Union Carbide Technical Center - Executive Summary |
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TECH CENTER EXECUTIVE SUMMARY UNION CARBIDE CORPORATION TECHNICAL CENTER RISK MANAGEMENT PLAN EXECUTIVE SUMMARY 1 Accidental Release Prevention and Emergency Response Policies The Union Carbide Technical Center 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 as to protect the environment. These programs include both Union Carbides Responsible Care. requirements and governmental requirements, such as the Environmental Protection Agencys (EPA) Risk Management Program (RMP) rule and the Occupational Safety and Health Administrations (OSHA) Process Safety Management (PSM) standard. 2 Stationary Source and Regulated Substances The South Charleston Technical Center is Union Carbides largest center for engineering, research and development, and integrate d data processing. Most of Union Carbides major processes for petrochemicals have been developed at the Technical Center. The RMP rule requires that if a facility, such as theTechnical Center, has a specific amount (threshold) or more of any one of 140 toxic and flammable chemicals, the facility must follow the RMP rule requirements. The site does not handle or store threshold quantities of EPA regulated toxic substances. The site uses threshold quantities of the following EPA RMP-regulated flammable substances in our pilot plant processes for research and development and in some cases for the production of chemical products: Propylene Ethylene Isopentane 1-Butene 3 Key Offsite Consequence Analysis Scenarios EPAs RMP rule requires 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 hypothetical scenarios. Unless otherwise specified, no credit was taken for admini strative controls or mitigation measures in evaluating the off-site impact of the scenarios. Chemical-specific steps to prevent these scenarios from occurring, and to mitigate their effects should they occur, are shown immediately after the scenario description. The site's general accident prevention program is described in Section 4. A) Regulated Toxic Substances Worst-Case Release Scenario The Technical Center does not handle or store threshold quantities of EPA RMP regulated toxic substances. Alternative Release Scenario(s) The Technical Center does not handle or store threshold quantities of EPA RMP regulated toxic substances. B) Regulated Flammable Substances Worst-Case Release Scenario(s) This scenario assumes catastrophic failure of a storage tank that releases 69,500 lbs. of propylene as a gas to the atmosphere, leading to a vapor cloud explosion. Written operating procedures and a high level shutdown device / alarm limits the maximum filling capacity of this stora ge tank to 80 percent (69,500 lbs). According to EPAs Off-Site Consequence Analysis (OCA) Guidance Table, this release could impact off-site public receptors. A concrete dike is present around the tank, but it is not recognized by EPA Look-up Table as a mitigating control due to propylenes rapid rate of vaporization. The following administrative control was used in this analysis: 7 Inventory Restriction: Written operating procedures and a high level shutdown device/alarm limit the maximum filling capacity of this storage tank to 80 percent (69,500 lbs.). In addition, specific steps to prevent this scenario from occurring, and to mitigate its effects should they occur, include: 7 Combustible Gas Detectors/Deluge System: Sensors are designed to detect flammable vapors and automatically activate an area alarm and deluge system (water spray) to suppress vapors. 7 Fire Water Spray Monitors: Area fire water spray monitors can be used to help suppress vapors. Alternative Release Scen ario This scenario assumes a chemical transfer during the unloading of ethylene from a tank truck, resulting in a liquid ethylene release of 5,000 lbs. per minutes for five minutes. It assumes the excess flow check valve on the tank truck fails, leading to a flash fire. According to the OCA Guidance Table, this release could impact off-site public receptors. The following active mitigation measures are used in this analysis: 7 Emergency Shutdown System: Combustible gas detectors are present to detect flammable vapors, automatically isolate and shutdown the chemical transfer pump, and activate the deluge system (water spray) to suppress vapors. 7 Operator Surveillance: An operator is required to be present while unloading ethylene from a tank truck. This scenario assumes that the combustible gas detector detects the ethylene vapor and actuates the emergency shutdown system within 5 minutes after the release or the operator detects the release within 5 minutes and manually stops the transfer. Other specific steps to prevent this scenario from occurring, and to mitigate its effects should they occur, include: 7 Fire Water Spray Monitors: Area fire water spray monitors can be used to help suppress vapors. 4 General Accidential Release Prevention Program A) General Program Our general accident prevention program consists of compliance with the EPA RMP rule and OSHAs PSM standard and implementation of Union Carbides 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 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 sce narios and to recommend corrective action(s) needed to prevent their occurrence. 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. 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. Mai ntenance Procedures: The plant has specific procedures for maintaining process equipment so that it operates safely. Maintenance Training: 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 inspected to ensure safe operation of process equipment, following recognized standards and/or government requirements. Management of Change: The plant has a management system to ensure that modified facilities and processes are safe for operation. 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 accidents and incidents are properly investigated to determine the cause(s) and implement corrective action(s) that are needed to prevent the event from reoccurring. Employee Partici pation: The plant has a program to involve employees in prevention program elements. Hot Work Permit: The plant 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. These general prevention elements and the chemical specific steps discussed in the previous section are parts of an overall management system t o prevent accidental chemical releases. Our company and our employees are committed to the standards that these management systems set. We have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. 5 Five-Year Accident History In the last five years there has not been an accident or incident involving an EPA RMP chemical at the Union Carbide Technical Center 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. 6 Emergency Response Program The Union Carbide Technical Center 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 response including: 7 Proper first-aid and medical treatment for exposures 7 Evacuation plans and accounting for personnel after an evacuation 7 Notification of local emergency response agencies and the public if a release occurs 7 Post-incident cleanup and decontamination requirements, and 7 Inspecting, testing, maintaining, and using emergency response equipment. The emergency response program is updated when necessary based on modifications made to facility processes. The Union CarbideTechnical Center maintains a trained emergency squad to handle fires, explosions, toxic vapor releases, spills, and medical emergencies. The plant emergency squad trains and drills with local emergency responders to enhance their skills and tactics for responding to an accidental chemical release. Critiques are held on drills and actual events. In addition to the plant emergency squad, Union Carbide staffs a Hazardous Emergency Leaks Prevention (HELP ) team in the Kanawha Valley that responds to accidental releases from transportation equipment throughout the continental United States. 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 Kanawha/Putnam emergency Planning Committee and the community. 7 Planned Changes to Improve Safety The following is a list of improvements that we are planning to implement at the facility to help prevent and/or better respond to accidental chemical releases: 7 Implement a new Corporate program which utilizes semi-quantitative assessment techniques in process hazard analyses to ensure that controls used for prevention or mitigation of hazards provide adequate protection 7 Implement a new Corporate program designed to ensure that process safety information is maintained evergreen 7 Implement the Apollo Root Cause Analysis problem solving technique to identify causes of process problems and effective solutions to prevent their reoccurrence 7 Replace and upgrade the Bulk Gas Storage combustible gas detectors for enhancing detector reliability 7 Upgrade of Polymer R&D Pilot Plant combustible gas detectors and emergency shutdown system for enhancing detector reliability. 7 Install redundant instrumentation on the Polymer Pilot Plant ethylene purification train 7 Revise and improve operator training packages for the Polymer R&D Pilot Plant. 7 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. |