Union Carbide Corporation - Executive Summary

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Union Carbide Corporation has a long-standing commitment to worker and public safety.  We are committed to operating and maintaining all of our processes in a safe and responsible manner. We have implemented a combination of accident release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public, as well as to protect the environment.  These programs include both Union Carbide's Responsible Care( requirements and governmental requirements, such as the Environmental Protection Agency's (EPA) Risk Management Program (RMP) rule, California's Accidental Release Prevention (CalARP) Program, and the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) standard.  The objective is to minimize the risk of a release of a hazardous material and if a release occurs, to minimize the potential impact to employees, the 
public and the environment. Union Carbide management is committed to providing appropriate training to all employees, and coordinating response activities, as necessary, with the local emergency response providers. 
The facility is located at 19500 Mariner Avenue in the City of Torrance, California.  The Union Carbide Torrance Terminal activities include the bulk storage, transfer and blending of chemicals. Tank cars are temporarily stationed on-site for the unloading of bulk chemicals.  The Torrance Terminal is recognized as a covered source under the RMP rule as the facility maintains quantities of a regulated substance listed in the RMP rule.  Currently, the only regulated substance present on-site in quantities above the threshold limit is vinyl acetate monomer (VAM). 
Annual VAM throughput is approximately 43 million pounds.  VAM is received by tank rail cars and stored in one aboveground tank dedicated for storage of VAM. 
 The tank description is summarized below: 
* Internal floating roof tank with primary and secondary rim seals; 
* 265,000-gallon capacity and 186,000-gallon maximum operating capacity; 
* Secondary containment with over 350,000-gallon capacity; and 
* Floating gauge for measuring liquid level. 
VAM is transferred via pipeline to the adjacent UCAR( Emulsion Systems (UES) latex manufacturing plant as needed or is shipped to customers via tank trucks.  Trucks are vented to a scrubber during loading to control the release of vapors.  If VAM is loaded directly from rail cars to trucks, a dedicated vapor balance system is used to reduce emissions to the atmosphere. 
A network of product transfer piping is routed between the VAM storage tank, the truck loading station and the adjacent UES latex plant.  All piping is coated to prevent corrosion and is supported by steel framework, which is securely fastened to concrete or asphalt platforms or foundations.  Underground sections of piping are enc 
ased by an outer pipe to prevent corrosion due to contact with soils. 
EPA's RMP rule requires that information be provided about the worst-case release scenario and alternative release scenario for our facility.  The following are brief summaries of these hypothetical scenarios.  Unless otherwise specified, no credit was taken for administrative controls or mitigation measures in evaluating the off-site impact of the scenarios.  
Worst-Case Release Scenario 
The worst-case release scenario for VAM included an instantaneous release of all the contents of the VAM storage tank into the 93-foot by 98-foot by 5-foot concrete dike area, which acts as passive mitigation for the release.  This release translates to a release of 186,000 gallons (1,445,220 pounds) based on the maximum safe fill capacity.  According to EPA's RMP*Comp(tm) model, this release could impact off-site public receptors.  The following administrative control and passive mitigation measure  
are used in this analysis: 
Inventory Restriction:   Written operating procedures, which include an operating checklist, limit the maximum filling capacity of the VAM storage tank to 186,000 gallons, approximately 70%.  This tank is equipped with an automatic in-tank float gauge, which is read daily by an operator.  At this fill capacity, procedures require operations to stop all transfers into the tank.   
Concrete Dike:  The dike contains and minimizes VAM evaporation to the atmosphere. 
Specific systems to prevent this scenario from occurring, as well as mitigate its effects should they occur, include: 
Reaction Prevention:  Systems in place to ensure reactivity of material stored in tanks is inhibited. 
Pressure Relief Systems:  Pressure relief systems help to ensure that over-pressures within tanks are mitigated. 
Equipment Design and Construction:  Design and construction codes and standards are met or exceeded. 
Alternative-Case Release Scenario 
The selected alternative-release 
scenario for VAM is a leaking valve, which is located in the dike area of the VAM storage tank.  The maximum offloading rate is 250 gallons per minute (1,943 pounds per minute) based on simultaneous offloading of two railcars.  This scenario leads to a 19,430-pound release of VAM in 10 minutes, the maximum time it may take an operator shut down the transfer pump.  The scenario assumes that the release is contained in the tank's dike area, which mitigates the release.  According to EPA's RMP*Comp(tm) model, this release could impact off-site public receptors.  The following active mitigation measures are used in this analysis: 
Emergency Shutdown Systems:  A manual emergency shutdown system is designed to shut down the transfer pump.   
Surveillance:  Operations personnel routinely monitor the process and facility perimeters. 
The Torrance Terminal's general accident prevention program consists of compliance with the following rules as 
well as implementation of Union Carbide's Operational Safety Program and Episodic Risk Management System. 
* California Code of Regulations, Title 19, Division 2, Chapter 4.5, CalARP Program 
* Code of Federal Regulations, Title  29, Part 1910, Process Safety Management (29 CFR 1910.119, Process Safety Management rule) 
* 40 CFR Part 68, Accidental Release Prevention (RMP rule) 
* 40 CFR Part 112, Spill Prevention, Control and Countermeasure 
* 40 CFR Part 264, Hazardous Waste Contingency Plan 
* 40 CFR Part 355, Emergency Planning and Community Right-to-Know Act (EPCRA) 
The following is a summary of the general accident prevention program in place at the Torrance Terminal. 
Compliance Audits 
To help ensure that the accident prevention program is functioning properly, Union Carbide periodically conducts corporate and plant-led audits to ensure that process operations comply with governmental and Union Carbide requirements.   
Contractor Safety Program 
Union Carbide uses contractors to s 
upplement its work force during periods of increased maintenance or construction activities. Due to the fact that some contractors work on or near process equipment, the facility has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform facility personnel of any hazards that they find during their work. 
Employee Participation 
Union Carbide encourages employees to participate in all facets of process safety management and accident prevention.  Employees have access to all information created as part of the facility accident prevention program.  Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that is maintained at the facility and addresses each accident p 
revention program element.  In addition, employees participate in keeping process safety information up to date by making periodic inspections, having an active role in writing operating procedures and being involved in many other aspects of the accident prevention program, such as incident investigations. 
Episodic Risk Management System 
Periodic reviews are 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. 
Equipment Design 
Vessels (including shipping containers) and other process equipment are designed according to recognized industry standards and/or governmental requirements. 
Incident Investigation 
Union Carbide promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The go 
al of each investigation is to determine the root cause of the incident by reviewing facts and developing corrective actions to prevent a recurrence of the incident or a similar incident.  
Management of Change 
Union Carbide has a comprehensive system to ensure that modified facilities and processes will be safe to operate. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. 
Mechanical Integrity 
Union Carbide has well-established practices and procedures to maintain tanks, piping systems, relief and vent systems, controls, pumps and transfer hoses, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying 
quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process equipment. 
Operating Procedures 
Union Carbide maintains written procedures that provide detail on how to safely operate a process, including various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. These procedures are periodically reviewed and annually certified as current and accurate. The procedures are maintained up-to-date by revising them as necessary. 
In addition, the plant maintains specific procedures for maintaining process equipment so that it operates safely.  The plant also trains persons who perform routine or complex maintenance tasks on process equipment. 
Operational Sa 
fety Program 
Union Carbide has a comprehensive program to ensure that all the elements listed within this accidental release prevention program are implemented at every Union Carbide location.  This Program includes accountabilities for timely and proper implementation of the program elements. 
Operational Safety Standards 
Design requirements for active and passive mitigation controls used to prevent major process hazards are documented in operational safety standards. 
Pre-startup Safety Reviews (PSSRs) 
Union Carbide conducts reviews just prior to startup to ensure that new and modified facilities and processes are safe for operation. A PSSR involves field verification of the construction and serves as a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. 
Process Hazard Analysis 
Union Carbide has a comprehensive program to help ensure that hazards associated with the various processes are identified and cont 
rolled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards.  Process hazard analyses are conducted every five years to identify major process hazard scenarios and to recommend corrective action(s) if needed to prevent their occurrence. 
Union Carbide primarily uses the What-If/Checklist analysis as well as Fault Tree Analysis techniques to perform these evaluations. These analyses are recognized as some of the most systematic and thorough hazard evaluation techniques. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise.  
Process Safety Information 
Union Carbide keeps a variety of technical documents that are used to help maintain safe operation of the processes.  Chemical hazard, process technology, and equipment information is documented, maintained up-to-date and available to operating personnel.  
-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). For specific process areas, the facility has documented safety-related limits for specific process parameters (e.g., temperature, pressure and level control) in the Operational Safety Standard (OSS) documents. The facility ensures that the process is maintained within these limits using process controls and monitoring instruments, automated operating systems, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems). 
The facility maintains numerous technical documents that provide information about the design and construction of process equipment. This information, in combination with written procedures and trained personnel, provides a means for establishing inspection and maintenance activities.  
Safe Work Practices 
Union Carbide has long-standing safe work practices in place to help ens 
ure worker and process safety.  Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout - tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. 
Training/Certification Programs 
To complement the written procedures for process operations, Union Carbide has implemented a comprehensive training and certification program for all employees involved in operating a process. After employees demonstrate (e.g., through tests, skills demonstration) havi 
ng adequate knowledge to perform the duties and tasks in a safe manner on their own, they are certified to work independently.  In addition, trained technical staff employees are available 24 hours a day to support operations. 
In the last five years there has not been an accident or incident involving an EPA RMP chemical at the Union Carbide Torrance Terminal that resulted in an on-site death, injury, or property damage; or a known off-site death, injury, evacuation, shelter-in-place, property damage or environmental damage.  
The Union Carbide Torrance Terminal maintains a written 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 respo 
nse, 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. Employees receive training in these procedures as necessary to perform their specific emergency response duties.  
The overall emergency response program for Union Carbide in Torrance is coordinated with the Torrance Fire Department (Administering Agency) and Local Emergency Planning Committee (LEPC). Union Carbide conducts periodic emergency drills that involve the emergency response organizations.  In addition, Union Carbide's Hazardous Emergency Leaks Prevention (HELP) team located in Torrance responds to accidental r 
eleases 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 Torrance Fire Department. 
The Union Carbide Torrance Terminal completes a thorough review of the affected VAM system(s) each time a design change is implemented and reviews the standard operating procedures at least every three years.  The Union Carbide audit team revalidates the process hazards analysis every five years from the date of the initial process hazards analysis.  Union Carbide is committed to using these methods to identify and implement ways to improve the safety of these systems.  These on-going programs continually aim to improve process safety.  The following is a list of specific improvements that we are planning t 
o implement at the Union Carbide Terminal in Torrance 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. 
* 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 quarter 2000.
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