r p / c i i mi 'tn mn I 

If 

Vt 

c. of. 

1 

«>> 

.0.'-' 

„ 

-

-

-

~-. 

c^"" 1 — 

_> 

; 

• 

•• 

. 

——————»•— — • 

i 

i -

. • • 

-

i 

j.. . "1 

• 

\ *" 

V •*" 

. 

» 

O t , V.l o.fe 0 _ 

• Vwl-rr.*'ti^vi^pi ol pvlfmcr, I* 

to 

Fij:. 5. fwilubility cf vinyl rlilrinile in pnly( vinyl cliWidc). 

<•: 

prcscnl in llic .system. AVisltin a short lime polymer separates out- lc form n third 

pli.isc because it is totally insoluble in the monomer and precipitates completely. The 

monomer is soluble in the polymer lo an extent as shown in Figure 5 where 1' is the 

volume fraction of polymer in the swollen phase and p/pu is the ratio of the actual pressure of Ihe vinyl chloride to the saturation vapor pressure. This curve is for :i Icinperatnrc of ,

r

)0°C which is :i typical value at which polymerization is carried out. Tlie 

solubility when expressed as ;i function of j'/jn, is reasonably independent of temperature. 

Figure G shows several published rets of data. (27-30) for the vnpor pressure of 

Ymyl chloride as a function of temperature. The full line represents what are believed 

to be the most accurate data, the maximum deviations of other data included i:i the 

d'mjjr.'irr. are of the order of — 10% nt C0°C. An empirical expression lias been derived 

fiont these data, the vapor pressure, p, bem;.*, ;;ivcu by eipiatiuit -1, 

' " '*• loR7»-fl + J;-M.7 a Ion r + cy ' 0 ) 

where o « O.S 120 ••'.. • 

1/ - -nr.o.D 

C « ~0.00-.M15 • " 

p « vapor picssurc in atmospheres, nbsohile. . . 

V «* te.mpeiatuie in *K , 

. Other physical properties of the monomer are j:iven in Tabic 10. 

Much nf the above information is taken fiom the nianufaeluiois' technical lilcralutc (.'HI) Mid has bi-rii obtained for tin: trchuiral r.iadc of vinyl chloride, which is only 

eWil \\\).!i"/(, pore. The impuiitirs c^mprisr. .v.r.lyhiie, (only il ft.-w parts per million if 

the polyim-malinn is not lo be alfrcled), aeetahlihyde, and hi;;her chlorinated hydro-

(M\-cmsH the monomer h*„* been mapufactund by the chf-steal mule vudn;; acetylene 
P.29 

172 CnLO»OC\U))OXF. AM) CJIi.t'JJ'.OliVDIiO " ' KUaWS 

, ' Tid.fr. ;. 1'liyi.io.l IV.n.i-iiir/i ../ Vinyl' CI.UIil,: 

». 

tfirliiii,". |>oi/iI, *0 . • . 

Jioilinr iinin'., 7('.fl mm I "j;, *C 

.trittific f;r.ivity « , • 

' 13.WC 

20/r c • • '•'* . 

up • • • 

tuifnrc Icftslon, nir, dyn/cin • . . 

-30 C C ' , i •' 

~20' C ' .'<*. . 

' -10' C • . ,'..*" • 

rptcific iir/it, cil/(j:)( eC) . . " •••.•' ; 

liquid, 20°C ; .. . * '• .-;..• 

Vf.por, 25'C , ' ; • .•;'.."- * 

Ctiticnl Icmacrntnrc, °C '*"••- '• 

Ctilircl pressure, .itm .••• . .•'•.'' 

'dielectric constant, J7;2eC • • . 

IU-AI of combustion, I.S'C, ronsf.-inl. pressure, keru/jj-mnlo. 

Ldtnl Jient of tv.ijiorntion, cnl/p 

..b P . .. . . '. : • 

.25'C : 

Ifttcnl licit of fusion, c-il/rj 

flftslipoial , . .. 

open tup, °F ' •,. 

•closed cup, "C 

. f-clf-ifctiilion temperature. *C ' • 

explosive limits in nir,* % by vol 

viocosity, liquid, cl' . 

," -<o°c .' 

' . ~30' O 

• -20' C '. . . r.** ' 

-10' C ' . . - ^ ••'A . 

Vnpor prcP-Miro .. " •'. 

•• ' 

"C * atm 

- 3 0 0.50 

'-2 0 ' 0.V7 

- 1 0 

• 0 

1.17 

1.70 

10 2.43 

°C 

20 

.10 

'50 

60 

GO 

i 

• * 

-l.*.3.7 

0.W2; 

.1.4010 

* • • 

23.87 

2?.. 27 

20.RS . 

• 

•0.3S 

'.0.203 

}!>SA 

52.7 

C.2G 

2S0.1G 

.79.63 •' 

71.20 

18.H , 

-10 3 

.-7 S 

472 

4-20 

0.3330 

0.302G 

0.27SD 

0.2503 

aim 

3.33 

4.51 

.0.04 

7.80 

0.03 

* Tlie inoit readily ifcr.il.iblc mixture is lb.il conl.iimnj; 7% vinyl chloride (1). 

pounds) bnii£ about polymerization, thus obscuring their inLcrmediatc presence, 

find liiiidei'io**, t lieii t'pi.iiiiilalivcsliidy. 

With chlorine, vinyl cliloride forms U.IMiiehloroethane. (sec p. l.'iS), and wilh 

bromine, J-r.hloio-l.^-dibioiiioeLhnne ()). In the presence of zinc chloride on silica 

{*c!, hydroi'.cn chloride comhiucs with vinyl chloride, at about IfXrC. lo give 1.1-

(lirhlnioilli.'uie (see p. MO); r.t room temperature nnd in.ahsrnro of catalysts, hydii>;*cn 

iodide, in .•.iinilur fashion, forms l-chloro-l-iodoel lunie. Sulfuryl chloride. (SO.C'l:), 

it) the piesriicc of pyiidiue, reads wilh vinyl chloride, at ordinary temperature, lo 

(•JVC 1,1,'.Mi•ieldoioi'lham- nnd 2,'J-dichloi nol banc st'lfonyl ehloiide. JJvpochlorous 

Acidimd \inyl chloride trad to yield ehloroacet.il.Ichyde, C*IC* 1TrC"11 -------O (0,0). 

)u the picseuce of nnhydiotis rihiiuiiiuut ehloiide, vinyl chloride condrmes with 

ctliyl rliloiide, nt .'i0nC, yielding the pioiliicls, l.l-diohloiorlhaiic and 1,1 ,:bl: ic.htorolutlnne. (7). At 0-6oO, vii i.v i chloride icae.ls wilh bciw.cnt:, in I ho presence of ••himiuum 
P.30 

•a 

.HS°HL 

)'i;i'.i;o:.A .'!. 

S-II V,X:f.y C/iKU 

Yr\\..:\\ N'-j. 

•p,p 

v ' ' ••) 

'•< 

p ^ ' 

,.•••'•(:ha roo C11fckojit*. 

K;;aclor Drop Valve Closed V<?S 

Slurry lic.-i:1c:r Valve Closed ' >• 

•• Charge. Pot Valves Cloned s 

A *; 1 il «i I: o r fu: a 1 P r c s s u r e ,,•»/,•) . j? IY^C 

Glycerine beve l f_ 

AMS hot;Lie Pull nnd In Plac e X— 

Jiat:ch CharL in Plac e and Pens 7 Inking 

TitC in man. a t fj * _/•___. 

Opera Lor: ___^-__r<___2___ 

''.•'.'•ICl'l. . ^ 

aw Mai; or j.o Is: Agitator Speed •/QQ&. 

•*c>i*Ix (Soln.^o./^V^) / ^ gal ' 

.tor (I) A-f-.rT gal (II) /fTf S aj .. 

>'lnnl; Quest ex 3 lb 

.1 ii.;*) nun Sulfate 

diuir, Nitrite 

5 lb 

^/ ^ gram 

lb 

litiator /H_P ' /cl lb 

lb 

lb 

•c'd VCM 

rgin VCM 

>orator: v. Hy(H'„,c,_, 

fPO QPQ - lb 

lb 

Batche s afte r Clean hip, 

Afte r Charge Checkout .-^'^•_t' J 

Set: I'oV.VTliMPKK'ATUltli: /3y/ 

Batcli leve l Before Heat-Up: ,•<' 

High Pressur e Set Poin t 

Kuplure Disc Statu s 

Operato r 

XX 

u.± s :> 

°F 

I

1

" 

_psig 

o 

. J//rfitj?< UTcrtirl natio n 

(D 

' (2) 

(3) . 

Additive. 1 

* Operator: 

« 

Dropping 

C^-H^ PSI Pressur e Drop , o r 

°F Jacke t Temper.•! Cure , o r 

Jiourj; n t poly LeriL-i-vra tvijv. 

csi ^r^c^rib) biThi? gfiM 

-ovny. (gib ) 

Degassing Tank

 s<r

~ 

Drop Valve Closed 

4 

£•/*/ 

/ ^ 

Slurr y Header Valve Closed^ 

Operator: _£-•/H" 

Z£ min 

Strippin g 

Strippin g Time 

Strippin g Temperatur e ^{A'(L3 °^ 

- * Operator: LHlJ^yL 

Blending , ' ••- ' 

Blend Tank ' STBlend Number ' S-- • 

Sample to Lab (4 o>;. jar or plastic bag) 

Operator: 

OPl-RATINC Tl MI- ACTUAL (MIN) f»T» (MIN) HI-ASON OF Mil.AY 

>sl Batch Dropped tf 

;

nt:;h Predu-ck A. 

<,><r 

:CL 

^.<X> :

>\h;h H;:0 . Pro.ntx /•: 

Other- Ingredients 

'•^•h VCM J!£^J.^'2: 

'»>;'•'.. Hcu-u p lyV : _-/< _ 

'^'•'•h Pressur e i^.op ^H^X'^ ' 

•

n,;;l> Ten,*.'nation f)'T Y ?•"<*" 

___L 

3' JMtMry** X^X?^> 

/a 15 

. cT;\ r>5 
P.31 
P.32 

"'£^: FORMOSA PLASTICS CORPORATION DELAWARE 

\~H/ P.O. ROX 320 • DELAWARE CITY, DELAWARE 19706 • TEL (302) 834-4575 

July 20, 1984 

CERTIFIED KAIL 

RETURN RECEIPT REQUESTED |*>, 

rr.V.. 

3 y.x- i 

M-''y- '"' 

Manager, Air Resources Section EJ^ ; C < : - '"'.--.-•••*.">l 

Delaware DNREC fctflTiV^ '°-uUv'' 

Robert R. French, P.E 

Manager, Air Resources Section 

P. 0. Box 1401 

Dover, DE 19903 

RE: VINYL CHLORIDE MONOMER RELEASE 

FORMOSA PLASTICS CORPORATION DE 

Dear Mr. French: 

In accordance with the State of Delaware Regulations Governing the 

Control of Air Pollution, Chapter XXI, Section 13, Subsection 3.2a.l 

Formosa Plastics is submitting this written report of a relief valve 

discharge of vinyl chloride monomer. 

NATURE AND CAUSE 

At 1645 hours on July 10, 1984, the relief valve on waste water knockout pot CT-210 on the VCM-waste water system was observed discharging. 

The rupture disc was found to have failed and was immediately blocked 

in. The estimated duration of discharge was 45 minutes, at 14.7% vinyl 

chloride monomer by analysis. 

Examination of the sequence of events Leading to the discharge indicated 

that probable cause was water which entered the CC-120 compressor causing an overload and subsequent overheating. This tripped the compressor 

motor out. 

APPROXIMATE TOTAL VINYL CHLORIDE MONOMER LOSS DURING DISCHARGE 

An orifice calculation was made yielding 56 SCFM flow as air, or 60 lbs. 

as vinyl chloride monomer, as follows: 

cu.ft. lh^. 

(56 min.air) (45 min.) (0.1.47) (0.162 cu.ft.) = 60 lbs. VCM 

ACTION TAKEN TO PREVENT DISCHARGE 

The failed rupture disc and relief valve was immediately blocked in. Our 

utilities department bas taken action to: (1) install a new temperature 

control and steam injection system for CD-210 and 211, tbe stripping columns; and (!•") installation of new temperature controls on the CC-12C 

compressor motor (motor vas delivered with incorrectly-sized temperature 
Robert R. French, P.E. 

H. Allen Wrigley, Jr. 

July 20, 1984 

page 2 of 2 

controls, or "heaters") to prevent a recurrance of premature motor 

trip-out. Investigation of feasibility of compressor CC-120 hookup to the scan-alarm system is also being conducted. 

Sincerely, 

H. Allen Wrigley, Jr. 

Environmental Manager 

HAW:jcc 
P.34 

.r^r,*^*-*- ._*-.*• 

<py\ 

*~£" FORMOSA PLASTICS CORPOii/-.,-,, .. rNT,r „,i r„. n T, pt-/ "•' p y,t DFT AWARE 

- ^ P.O. OOX 31'0 •-DELAWARE CITY. DELAWAlu ,. .. VL.)*I\.W *\i\L. 

/ /'« "tl. (30*") KM-45/5 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

July 25, 1984 JUL ''-"? ---• 

Robert R. French, P.E. 

Manager, Air Resources SecLion 

State of Delaware 

Department of Natural Resources 

nnd Environmental Control 

P.O. Box 1401 

Dover, Delaware 19903 

Dear Mr. French: 

RE: Vinyl Chloride Monomer Releaso 

Formosa Plastics Corporation, p,, | 

• W/|f(i 

P 2 8 <* -••«''-.' 3 

{-^iCi-i^r F0ruc_:i r' i:f,..;j -\;AM 

N i l till* WK iW.MV 

t: ...-<• Ici v • 

'•".i "ij'iTn 

i QH^I < o ^ <_^ ^ •^>^*^ <-_ 

rr'.ii i f<.:•••.<) 

~C^V^JL^_T- _ VCKQ.O) 

3~i 

In accordance with the State of Del.-^..,,. 

of Air Pollution, Chap 

is submitting this wr 

Nrt_ture and Cause 

ie State of Del tv. 

pter XXI S*1- ''''•'•' Regulations Governing tbe Control 

•in-nr,Y,.'nr.^

 ,<n 1 •> Subsection 3.2 a.l Formosa Plastics 

" Vinyl chloride monomer release. 

the reactor into the reactor buil •* ' \ VluV'l chloride monomer to escape from 

'>• >n\d atmosphere. 

An inspection of the bottom valve *•> ,, . 

valve together had sheared off. -»..\

 tlle studded bolts which hold the 

to n metallurgist to determine the'^\!:tUviii- valve and valve parts were sent 

waiting for a written report fron * »V!Ui?°

 o f th u failure. We are currently 

However, indications are tlie studs ^ . ""Allergist on his determination. 

"

k"l'° over-torqued. 
P.35 

Robert R. French, P.E. -2- July 25, 1984 

Approximate Total Vinyl Chloride Monomer Loss During Discbarge 

13,236 lbs. of vinyl chloride monomer was lost during the discharge. 

Method Used for Determining the Vinyl Chloride Loss 

3 

At 64 psig, PC-ILC1 = 55.5 lb./ft (assuming tank vapor space is 

• saturated with VCM) 

ST-305, accumulator tank, capacity is 4600 gallons - See attached equipment 

drawing. 

4600 gallons ( 1 ft.3 ) = 615 ft.3 

(7.48 gallons) 

Therefore, full tank holds 

(55.5 lb./ft3) (615 ft.3) = 34,133 lbs. 

Level indicator showed a 33% increase during the incident. 

34,133 lbs. x .33 = 11,264 lbs. 

came into accumulator during incident. 

Because of emergency equalizing procedure, 4,500 lbs. of the above 11,264 lbs. 

came from Reactor SR-403, which was being charged (and weighed) at the time. 

Therefore, the amount of VCM recovered from SR-402 during the incident was 

11,264 lbs. - 4,500 lbs. = 6,764 lbs. of VCM 

Therefore, amount loss (assuming negligible polymerization) 

20,000 -6,764 = 13,236 lbs. 

Action Taken to Minimize the Release 

On Thursday, July 19, 1984, batch S-3734 was charged in Reactor SR-402 at 

approximately 10:30 A.M. The batch was in its heatup cycle and had reached 

reaction temperature and pressure at 11:35 A.M. At this point in the reaction 

cycle a loud noise was heard by the operators in the reactor control room. The 

"A" Operator, Thelma Donovan, was charging vinyl chloride monomer to Reactor 

SR-403 at the time of the incident. She had pumped in approximately 4,500 lbs. 

of VCM. Upon hearing the loud noise she immediately hit the emergency shutdown 

button on the weigh tank. This shut down the VCM pumping to Reactor SR-403. 

The gas detection system sounded within seconds of the loud noise and the 

sprinkler system was activated automatically by the gas detection system. 
P.36 

Robert R. French, P.E. -3- July 25, 1984 

Jerry Johnson, the Area Manager, was in the SPVC-I reaction area at the time 

of the incident. He immediately went to the SPVC-II control room. He instructed the "B" Operator to don his self-contained breathing apparatus and 

enter the reaction area and start venting Reactor SR-402 to the VCM recovery 

system. A second "B" Operator arrived and was instructed to equalize Reactor 

SR-402 to Reactor SR-409. Reactor SR-409 was in standby. The equalization 

of the two reactors was accomplished by opening the VCM charge valves between 

the two reactors. 

Since the vinyl chloride was being released inside the reaction area, the 

decision was made to pull the emergency vent on the reactor to reduce the 

pressure on the vessel as quickly as possible, thus reducing the risk of 

fire and possible explosion. The emergency vent on Reactor SR-402 was in the 

open position for five minutes. 

At approximately 12:00 noon the vents to tlie VCM recovery system were closed 

and then reactor was vented to the evacuation jet. Once the pressure on the 

reactor reached 0 psig, the low pressure vent system was connected to the 

reactor to prevent VCM vapors from being released inside the reaction area. 

Using the Areas Continuing Monitoring System and Gas Detection System, VCM 

levels in the area were monitored and once they reached the safe level the 

sprinklers were turned off and an inspection made of the reactor. 

Additionally, the Plant's Disaster Plan was implemented. The fire department 

was called in to stand by in case of a fire or explosion. Plant personnel 

took quick action to bring the emergency condition under control. 

As a precaution until it is determined why the Pacific ball valve failed, we 

are replacing all Pacific ball valves in reactor service. 

Measures Adopted to Prevent Future Releases 

The immediate action taken was to replace the ball valve with a single bodied 

valve wherever they were used in the bottom of the Solids Addition Pots. Future measures will depend on the written report from the metallurgist on his 

findings. 

Should you have any questions or need additional information please give me 

a call. 

Sincerely, 

C. W. l'.ager^ 

Operations Manager 

CWU-.ll 

Attachments 

bec: Stephen Herrmann, Esq, 
P.37 

. ® 

A5ME X\VI ' (,L)LVC\5 -> ft 

IIP, / ,^ , / .. * 

V^ ^ 

J/Nd^v f 1 

1 ^ 4 McXE: 

• /.J? /I £ ;2o: 

i/ X •• • :. 

JACKC7- , 

C2/f^A

 HoLL5, 

' _L_ 

4SCU.-10 

(TYi'.> 

<B> 

. j^rrri^f^-4.- —-V—Til -r) 

(p^ «< —->-• p/Mr'i.ri JAcK/-:r- // ^'/l 

.'M(B) 

ELEVATION 
P.38 

•vQzrV

 FCRMOS A

 PLASTICS CORPORATION DELAWARE 

v H / P.O. BOX 320 • DELAWARE": CITV, DGtAWARE 19706 • TEt (302) 834-4575 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

Jul y 9, 1984 

RECEIVED 

Mr. Robert R. French, P.E. 

Manager, Air Resources Section 

State of Delaware 

Department of Natural Resources 

and Environmental Control 

P. 0. liox 1401 

JUL 121984 

ENFORCEMENT CASE 

ACTIVITIES SECTION 

_>«J V 

n ,3 I'P r\ n 

RE: VINYL CHLORIDE MONOMER RELEASE 

FORMOSA PLASTICS CORPORATION DE * 

Dear Mr. French: 

In accordance with the State of Delaware Regulations Governing the 

Control of Air Pollution, Chapter XXI, Section 13, Subsection 3.2a.l. 

Formosa Plastics is submitting this written report of a relief valve 

discharge of vinyl chloride monomer. 

Nature and Cause 

At 1442 hours on June 30, reactor SR-401 in the S-II plant hydrostatted, 

causing failure of a rupture disc as well as a discharge from the relief 

valve, of one to two seconds duration. A transfer of the batch was immediately initiated. Subsequent investigation revealed erratic deionized 

water (D/l) meter readings, which led to batch overcharge. The erratic 

readings were caused not by faulty D/I meters, but by a partially closed 

valve on the discharge side of the D/I meter. 

Approximate Total Vinyl Chloride Monomer Loss During Discharge 

The approximate total vinyl chloride monomer (VCM) loss to the atmosphere 

during discharge was 176 

Method Used to Determine VCM loss 

An orifice calculation was made based on a release of two seconds, the 

duration of discharge. 

Action Taken to Prevent Discharge 

Immediately upon discharge, the "A" operator initiated transfer of the 

batch to the degassing tank, with the later assist from the foreman. Confirmation of the relief valve properly reseating was then made. 
P.39 

Robert R. French, P.E. Page 2 of 2 

H. A. Wrigley, Jr. July 9, 1984 

Measures Adopted to Prevent Future Discharges 

Investigation is being conducted to quantitatively determine the 

effect of valve throttling upon the D/I meter. Operators are being 

given additional training to emphasize the effect of valve settings 

on D/I flow meter performance. 

If you have any further questions, please do not hesitate to call 

either Mr. Robert Boyer at (302) 836-2210 or myself at (302) 836-

2219. 

6k&M 

H. Allen Wrigley", 

Environmental Manager 

HAW:jcc 

CC: U. S. Environmental Protection Agency 

Region III 

6th and Walnut Streets 

Philadelphia, PA 19101 

ATTN: Mr. Ron Patterson 3AM22 
P.40 

G £>->e>e <4 o •£<* & w) uc 'A 

vJ^CtftpJ- vYI 

p-*- x) 

rt* - i/,os- *». '". 

7h' (SH 

•> -- c; 2_ _. 

I <"-v 

\~1 io /bs> <_H-^ ,v»^r* Sr*X 

£ ^ ••£"* „5 S <-"* '**",• 

V Cl~\ 

Wn •^g.- W "hry-~ 'own a r~i 
P.41 

i'l): uo;; I'A.i I;KSON OA N '.') 

'Xh ^ I'OiiiM(.).'•;A i'l Ml.TiCS CCdirO.-. .']H>li Dl i ;•• \vA11K 

HJ H p o IJOX ;i, vi» i jf i '••./,'. >i .1. oil v. r-i i PPVVAI n i :. .p. • i; i (in ',, n u vri\. 

-

 r'EIVt 

.Januar y .'0 , lOb'l 

APR 2 ?984 

SPECIAL COMPLIANCE SECTIOK" 

EPA, REG/ON III 

Mr. Robert H. French , i'.h . 

Manager, Air Re:iource.; Section 

Stat e of Delaware 

Department, of Natural Reaourcer 

a n d lrllV i !"'(. >i IliUJl il,.'i I i 'i 'ill m l 

P.O. box I'lOl 

Dover, Delaware IWi 

*' 'JAN 2 61984 

•:_ii>. 

S\..-J 

MATE OF DELAWARE 

U'.V Of li'VU'ONMENI-M C.ONIROt. 

V/ILMINCIOK OhflCE 

l.i.: Vmy L ''i: h ii'n.u- !v;wi MIII. -c Releas e 

l'V;]-|lip i;i. i '• ' La. '•!. i i:.'. i \ <l -| 'Oi 'aL i Ol / \)\\. 

Dea r Mr. l-Vench 

I n accordanc e wit h Stat e H' U-I.-.WH V !.. y u la.) ion:; hovemln g tli e Contro l o f Air l'ol'lul iuii, Chapte r X •. I , ."•••i i..n i) , .* "ul.»:*.i -i;l i< >; i •i.^a.'.l., l-'oi-imx-a 

Plastic; * l a submittin g th!.- wril.it i, I-I-J-.I-I o r ..yen (y i • I i: •.. •! i;ii-f';o;' from 

emergency relit:!.' v. 11 v -:.*. wil h viny l i -J J I > •- •»• i- • !•••.. i n U r ai n • -.phf-iv, which 

occurre d a t I'^l'i liuiii';-, -. J_ J .lanu.ar, Hi, lua' g \'<, I |. 'W i i ;g I'ailui'p- ol" bot h 

electi'ica l power' r.uop.ly aad eiik-r. .- i i>-y I«'W<I ba.-kup. 

-• " I 

Nature and Caiuie ,

 !' 

At 1.3'l'3 houru on January I'.), *.h'- ! v 'lr.var.- • "i t.y plant, a t Kormoya R'lastl cr. 

experienced a power ''ai'lure , which aimi d>...i! all power i.u the plant . l\me.rgency power fo r the S-1. an.I .)•-:' plan;..-, w... U..L aval lakh h.-.-.'nir.i' the emergency generators supplying l.hur.e pluuir li I n.|. peri'-i'm. Wi tli-. iiil. emergency 

power for agitation , th e balch-k i II h r pr• • •> mn- i::. ri' '1 I')()'.;' elT.'ctive . 

Although operators Were .;ur.m:;:Tul in v.i'i.i I i-.-.iu-'; :;>-vi-ra I r< ac' or:: a t high 

pressur e t o empty reactors, thus e .luring lb - number op release:;, seven re -

-actors blew rupture' disks. 

The S-1 emergency power i •< -n r.l-nr di : sie c .;s; u'My ..lart , but shut hewn 

on high tempei'ature due to a faulty i. raur.I'ei- switch , '..hi h pr'eventud supply 

of power to the emergency generato r cuiday ; ran. Th.-- :'--.' emergency "\>wer 

generato r did not star t due Lo a fuel iu• 1 iu-...**• 1'auit, an.I uvererauked unti l 

the batten'ie s went flat . 

Approximate 'J'otal Vinyl Chloride I'-yijoiiipj; J ,yss hiirliir I ii s d iarg_e 

The approximate tota l vinyl ehlm-hle n,> <i n HH. -r (WM) lo:'..: to the atinuaplien 

during discharg e war, l.(>,uY.' UJ:; . Iikltvhliu! leases were ar. I'ul. low:;: 
Hubert H. I'riuah 

.January .-•>, 1'iH'i 

Pa^u 'J\u> 

S-^_l'l;u}t 

V^'U-ti-jr No_. VU-'i I/'.;:; (lbs.) 

PR ''fid ' ' ""'"•To'iy.T 

PR '10'i I'.lb.M 

PR 'io;- I'jkk.o 

S-2 Plant 

"Reactor do. VCM ho:;:; ( lbs.J 

SlHllO " ' ' ':>Ci?i"\J)"' 

SR iioi r.'Ci'.sy. ,-• 

SR '108 jOO'-S.'l 

SR 'KH i\00.0 

Method Used to JX.". <• rmi.no VCM I,iy.•• 

Orific e ea'h.:'11.'ii.ii'tis were mi., v I'or a J'el eas e of one minute dui'atiun 

from rupLui'p' dis!-; ;'• iiur. l e r.-ll«-r valve j'.-ri.aL J'or each reacto r in it s 

respectiv e sl.ag.e • >!' reac t Lou. Ca ! • aflat, i > -ns an attached . 

Action Taken to IV.-ve.nl Pi :.;• ha eg. 

The production -op. rakers I'uiluWed the precedum. I»r I'oWe'i* Kail ure . 

Termination promicr. ' !'or each bai-ri: u.iiic: Ai-'L'- was, a.-.-, .i.-g lis.hed withi n ten 

(10) minutes . Addition.ij.|y , the < s nr;.1 ors w.-rc- r.ucc. ss I ,i I in transferrin g 

nuteria l from Irij'ji pressur e bati'b s I.CJ empty rcicter., , knu.; reducing th e 

number oi' releases. 

Concui'j'eni.ly will. Lb- ub>v.- i plVrts, aiid i num -• 1 i .* t *. - i •/ upon power failure , 

pi'Oductlon and iinintena.ucc pe'rs • >ni:..-1 worked quickly lo provide emergency 

power and/or rostui v norma] power I.o lb - plant . 

Measures A-kiptod t o Prevent lAilsr. • Discharges 

LimiodiaW- inve.u igatiuii condii-tcd I.v tn-hnica l i-T.'-m:; in th'• plan t 

a t the- tliix: ol' power failur e revealed a pua i.e-phas, k.iuit on th'• K--P -. 

undergroun.i I'c'p-der. 'I'his J'aulL, .i ;. ev.i.ien.-i d hy w.ul.-r l.ikrusioii ok the 

conduit, caused a Delunrva Power and Llg.nl riivui t Ln at.'.r to • > j ••- 11, shuttin g 

down al l power lo the plant . A nodikicc) L.n to th' syri..,-m, mc.-ul ly com- ,. 

pleted , allowed Asolat ion ok the I'auli iu l'e.-der line .', alh'Wln- m..loj',atl.Oll of power from DPM. to Peed r line I. 
Robei'L R. Drench 

January Pi), l-.J-'S'l 

Pago Thl'oe 

A fulf-se a Lo investigatio n was, i im, u 'dial e I.V begun, resultin g not only 

i n analysis and repair ok il-oiir. wiiich wore causativ e factors, but a task 

force assl.gui:n-ni to impj'ove bash: design ok, and procedures relatin g to , 

emergency power equipment. 

The power failur e was. simi! ir g • lb - one lhat. occurred in Jovemb-r 

l

l

Ju.' on the u u. lergmuir I load line- I'or ihe SPW area . k'.v lik-nce of simik a 

watei' intrusio n into the conduit iu v., '\\iXy kailui v led to "high pot" 

testing, of al l our underground lin>s in Spring "k '][)..]'J

ti with passing, iv -

sults. lu this ins lance , no', only will, ihe kaulled lin e l:e replaced , but 

the conduit thoroughly sealed , and a weather head Installe d tha t was not 

part oi' the origina l Insta'Plai '. .,-i. Min- P.-.'' load and .''.PVC keeder liner. 

Which Were lust.alL.-d a t the s.ine k.lin. as th e tk,1 I'eedei', but which have 

not failed , will be purged and sealed also . 

Specifi c mi i i iteiiajio • Ituiis relaip..d to I'epair and upgrade tin.: system 

area 

S-1 o ri''Wind gi nej-ai or or purchase new generator; 

0 chu i, .• • ti-an: -, l'e-r switch J'r-am fri :•'.. b>a clutc h to spring-loade d , 

elect! b-al ly Le Id l.yp. •; 

S-2 0 repair Pile.I. reservoir. 

Additionally , al l 1'uur generators in the plant .v PI ! l e tie d tog...'ther, 

SO that even "if throe ed" the Pour g-- -ms-ai. >w tailed , we would have t.b: 

capability oL' supp! y.iug'emergency p •>•;:• r to .-.II r-acLor a,';i Lat ors.. Add i 

tionally , we will ha. v.- the can..!/. !ii .- >|' m-.-.l ing an,; or all ge,,, ;-,-(tors- under 

load i n non-power failur e (normP suisl./) cudltio n ok tn. p'lanl. 

If you have any fui-thei' q; .e.s. iu:,. ..-•• . K.-: • i .1 •> •....Mil i ••*'•• : i nkermd ion , 

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P.51 

^'•^X- FORMOSA PLASTICS CORPORATION DELAWARE 

P.O. BOX 320 • DELAWARE CITY, DELAWARE 19706 • TEL (302) 634-4575 

April 4, 1984 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

Robert R. French, P.E. 

State of Delaware 

Department of Natural Resources 

and Environmental Control 

P. 0. Box 1401 

Dover, Delaware 19903 

Dear Mr. French: 

RE: NESHAP Semiannual Report of March 14, 1984: 

Addendum Report of VCM Leak from Storage 

Sphere PT-103, October 31, 1983, and Reactor 

Release November 4, 1983 

Reference the above letter report of October 31, 1983 sent to you 

regarding detection and corrective action of a VCM storage sphere 

leak, and release on November 4 of VCM from Reactor PR-403, records 

of those reports were forwarded to Delaware Environmental Control 

Offices, but inadvertently omitted from the semiannual report issued 

March 14, 1984. These reports were issued during the interim period 

of employment of previous and present environmental managers, and 

hence, were not included in files reviewed for the NESHAP report. 

We are also forwarding copies of the original reports to the U.S. 

Environmental Protection Agency, Region III offices. 

If you have any questions, please do not hesitate to call me at (302) 

836-2219. 

Sincerely, 

H. Allen Wrigley, Jr. 

Environmental Manager 

HAW/jcc 

CC: Joseph J. Hardman, P.E. /*?_£*""' 

US EPA Thomas Voltaggio**^ ^O^** ' 

*••*- £ ix _** 

'*-*», 

*^«*A** 
P.52 

Z^S ^ FORMOSA PLASTICS CORPORATION DELAWARE 

NCZ-/"^ P.O. BOX 320 • DELAWARE CITY, DELAWARE 19706 • TEL (302) 834-4575 

Octobe r 31 , 1983 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

yJ~V 

Robert R. French, P.E. 

Manager, Air Resources Section 

State of Delaware 

Department of Natural Resources 

and Environmental Control 

P.O. Box 1401 

Dover, Delaware 19903 

tfl i_L> W S* ii V Lc_ ?_^ 

APR 1 9. iy*M 

SPECIAL COMPLIANCE SECTION 

EPA, REGION II I 

Dea r Mr. French : 

RE: Excess Emission 

Storage Sphere PT-103 

October 17,. 1983 

Formosa Plastics Corporation Delaware is filing this written report 

covering the above referenced excess emission. On Monday, October 17, 1983, 

our leak technician found a pin hole leak in the 1" balance line on PT-103. 

This leak occurred due to the carbon steel line corroding near the top 

of the storage sphere. The line was electric traced and insulated. It 

is thought the corrosion rate was accelerated because the insulation was 

being watered during summer operations. It has been standard practice to 

run city water to the top of the sphere and allow the water to be distributed 

over the surface of the sphere to control the vapor pressure during unloading 

operations. 

After the leak was found, Formosa Plastics Corporation Delaware took 

the following action: 

a) An attempt was made to isolate the leak. However, the leak was 

between tlie storage sphere and the first shut-off valve on the balance 

line. 

b) Notified surrounding neighbors that we had a leak and what action was 

being taken to handle the situation. 

c) Leak technicians were assigned to provide continuous monitoring for 

the storage area, fence line and surrounding neighbors. 
P.53 

Mr. Robert R. French -2- October 31, 1983 

d) Notified the State of Delaware Air Resources Section of our leak. 

e) Fire equipment was placed in standby in case the status of the leak 

should change. 

f) Production supervision was scheduled around-the-clock to supervise 

the emptying of the storage sphere. 

It is estimated that we lost 576 pounds of vinyl chloride over a 

four day period. 

Calculation 

6# VCM/hr. x 24 hrs. x 4 days = 576 lbs.ACM. 

The following action is being taken to prevent a similar occurrence: 

1) Inspect condition and thickness of VCM outlet lines. 

2) Replace piping for balance line using stainless steel 316 instead of 

carbon steel. 

3) Install supports for piping under storage sphere. 

4) Recondition heat sensors as needed. 

5) Spot clean and paint sphere. 

6) Inspect all insulated piping at dome of sphere. 

7). Remove all valves and inspect for proper operation. 

8) Send out relief valves for reconditioning and setting. 

9) Calibrate LIT, PIT AND PI. 

10) Check and clean excess flow and fire shut-off valves. 

11) Check thickness of PT-103. 

12) Remove all insulation below cooling crown on PT-103. 

13) Open, inspect and clean storage sphere PT-103. 

14) Unplug 2" evacuation line to PT-103. 
P.54 

Mr. Robert R. French -3- October 31, 1983 

It is felt the above action will place the storage sphere in good 

operating condition. This type of inspection will be performed periodically 

to assure the storage sphere is in good operating condition at all times. 

If you should have any questions or need additional information, please 

give me a call. 

Sincerely, 

CWH/mah 

^.VSN\C, 

C. W... Ha ger 

Administration MaT 
P.55 

"

/

- ^ V FORMOSA PLASTICS CORPORATION DELAWARE 

P.O. BOX 320 * DELAWARE CITY. DELAWARE 19706 • TEL (302) 834-4575 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

November 4, 1983 

Joseph J. Hardman, P.E. 

State of Delaware 

Department of Natural Resources 

and Environmental Control 

Division of Environmental Control 

P.O. Box 1401 

Dover, DE 19903 

RE: Excess Emission - Batch P-6362 

November 4, 1983 

Dear Mr. Hardman: 

Formosa Plastics Corporation of Delaware is reporting to your 

office an estimated loss of 2800 pounds of vinyl chloride to 

the atmosphere during the heat-up of this batch in reactor 

PR-403. The cause of this loss was the premature failure of 

the pressure relief system. When the pressure reached 185 

psig the release.began and lasted one to two minutes. The 

previous batch in this reactor reacted at 195-200 psig without any problem. The rupture disc and relief valve are being 

replaced. 

If there are any further questions pertaining to this incident, 

please feel free to contact me. 

Sincerely, 

Carl E. Subrick ^'-*<-.V?&.D 

Temporary Associate Regulatory „D 

Affairs Specialist ^ K ] 2 ]%q 

CES:11 ^sssr 
P.56 

/ 

I^3S ^ FORMOSA PLASTICS CORPORATION DELAWARE 

\j£/ P.O. BOX 320 • DELAWARE CITY. DELAWARE 1&706 • TEL (302) 834-4575 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED nr. r. 

r* 

December 22 , 1983 

•a-.-: ;*t •-. ->• .--^s »"**? K 

Robert R. French, P.E. flCWl^-i i to C^i^J 

Manager, Air Resources Section /A/>*\ . 

Delaware Department of Natura l Resources APR 1 1 1MW4 0 '!)£"•-" 

and Environmental Control

 H TM L L l3C H / 

P.O. Box 1401 

Dover, Delawar e 19901 SPECIAL COMPLIANCE SECTION 

EPA, REGION III 

R E: Vinyl Chloride Monomer Release 

Formosa Plastics Corporation DE 

Dear Mr. French: 

Formosa Plastics Corporation Delaware is filing this written report regarding 

an emergency release to the atmosphere of approximately 388 pounds of reactant 

containing an estimated 109 pounds of vinyl chloride monomer. No discharge 

occurred to the atmosphere from a manual vent valve or relief valve. 

Nature and Cause: 

Approximately two hours into the batch reaction in reactor SR407, the agitator 

shaft coupling failed. The batch was immediately killed, however, the shortstop 

w as not totally effective due to a total lack of agitation. 

In order to prevent a relief valve discharge, a slow transfer of the batch to the 

ST413 degassing tank started, during which time a gasket*on Gorator SG400W failed. 

Corrective action was immediately taken, but not before the header partially de -

pressured from 120 psig. 

Date and Time: 

Saturday, December 17 , 1983 at 1045 hours. 

Approximate Total VCM Loss During Discharge: 

An estimated 109 lbs. of vinyl chloride monomer was released in the immediate 

vicinity of a Bacharach sensor, activating the sprinkler System. 
Robert R. French, P.E. -2- December _, 1983 

Method Used for Determining VCM Loss: 

Calculations are attached. 

Action Taken to Prevent Discharge: 

Prior to the Gorator gasket failure, a slow transfer of the shortstopped batch 

was attempted to prevent runaway polymerization and an accompanying relief 

valve discharge. No disk rupture occurred due to immediate action by the operators; however, the transfer was premature in that the transfer was attempted 

above the Gorator operating pressure rating of 100 psig. 

Measures Adopted to Prevent Future Discharge: 

The above incident was ultimately caused by a mechanical failure of the agitator, 

and is considered a highly unusual occurrence which led to an unavoidable release. Operators have been cautioned to not attempt such corrective action until 

the reactor pressure is at or below 100 psig. 

Corrective maintenance was performed on both the agitator and the Gorator. 

If you have any further questions, please do not hesitate to contact me at 836-

2219. 

Sincerely yours,^\\y 

fliy2^c^<HX^ 

H. Allen Wrigley, Jr. 

Environmental Manager 

HAW:11 

Attachment 

cc: Joseph Hardman, P.E. 
X?/'7/f3 ..__.;_ 

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P.59 

6><* r*<j3'*+ 

FORMOSA PLASTICS CORPORATION DELAWARE 

P.O. BOX 320 • DELAWARE CITY, DELAWARE 19706 • TEL (302) 834-4575 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

REC i_ 

"• ':* * t 

_ :._ ».p* 

November 23, 1983 APR 11 1984 Ar,-

SPECIAL COMPLIANCE SEC. ION 

EPA, REGION II I 

6 rX 

SIAW Of -**** * 

tf 

Robert R. French, P.E. 

Manager, Air Resources Section 

Delaware Department of Natural Resources 

and Environmental Control 

P.O. Box 1401 

Dover, Delaware 19903 

Dear Mr. French: 

r.-

 : .--••• •X'H. H 

I'. . Mi l 

DEC! 1983 i ! • \ •u 

I 1 

Tt i'A 

,.N_ I : .-t _..i ; 

.•JNJitOL 

RE: Vinyl Chloride Monomer Release 

Formosa Plastics Corporation DE 

'In accordance with National Emission Standards for Hazardous Air Pollutants, 

Part 61 of Chapter I, Title 40, Section 61.65(a) Relief Valve Discharges, 

Formosa Plastics Corporation, Delaware makes the following report concerning 

the above referenced release. 

The address of the source: 

Formosa Plastics Corporation, Delaware 

P.O. Box 320 

Schoolhouse Road 

Delaware City, Delaware 19706 

Source of Release: Suspension Plant SPVC-I 

A. Nature of Cause: 

Batch P-6632 was charged at 01:45 hours on November 20, 1983 in Reactor 

PR-403. In reviewing the batch chart, the reaction pressure rose and 

leveled off at 184 psig. At approximately 03:30 hours, the rupture 

disc failed and the relief valve opened and released a mixture of water, 

suspending agent and vinyl chloride to the atmosphere. 

An investigation was made and it was determlnned the rupture disc failed 

prematurely at 184 psig based on pressure PIC and local gauge readings. 
P.60 

Robert R. French, P.E. 

Vinyl Chloride Monomer Release 

Page Two 

B. Date and Time of Release: 

Sunday, November 20, 1983 at 03:30 hours 

C. Approximate Total Loss of Vinyl Chloride: 

Nine hundred thirty-four (934) pounds of vinyl chloride released 

D. Method Used to Determine Amount: 

A visual observation of the reactor contents indicated that approximately 

three feet were lost. Normally the amount of the release can be calculated based on the amount of vinyl chloride recovered in our recovery system and the amount of vinyl chloride converted to Polyvinyl Chloride. 

Since the level in the recovery was at the zero level mark, we were unable to use this method. 

Our calculation of the loss is as follows: 

Safety valve size: 4" x 6" 

Orifice Area: 6.38 inches2 

W-CKAP 

\J ZT 

(0/Hour) 

k- CP/CN for C2H CL -1.2 

C» 335 

K- 0.97 

A- 6.38 

P- (193+164)/2 + 14.7 - 193.2 

M- 62.5 

Z= 0.92 

!•f __ _ 152° _ fF « -= 612° OJ._ KR I " ' 

W- (335) (0.97) (6.38) (193.2) / 62.5 

V (0.92)(612) 

133448.8 #/hr. - 22240/minute 

E. 

It is estimated that the safety valve was opened for 1 minute. 

The amount of vinyl chloride charged to the reactor is equal to 

422 of total ingredients charged. 

(2224#/min.) (1 minute) (0.42) - 934 lbs. of vinyl chloride released 

Action Taken to Minimize Discharge: 

1. Batch was terminated 

2. Stripping operations started to recover monomer 

3. Relief valve reseated 
P.61 

Robert R. French, P.E. 

Vinyl Chloride Monomer Release 

Page Three 

F. Measures Adopted to Prevent Future Discharges: 

1. Configuration of reactor changed 

2. Contacted manufacturer of rupture disc and they recommended that 

operating conditions should not exceed 90% of rupture disc design 

pressure 

If there are further questions concerning this matter, please contact me. 

Sincerely, 

^5)\oT ^ 

C. W. Hager 

Administration Manager 

CWH:11 
P.62 

FORMOSA PLASTICS CORPORATION DELAWARE 

P.O. BOX 320 • DELAWARE CITY. DELAWARE 19706 • TEL (302) B34-4575 

CERTIFIED MAIL 

RETURN RECIEPT REQUESTED 

^ aasoi ••"'J*: .*•-

\vtfi' 

October 7, 1983 

Robert R. French, P.E. 

Manager, Air Resources Section 

Stat e of Delaware 

Department of Natura l Resources 

and Environmental Control 

P.O. Box 1401 

Dover, Delaware 19903 

•s, *w*^ -*-••"" .^- •:** " "•"

 :i--"'"*"1 

m '-<UE ? L-C-i^. ii _" • 

APR 11 Ito 

D 

i'tt-i'.* 

XW<£ Oc r 13, *3 

UA_*. OHUJU 

SPECIAL COMPLIANCE SECTION 

EPA, REGION II I 

RE: Excess Emission - Batch S-5195 

October 4 , 1983 

Dear Mr. French: 

Formosa Plastics Corporation of Delaware is reporting to your office an estimated 

loss of 1000 pounds vinyl chloride to atmosphere during the transfer of this 

completely polymerized batch from reactor SR-405 to degassing tank ST-412 for 

the stripping operation to remove the remaining unreacted vinyl chloride. The 

cause of this loss was both the failure of the operator to close the EDC valve 

and the leaking through of a second valve. This valve in question has been 

repaired. Also, the operator who made the error is being given disciplinary 

action. 

If there are further questions pertaining to this incident, please feel free 

to contact- me. 

Sincerely, 

CUM~#- fa 

Charles A. Markowitz 

Associate Regulatory 

Affairs Specialist 

CAM:11 
P.63 

-_SN F JRMOSA PLASTICS CORPORATION DELAWARE 

.'.O. BOX 320 • DELAWARE CITY, DELAWARE 19706 • TEL J302) 834-4575 

June 30, 1983 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

Robert R. French, P.E. 

Manager, Air Resources Section 

Delaware Dept. of Natural Resources 

and Environmental Control 

P.O. Box 1401 

Dover, DE 19901 

Dear Mr. French: 

RE: Vinyl Chloride Monomer Release 

Formosa Plastics Corporation DE 

In accordance with National Emission Standards for Hazardous Air 

Pollutants, Part 61 of Chapter I, Title 40, Section 61.65(a) Relief Valve 

Discharges, Polyvinyl Chloride Plant located at Delaware City, Delaware; 

the address for this source: 

P. 6. Box 320 

Schoolhouse Road 

Delaware City, DE 19706 

Source of Release: 

Suspension-II Area 

A. Nature of Cause: 

Batch S-3303 was charged in reactor SR-410 at 5:45 a.m. on June 21, 1983. 

At approximately 7:45 a.m., the reactor's relief valve opened because of 

high pressure and discharged about 1/5 of the batch into the atmosphere. 

The cause of this discharge was a faulty pressure transmitter which did not 

warn operating personnel of the fact that high pressure was present. 

B. Date and Time: 

Tuesday, June 21, 1983 at 0745 hours. 

^ \m > 

Pi/ 

D^Ar»ni-. ^ "'' " :* -'X-

'!* • %X v. "<> 

ML S1383 \ \ * 

" ' " ' .'u - ; ; • ••• ; p •-.. . • : ,- , ... ,, u 

% / ^ 
P.64 

Robert R. French, P.E. -2- June 29, 1983 

C. Approximate Total Loss of Vinyl Chloride: 

Two thousand four hundred eight (2,408) pounds of vinyl chloride 

discharged to atmosphere. 

D. Method Used to Determine Loss: 

From the time that the discharge took place, it is estimated that 30% 

conversion took place. Observation of the liquid level remaining in the 

reactor indicate about 20% of the batch was lost to atmosphere. 

17,200 - Lbs. VCM charged in reactor 

5,160 - Lbs. VCM converted to PVC 

12,040 - Lbs. VCM unreacted in reactor 

2,408 - Lbs. VCM discharged to atmosphere 

9,632 - Lbs. VCM in reactor after discharge 

30% - conversion VCM to PVC 

E. Action Taken to Prevent Discharge: 

Instrument failure did not warn operating personnel of high pressure 

conditions in order to take corrective actions. 

F. Measures Adopted to Prevent Future Discharges: 

1, Pressure transmitter has been repaired. 

2, Operating personnel and supervisors have been advised to this incident and to examine batch operating conditions for similar instrument failure 

and to take necessary corrective actions. 

3, The operating procedure for control of hot batches will be reviewed 

and changed to meet the present needs of the plant. 

If there are further questions pertaining to the information submitted, 

please feel free to contact me. 

Sincerely, 

Charles A. Markowitz 

Associate Regulatory Affairs 

Specialist 

CAM/mah 
P.65 

FORMOSA PLASTICS CORPORATION DELAWARE 

P.O. BOX 320 • DELAWARE CITY, DELAWARE 19706 • TEL (302) 834-4575 

July 8, 1983 

R E C 

VA, v 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED mi I 5 IQ til 

Robert R. French 

Manager, Air Resources Section 

Delaware Dept. of Natural Resources 

and Environmental Control 

P.O. Box 1401 

Dover, DE 19901 

Dear Mr. French: 

EPA, REGiu {

'ii ill 

&:>/.'( 

RECEIVED 

JUL I \ 1983 

OFFICE Of RE6I0HAL 

RE: Vinyl Chloride Monomer Release 

Formosa Plastics Corporation Delaware 

In accordance with National Emission Standards for Hazardous Air 

Pollutants, Part 61 of Chapter I, Title 40, Section 61.65(a) Relief Valve 

Discharges, Polyvinyl Chloride Plant located at Delaware City, Delaware; 

the address for this source: 

P.O. Box 320 

Schoolhouse Road 

Delaware City, DE 

Source of Releases: 

Release No. 1: Suspension-II Plant 

Release No. 2: Emulsion-II Plant 

19706 

A, Nature of Cause ; 

Release No.-l: Batch S-3447 was charged at 2130 hours June 30, 1983 

in reactor SR-409. At approximately 2 330 hours, a vinyl chloride 

release of short duration took place through the relief valve because 

of high pressure. Reactor chart indicated that batch temperature did 

not pass 100°. F nor batch pressure above 140 psig. Investigation of 

. instrumentation afterwards indicated that the pressure pik fluid had 

leaked and temperature calibration was off. 

PH n> .- ' ! t r 

ML 15 WQ3 

Alii t 'nuofwiiv.^ 

BM mtnXiXnti) 
P.66 

Mr. Robert R. French -2- July 8, 1983 

Release No. 2: Batch D-1618 was charged at 1330 hours on July 3, 1983, 

in reactor DR-408. Pressure rise continued past 200 psig on batch chart. 

Examination of rupture disk indicates that it was only cracked, thereby 

considerably constricting any release which would have occurred. Local 

pressure gauge at the time of release was 245 psig. Observations of 

vent pipe of DR-408 was that cream-like material could be seen being 

emitted. 

B. Date and Time of Release: 

Release No. 1: Thursday, June 30, 1983 at 23 30 hours 

Release No. 2: Sunday, July 3, 1983 at 1410 hours 

C. Approximate Total Loss of Vinyl Chloride: 

Release No. 1: Less than one hundred *(100) pounds of vinyl chloride 

released to atmosphere. 

Release No. 2: Less than one hundred (100) pounds of vinyl chloride 

released to atmosphere. 

D. Method Used to Determine Amount: 

Release No. 1: Because of the short duration (a few seconds), the 

facts that reaction liquid level was unchanged and no slurry could be 

seen in the area, it is estimated that less than 100 lbs. of VCM was 

lost. 

Release No. 2: Because of the rupture disk having only a small crack 

and the visual observations of release, it is estimated that less than 

100 lbs. of VCM was lost. 

E. Action Taken to Minimize Discharge: 

Release No. 1: 

(1) Once high pressure condition was realized, batch was terminated. 

(2) Stripping operation to reduce pressure was then, immediately started. 

Release No. 2: 

(1) Reactor DR-408 batch was partially transferred to an empty reactor 

DR-401 to reduce pressure. 
P.67 

Mr. Robert R. French -3- July 8, 1983 

F. Measures Adopted to Prevent Future Discharges:. 

Release No. 1: 

(1) Instrumentation on'this reactor was repaired and recalibrated. 

(2) The pressure test procedure is being modified to include a 

check of the local pressure gauge vs. instrument pressure to 

confirm instrument accuracy. 

(3) All other reactor instrumentation has been inspected and recalibrated for proper operation. 

(4) Operators have been reinstructed as to the proper setting of 

high pressure set point alarm. 

Release No. 2: 

(1) Rupture disk has been sent back to the supplier for inspection. 

(2) The catalyst that was used will be checked for activity before 

it is used in production. 

If there are further questions concerning this matter,' feel free to 

contact me. 

Sincerely, 

d/*^.f. ^^Wjf 

Charles A. Markowitz •<=_r-' 

Associate Regulatory Affairs 

Specialist 

CAM/mah 

cc: Mr. 

Mr. 

Mr. 

Mr. 

Stan Leskowski, EPA 

Joe Hardman, DE DNREC 

Yen-Ho Huang, FPC NJ 

Robert Boyer, FPC DE 
P.68 

(fcXX iV 

^^^. FORMOSA PLASTICS CORPORATION DELAWARE 

\ & S P.O. BOX 320 • DELAWARE CITY, DELAWARE 19706 • TEL (302) 834-4575 

$et>^ 

August 26, 1983 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

RECEIVED 

AUG9-9 1983 

EPA, REGION III 

mi Of RtGlOiiM AOMINISIRATM 

Robert R. French, P.E. 

Manager, Air Resources Section 

Delaware Department of Natural Resources 

and Environmental Control 

P.O. Box 1401 

Dover, Delaware 19901 

Dear Mr. French: 

RE: Vinyl Chloride Monomer Release 

Formosa PI istics Corporation DE 

In accordance with National Em;ssion Standards for Hazardous Air 

Pollutants, Part 61 of Chapter I, Title 40, Section 61.65(a) Relief Valve 

Discharges, Polyvinyl Chloride Plant located at Delaware City, Delaware; 

the address for this source: 

P.O. Box 320 

Schoolhouse Road 

Delaware City, DE 19706 

Source of Release: Emulsion-II Plant 

A. Nature of Cause: 

Batch D-2109 was charged at 1130 hours on August 17, 1983 in reactor 

DR-401, An examination cf the batch chart at 1700 hours indicated that 

the batch had stopped polymerizing. This brought about an investigation 

of the catalyst charge system. For emulsion batches, two solutions R10 

(acid) and C2 (peroxide) are introduced concurrently into the reactor 

which are used to initiate the reaction. It was found that the R10 line 

was plugged. Two increments of h lb. R10 was added followed by h lb. and 

1 lb. to help try to start the reaction. At the time the R10 tank was 

being remade, the rupture disk blew and relief valve lifted discharging 

n 

IC 

RECEIVED 

SEP 0 8 1983 

AIR MOMTORING 

RECEIVED RECEIVED 

AUG 31 1983 

EPA-FNVihO^.-^L 

SERViCtS DiVtSiON 

SEP 15 1983 

SPECIAL COMPLIANCE SECTIOH 

EPA, REGION II I 
P.69 

/ 

/ 

J 

Robert R. French, P.E. -2 - August 26, 1983 

vinyl chloride to atmosphere. Batch pressure indication was only showing 

140 psi at the time of discharge and only increased to 155 psig before 

dropping off to zero when the batch was terminated and stripped off. 

B. Date and Time of Release: 

Wednesday, August 17 at 1930 hours. 

C. Approximate Total Loss of Vinyl Chloride: 

Three hundred thirty (330) pounds of vinyl chloride released to 

atmosphere. 

D. Method Used to Determine Amount: 

A visual observation of reactor solution indicates that 2S feet were 

lost. This is equivalent to 530 gallons (7.8 lb./gal.) or 4,130 lbs. of 

solution of which 60% is water and 40% VCM, PVC, soap (1,653 lbs.). It 

is estimated that the batch conversion was 60% which would amount to 660 

lbs. unreacted vinyl chloride monomer, of which it is estimated that one-half 

was discharged to the atnipsphere and the other half to the recovery system. 

E. Action Taken to Minimize Discharge: 

(1) Once high pressure condition was realized, batch was terminated 

with -methylstyrene (AMS). 

(2) Stripping operation to reduce pressure was immediately started. 

F. 'Measures Adopted to Prevent Future Discharges: 

(1) Instrumentation on this reactor was repaired and recalibrated. 

(2) Operation of catalyst charging has been changed to specify that 

both C2 and R10 must be introduced together. If there is an interruption 

of flow for either C2 or R10, then the other one will be halted until the 

problem can be solved. 
P.70 

Robert R. French, P.E. -3- August 26, 1983 

If there are further questions concerning this matter, feel free to 

contact me. 

CAM/mah 

cc: Mr. Leskowski 

EPA, Region III 

^_wi-^.^?a«^C 

Charles A. Markowitz 

Associate Regulatory Affairs 

Specialist 
P.71 

^ S ^ FORMOSA PLASTICS CORPORATION DELAWARE 

^^£s P.O. BOX 320 • DELAWARE CITY, DELAWARE 19706 • TEL (302) 834-4575 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

August 13, 1984 

Mr. Ronald J. Patterson, 3AM22 

U.S. Environmental Protection Agency, 

Region III 

Sixth and Walnut Streets 

Philadelphia, Pennsylvania 19106 

Dear Mr. Patterson: 

Please find enclosed a copy of our July 25, 1984 report issued to 

the State of Delaware, Department of Natural Resources and Environmental Control, Air Resources Section. This was apparently not forwarded to your office during my absence from the plant. 

Also attached is a copy of the metallurgical report mentioned in the 

penultimate paragraph of the July 25 report, received subsequent to 

that date, and forwarded to Mr. Joseph Hardman today. 

If you have any questions, please call me at (302) 836-2219. 

Sincerely, 

H. Allen Wrigley, Jr. 

Environmental Manager 

HAW:ek 

Attachment 

c c . Joseph J. Hardman, P.E., 

Delaware (Air Resources Section) 
P.72 

XX FORMOSA PLASTICS CORPORATION DELAWARE 

Xt/ ' P.O. BOX SIX) • DELAWARE CITY, DELAWARE 19706 • TEL (302) 834-4S75 

CERTIFIED MAIL 

_RETUW*_ JUXE_ir_T .J}Ji_y_iiSTED 

July 25i 1984 

Robert R. French, P.E. 

Manager, Air Resources Section 

State of Delaware 

Department of Natural Resources 

nnd Environmental Control 

T.O. Box 1401 

Dover, Delaware 19903 

Dear Mr. French: 

RE: Vinyl Chloride Monomer Release 

Formosa Plastics Corporation Delaware 

In accordance with the State of Delaware Regulations Governing the Control 

of Air Pollution, Chapter XXI, Section 13, Subsection 3.2 a.l Formosa Plastics 

is submitting this written report of a vinyl chloride monomer release. 

Nature and Cause 

On Thursday, July 19, 1984 hatch S-3734 was charged in Reactor SR-402. at 

approximately 10:30 A.M. The batch vas in its heatup cycle and had reached 

reaction temperature and pressure at 11:35 A.M. At this point in the reaction cycle the bottom valve on the. Solids Addition Pot failed. This valve 

failure allowed water, PVC resin and vinyl, chloride monomer to escape from 

the reactor into the reactor building and atmosphere. 

An inspection of the bottom valve showed the studded bolts which hold the 

valve together had sheared off. The studs, valve and valve parts were sent 

to a metallurgist to determine the cause of the failure. We arc currently 

waitint*. ft*"" n written report from the metallurgist on his determination. 

However, indications arc the studs were ovcr-torqucd. 
P.73 

Robert R. French, P.E. -2- July 25, 1984 

Approximate Total Vinyl Chloride Monomer Loss During Discharge 

13,236 lbs. of vinyl chloride monomer was lost during the discharge. 

Method Used for Determining the Vinyl Chloride Loss 

3 

At 64 psig, PC„H„C1 =55.5 lb./ft (assuming tank vapor space is 

saturated with VCM) 

ST-305, accumulator tank, capacity is 4600 gallons - See attached equipment 

drawing. 

4600 gallons ( 1 ft.3 ) = 615 ft.3 

(7.48 gallons) 

Therefore, full tank holds 

(55.5 lb./ft3) (615 ft.3) = 34,133 lbs. 

Level indicator showed a 33% increase during the incident. 

34,133 lbs. x .33 = 11,264 lbs. 

came into accumulator during incident. 

Because of emergency equalizing procedure, 4,500 lbs. of the above 11,264 lbs. 

came from Reactor SR-403, which was being charged (and weighed) at the time. 

Therefore, the amount of VCM recovered from SR-402 during the incident was 

11,264 lbs. - 4,500 lbs. = 6,764 lbs. of VCM 

Therefore, amount loss (assuming negligible polymerization) 

20,000 -6,764 = 13,236 lbs. 

Action Taken to Minimize the Release 

On Thursday, July 19, 1984, batch S-3734 was charged in Reactor SR-402 at 

approximately 10:30 A.M. The batch was in its heatup cycle and had reached 

reaction temperature and pressure at 11:35 A.M. At this point in the reaction 

cycle a loud noise was heard by the operators in tlie reactor control room. The 

"A" Operator, Thelma Donovan, was charging vinyl chloride monomer to Reactor 

SR-403 at the time of the incident. She had pur.iped in approximately 4,500 lbs. 

of VCM. Upon hearing the loud noise she immediately hit the emergency shutdown 

button on the weigh tank. This shut down the VCM pumping to Reactor SR-403. 

The gas detection system sounded within seconds of the loud noise and the 

sprinkler system was activated automatically by the gas detection system. 
P.74 

Robert R. French, P.E. -3- July 25, 1984 

Jerry Johnson, the Area Manager, was in the SPVC-I reaction area at the time 

of the incident. He immediately went to the SPVC-II control room. He instructed the "B" Operator to don his self-contained breathing apparatus and 

enter the reaction area and start venting Reactor SR-402 to the VCM recovery 

system. A second "B" Operator arrived and was instructed to equalize Reactor 

SR-402 to Reactor SR-409. Reactor SR-409 was in standby. The equalization 

of the two reactors was accomplished by opening the VCM charge valves between 

the two reactors. 

Since the vinyl chloride was being released inside the reaction area, the 

decision was made to pull the emergency vent on the reactor to reduce the 

pressure on the vessel as quickly as possible, thus reducing the risk of 

fire and possible explosion. The emergency vent on Reactor SR-402 was in the 

open position for five minutes. 

At approximately 12:00 noon the vents to the VCM recovery system were closed 

and then reactor was vented to the evacuation jet. Once the pressure on the 

reactor reached 0 psig, the low pressure vent system was connected to the 

reactor to prevent VCM vapors from being released inside the reaction area. 

Using the Areas Continuing Monitoring System and Gas Detection System, VCM 

levels in the area were monitored and once they reached the safe level the 

sprinklers were turned off and an inspection made of the reactor. 

Additionally, the Plant's Disaster Plan was implemented. The fire department 

was called in to stand by in case of a fire or explosion. Plant personnel 

took quick action to bring the emergency condition under control. 

As a precaution until it is determined why the Pacific ball valve failed, we 

are replacing all Pacific ball valves in reactor service. 

Measures Adopted to Prevent Future Releases 

The immediate action taken was to replace the ball valve with a single bodied 

valve wherever they were used in the bottom of the Solids Addition Pots. Future measures will depend on the written report from the metallurgist on his 

findings. 

Should you have any questions or need additional information please give me 

a call. 

Sincerely, 

C. W. Hager^ \ 

Operations Manager 

CW11:11 

Attaclinients 

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4020 NEW CASTLE AVENUE'P.O f"OX 1M1 • WILMINGTON. DELAWARE 19899 • 302-&SS-73^0 

August 6, 1984 

FORMOSA PLASTICS CORPORATION 

Schoolhouse Road 

Delaware City, DE. 19706 

ATTENTION: MR. KEN KERNS 

REFERENCE: P.O. No. 07336 Lehigh Project No. 786-84 

Dear Mr. Kerns: 

We have examined a 3" cast stainless steel ball valve which you 

recently delivered to the laboratory to determine tne reason 

for failure. It was reported that the valve failed during 

service when eight stud bolts attaching a flange to one end of 

the valve failed suddenly , and apparently simultaneously. The 

valve was located on top of a vinyl chloride reactor operating 

at 130 psi pressure, and 180°F, at the time of failure. It is 

used to charge raw materials to the reactor in a batch-type 

operation. Failure of the valve, which resulted in complete 

separation of the top flanged joint, allowed some portion of 

the chemical reactants to spill into the surrounding 

atmosphere. 

The following report describes the results of the laboratory 

examination of the failed valve components. 

EXAMINATION OF VALVE BODY: 

The failed 

seat rings 

the valve 

ball plug, 

floor next 

dent appar 

also dente 

is fitted 

have to be 

be ejected 

were compl 

valve body is shown in F 

, and portions of the bro 

failed at the flange, int 

and the two Teflon seats 

to the reactor. The bal 

ently caused by an impact 

d and deformed by the fai 

to the shaft by an elonga 

rotated to a closed, or 

through the failed end o 

etely broken as shown. 

i 

k 

gure 

en s 

ernal 

. r-l . 

1 

t 

Th 

was 

Th 

ure. 

ed s 

nearl 

t

: the 

1, wi 

tuds a 

press 

ese wc 

damag 

e Tefl 

Beca 

lot, t 

y cl os 

valve 

th two Teflon 

nd nuts. When 

ure ejected the 

re found on the 

ed by a deep 

on rings were 

use the ball plug 

he valve would 

ed position, to 

. All eight studs 

Figure 2 is a side view of the valve showing the bottom flange 

(the side closest to tlie reactor) still intact, and "hard" 

against the mid-body of the valve. None of the studs for tho 

bottom flange were broken, and all were at least finger 

handling tight. 
P.77 

FORMOSA PLASTICS CORPORATION Aug. 6, 1904 

Lehigh Project Nc 786-84 2 

The 3BA1-10 is a foundry pattern number." In addition, all 

three cast components were marked with.the material 

identification, CF8M, for 18-8 stainless steel with molybdenum, 

which is the cast equivalent of wrought Type 316 stainless 

steel. 

Figure 3 is a side view of one of the broken stud bolts. The 

bolts are 7/16" dia, 14 thd./in. size, 18-8 type stainless 

steel. The bolt was elongated by the failure as can be seen 

from the stretched threads on each side of the fracture. The 

failure appears to be a typical ductile tensile fracture for 

this type of material. 

EXAMINATION OF STUD NUTS: . 

Close examination of the 18-8 stainless steel nuts removed from 

the broken studs showed evidence of over-tightening. One of 

the nuts, representative of those examined from the failed 

flange* is shown in Figures 4 and 5. Note that the washer 

face, which is the contact surface of the nut against the 

flange, is severely scored and mechanically gouged, as if from 

heavy turning pressure. Also note that the flats on the side 

of the nut are mashed from heavy wrench pressure, and are 

upset, or crushed at the bottom corners. 

DISASSEMBLY OF BOTTOM FLANGE: 

During the examination, the bottom flange was disassembled from 

the mid-body piece. The writer was not present when the flange 

was removed. However, it was reported that the nuts were not 

visibly loose. There was a flat Teflon ring gasket between the 

flange and mid-body, which fit into a ring groove. As measured 

with the flange faces superimposed, but not bolted, and 

re-using the old gasket, there was a clearance of no more than 

0.008 between the super-imposed flange faces. The ring groove 

was 0.102" deep, and the reused gasket was 0.110" thick. The 

small clearance may be the result of "cold-set" of the Teflon 

during service. We did not have a new gasket for thickness 

comparisons. 

EXAMINATION OF UNFAILED NUTS: 

The eight nuts removed from the unfailed flange are shown in 

Figures 6 and 7. Note that the washer face surfaces and the 

flats are distorted and mashed by heavy torquing pressures. 
FORMOSA PLASTICS ' 

Lehigh Project Nc 

'OR PO RATION 

786-84 

Aug. 

3 

6, 1904 

EXAMINATIONS OF UNFAILED STUDS: 

The threads on the eight unbroken studs showed thread 

stretching similar to, but not as severe as that on the broken 

studs at the opposite end. In Figure 8, a 7/16" dia. , 14 

thd./in.tap is positioned next to one of the stretched studs. 

For approximately two-inches of exposed thread, the stud has 

been'elongated by the pitch of one thread. The elongation is 

0.070", or 3.5% of total thread exposed. 

EXAMINATION OF UNFAILED FLANGE: 

The top surface of the flange in contact with the flange nuts 

is shown in Figure 9. Note that the bolt hole surfaces are 

mashed and scored by contact pressure of the nuts, during 

tightening on the studs. 

HEAT TESTS OF TEFLON RINGS: 

Figure 10 shows one of the Teflon seat rings found on the floor 

after the failure. The ring is bent into a a permanent oval 

shape and is no longer flat . It also is deeply indented. 

Laboratory tests were run to determine the temperature required 

for this kind of damage. 

It was found that a new Teflon ring, provided by a valve 

maintenance service, could be damaged in a similar manner by 

heating 200 to 300°F, in a controlled laboratory oven, 

followed by bending and squeezing with pliers. 

DISCUSSION: 

CUrsory evaluation of the failed components might lead to the 

conclusion that failure was caused by internal detonation. 

However, the detonation would have to be substantial to cause 

simultaneous rupture of eight bolt with minimum tensile 

strengths of 75,000 psi (Refer to ASTM A193, Class B8 for Type 

304 stainless steel). A safe bolting stress, according to 

handbooks, should be no higher than about 10% of the ultimate 

tensile strength of the bolt. On the other hand, if the bolts 

had been inadvertently over-tightened, and stressed close to 

breaking, failure would come with little additional loading. 

It appears that over-tightening, and abnormal high bolt 

stresses, were principally responsible for failure during 

service. 

Assuming that the bolts were close to breaking when the valve 

was placed into service, acts normal to the operation of the 

reactor might be sufficient to "touch-off" failure. It could 

be no more than opening, or closing the valve. Or there could 

have been some other incremental stress on the pipe, or 

reactor. There could even have been a small 
FORMOSA PLASTICS 1PORATION Aug. 6, 1984 

Lehigh Project No. 786-84 4 

detonation, not normally a problem, unless the bolts were 

already close to failure from over-stressing. We understand 

that the reactors occasionally experience small detonations 

during start-up charging. 

There is evidence of over-tightening where the nut washer faces 

are heavily scored, and the flats, in contact with a wrench, 

are mashed. It should be noted that the bottom flange, in 

Figure 2, is "hard" against the mid-body section. When the 

flange was removed, the bolts were noticeably elongated, as if 

from over-tightening. If the bottom flange bolts had been 

stretched by a detonation, we would expect the bottom flange, 

and nuts to be visibly loose. 

The valve manufacture, in private conversations, has noted that 

this particular ball valve should be assembled using torques of 

45 to 60 in.-lbs. for 7/16" dia., 14 thd./in. studs. The 

recommended torque at these values should not cause the nuts to 

upset and mash as described in the report. The valve 

manufacture also stated that new valves of this style no longer 

use flat Teflon flange gaskets like those in the failed valve. 

The recommendation is to use a "chevron-packing" type gasket of 

alternating Teflon and stainless steel, which is much like a 

flexitallic design. 

CONCLUSION: 

Based on the results of our examination, it is our opinion that 

the ball valve failed as a result of over-tightened stud bolts 

at the failed flange. It appears that the stud bolts were in a 

highly stressed condition, and close to failure, prior to some 

final unknown event, which caused the final fractures by some 

small amount of additional bolt loading. The final event could 

have been inherent to the operation of the valve, and/or 

reactor. It could also have been a small low-level detonation 

inherent to charging the reactor, and which, to our 

knowledge, has not previously caused any serious problem. 

The rather small, clearance of 0.008" between the flange faces 

could be part of the problem. We do not know, at this time, 

whether the small clearance is caused by "cold-set", or whether 

the gasket was under-sized when installed. If the gasket were 

too thin, it would make it difficult to get a leak-tight joint 

without danger of over-torquing. 
P.80 

FORMOSA PLASTICS ' '<PORATION Aug. 6, 198 4 

Lehigh Project No. 786-84 5 

We hope that we have answered questions concerning the cause of 

valve failure. If additional explanations are required, or if 

more work should be done, do not hesitate to contact us. 

Very truly yours, 

LEHIGH TESTING LABORATORIES, INC. 

Lewis H. Reid, P.E. 

Consulting Metallurgist 

LHR;cj-s 

Enclosures 

LTL letters and reports apply only to the specific materials, 

products, or processes tested, examined, surveyed, inspected, 

or calculated; and are not necessarily indicative of the 

qualities of apparently identical or similar materials, 

products, or processes. The liability of Lehigh Testing 

Laboratories, Inc., with respect to the services rendered 

herein, shall be limited to the amount of the consideration 

paid for such services and shall not include any consequential 

damages. 
Formosa Piastres Corp 

Lehigh Proje . No. 786-84 

P.81 

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Figure 1: Components of failed valve received 

at the laboratory 

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Figure 2: Side view of failed valve 

Magnification:. 0.5X 
Formosa Plastics Corp 

Lehigh Projc . No. 786-84 

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Figure 3: Side view of broken stud at failed end 

of valve 

Magnification: 3X 
Formosa PlasHc s Corp 

Lehigh Proje , No. 786-84 

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Figure 4: View of washer face (contact face) 

of nut from failed stud 

Magnification: 3X 

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Figure 5: View of crushed fiat on side of nut in 

Firm re 4 
Formosa Plas'*'cs Corp 

Lehigh Projc\ No. 786-84 

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Figure 6: View of washer face surfaces on nuts 

removed from unfailed end 

Magnification: IX 

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Fiqure 7: View of mashed' flats on nuts in Figure 6 

Magnification: IX 
P.85 

Formosa 'Plastics Corp 

Lehigh Proj' . No. 786-84 

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Figure 8: View of stud at unbroken end of valve, 

compared to a standard thread tap 

Magnification: 2X . 
P.86 

Formosa Plastics Corp 

Lehigh Project No. 786-84 

Hi 

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Figure 9: View of unfailed flange showing mashed 

bolt holes 

Magnification: 1.25X 

,V7,lTl' *<*#ju»m M •*• f (KVA " "»•«•'»"' i_^i"*i*wmj_ *^'HJP>*«-M'* ••**-»'•» w.wi^-i w> ipi.iii-* rf-^,

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Fiaure 10: Teflon seal ring from failed valve 

Magnification: 0.75X 
' / 

P.87 

"

/

£ ^ FORMOSA PLASTICS CORPORATION DELAWARE 

~

>S^l£f P.O. BOX 320 • DELAWARE CITY, DELAWARE 19706 • TEL (302) 834-4575 

April 25, 1983 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

r t JV.... 

tion ' ' 

|\PR29«83 j 

28 1??3 1 

s,Arf

 <* oaAw, 

r.n,'. -,7ATE 9'

 r;.','1,

\.'CONTROL 

,yw~i^>*-

 c ' .iu 

Robert R, French, P,E. 

Manager, Air Resources Sec 

Delaware Dept, of Natura l Resources,, <_, . 

and Environmental Control W> 

P,0 . Box 140 1 

Dover, DE 1990 1 

Dear Mr. French: 

RE: Vinyl Chloride Monomer Releases 

Formosa Plastics Corporation Delaware 

In accordance with National Emission Standards for Hazardous Air Pollutants, 

Part 61 of Chapter I, Title 40, Section 61.65(a) Relief Valve Discharges, 

Polyvinyl Chloride Plant located at the Delaware City, Delaware; the 

address for this source: 

P.O. Box 320 

Schoolhouse Road 

Delaware City, Delaware 19706 

Source of Releases: 

Release ill: Carbon Bed Area 

Release 112: Emulsion Tank Farm 

A. Nature of Cause: 

Release ill: A vinyl chloride (VCM) leak occurred on a VCM waste 

storage gas bullet CT-100C. 

V 

>\ 

J v 

Release #2: An overpressuring of vinyl chloride (VCM) storage bullet 

DT-102B occurred which resulted from an operator error during the unloading operation of a VCM tank car. Line-up of valves was such that 

the A bullet was being emptied while B bullet was filled until VCM 

pressure exceeded 200 psi. Rupture disk blew and relief valve lifted 

for approximately 45 seconds causing a VCM discharge to atmosphere. 
/ 

Robert R. French -2- April 25, 1983 

B. Date and Time of Release: 

Release #1: Monday, April 18, 1983 at 1400 hours to 1845 hours. 

Release #2: Tuesday, April 19, 1983 at 0300 hours. 

C. Approximate Total Loss of Vinyl Chloride; 

Release #1: Less than one hundred (100) pounds of vinyl chloride 

released. 

Release #2: Two thousand twenty-five (2025) pounds of vinyl chloride 

discharged to atmosphere. 

D. Method Used to Determine Amount: 

Release #1: Conditions of CT-100C 

V = 30,000 gallons (4010.7 cu.ft.) 

P = 50 psig 

Volume of vent gas 

50 

14.7 x 4010.7 = 13641.8 

Weight of vent gas (density at 45% VCM = 0.11 ^j ) 

of the 982"lbs. VCM in the tank, it is estimated that only 

5% of the VCM was discharged. Therefore, less than 100 lbs. 

is estimated to be released to atmosphere. 

Release #2: It is estimated from the pump curves that 270 gallons 

vinyl chloride were discharged during the time that the relief valve 

lifted. 

E. Action Taken to Prevent Discharge: 

Release #1: 

(1) Once the leak was recognized, a water hose was put on the leak to 

minimize the fire and explosion hazard. 

(2) Incineration rate from this tank was increased to help reduce VCM 

pressure in the tank. 

(3) All venting from the reactor plants to this storage tank was stopped. 

(4) Recovery systems from reactor plants were utilized to help further 

reduce pressure. 

(5) Leak was fixed by plugging weep hole with tapped pipe and valve. 
Robert R. French -3- April 25, 1983 

Release #2: 

(1) As soon as the operator became aware of the high pressure, charge 

pumps were shut off, stopping VCM from being pumped into B bullet and 

thereby halting the discharge. 

F. Measures Adopted to Prevent Future Discharge: 

Release #1: 

(1) At the present time, vinyl chloride waste storage gas bullet CT-100C 

is being taken out of service and welds, valves, and gaskets are being 

replaced or repaired, as required. 

(2) A valve has been connected to each weep hole and left opened so 

that if a similar leak occurs in a flange weld, the valve only has to 

be closed in order to stop the leak. 

Release #2: 

(1) Operators and foremen will be reinstructed as to the correct 

operating procedures. Operators will be retrained, if necessary. 

Several key safety issues will be stressed. 

(2) Safety interlocks will be designed into the system to prevent 

this from occurring again. 

(3) Mechanical defects associated with the selector switch will also 

be corrected. 

If there are further questions pertaining to the information submitted, 

feel free to contact me. 

Sincerely, 

Charles A. Markowitz «—^ 

Associate Regulatory Affairs 

Specialist 

CAM:mah 

cc: Mr. Peter N. Bibco 

Mr. William G. Razor 
P.90 

v FORMOSA PLASTICS CORPORATION DELAWARE 

_ £ • P.O. BOX 320 • DELAWARE CITY, DELAWARE 19706 «• TEL (302) 834-4575 

March 18, 1983 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

Robert R, French, P.E. RECEIVED 

Manager, Air Resources Section 

Delaware Department of Natural Resources MAR ? 4 198 i 

and Environmental Control 

P.O. Box 1401 

Dover, Delaware 19901 

EPA-FNV!K_ vivitNVAL 

SERViChS DiViSlON 

Dear Mr, French; 

RE: Vinyl Chloride Monomer Release 

Formosa Plastics Corporation DE 

In accordance with the National Emission Standard for Hazardous Air Pollutants, Part 61 of Chapter I, Title 40, Section 61.65(a) - Relief Valve 

Discharge, Polyvinyl Chloride Plant located at Delaware City, Delaware; 

the address for this source: 

P.O. Box 320 

Schoolhouse Road 

Delaware City, DE 19706 

Source of Release: 

Suspension-II Area 

A, Nature of Cause: 

Batch S-1207 was charged in reactor SR-407 at 8:15 p.m. on March 8, 1983. 

At 10:15 p,ra. the plant experienced a power interruption which caused 

a number of motors to fail. All motors that failed were restarted 

except for a Worthington air compressor which supplied the plant with 

instrument air. The loss of instrument air caused the following things 

to happen: 1) fail open of the cooling water valves, 2) loss of 

batch temperature and pressure information in the control rooms, and 

A-6 
P.91 

Robert R, French -2- March 18, 1983 

3) the water deluge systems to activate in the S-2 reactor building, 

warehouse and S-I third recovery system, Since power was returned 

almost immediately, no action was taken to terminate batches. Local 

pressure gauges were checked periodically. At this time it was 

apparent there was high pressure in SR-407 and the termination procedure was started, During this time, reactor SR-407 was also vented 

to SR-402 to help further reduce the pressure, ' Both steps were not 

enough to bring the reactor under control so as to prevent the blowing 

of the rupture disk and a VCM release to atmosphere, 

B, Date and Time: 

Tuesday, March 8, 1983 at 2230 hours. 

C, Approximate Total Loss of Vinyl Chloride: 

Two thousand two hundred eleven pounds of vinyl chloride lost to 

atmosphere, 

D, Method Used to Determine Loss: 

From levels in reactors SR-407 and SR-402, it is estimated that 20% 

of the batch was 

VCM lost _ fract 

pounds batch 

of the batch was lost, The following determination is made: / ,-,./„ ' 

tion of f VCM charged _ / reaction time at discharge) / VCM )J 

h lost V pounds Total Poly Time, charged 

0,20 (17,200 - ( 2.5^ (17200)) 

hours 

7

 "HH -H.,, 

= 2,211 lbs, VCM released to atmosphere 

Action Taken to Prevent Discharge: 

1) <=\-methyl styrene (2% gallons) was added to batch. 

2) Batch was vented to empty reactor SR-402 to help reduce pressure. 

3) Steam was manually shut off to the plant. 
P.92 

Robert R, French -3- March 18, 1983 

F, Measures Adopted to Prevent Future Discharges: 

1) Upon a loss of instrument air, all poly batches will be terminated 

promptly, 

2) Auxiliary air will be made available and checked on a daily basis 

so as to be able to restart air compressors. 

If there are further questions concerning the information submitted, feel 

free to contact me, 

Sincerely, 

(%*&, &. foM^*^. 

Charles A. Markowitz 

Associate Regulatory 

Affairs Specialist 

CAM:mah 

cc: Peter Bibko 

U.S. EPA 
P.93 

XSN FORMOSA PLASTICS CORPORATION DELAWARE 

P.O. BOX 320 • DELAWARE CITY, DELAWARE 19706 • TEL (302) 834-4575 

:QA - iooo?> 

March 4, 1983 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

Robert R, French, P.E, 

Manager, Air Resources Section 

Delaware Department of Natural Resources 

and Environmental Control 

P.O. Box 1401 

Dover, DE 19901 

Dear Mr, French: 

RE: Vinyl Chloride Monomer Release 

Formosa Plastics Corporation DE 

In accordance with the National Emission Standard for Hazardous Air Pollutants, 

Part 61 of Chapter I, Title 40, Section 61,65 (a) - Relief Valve Discharges, 

Polyvinyl Chloride Plant located at Delaware City, Delaware; the address for 

this source: .. 

P.O. Box 320 

Schoolhouse Road 

Delaware City, DE 19706 

Source of Release: 

Emulsion-II Area 

Nature of Cause: 

Batch D-348 was being charged in reactor DR-403 at the E-II Plant. When 

agitator was turned on to start batch reactor, pressure quickly increased 

until rupture disk blew and relief valve lifted causing a vinyl chloride 

monomer release to atmosphere which lasted approximately lh minutes. The 

major cause of release was D/I water valve leaking through which resulted 

in the batch being overcharged and hydrostating. It also should be noted 

that operator did not check reactor level before turning on agitator. 

RECEIVED iEi EI¥EDRE:cEfVED ' 

MAR 0 9 1983 

EPA-ENVIRONMENTAL 

SERVICES DiViSlON 

!••?$ £ 

." 3 rZH 

SECT'OX 

MAR - 8 |9 f i 3 

EPA, KEGION i n 

**§am mam 

•4 

3 
P.94 

Robert R. French -2- March 4, 1983 

B, Date and Time of Release: 

Thursday, February 25, 1983, at 2125 hours. 

C, Approximate Total Loss of Vinyl Chloride: 

Two thousand forty (2040) lbs, vinyl chloride monomer was discharged to 

atmosphere. 

D, Method Used to Determine Loss: 

The amount of vinyl chloride lost to atmosphere was determined from the 

% solids in the batch, 19.5%, vs. an average of 26,9% solids in the other 

batches. It is also assumed that there was 10% more water in that batch 

and since the stripping operation was started immediately on the reactor 

an extra 1000 lbs. VCM more than normal was recovered. 

Lbs, VCM charged = 18,000 Lbs. 

Lbs. VCM converted to PVC = 11,960 Lbs. 

Lbs, VCM recovered = 4,000 Lbs. 

Lbs. VCM released to atmosphere = 2,040 Lbs. 

E, Action Taken to Prevent Discharge: ... - -.. - —-

1, Stripping operation was started immediately to remove unreacted 

vinyl chloride in order to lower reactor pressure. 

2, Batch was also placed in full cooling. 

F, Measures Adopted to Prevent Future Discharge: 

1, Disciplinary action has been given to the two operators involved in 

charging of this batch. 

2, Deionized water valve has been repaired. 

3, All E-2 (emulsion plant) A-operators will be retrained as to the 

importance of checking reactor levels at certain times during the 

charge procedure. 
P.95 

Robert R. French -3- March 3, 1983 

If you need additional information or have any questions, feel free to 

contact me, 

Sincerely, , 

Charles A. Markowitz 

Associate Regulatory 

Affairs Specialist 

CAM:mah 

cc: Mr, Peter Bibko, Administrator 

Region III, EPA 
P.96 

>_3S FORMOSA PLASTICS CORPORATION DELAWARE 

P.O. BOX 320 • DELAWARE CITY, DELAWARE 19706 • TEL (302) 834-4575 

January 14, 1983 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

Robert R. French, P.E. 

Manager, Air Resources Section 

Delaware Department of Natural Resources 

and Environmental Control 

P.O. Box 1401 

Dover, Delaware 19901 

Dear Mr. French: 

RE: VINYL CHLORIDE MONOMER RELEASE 

FORMOSA PLASTICS CORPORATION, DE 

In accordance with the National Emission Standards for Hazardous 

Air Pollutants, Part 61 of Chapter I, Title 40, Section 61.65(a) 

Relief Valve Discharges, Polyvinyl Chloride Plant located at 

Delaware City, Delaware; the address for this source: 

Source of Releases: 

P.O. Box 320 

Schoolhouse Road 

Delaware City, DE 19706 

Release #1: 

Release #2: 

Carbon Bed Area 

Emulsion Plant EPVC-II 

A. Nature of Cause: 

Release #1. A vinyl chloride (VCM) leak occurred on a VCM 

waste storage gas bullet CT-100C. Pressure on the bullet 

at the time of the leak was 60 psig with a concentration of 

35% VCM. 

Release #2. An unauthorized opening of reactor DR-4 05 

occurred when a mechanic pulled a steam sparging spool 

on a reactor which had a batch of terminated, but not 

completely stripped, latex in it. 
P.97 

ROBERT R. FRENCH, P.E. -2- JANUARY 14, 1983 

B. Date and Time of Release 

Release #1: Thursday to Friday, January 6-7, 1983 

at 2330 hours to 1300 hours 

Release #2: Thursday, January 13, 1983 at 1145 hours 

C. Approximate Total Loss of Vinyl Chloride 

Release #1: Less than one hundred (100) pounds of vinyl 

chloride released 

Release #2: Less than one hundred (100) pounds of vinyl 

chloride released 

D. Method Used to Determine Amount 

Release #1: 

Conditions of CT-100C 

V=30000 gallons (4010.7 cu. ft.) 

P=60 psig. 

Volume of vent gas 

6 0 x 4010.7 = 16370 ft.3 

14.7 

Weight of vent gas 

16370 x 0.1015 = 1661.6 lbs. - (581.6 lbs. VCM) 

Of the 581.6 lbs. VCM in the tank it is estimated that only 

15% of the VCM in the tank was discharged. The remaining 

VCM in the tank was either incinerated in the boilers or 

vented to other VCM storage tanks. 

Release #2: It is estimated that 2 feet 2 inches of reaction 

mixture was lost to the drain. It is estimated that 2% of the 

1500 lbs. PVC lost was vinyl chloride which would calculate 

out to be 30 lbs. VCM. 

E. Action Taken to Prevent Discharge 

Release #1: • 

(1) Once the leak was recognized the sprinkler system was 

turned on to minimize the fire and explosion hazards. 
P.98 

ROBERT R. FRENCH, P.E. -3- JANUARY 14, 1983 

(2) Incineration rate from this tank was increased to help 

reduce the pressure. 

(3) This waste gas bullet was also vented to other storage 

tanks to help reduce pressure. -

(4) All venting from the reaction plants to this storage 

tank was stopped 

(5) Recovery systems from reactor plants were utilized to 

help reduce pressure 

Release #2: 

(1) When sparging spool was plugged, spool was reassembled 

to stop discharge 

(2) Disciplinary action will be taken 

(3) Mechanic will be retrained in this operation 

F. Measures Adopted to Prevent Future Discharge 

Release #1: At the present time each vinyl chloride waste gas 

storage bullet is being taken.out of service and such valves 

and gaskets are being inspected and replaced as required. 

Release #2: Mechanic involved will be given additional training. 

If there are further questions concerning the information submitted 

please do not hesitate to contact me. 

Sincerely, 

Charles A. Markowitz 

Associate Regulatory 

Affairs Specialist 

CAM:11 

cc^Mr . Peter N. Bibco 
P.99 

, TM FORMOSA PLASTICS CORPORATION DELAWARE 

xj£ / P.O. 30X 320 • DELAWARE CITY, DELAWARE 19706 • 7i"L (302) 834-4575 

October 9, 1984 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

Robert R. French, P.E. 

Manager, Air Resources Section 

State of Delaware 

Department of Natural Resources 

and Environmental Control 

P.O. Box 1401 

Dover, Delaware 19903 

RE: Resin Spill 

Dear Mr. French: 

Formosa Plastics Corporation Delaware hereby confirms a spill of resin October 7, 

reported by telephone to Mr. Joseph Hardman on October 9, as per conditions of 

APC Permit 82/266, paragraph 3, and Delaware Code, Chapter 7, Section 6006, 

Reporting Emissions. 

At approximately 1200 hours on October 7, a spill of approximately 3000 lbs. 

of resin from Silo DT601B occurred due to silo overfill.. Operations has cited 

the blow tank weigh scale calibration as the cause, and has submitted a corrective 

maintenance work order. Cleanup of the spilled resin, confined to the inuredinue 

area of the silos, was promptly initiated. 

If you have any questions or need additional information, please do not hesitate 

to telephone me at (302) 836-2219. 

Sincerely, _^ 

sa-- '(Qxut MUH . , v 

H. Allen Wrigle ^ Jr . . *• tf£h$L 

Environmental Manager . • ^nr A %. v^M 

HAW:11 

cc: Joseph J. Hardman, P.E. 

Ronald Patterson 
p.1 

>5£y FORMOSA PLASTICS CORPORATION DELAWARE 

P.O. BOX 320 • DELAWARE CITY, DELAWARE 19706 • TEL (302) 834-4575 

December 2, 1982 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

Mr. Robert R, French, P.E. 

Manager, Air Resources Section 

Delaware Department of Natural 

Resources & Environmental Control 

P. 0. Box 1401 

Dover, Delaware 19901 

Dear Mr. French: 

RE: VINYL CHLORIDE MONOMER RELEASE 

FORMOSA PLASTICS CORPORATION, DE 

In accordance with National Emission Standards for hazardous Air 

Pollutants, Part 61 of Chapter I, Title 40, Section 61.65 (a) Relief 

Valve Discharges, Polyvinyl Chloride Plant located af Delaware City, 

Delaware; the address for this source: 

Post Office Box 320 

Schoolhouse Road 

Delaware City, Delaware 19706 

Source of Release: SPVC-II Plant 

A. Nature of Cause 

A vinyl chloride (VCM) release occurred from reactor SR-406 

because of the additional amount of catalyst added to counteract the 

*< -methyl styrene, a short stop present in the recovered vinyl chloride 

monomer. During previous day of operation, a power outage had occurred 

at the plant which resulted in all suspension batches being immediately 

terminated withK -methyl styrene (AMS). Since all these batches had to 

be stripped aOBunreacted vinyl chloride recovered had AMS present in it, 

it was believed that more catalyst then normal would be required in 

order to react this monomer. One batch was charged in both the SPVC-I 

and SPVC-II plant at the increased catalyst levels. Both batches were 

observed closely and upon seeing high pressure rise, AMS was immediately 

added to that reactor but pressure rise continued until release to >V X 

atmosphere. The batch in the S-I Plant was brought under control, but \^ *\ v 

the batch in the S-2 Plant was not controlled even after venting to ^ ^ 

another reactor and the recovery system. <P% f~ /T+f^ i\ t T~f^ <t"V 

V /" RECEIVED b.V 

DEC - 6 1982 * 

% < 
P.2 

Mr. Robert R. French, P.E. - 2 - December 2, 1982 

B. Date and Time of Release 

Thursday, November 25, 1982 at 0100 hours. 

C. Approximate Total Loss of Vinyl Chloride 

Six thousand five hundred (6,500) pounds vinyl chloride was 

estimated to be discharged to atmosphere. 

D. Method Used to Determine Loss 

17,500 = lbs. VCM charged in SR-406 

4,500 = lbs. VCM recovered in accumulator estimated from level 

indicators before and after batch. 

3,500 = lbs. VCM converted to PVC assuming 20% conversion; 

estimated from batch card conditions - temperature, 

reaction time and pressure. 

3,000 = lbs. VCM remaining in batch estimated from sharp decrease 

in pressure after release or transferred to other 

reactor, 

6,500 = lbs. VCM discharged to atmosphere* 

E. . Action Taken To Prevent Discharge 

1. AMS was added to reactor. 

2. Manual steam to reactor was blocked in. 

3. Reactor was vented to reactor SR-403 and two degassing tanks in 

an attempt to lower pressure. 

F. Measures Adopted To Prevent Future Discharges 

1, Catalyst amounts in future charges were considerably reduced 

•<« far. 4 r\a . 

2, Under similar conditions, such increased amount of catalyst 

will not be used again. 

If there are any further questions concerning the information 

submitted, do not hesitate to contact me. 

Sincerely, 

Charles A. Markowitz 

Associate Regulatory 

Affairs Specialist 

.CAM/ctv 
P.3 

FOR2VIOSA PLASTICS CORPORATION DELAWARE 

P.O. BOX 320 • DELAWARE CITY, DELAWARE 19706» TEL (302) 834-4575 

> 'yi-

/ / 

September 24, 1982 RECEIVED 

*£, 

c

^ 

"**&»// / 

eo 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

Mr. Robert R. French, P.E. 

Manager, Air Resources Section 

Delaware Department of Natural 

Resources & Environmental Control 

P.O. Box 1401 

Dover, DE 19901 

Dear Mr. French: 

Re: Vinyl Chloride Monomer Release 

Formosa Plastics Corporation DE 

In accordance with National Emission Standards for hazard- ' 

ous Air Pollutants, Part 61 of Chapter I, Title 40, Section 61.65(a) 

Relief Valve Discharges, Polyvinyl Chloride Plant located at Delaware 

City, Delaware; the address for this source: 

Post Office Box 320 

Schoolhouse Road 

Delaware City, Delaware 19706 

Source of Release: EPVC-II Plant 

OCT 4 iQQ •32 

AIR & WASTE MANAGEMENT 

r r ; DIVISION

 mt m 

EPA REGION Ul 

A. Nature of Cause 

A vinyl chloride (VCM) release of short duration occurred from 

Accumulator, DT-303, because of a hydrostat. 

B. Date and Time of Release 

SEP 30 

E 

1982 

Thursday, September 16, 1982 at 1445 hours. 

Approximate Total loss of Vinyl Chloride 

Two hundred fifty (250) pounds vinyl chloride was discharged 

to atmosphere. 

Method Used to Determine Loss 

Observations of liquid level in the accumulator indicate 

that there was no loss of liquid VCM. Because of that fact 

and the short duration of this release, it is estimated that 

no more than two hundred fifty pounds of VCM was lost. 

• •. - 'K 

a 

...Ai 

I 

t^X. 
Vinyl Chloride Monomer Release 

September 24, 1982 

Page 2 

E. Action Taken to Prevent Discharge 

1. Upon discovery of this problem, operator switched 

to the other rupture disc. 

2. Recovery systems were also shut down to reduce, pressure 

build-up. 

F. Measures Adopted to Prevent Future Discharges 

Level Indicator (L.I.) for DT-303 will be repaired. 

If there are further questions concerning the information submitted, 

feel free to contact me. 

CAM/cam 

Sincerely, 

Charles A. Markowitz 

Associate Regulatory 

Affairs Specialist 

CC. Mr. Peter Bibco (EPA Region III) 
P.5 

JOP.VOSA PLASTi'bbS CORPORA/r.ON DI.b.,A VvAib^ 

P.O. BOX 320 • DELAWARE CITY, DELAWARE 19706 • TEL (302) 834-4575 

August 31, 1982 

CERTIFIED MAIL . 

RETURN RECEIPT REQUESTED 

Mr. Peter N. Bibco 

Regional Administrator 

U. S. Environmental Protection Agency 

Region III, Sixth and Walnut Streets vl "\j 

Philadelphia, Pennsylvania 19106 ^ 'l 

Dear Mr. Bibco: ' ^ ^y^ 

RE: VINYL CHLORIDE MONOMER RELEASE 

FORMOSA PLASTICS CORPORATION DELAWARE 

In accordance with the National Emission Standards for Hazardous Air 

Pollutants, Part 61 of Chapter I, Title 40, Section 61.65 (a) Relief Valve 

Discharges, Polyvinyl Chloride Plant located at Delaware City, Delaware; the 

address of this source: 

Post Office Box 320 

School House Road 

Delaware City, Delaware 19706 

Source of Release: SPVC-II Plant 

A. Nature of Cause 

Vinyl Chloride Monomer (VCM) was released from reactor SR-410 because of 

operator error. In the transfer of ethylene dichloride (EDC), an organic solvent 

used to clean dirty reactors, from reactor SR-409 to PT-206, the operator 

mistakenly aligned reactor SR-410 which had a polymerization reaction in it. The 

result was a release of VCM from SR-410 to PT-206, an EDC storage tank to 

atmosphere. 

B. Date and Time of Release 

Monday, August 23, 1982, at 0900 hours 

C. Approximate Total Loss of Vinyl Chloride 

It is estimated that fifty-six hundred ten (5,610) pounds of vinyl chloride 

monomer (VCM) was released to atmosphere. 

RECF*Vb~ 

n i i\ •«* i \.. . 

E P A .?>:.•#<>.:;. Il l 
P.6 

Mr. Peter N. Bibco 

Page 2 

August 31, 1982 

D. Method Used to Determine Loss 

Visual observation of the batch after release indicates that approximately 

one-third of the reactor's contents was discharged, It is assumed that at 

the time"of discharge there was 1% conversion of VCM to polyvinyl chloride (PVC, 

17,000 lbs. VCM charged in reactor SR-410 

170 lbs. VCM converted to PVC 

5,610 lbs. VCM discharged to atmosphere 

11,220 lbs. VCM remaining in reactor 

E. Action Taken to Prevent Discharge 

Plant foreman closed EDC line when reactor was found to be discharging to 

PT-206. 

F. Measures Adopted to Prevent Future Discharge 

1. Operator was retrained as to the correct EDC transfer procedure. 

2. The operator was also given disciplinary time off because of his 

carelessness. 

If there are questions pertaining to the information submitted, feel 

free to contact me. 

Sincerely, 

Charles A. Markowitz 

Associate Regulatory 

Affairs Specialist 

CAM/1 tg 

cc: Mr. Robert French 
P.7 

- ^ V - '.-.?.VOSA PLASTICS COPJ" 

P.O. BOX 320 • DELAWARE CITY, DELAWARE 19706 • TEL (302) 834-4575 

July 17, 1981 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

Mr. Jack Schramm, Reg. Administrator 

U. S. Environmental Protection Agency 

Region III, Sixth and Walnut Streets 

Philadelphia, PA 18106 

Dear Mr. Schramm: 

Re: Vinyl Chloride Monomer Release 

Formosa Plastics Corporation DE 

In accordance with the National Emission Standards for 

Hazardous Air Pollutants, Part 61 of Chapter I, Title 40, 

Section 61.65(a) - Relief Valve Discharges, Polyvinyl Chloride 

Plant located at Delaware City; the address for this source: 

P. 0. Box 320 

Schoolhouse Road 

Delaware City, DE 19706 

Source of Release: SPVC-I Plant 

A. Nature of Cause 

A vinyl chloride (VCM) release occurred from reactor 

PR-407 at approximately 1315 hours on July 8, 1981, because of 

high pressure resulting from insufficient cooling of the batch. 

When instrumentation called for cooling, water was short circuited out the suction line back to the tower. This was made 

possible by a check valve staying open and the recirculating 

pump not starting. Also, because of a bad transmitter, the 

pressure pick in the control room did not accurately indicate 

the existing high pressure in the batch so that more prompt 

corrective action could have been taken to prevent this release. 

B. Date and Time of Release 

Wednesday, July 8, 1981, at 1315 hours. 

C. Approximate Total Loss of Vinyl Chloride 

Twenty-seven hundred seven (2,707) pounds vinyl chloride \^\ 

discharged to atmosphere. 
P.8 

Mr. Jack Schramm, Reg. Administrator 

July 16, 1981 

Page 2 

D. Method Used to Determine Loss 

It is estimated from the 1% hour reaction time at increased 

reaction temperature that 30% of the VCM was converted to polyvinyl 

chloride. 

Lbs. VCM Charged to Reactor 

% Conversion 

Lbs. VCM Emitted to Atmosphere 

Lbs. VCM Remaining in Batch 

11,600 

30% 

2,707 

5,413 

Visual observation from levels in the reactor showed that 

approximately 1/3 of reactor contents were discharged to the 

atmosphere. Some of the batch contents were also transferred 

to reactor PR-403. 

E. Action Taken to Prevent Discharge 

1. Two shots of a-methylstyrene (AMS) were added to moderate 

batch temperature. 

2. Recirculating pump was manually placed in full chill. 

3. Batch was equalized with PR-403, an empty reactor. 

4. The stripping operation was started to reduce pressure. 

F. Measures Adopted to Prevent Future Discharges 

1. All recirculating pumps are now being operated in manual. 

,2. The pressure transmitter has been repaired. 

3. Pumps will be rewired, so as to activate when pressure 

reaches 4 psi on the Moore Controller. 

If there are further questions concerning the information 

submitted, feel free to contact me. 

Sincerely, 

Charles A. Markowitz 

Associate Regulatory Affairs 

Specialist 

CAM:cdr 

cc: Robert R. French 

Robert Taggert 
P.9 

PLASTICS 

DIVISION 

Stauffer Stauffer Chemical Company 

P.O. Box 320 / Delaware City, Delaware 19706 / Telephone (302) 834-4575 

May 14 , 1981 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

! h 

NJV ) 

Mr. Thomas Voltaggio, Acting Director 

U.S. Environmental Protection Agency 

Enforcement Division 

Sixth & Walnut Streets 

Philadelphia, PA 19106 

Dear Mr. Voltaggio: 

By this letter, Stauffer Chemical Company (the transferor) 

and Formosa Plastics Corporation USA (the transferee), hereby 

inform the United States Environmental Protection Agency that 

on or around May 14, 1981 operational control and ownership of 

the Stauffer Chemical Company Polymers Plant, P.O. Box 320, 

Delaware City, Delaware shall be transferred to Formosa Plastics 

Corporation USA, headquartered at 66 Hanover Road, Florham Park, 

New Jersey 07932. 

As a result of the change in operational control and ownership, both Stauffer Chemical Company and Formosa Plastics Corporation USA agree that the responsibility to comply with the 

National Emission Standards for Hazardous Air Pollutants, Part 61 

of Chapter I, Title 40 - Vinyl Chloride Standard should be 

transferred to Formosa Plastics Corporation USA. 

If you have any questions concerning this matter, feel free 

to contact me at (302)834-4575 extension 285. 

Sincerely, 

Charles A. Markowitz

 <~^ 

Associate Regulatory Affairs 

Specialist 

CAM/pj ^ t-
P.10 

7 •'.. 

^^^FORMOS A PLASTICS CORPORATION DELAWARE RECEj ' / tlL) 

P.O. BOX 320 • DELAWARE CITY. DELAWARE 19706 • TEL (302) 834-4575 

August 26, 1982 

SEP G1 

AIR & WA 

Lb\- : '..• • 

Mr. Peter N. Bibco EPA ivbCv< • .... 

Regional Administrator Certified Mail 

U. S. Environmental Protection Agency Return Receipt Requested 

Region III, Sixth and Walnut Streets 

Philadelphia, PA 19106 

Dear Mr. Bibco: 

RE: Vinyl Chloride Monomer Release 

Formosa Plastics Corporation Delaware 

In accordance with the National Emission Standards for Hazardous Air 

Pollutants, Part 61 of Chapter I, Title 40, Section 61.65 (a) Relief Valve 

Discharges, Polyvinyl Plant located at Delaware City, Delaware; the address 

of this source: 

Post Office Box 320 

School House Road 

Delaware City, Delaware 19706 

Source of Release: SPVC-I Plant 

A. Nature of Cause 

Vinyl Chloride (VCM) release occurred from reactor PR-404 because of 

failure to add premix solution to batch. High pressure condition 

was also not accurately determined because of partially plugged 

pressure gauge. Operator was therefore unaware of high pressure 

condition and, therefore, did not perform necessary corrective action 

to terminate batch. 

B. Date and Time of Release 

Wednesday, August 25, 1982, at 1500 hours. 

C. Approximate Total Loss of Vinyl Chloride 

It is estimated that two hundred (200) pounds of vinyl chloride monomer 

(VCM) was released to the atmosphere. 

D. Method Used to Determine Loss 

-^ Relief Valve discharge only lasted a couple of seconds. No change in 

liquid level was observed in reactor. Two hundred pounds VCM is only 

a rough estimate. 
P.11 

Peter N. Bibco 

Page Two 

E. Action Taken to Prevent Discharge 

Because of malfunction of pressure gauge, operator was not aware of 

high pressure problem until release had already occurred. No preventive action was therefore taken, a-methylstyrene was added 

immediately once the existing high pressure condition was realized. 

F. Measures Adopted to Prevent Future Discharge 

1. The operator was retrained as to the charging procedure. 

2. The operator was also given disciplinary time off because of 

his carelessness. 

If there are any other questions pertaining to the information 

submitted, feel free to contact me. 

Sincerely, 

Charles A. Markowitz 

Associate Regulatory 

Affairs Specialist 

CAM:alp 
P.12 

FORMOSA PLASTICS CORPORATION DELAWArU: 

P.O. BOX 320 • DELAWARE CITY, DELAWARE 19706 • TEL (302) 834-4575 

October 7, 1981 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

Mr. Peter N. Bibco 

Regional Administrator 

U. S. Environmental Protective Agency 

Region III 

6th & Walnut Streets 

Philadelphia, PA 19106 

Dear Mr. Bibco: 

Re: Vinyl Chloride Monomer Release 

Formosa Plastics Corporation DE 

In accordance with the National Emission Standards for 

Hazardous Air Pollutants, Part 61 of Chapter I, Title 40, 

Section 61.65 (a) Relief Valve Discharges, Polyvinyl Chloride 

Plant located at Delaware City, Delaware; the address for this 

source: 

Post Office Box 320 

Schoolhouse Road 

Delaware City, DE 19706 

Source of Release: EPVC-II Tank Farm. 

A. Nature of Cause 

Operator was unloading tank car and recycling to DT102B 

storage bullet, when he got a high level in DT102B. He 

switched the unloading lines to DT102A, but failed to switch 

the recycle line. The tank continued to fill and hydrostated, 

blowing the rupture disk. 

B. Date and Time 

Wednesday, September 29, 1981 at 1500 hours. 

C. Approximate Total Loss of Vinyl Chloride * 

-,t Six hundred (600) pounds of vinyl chloride released to 

the atmosphere. V v 

1 ^5 
P.13 

Vinyl Chloride Monomer Release 

Formosa Plastics Corporation DE 

October 7, 1981 

Page 2 of 2 

D. Method Used to Determine Loss 

It is estimated that the relief valve lifted for 20 

seconds before receding. The loading rate of the pump is 

approximately 1500 lbs/min. Because of the high pressure 

condition that estimated rate of discharge was increased by 

20% of the pump flow rate. 

E. Action Taken to Prevent Discharge 

1. Upon notification from high pressure alarm,operator 

went to tank farm to open recycle valve to DT-102C 

storage vessel. 

2. Foreman shut off charge pump. These two actions 

allowed pressure to equalize to DT102 A & C and the 

12% of VCM was recycled from DT102B to DT-102C to 

lower the liquid level in DT-102B. 

F. Measures Adopted to Prevent Future Discharges 

1. Operator was reinstructed in the correct unloading 

procedure for VCM cars. 

2. Operator was given 3 days disciplinary time off (DTO) 

If there are any further questions pertaining to the 

information submitted, please do not hesitate to contact me. 

Sincerely, 

c^^ ^ (2. 

Charles A. Markowitz 

Associate Regulatory 

Affairs Specialist 

CAM:pd 
P.M 

P.O. BOX 320 • DELAWARE CITY. DELAWARE 19706 • TEL (302) 834-4575 

August 28, 1981 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

Mr. Jack Schramm 

Regulatory Administrator 

U. S. Environmental Protection Agency 

Region III, Sixth and Walnut Streets 

Philadelphia, Pennsylvania 18106 

Dear Mr. Schramm: 

Re: Vinyl Chloride Monomer Release 

Formosa Plastics Corporation DE 

In accordance with the National Emission Standards for hazardous Air Pollutants, Part 61 of Chapter I, Title 40, Section 61.65(a) 

Relief Valve Discharges, Polyvinyl Chloride Plant located at Delaware 

City, Delaware; the address for this source: 

Post Office Box 320 

Schoolhouse Road 

Delaware City, Delaware 19706 

Source of Release: EPVC-II Plant 

A. Nature of Cause 

A vinyl chloride (VCM) release occurred from 

Accumulator DT-30 3 at approximately 1700 hours 

on August 19, 1981, because an LPV valve opened 

during the stripping of a batch in reactor DR-406. 

Air was subsequently pulled into the system, causing pressure to rise in DT-303 to over 100 p.s.i. 

and blow the rupture disc. 

B. Date and Time of Release 

Wednesday, August 19, 1981, at 1700 hours. 

C. Approximate Total Loss of Vinyl Chloride 

Less than fifty (50) pounds vinyl chloride was \ v 

discharged to atmosphere. ^V 

V 
P.15 

Vinyl Chloride Monomer Release 

August 28, 1981 

Page 2 

D. Method Used to Determine Loss 

Due to the short duration of this release and the fact 

that no loss in the accumulator could be determined, it 

is estimated that less than fifty (50) pounds of VCM 

were discharged. Also, no high levels were picked by 

the continuous monitoring system in the plant. 

E. Action Taken to Prevent Discharge 

Release took place so quickly that no preventive action 

was possible. Within seconds the 1st stage of recovery 

system kicked out because of the high pressure and the 

2nd stage shut down. 

F. Measure Adopted to Prevent Future Discharges 

1. Rupture disk was replaced on accumlator. 

2. Each operator on that shift who may have been responsible for this error was retrained as to the 

importance of checking and rechecking such procedures 

and preventing such discharges. 

3. An investigation of this incident could not definitely 

pinpoint this error to a specific operator. 

If there are further question concerning the information, feel 

free to contact me. 

Sincerely, 

Charles A. Markowitz 

Associate. Regulatory 

Affairs Specialist 

CAM:als 
P.16 

^SX 

P.O. BOX 320 • DELAWARE CITY. DELAWARE 19706 • TEL (302) 834-4575 

September 25, 1981 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

Mr. Peter N. Bibco 

Regional Administrator 

U. S. Environmental Protection Agency 

Region III; Sixth and Walnut Streets 

Philadelphia, PA 19106 

Dear Mr. Bibco: 

Re: Vinyl Chloride Monomer Release 

Formosa Plastics Corporation DE 

In accordance with the National Emission Standards for hazardous Air Pollutants, Part 61 of Chapter I, Title 40, Section 61.65(a) 

Relief Valve Discharges, Polyvinyl Chloride Plant located at Delaware City, Delaware; the address for this source: 

Post Office Box 320 

Schoolhouse Road 

Delaware City, DE 19706 

Source of Release: SPVC-I and SPVC-II Plants 

A. Nature of Cause 

Vinyl Chloride (VCM) releases occurred from nine 

reactors and three stripping tanks in the time 

period of 0130 to 0300 hours on September 16, 1981. 

The causes of these releases are listed: 

1. At 0057 hours, the Delaware City Plant 

experienced a power outage. The areas 

affected were the SPVC-I and SPVC-II 

Plants. 
P.17 

Vinyl Chloride Monomer Release 

September 25, 1981 

Page 2 

2. It was also discovered at 0120 hours that 

a Worthington Air Compressor had shut 

down. Loss of air pressure prompted the 

terminating of all suspension batches 

that were reacting. 

3. At 0130 hours both the S-I and E-I emergency generators shut-down and were restarted. The cause of this shut-down 

was overheating because of an exciter 

circuit fuse blowing on the S-I generator. 

In both cases, the generator engines worked 

properly. However, overheating caused 

both units to be inoperable, since both 

The S-I and E-I emergency cooling fans 

operate off of the output of the S-I 

generator. 

4. Loss of power in the S-I plant prevented 

agitators from being operated, causing 

batches to heat up, build pressures, blow 

rupture discs and lift valves releasing 

to the atmosphere. 

Due to these emergency generators not 

operating, the air compressors, which 

are on emergency power, could not be 

utilized. Loss of this air pressure 

in the S-I and S-II plants also reduced 

the amount of city water pressure. Even 

with agitators running in the S-II plant, 

reduced cooling caused batches to get 

out of control, build up pressure, and 

release to the atmosphere. 

B. Date and Time of Release 

Wednesday, September 16, 1981, from 0130 to 0300 hours. 

C. Approximate Total Loss of Vinyl Chloride 

It is estimated that twenty-eight thousand six (28,006) 

pounds vinyl chloride monomer (VCM) was released to 

the atmosphere. 

D. Method Used to Determine Loss 

For all nine batches released to the atmosphere, an 

estimate as to how much of the batch was lost was 

made from visual observations and how much vinyl 
P.18 

Vinyl Chloride Monomer Release 

September 25, 1981 

Page 3 

chloride (VCM) was converted to polyvinyl chloride 

(PVC) during the reaction. In the S-II plant it is 

estimated that 16,500 pounds of VCM is converted 

over a 4.5 hour poly-reaction time to 15,000 pounds 

PVC, leaving 1,500 pounds of VCM unreacted. In the 

S-I plant, 11,500 pounds of VCM was converted to 

10,000 pounds of PVC over a 7 hour poly-reaction 

time. Using the information available, the attached 

formula is derived, and information for each of 

the batches is set forth in the attached table 

(Appendix). 

E. Action Taken to Prevent Discharge 

1. Several attempts were made to restart emergency generators when overheating was 

taking place. 

2. a-methyl styrene (AMS) was added to terminate 

all reacting suspension batches. 

3. Sprinklers were turned on in both plants to 

reduce fire hazard and to provide cooling 

for reactor domes. 

F. Measures Adopted to Prevent Future Discharges 

1. Operators have been re-instructed as to the 

.proper termination of reacting batches upon 

a power outage. 

2. Amounts of AMS added to terminate reacting 

suspension batches will be increased depending on the exisitng conditons. Also, other 

terminators will be examined to determine 

their effectiveness in killing the polymerization reaction. 

/ 3. Emergency drills will be conducted within 

* the next two weeks simulating a power outage. 

4. Fans on the emergency generators will be put 

on separate circiuts so as to eliminate the 

inter-dependency of one generator on another. 

5. The existing weekly generator checks will 

include a simulated power outage. This will 

enable us to check all functions of the emergency system, i.e., motor operation, generator operation, automatic power transfer 

switch operation. 

\ 
P.19 

Vinyl Chloride Monomer Release 

September 25, 1981 

Page 4 

6. Production foreman will be re-instructed in 

the proper trouble shooting procedures for 

the emergency generators. 

If there are further questions concerning the information 

submitted, feel free to contact me. 

Sincerely, 

/Pran ''FranVk . JyDoyl T I /Tirwrl c. e ' 

Plant Manager 

FJD/drk 

Attachment 
-APPENDIX-

— 

VCM LOST 

POUNDS 

REACTOR 

NUMBER 

PR-401 

PR-402 

PR-404 

PR-410 

PR-411 

SR-401 

SR-403 

SR-404 

SR-410 

PT-415 

PT-416 

PT-4] 17 

= 

BATCH 

NUMBER 

P-4341 

P-4343 

P-4342 

P-4 34 5 

P-4344 

S-4136 

S--4131 

S-4134 

S-4135 

-

-

-

FRACTION OF 

BATCH LOST 

-

FRACTION OF i 

BATCH LOST 

0.50 

0.50 

0.50 

0.75 

0.67 

0.33 

0.0 

0.20 

0.75 

-

-

-

VCM CHARGED, 

POUNDS 

/CM CHARGED, 

POUNDS 

11500 

11500 

11500 

11500 

11500 

16500 

16500 

16500 

16500 

-

-

-

-

REACTION TIME, HOURS 

AT DISCHARGE 

TOTAL POLY 

TIME REACTED 

AT DISCHARGE, 

HOURS 

4.75 

4.25 

3.75 

2.0 

2.5 

3.25 

4.5 

4.5 

2.75 

-

-

-

TIME , HOURS 

POUNDS VCM 

CONVERTED 

TOTAL NCR 

POLY TIME, VCM LOST, 

HOURS POUNDS 

7.0 

7.0 

7.0 

7.0 

7.0 

4.5 

4.5 

4.5 

4.5 

-

-

-

2357 

2714 

3071 

6482 

5312 

1870 

*100 

300 

5500 

*100 

*100 

*100 

TOTAL: 2 3,006 

*For Vessels SR-403, PT-415, PT-416 and PT-417, no visible losses were observed, 

Since batches had been terminated, 100 pounds of VCM is the estimated loss. 
P.21 

C - c ••' ,»' J -,(.'•:" C-s> 

bOFMCSA Pl.ASrCS CORPORATION DELAWARE 

P.O. BOX 320 • DELAWARE CITY, DELAWARE 19706 • TEL (302) 834-4575 

June 30, 1981 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

Mr. Jack Schramm, Req. Administrator 

U.S. Environmental Protection Agency 

Region III, Sixth and Walnut Streets 

Philadelphia, PA 18106 

Dear Mr. Schramm: 

Re: Vinyl Chloride Monomer Release 

Formosa Plastics Corporation DE 

In accordance with the National Emission Standards for 

Hazardous Air Pollutants, Part 61 of Chapter I, Title 40, 

Section 61.65(a) - Relief Valve Discharges, Polyvinyl Chloride 

located at Delaware City; the address for this source is: 

P.O. Box 320 

Schoolhouse Road 

Delaware City, DE 19706 

Source of Release: SPVC-I Plant 

A. Nature of Cause 

A vinyl chloride (VCM) release occurred from PT-306, a 

vinyl acetate (VAM) accumulator, at 1810 hours on June 23, 1981. 

Even though valves between the knockout pot and the VCM recovery 

system and the VAM system were closed, there was enough leakage 

through these valves for the rupture disc to fail and its relief 

valve to lift. Rupture disc had apparently failed because of 

excessive flexing and relief valve did not have proper pressure 

rating. 

B. Date and Time of Release 

Tuesday, June 23, 1981 at 0810 hours. 

C. Approximate Total Loss of Vinyl Chloride 

It is estimated that less than one hundred (100) pounds of \i 

vinyl chloride was released to the atmosphere. ,W 

fy kf3 

V 

» 
P.22 

Mr. Jack Schramm, Reg. Administrator 

June 30, 1981 

Page 2 

D. Method Used to Determine Loss 

Because of the short duration of this discharge and the 

possible presence of some vinyl acetate, it is estimated that 

less than one hundred (100) pounds of vinyl chloride, was lost 

to the atmosphere. 

E. Action Taken to Prevent Discharge 

1. Release was stopped by equalizing pressures in 

A and B recovery system and restarting B-l 

vacuum pump. 

F. Measures Adopted to Prevent Future Discharges 

1. Such vessels will be blinded off when not in use. 

2. Proper relief protection will be installed on PT-306. 

If there are any further questions, feel free to call me. 

Sincerely, 

Charles A. Markowitz 

Associate Regulatory Affairs 

Specialist 

CAM/bj 

cc: R. French 

R. Taggert 
P.23 

'. . 

^SN. : n~ r.-r v-: 

P.O. BOX 320 • DELAWARE CITY. DELAWARE 19706 • TEL (302) 834-4575 

May 27, 1981 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

Mr. Jack Schramm, Reg. Administrator 

U. S. Environmental Protection Agency 

Region III, Sixth and Walnut Streets 

Philadelphia, PA 18106 

Dear Mr. Schramm: 

Re: Vinyl Chloride Monomer Release 

Formosa Plastics Corporation USA 

In accordance with the National Emission Standards for 

Hazardous Air Pollutants, Part 61 of Chapter I, Title 40, 

Section 61.65(a) - Relief Valve Discharges, Polyvinyl Chloride 

located at Delaware City; the address for this source is: 

P. 0. Box 320 

Schoolhouse Road 

Delaware City, DE 

Source of the Release: SPVC-II Plant 

19706 

A. Nature of Cause 

Batch S-1789 was charged at approximately 0730 hours in 

reactor SR-407. At 0935 hours a B operator mistakenly pulled 

the emergency vent for SR-407 instead of reactor SR-405 that he 

was spray rinsing. A release of reaction mixture (vinyl chloride, 

polyvinyl chloride, and water) to the atmosphere took place for 

less than 30 seconds until the operator realized his error and 

closed the vent. 

B. Date and Time of Release 

Monday, May 18, 1981 at 0935 hours 

C. Approximate Total Loss of Vinyl Chloride 

Four hundred eighty four (484) pounds vinyl chloride released 

to the atmosphere. 
P.24 

Mr. Jack Schramm, Reg. Administrator 

May 27, 1981 

Page 2 

D. Method Used to Determine Loss 

Lbs. VCM Charge to Reactor 17,000 

% Conversion 25% 

Lbs. VCM Emitted to Atmosphere 484 

Lbs. VCM Remaining in Batch 12,266 

Lbs. VCM Converted to PVC 4,250 

VCM Vapor Discharged - Assuming 500 gallons vapor space 

at 150 psia and T - 135°F = 595°R; z = .8 (compressibility 

factor); density VCM = 0.1616 lbs./ft.3 at 70°F - 1 atm 

, 1 ,530°R, . 500 gallons. ,.,.,- lbs. .150 psia . _ -i o-j 1Kc. TTPM 

(OTSO)

 (595°R> (7.48l gallons* ( '161 6 ft"^ IttlpelJ " 12 3 lb S \ ^ 

ftT3 — vapor 

VCM Liquid - Approximately six-inch loss of reaction mixture 

was estimated from visual observation to have been discharged to 

the atmosphere. 17.5' is the depth of the total reaction mixture. 

,12,627 lbs. VCM . , 0.5', _ „,-, ,. „_„ ,,„„,,, ( . . . . . ) (T-=—rr 361 lbs. VCM Liquid 'remaining in mixture'

 v17.5'' ^ 

Lbs. VCM Released = 361 + 123 = 484 lbs. 

E. Action Taken to Prevent Discharge 

As soon as mistake was realized, emergency vent was closed. 

F. Measures Adopted to Prevent Future Discharge 

1. Operator has been retrained as to the proper procedure 

of venting a reactor and been given disciplinary time off 

for not following procedure. 

2. Emergency vent knobs have been numbered on front of 

the knob. 

If there are further questions feel free to call me. 

Sincerely, 

Charles A. Markowitz 

Associate Regulatory Affairs 

Specialist 

CAM:cdr