UNION CARBIDE CORPORATION TAFT/ STAR COMPLEX - Executive Summary |
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Union Carbide's Taft/Star Complex LDEQ (Louisiana Department of Environmental Quality) Identification number is 2083. 1. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The Union Carbide Taft/Star Complex is committed to operating and maintaining all of our processes in a safe and responsible manner. We have implemented a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public, as well to protect the environment. These programs include both Union Carbide's Responsible Care. requirements and governmental requirements, such as, the Louisiana Chemical Accident Prevention Program, the Environmental Protection Agency's (EPA) Risk Management Program (RMP) rule and the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) standard. 2. STATIONARY SOURCE AND REGULATED SUBSTANCES Union Carbide's Taft /Star Plant is a petrochemical manufacturing f acility that converts petroleum-based raw materials into a variety of basic building block and intermediate chemicals for customers in many parts of the world. The facility also produces polyethylene plastic pellets that are shipped worldwide. The RMP rule requires that if a facility, such as the Taft /Star Plant, has a specific amount (threshold) or more of any one of 140 toxic and flammable chemicals, the facility must follow the RMP rule requirements for that chemical. . The Union Carbide Taft/Star Complex has 19 chemicals in threshold quantities encompassed by this rule. They are as follows: Acetaldehyde (f) , Acrolein(t), Ammonia (t) , Butadiene (f) , Butene (f) , Ethane (f) , Ethyl Ether (f) , Ethylene (f) , Ethylene Oxide (t) , Ethylenediamine (t) , Hydrochloric Acid (t) , Hydrogen (f) , Isopentane (f) , Methane (f) , Methyl Mercaptan (t) , Peracetic Acid (t) , Propane (f), Propylene (f), Vinyl Methyl Ether (f) 3. KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RMP rule r equires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario. General steps to prevent these scenarios from occurring and to mitigate their effects should they occur appear in Section 4. A) Regulated Toxic Chemical (s) Worst-case Release Scenario(s) Acrolein - This scenario assumes an instantaneous failure of the tank walls and safety systems releases the entire contents of a 186,000 lb. tank in 10 minutes, with the worst possible weather conditions ( no wind, low humidity). According to OCA Guidance Table , this release could impact off-site public receptors. In addition to proper engineering , design and construction, the accident prevention in place consists of the following: *Inventory Restriction - Written operating procedu res and a high-level shutoff system limits the maximum filling capacity with redundant overfill protection. *Tank is enclosed in concrete bunker under an earthen mound. *Special service design standards and special inspection and testing is done. *The pressure relief devices are routed to a flare system. *A reaction prevention system , which includes an inhibitor system, multiple emergency dump and disposal facilities, redundant temperature monitoring. Alternative Release Scenario(s) Acrolein - This scenario assumes a transfer line develops a flange leak and approximately 500 lbs. of Acrolein is lost to the atmosphere. The wind speed is 3 meters/sec. and the stability class D is used. An individual detects the release, actuates the alarm system, and unit personnel isolate the leak in 30 minutes. According to OCA Guidance Table, this release could impact off-site public receptors. In addition to proper engineering , design and construction, the accident prevention in place consists of the following: *Special service design standards *Special inspection and testing *Automatic isolation valves Ammonia - This scenario assumes a three inch ammonia pipeline develops a crack along the weld on 3/4" drain valve. The crack is =" long by 1/32" wide. Approximately 1,260 lbs. of material is lost. The wind speed is 3 meters/sec. and the stability class D is used. An individual detects the release, actuates the alarm system, and unit personnel isolate the leak in 30 minutes. According to OCA Guidance Table , this release could impact off-site public receptors. In addition to proper engineering , design and construction, the accidental prevention in place consists of the following: *Periodic inspection and testing *A flare to reduce line pressure in case of an emergency *Automatic isolation valves Ethylene Oxide - This scenario assumes a gasket fails on a 4" pipe during transfer conditions. Approximately 2,500 lbs. of material is lost. The wind speed is 3 meters/sec. and the stability class D is used. An individual detects the release, actuates the alarm system, and unit personnel isolate the leak in 20 minutes. According to OCA Guidance Table , this release could impact off-site public receptors. In addition to proper engineering , design and construction, the accident prevention in place consists of the following: *Periodic inspection and testing *A flare to reduce line pressure in case of an emergency *Remotely operated ESD (Emergency Shut Down) isolation valves *Periodic Fugitive Emission monitoring Ethylenediamine - This scenario assumes the Ethylenediamine pipe line develops a leak as it is crossing La. Highway 18 during a transfer of material to the marine dock. Approximately 9,380 lbs. of material is lost. The wind speed is 3 meters/sec. and the stability class D is used. An individual detects the release, actuates the alarm system, and unit personnel isolate the leak in 30 minutes. According to OCA Guidance Table , this release could impact off-site public receptors. In addition to proper engineering , design and construction, the accident prevention in place consists of the following: *Periodic inspection and testing *Full time attention to loading and transfer Hydrochloric Acid - This scenario assumes an expansion joint at the HCL tank develops a crack resulting in a 5,000 lb. loss of material. The wind speed is 3 meters/sec. and the stability class D is used An individual detects the release, actuates the alarm system, and unit personnel isolate the leak in 20 minutes. According to OCA Guidance Table , this release could impact off-site public receptors. In addition to proper engineering , design and construction, the accident prevention in place consists of the following: *Periodic inspection and testing *Isolation valves *Level deviation alarm readout (informs technician that Tank inventory is decreasing) Methyl Mercaptan - This scenario assumes a tank car of methyl mercaptan is being unloaded and a flange develop s a leak releasing 2,000 lbs. The wind speed is 3 meters/sec. and the stability class D is used. An individual detects the release, actuates the alarm system, and unit personnel isolate the leak in 20 minutes. According to OCA Guidance Table , this release could impact off-site public receptors. In addition to proper engineering , design and construction, the accident prevention in place consists of the following: *Periodic inspection and testing *Specific chemical detectors *Deluge systems *Special torquing procedures and leak testing before placing unit in service *Lines pressure tested prior to unloading *Remotely operated ESD (Emergency Shut Down) isolation valves *Methyl Mercaptan detection system Peracetic Acid- This scenario assumes a pump discharge pipe flange leak (1.5" long x 0.05" wide) occurs releasing 2,220 lbs. of material. The wind speed is 3 meters/sec. and the stability class D is used. An individual detects the release, actuates the alarm system, and unit personnel i solate the leak in 20 minutes. According to OCA Guidance Table , this release could impact off-site public receptors. In addition to proper engineering , design and construction, the accident prevention in place consists of the following: *Periodic inspection and testing *An emergency burning pit *Special start up preparations *Remotely operated ESD isolation valves *Combustible Gas Detectors B) Regulated Flammable Chemicals Worst-case Release Scenario(s) Propylene - This scenario assumes complete failure of the propylene storage sphere and total release of its entire contents (5,100,000 lbs.) within 10 minutes. The entire volume vaporizes instantaneously and explodes. According to OCA Guidance Table , this release could impact off-site public receptors. In addition to proper engineering , design and construction, the accident prevention in place consists of the following: *Periodic inspection and testing of lines and equipment *Redundant overfill protection *Pressure relief devices routed to a flare *Remotely operated isolation valves *Combustible Gas Detection Systems Alternative Release Scenario(s) Propylene - This scenario assumes a transfer pump discharge flange fails and 8,500 lbs. of material is lost to the environment over a 20 minute period and the gas cloud explodes. According to OCA Guidance Table , this release could impact off-site public receptors. Automatic isolation and activation of area deluge system minimize the release. In addition to proper engineering , design and construction, the accident prevention in place consists of the following: *Periodic inspection and testing of lines and equipment *Automatic deluge system *Remotely operated isolation valves Various emergency response measures also exist such as: *Alarm systems *Trained emergency responders *Mobile and fixed fire protection equipment *Water spray to minimize releases *Communication link to off-site responders 4. GENERAL ACCIDENT RELEASE PREVENTION PROGRAM AND CHEMICAL PREVENTI ON STEPS At Union Carbide we take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our general accident prevention program consists of compliance with the Louisiana Chemical Accident Prevention Program, the EPA RMP rule and OSHA's PSM standard and implementation of Union Carbide's Operational Safety Program and Episodic Risk Management System. Key elements include: Equipment Design: Vessels (including shipping containers) and other process equipment are designed according to recognized industry standards and/or governmental requirements. Process Safety Information: Chemical hazard, process technology, and equipment information is documented, maintained up-to-date, and available to operating personnel. Process Hazard Analysis: Process hazard analyses are conducted every five years to identify major process hazard scenarios and to recommend corrective action(s) needed to prevent their occurrence. Episodic Risk Management: Periodic reviews ar e conducted to identify hazards which could have significant community impact and to recommend corrective action(s) needed to prevent their occurrence. These reviews utilize advanced quantitative risk assessment techniques. Operational Safety Standards: Design requirements for active and passive mitigation controls used to prevent major process hazards are documented in operational safety standards. Operating Procedures: Operating procedures provide detail on how to safely operate a process and are maintained up-to-date. Operator Training/Certification Program: The plant has a training and testing program which provides operators with the proper skills and knowledge prior to allowing them to independently operate a process. Technical Staff Training and Support: Trained technical staff employees are available 24 hours a day to support operations. Maintenance Procedures: The plant has specific procedures for maintaining process equipment so that it operates safely. Maintenance Trai ning: The plant trains persons who perform routine or complex maintenance tasks on process equipment. Mechanical Integrity Program: Vessels (including shipping containers) and other process equipment are periodically tested and/or inspected to ensure safe operation of process equipment, following recognized industry standards and/or governmental requirements. Management of Change: The plant has a management system to ensure that modified facilities and processes will be safe to operate. Pre-startup Safety Reviews: Reviews are conducted just prior to startup to ensure that modified facilities and processes are safe for operation. Incident Investigation: The plant has a program to ensure that accidents and incidents are properly investigated to determine the cause(s) and to implement corrective action(s) that are needed to prevent the event from reoccurring. Employee Participation: The plant has a program to involve employees in prevention program elements. Hot Work Permit: The pl ant has a procedure to ensure that welding, cutting and brazing are safely performed in areas where flammable or combustible material may be present. Contractor Safety Program: The plant has a program to ensure that contractors are properly trained and perform their work in compliance with safety requirements. Compliance Audits: Periodic Corporate and plant-led audits are conducted to ensure that process operations comply with governmental and Union Carbide requirements. Operational Safety Program: Union Carbide has a comprehensive program to ensure that all the elements listed above are implemented at every Union Carbide location. This Program includes accountabilities for timely and proper implementation of the program elements. Our management systems address each of the key features of successful prevention programs including: 5. FIVE-YEAR ACCIDENT HISTORY During the last five years, there have been no accidental releases from covered processes at the Taft/Star Plant that re sulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. 6. EMERGENCY RESPONSE PROGRAM The Taft / Star Complex Plant maintains an emergency response program to protect worker and public safety, as well as the environment. The program consists of procedures for responding to releases of hazardous substances, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including: *Proper first-aid and medical treatment for exposures *Evacuation plans and accounting for personnel after an evacuation *Notification of local emergency response agencies and the public if a release occurs *Post-incident cleanup and decontamination requirements, and *Inspecting, testing, maintaining, and using emergency response equipment The emergency response program is updated when necessary based on modifications made to facility processes. The Taft / Star Plant maintains a trained emergency squad to handle fires, explosions, toxic vapor releases, spills, and medical emergencies. Information is shared with local emergency responders to enhance their skills and tactics for responding to an accidental chemical release from our facility. Critiques are held on drills and actual events. In addition to the plant emergency squad, Union Carbide's Hazardous Emergency Leaks Prevention (HELP ) team responds to accidental releases from transportation incidents occurring in the continental U.S. The emergency response program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Detailed emergency response plans are developed and coordinated with the St. Charles Parish Emergency Planning Committee and the community. 7.PLANNED CHANGES TO IMPROVE SAFETY On-going programs, such as process hazard analysis reevaluations, continually aim to improve process safety. The following is a list of specific improvements that we are planning to implement at the Taft / Star Complex to help prevent and/or better respond to accidental chemical releases: *A new Corporate program that uses semi-quantitative assessment techniques in process hazard analyses to ensure that controls used for prevention or mitigation of hazards provide adequate protection. *A new Corporate program designed to ensure that process safety information is kept up-to-date. *Install a new modified valve handle on Methyl Mercaptan tank car valves to prevent inadvertent operation. *Union Carbide continues to implement a corporate-wide strategy to avoid computer hardware and software systems operating disruptions due to the year 2000 changeover. The latest information on the company's Y2K efforts can be found on our Internet site -- www.unioncarbide.com. This information will be periodically updated through first quar ter 2000. *Reduce the volume of stored ammonia by 50% with a change in operating philosophy to use only one tank of liquid ammonia versus two. Also, install magnetic sight glass in the ammonia storage area which reduces the possibility of an ammonia release or equipment failure and increases the reliability of the existing sight glass at least 100 fold. *Modify existing oxide tank car temperature monitoring system during loading operations which reduces the potential for flaring. *Upgrade the peracetic acid tank dump interlock system to reduce the possibility of accidental dumps. *Implement projects in the peracetic acid unit to reduce risk of equipment failure and emissions i.e., upgrade the material of construction of equipment and the installation of double mechanical seals on unit pumps. |