VOC Process Equipment Clearing, Cleaning, and Routine Maintenance. Individual Unit Function: Environmental Procedure No.: PA Page: 1 of 10

Transcription

1 Procedure No.: PA Page: 1 of 10 Port Arthur, TX. Reviewed: 01/2018 Effective: 01/25/18 (Rev 06) Supersedes: 1/17 Preparer: Owner: Approver: EHS Specialist - Env EHS Specialist - Env EHS Manager Document Revision Change Table Revision Number Revision Description Revised By Revision Date New 1 Updated Attachment A with BFLP Information RY 08/12 2 Updated Attachment C with revised clearing form MS 09/12 3 Updated BFLP with BTP, no other changes needed AH 07/15 4 One typo fied GW 10/16 5 Added a place to document LEL/Ultrarae serial number to clearing AH 01/17 form 6 Reviewed and minor grammar and spelling changes GW 01/18

2 Procedure No.: PA Page: 2 of 10 Port Arthur, TX. Reviewed: 01/2018 Effective: 01/25/18 (Rev 06) Supersedes: 1/17 1. PURPOSE Provide guidelines to ensure compliance with environmental MSS air permitting requirements. Establish a standard process for safely clearing, cleaning and/or isolating equipment, in VOC process service during routine maintenance activities. 2. DEFINITIONS 2.1. Leak Detection and Repair (LDAR) For the purpose of this procedure, LDAR means a Federally mandated Environmental Protection Agency (EPA) program, which requires our site to monitor for fugitive emissions, including flange leaks, valve-stem leak, packing leaks, and pump seals. The monitoring is conducted via EPA Method 21, which utilized a TVA analyzer which reads in ppm VOC. A leak is typically any reading above 500 ppm VOC Lower Eplosive Limit (LEL) Lowest concentration (percentage) of a gas or vapor in air capable of producing a flash of fire in presence of an ignition source (arc, flame, heat). Concentrations lower than LEL are 'too lean' to burn. 2.3., Startup, & Shutdown (MSS) One type of TCEQ permit which regulates emissions & work practices during, Startup, & Shutdown activities, including clearing equipment for routine maintenance Open Ended Lines (OEL) Open-ended valve or line means any valve, ecept safety relief valves, having one side of the valve seat in contact with process fluid and one side open to the atmosphere, either directly or through open piping Teas Commission on Environmental Quality (TCEQ) State of Teas environmental agency responsible for creating state regulatory laws and issuing environmental permits Volatile Organic Compound (VOC) Any organic compound which participates in atmospheric photochemical reactions; or which is measured by a reference method, an equivalent method, an alternative method, or which is determined by procedures specified under any subpart.

3 Procedure No.: PA Page: 3 of 10 Reviewed: 01/2017 Effective: 01/16/17 Supersedes: 10/01/16 (Rev 04) 3. SCOPE This procedure applies to all process or storage equipment in VOC service at the BASF Port Arthur facility. Attachment B is included to help aid in determining the requirements of this procedure. This procedure DOES NOT apply if equipment is opened for the sole purpose of isolation blinding or a task is listed on Attachment A. 4. PROCEDURE 4.1. Isolation of Equipment for Clearing and Cleaning Isolate process equipment using manual valves that will prevent process flows from entering into equipment cavity Depressurize System to Dry/Wet Flare Setup temporary and/or align permanent connections to vent-off process liquid/vapor pressure to the wet/dry flare system. If the process manual block valves used to isolate the equipment are maintaining proper process flow isolation from entering the equipment proceed to section If it is noticed that isolation block valves are leaking by enough to affect proper clearing of equipment, ensure valves are properly closed and/or consider valve seat flushing. A. If the leaking valve can be identified attempt to correct by flushing valve seats with process flow. Open leaking valve to allow product flow over valve seat (possibly removing debris) while maintaining all other isolation valves closed, direct this process flow to the wet/dry flare system or drain through a low point bleed to an inert containment vessel. B. If valve seat flushing is not successful, determine if closure of an additional block valve(s) is available to isolate equipment If still not successful in establishing proper equipment isolation, close all drain points and bleeders and remove temporary connections (replace bull plugs or blinds) use eisting or install a pressure gauge (ensure gauge is appropriate for service) on isolated equipment to determine pressure increase rate over a 30 minute period. This information may be used for calculation to determine the severity of the internal valve leak Contact Shift Supervisor and inform on inadequate isolation issue(s) Assemble a team (Operations Management,, and EHS) to determine an acceptable path forward.

4 Procedure No.: PA Page: 4 of 10 Reviewed: 01/2017 Effective: 01/16/17 Supersedes: 10/01/16 (Rev 04) 4. PROCEDURE cont d 4.3. Clearing and Cleaning of Isolated Equipment To ensure isolated equipment is properly cleared for out of service and/or routine maintenance activities, follow the appropriate operations approved equipment clearing/cleaning procedure located in Documentum. If the equipment clearing procedure does not adequately address or cannot be located, contact the Shift Coordinator for further instructions If mied phase materials (liquids & vapors) must be removed from process equipment, the cleared material shall be routed to a knockout drum or equivalent to allow for managed initial phase separation. (Plant Flare Knockout Drum meets this requirement) All liquids from process equipment must be removed to the maimum etent practical prior to opening equipment to commence degassing and/or maintenance. Liquids must be drained into a closed vessel or closed liquid recovery system (Vacuum Truck with emissions controls meets this requirement) unless prevented by the physical configuration of the equipment. If it is necessary to drain liquid into an open pan or sump, the liquid must be covered or transferred to a covered vessel within one hour of being drained Ensure control valves are open and other potential locations that may trap or prevent thorough flushing/cleaning between isolation valves are addressed In order to comply with TCEQ MSS Equipment Clearing requirements, Facilities being prepared for maintenance shall not be vented directly to atmosphere until the LEL concentration has been verified to be less than 1% and Butadiene and Benzene are less than 5 ppm. The LEL/BD/BZ sample should be taken from inside the vessel, vent, or drain valve so as to minimize air dilution (please see Attachment B - Environmental MSS Decision Flowchart). Note: If the equipment is blinded or immediately replaced (replacement with new equipment would require less than or equal time as blinding) then Attachment B - Environmental MSS Decision Flow Chart DOES NOT apply.

5 Procedure No.: PA Page: 5 of 10 Reviewed: 01/2017 Effective: 01/16/17 Supersedes: 10/01/16 (Rev 04) 4. PROCEDURE cont d Record sampling results on Attachment C (This form part of the MIP packages and will print out with any other necessary MIP paperwork) and place in a folder inside the Control Room Permit Room for BTP or inside the C-Can for C4. These sheets will be picked up at the end of each month for environmental compliance. If more than one piece of equipment is being cleared together as a system, please list all equipment that is being cleared in the Equipment Number and/or Description bo (attaching a list of equipment is perfectly acceptable). One LEL sample location/reading is acceptable as long as it is downstream and representable of the system being cleared To help communicate equipment condition to other shift personnel identify on white boards in permit area of equipment status. This will help oncoming shift troubleshoot to resolve issues. Is system coming down soon for Outage/Turnaround so it can be addressed during shutdown? Use alternative cleaning (soaps, chemicals, water, etc ) Non-routine procedure or deviation being developed to address safety and environmental requirements Monitoring/Sampling Results above VOC/ Personnel Emission Limits After equipment clearing/cleaning procedure has been completed monitor/sample with the appropriate meter (LEL meters, PIDS, dragger tubes) for oygen, LEL, Benzene, 1,3 Butadiene to determine if there are any potential chemical eposure concerns (see PA Benzene Compliance or PA Butadiene Compliance procedure for further instruction). Note: Propylene services needs additional NORM testing from Health and Safety Group. For details regarding equipment locations and Hazcom requirements refer to Site procedure PA Contact Site Safety for assistance Monitor/sample internal atmosphere of the equipment through bleed/opening and record results on Safework permit to help determine potential eposure concerns and minimum PPE requirements If detection of any reading inside equipment is outside of acceptable eposure limits then evaluation of source needs to be investigated. Acceptable ranges are: Oygen to 21.0 % LEL to 1.0 % BZ/BD to 0.5 ppm

6 Procedure No.: PA Page: 6 of 10 Reviewed: 01/2017 Effective: 01/16/17 Supersedes: 10/01/16 (Rev 04) 4. PROCEDURE cont d To help identify any potential area eposure concerns place meter inlet tube directly at center of opening to determine if vapor volume is leaking to atmosphere If the equipment cannot be properly cleared and cleaned per the acceptable eposure/emission limits, then assemble a team of Operations,, and EHS personnel to help develop an approved path forward to address these concerns If all reasonable clearing methods are unable to reach 1% or less LEL and plant personnel choose to open the equipment without blinding or immediate replacement, an AIM report should be filled out and an environmental Title V deviation will be recorded. Note: Once the maimum allowable clearing/cleaning limit for Benzene / 1,3 Butadiene has been established for the specific system or individual piece of equipment and if it is greater than the OSHA action level limit (8 Hr TWA 0.5 ppm) all equipment line breaking maintenance/servicing activities should be considered as a potential Regulated Area and follow eisting site procedures PA Benzene Compliance and/or PA ,3 Butadiene Compliance for the appropriate potential eposure concern MSS OEL requirements for Routine please follow the basic clearing/cleaning steps below If the isolation configuration results in having one side of the valve seat in contact with process fluid and one side open to the atmosphere either directly or through open piping (Single Isolation Valve), an Open-Ended Line (OEL) has been created The open-ended line or valve must be capped, blind flanged, plugged, or second valve installed within 120 hours (5 days) of OEL creation If the OEL cannot be eliminated within 120 hours, the LDAR Supervisor should be contacted immediately (5238) to monitor the OEL. A technician is now required to monitor the OEL once at the end of the 120 hour period following the creation of the OEL with a Method 21 approved analyzer. Leaks are indicated by reading of 500 ppm above background and MUST be repaired/ eliminated within 120 hours. Note: If the OEL is not repaired or eliminated as stated above, an AIM report should be filled out and an environmental Title V deviation will be recorded.

7 Procedure No.: PA Page: 7 of 10 Reviewed: 01/2017 Effective: 01/16/17 Supersedes: 10/01/16 (Rev 04) 5. RESPONSIBILITIES Operations Manager / Shift Supervisor/ Operations Coordinators / Operations Shift & Production Specialist Has the primary responsibility of understanding and following the requirements of this procedure. Reporting any deficiencies related to equipment, testing method, and written procedure to their immediate supervisor. EHS Manager Has the primary responsibility of initiation, reissuance, administration, and/or interpretation of this procedure. Operations Director Has primary responsibility for the implementation of this procedure. 6. RELATED DOCUMENTS Attachment A Attachment B Attachment C PA PA PA PA PA List of Routine work that DOES NOT require clearing to 1% LEL for Environmental Regulatory purposes Decision Flow Chart MSS Equipment Clearing Form Port Arthur Natural Occurring Radioactive Material (NORM) procedure Port Arthur Benzene Eposure procedure Port Arthur Benzene Compliance procedure Port Arthur Butadiene Eposure procedure Port Arthur Butadiene Compliance procedure

8 PA Attachment A C4 Permit No , PSD-TX-950, and N-018 Attachment A INHERENTLY LOW EMITTING ACTIVITIES Emissions Activity VOC NO CO PM H 2 S/SO 2 Chemicals/Lubricants Replace analyzer filters Calibrate analyzers Analyzer purging Sample purging Sample media changing Pipeline pigging Instrumentation maintenance Carbon canister replacement Drain equipment to controlled sewer BTP Permit No , PSD-TX-903, and N-007 Attachment A INHERENTLY LOW EMITTING ACTIVITIES Emissions Activity VOC NO CO PM H 2 S/SO 2 Chemicals/Lubricants Replace analyzer filters Calibrate analyzers Analyzer purging Sample purging Sample media changing Instrumentation maintenance Carbon canister replacement Drain equipment to controlled sewer

9 Decision Flow Chart PA Attachment B DOES NOT APPLY if equipment is opened for the sole purpose for isolation blinding or task is listed on Attachment A of this procedure. Isolate equipment using valves to prevent process flows from re-entering equipment cavity. Depressurize equipment to Dry/Wet flare. Approved Operations Procedure located in Documentum. Determine if isolation valve(s) are leaking? NO YES Attempt to identify and correct leaking valve(s). Clear/clean process equipment using appropriate approved Operations equipment procedure. YES Isolation Valve(s) leakage stopped? NO Test internal atmosphere of equipment for O2, LEL, BZ/BD (<19.5 O2 can affect LEL/VOC readings/measurements). YES Additional means available to isolate equipment? NO If possible use eisting or install a pressure gauge on isolated equipment to determine pressure increase rate over a 30 minute period. NOTE: Record/retain equipment monitoring results for 5 years. Air permit Limits LEL<1.0 % BZ/BD <5.0 ppm? YES Open and remove/repair equipment. NO Contact Shift Coordinator and inform. Op s, Maint, and EHS to determine an acceptable path forward. YES Contact Shift Coordinator and inform on inadequate isolation issue(s). Leaking valve need further evaluation? NO If job is planned for equipment to be open >120 Hrs without isolation blinds or double block & bleed, contact EMS (5238) to arrange for additional monitoring. MSS-OEL requires installation of isolation blinds or equipment replacement immediately. If open equipment is leaking >500 ppm blinding is required with-in 120 hours. If equipment cannot be properly isolated to prevent VOC emissions to atmosphere during equipment repair/replacement - AIMS report must be generated for Title V Deviation reporting.

10 PA Name: Shift (circle): Day / Night MSS Equipment Clearing Form Date: Attachment C Complete this form for all equipment clearing activities related to, Startup, and Shutdown activities. Equipment Number and Description: Reason for Inspection Repair Replacement Routine/Preventive Startup Shutdown Other (describe) Clearing and Purging to Flare: Was equipment vented to a flare or other control? YES NO C4 HP Flare C4 LP Flare BTP Flare T.O. BTP Slop Drum Other Start Date (equipment OOS) Clearing / Purging Time Start Time End Date End Time Was equipment opened to atmosphere? YES NO Before equipment can be vented to atmosphere, test for concentration. Emissions/Venting associated with installing blinds for isolation is EXEMPT from the LEL and PPM requirements below. LEL must be less than or equal to 1%. 1,2-butadiene, 1,3-butadiene, and benzene must be less than 5 ppm. Test Result: LEL or PPM BD PPM BZ Serial Number of LEL/UltraRAE When was the equipment opened to the atmosphere? Date: Time: AM / PM Retain for Environmental Title-V MSS-OEL Air Permit Record Keeping Compliance **Included in MIP printed material packages**