Union Carbide Corporation Texas City Plant - Executive Summary |
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UNION CARBIDE CORPORATION TEXAS CITY, TEXAS PLANT RISK MANAGEMENT PLAN EXECUTIVE SUMMARY 1. Accidental Release Prevention and Emergency Response Policies The Union Carbide Texas City Plant 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 CareR requirements and governmental requirements, such as 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. Description of the Facility and Regulated Substances The Union Carbide Texas City Plant is a manufacturing facility that annually produces more than 5 billion pounds of chemical products in it s various operating units. Most are intermediates used in other Union Carbide processes, or sold to customers who convert them into finished products. The RMP rule requires that if a facility, such as the Texas City 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 Texas City Plant has the following RMP-regulated toxic substances in quantities above the threshold: 7 Vinyl Acetate 7 Chlorine 7 Isopropyl chloroformate 7 Ethylene Oxide The plant has the following RMP-regulated flammable substances in quantities above the threshold: 7 1,3-Butadiene 7 Propylene 7 Ethane 7 Methane 7 Propane 7 Ethylene 7 Hydrogen 7 Ethyl ether 7 Vinyl chloride 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 administrative 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 plant's general accident prevention program is described in Section 4. A) Regulated Toxic Chemicals Worst-Case Release Scenario Ethylene Oxide: This scenario assumes that the failure of a ethylene oxide rail car releases 165,000 pounds of ethylene oxide. According to EPAs Offsite Consequence Analysis (OCA) Guidance Table, this release could impact off-site public receptors. Specific steps to prevent this scenario from occurring, and to mitigate its effects should they occur, include: 7 Equipment Design and Construction: Rail Design and construction codes and standards are met or exceeded. Rail cars are specif ically designed for ethylene oxide. 7 Equipment Operating Standards: There are multiple levels of protection to prevent a back flow situation involving railcars that include check valves and differential pressure trips. Operating pressures also provide an inherent protection against reverse flow. 7 Surveillance:. The process is monitored by trained, certified operators. Area gas detectors provide continuous automatic monitoring. 7 Emergency Response Plans: Emergency response plans are current and drills are performed and critiqued. 7 Emergency Response Personnel and Equipment: An Emergency Director is on site and trained emergency responders and mobile fire protection equipment available. 7 Deluge System: The Ethylene Oxide area is water deluge spray protected at all places ethylene oxide could be present. Alternative Release Scenarios Ethylene Oxide:: This scenario assumes that a leak develops at the Ethylene Oxide unloading pump total flow recirculation heat exchanger releasi ng 2,500 pounds of ethylene oxide. According to EPAs OCA Guidance Table, this release could impact off-site public receptors. This scenario assumes that the operator detects and mitigates the release within 5 minutes. Specific steps to prevent this scenario from occurring, and to mitigate its effects should they occur, include: 7 Critical redundant gas detectors and alarm system: This system is designed to detect ethylene oxide vapors and activate an alarm. 7 Equipment Design and Construction: Design and construction codes and standards are met or exceeded. 7 Piping: Piping is designed and tested to meet rigid Union Carbide standards that meet or exceed industry standards. 7 Surveillance: The process is monitored by computers and trained, certified operators. Area gas detectors provide continuous automatic monitoring. 7 Emergency Response Plans: Emergency response plans are current and drills are performed and critiqued. 7 Emergency Response Personnel and Equipment: An Emergency Dire ctor is on site and trained emergency responders and mobile fire protection equipment available. 7 Deluge System: The Ethylene Oxide area is water deluge spray protected at all places ethylene oxide could be present. Isopropyl chloroformate: This scenario assumes that a leak develops at a pump seal releasing 300 pounds of liquid isopropyl chloroformate within a diked area. According to EPAs OCA Guidance Table, this release could impact off-site public receptors. This scenario assumes that the operator detects and shuts down the pump within 20 minutes. Specific steps to prevent this scenario from occurring, and to mitigate its effects should they occur, include: 7 Equipment Design and Construction: Design and construction codes and standards are met or exceeded. 7 Piping: Piping is welded to minimize the number of flanges. 7 Surveillance: The process is monitored by computers and trained, certified operators. 7 Emergency Response Plans: Emergency response plans are current and dr ills are performed and critiqued. 7 Emergency Response Personnel and Equipment: An Emergency Director is on site and trained emergency responders and mobile fire protection equipment available. Chlorine: This scenario assumes that a failure of a chlorine cylinder valve releases 270 pounds of chlorine. According to EPAs OCA Guidance Table, this release could impact off-site public receptors. The following active mitigation measure is used in this analysis: 7 Critical redundant gas detectors and alarm system: This system is designed to detect chlorine vapors and activate an alarm. Specific steps to prevent this scenario from occurring, and to mitigate its effects should they occur, include: 7 Equipment Design and Construction: Design and construction codes and standards are met or exceeded. 7 Piping: Piping is welded to minimize the number of flanges. 7 Surveillance: The process is monitored by computers and trained, certified operators. 7 Emergency Response Plans: Emergency response plans are current and drills are performed and critiqued. 7 Emergency Response Personnel and Equipment: An Emergency Director is on site and trained emergency responders and mobile fire protection equipment available. 7 Chlorine Emergency Response Kit: A special chlorine response kit is on hand to for use by emergency responders. B) Regulated Flammable Chemicals Worst-Case Release Scenario -- 1,3-Butadiene: This scenario assumes that a failure of a 1,3-Butadiene storage tank releases 4,207,000 pounds of butadiene to the air, leading to a vapor cloud explosion. According to EPAs OCA Guidance Table, this release could impact off-site public receptors. Specific steps to prevent this scenario from occurring, and to mitigate its effects should they occur, include: 7 Equipment Design and Construction: Design and construction codes and standards are met or exceeded. 7 Gas Detection Devices and Alarms: The butadiene process area is equipped with gas detection devices and alarms. 7 Survei llance: The process is monitored by computers and trained, certified operators. 7 Emergency Response Plans: Emergency response plans are current and drills are performed and critiqued. 7 Emergency Response Personnel and Equipment: An Emergency Director is on site and trained emergency responders and mobile fire protection equipment available. Alternate Release Scenario -- Flammable Mixture: This scenario assumes that a failure of the piping on pump discharge of propylene/propane mixture releases 118,000 pounds of propylene/propane to the air, leading to a vapor cloud explosion. According to EPAs OCA Guidance Table, this release could impact off-site public receptors. Specific steps to prevent this scenario from occurring, and to mitigate its effects should they occur, include: 7 Equipment Design and Construction: Design and construction codes and standards are met or exceeded. 7 Gas Detection Devices and Alarms: The process area is equipped with gas detection devices and alarms. 7 Surveillance: The process is monitored by computers and trained, certified operators. 7 Emergency Response Plans: Emergency response plans are current and drills are performed and critiqued. 7 Emergency Response Personnel and Equipment: An Emergency Director is on site and trained emergency responders and mobile fire protection equipment available. 4. General Accidental Release Prevention Program Our general accident prevention program consists of compliance with 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 Anal ysis: 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 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. Maintenance 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/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 cau se(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 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 ele ments and the chemical-specific steps discussed in the previous section are parts of an overall management system to 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 There have been no releases of RMP covered chemicals at the Texas City Plant in the past five years that resulted in known off-site death, injury, evacuation, shelter-in-place, property damage or environmental damage. The following incidents meet the EPA Risk Management Program reporting requirements with respect to on-site injuries involving a release of a RMP covered chemical: 11/4/94 An employee experienced irritation of the face and shoulder after exposure to liquid vinyl acetate spray. The employee showered and changed clothing and returned to work. 12/29/95 An employee exp erienced irritation of the throat after a safety valve on a tank containing flammables lifted. The employee received medical attention and returned to work the same day. 11/3/97 An employee experienced irritation of the nose and throat and coughing after exposure to chlorine. The employee received medical attention and returned to work 5 days later. 03/22/99 An employee experienced coughing, sore throat, nausea, and headache after exposure to vinyl acetate vapors from a leak. The employee received medical attention and returned to work the same day. 6. EMERGENCY RESPONSE PROGRAM The Texas City Plant 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-a id 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 Texas City Plant maintains a trained emergency squad to handle fires, explosions, toxic vapor releases, spills, and medical emergencies. The plant 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's Hazardous Emergency Leaks Prevention (HELP ) team responds to accidental releases from transportation incidents occurring in the continental U.S. The emerg ency 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 Texas City/La Marque Local Emergency Planning Committee. 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 Texas City Plant to help prevent and/or better respond to accidental chemical releases: 7 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 7 A new Corporate program designed to ensure that process safety information is kept up-to-date. 7 An updated Corporate program that improves procedures and standards for safel y handling spills of flammable materials. 7 An updated Corporate program that improves procedures and standards for small sample shipping. 7 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. |