UCAR Resinas Caribe, Inc. - Executive Summary

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1. Accidental Release Prevention and Emergency Response Policies 
UCAR Resinas Caribe, Inc. 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 Carbide's Responsible Care requirements and governmental requirements, such as the United States 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 
UCAR Resinas Caribe, Inc. is a subsidiary plant of UCAR Emulsion Systems, with headquarters in Cary, NC.  UCAR Emuls 
ion Systems is a division of the Union Carbide Corporation, one of the worlds leading manufacturers of basic and specialty chemicals.  Since its inception in 1977, UCAR Resinas Caribe, Inc. has been dedicated to the manufacture of emulsion polymers for use throughout the paint, adhesives and architectural coatings industry.  The site covers a total area of 4.3 acres located in lot 38, on B street of Luchetti Industrial Park, in the city of Bayamon, Puerto Rico. 
The RMP rule requires that if a facility, such as UCAR Resinas Caribe, Inc., 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.  UCAR Resinas Caribe, Inc. has the following RMP-regulated toxic substance at levels above threshold quantities:  
7 Vinyl Acetate Monomer (Acetic acid ethenyl ester) 
UCAR Resinas Caribe, Inc. has no RMP-regulated flammable substances in amounts exceeding the specified threshold limits. 
Key Offsite Consequence Analysis Scenarios 
EPAs Risk Management Planning (RMP) rule requires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) involving one of the toxic chemicals identified in 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: 
Vinyl Acetate Monomer (VAM):  Vinyl Acetate Monomer (VAM) is stored in a 10,000 gallon storage tank located towards the east end of the facility.  The  scenario assumes the total collapse of this storage  
tank, releasing 78,200 pounds of VAM as a liquid to the spill containment basin.  Written operating procedures and a high-level interlock shutdown system limit the maximum filling capacity of this storage tank to 95 percent in volume (74,290 pounds). According to EPAs Offsite Consequence Analysis (OCA) Guidance Table, this release could impact off-site public receptors.  The following passive mitigation measure was used in this analysis: 
7- Secondary Containment:  The tank is located inside a concrete dike sufficiently impervious to contain and prevent permeation of any liquid leaks from the tank.  
Specific steps to prevent this scenario from occurring, and to mitigate its effects should they occur, include: 
7- Tank Construction:  The tank is constructed of material that is not attacked by the stored chemical (stainless steel) according to recognized industry codes and standards for containment and overall safety. 
7- High Level Interlock Shutdown System:  An high level alarm activ 
ates at 90% volume level to alert the operator in the unloading area as well as operators located in the mezzanine area inside the process building.  Also, an emergency interlock shutdown system is in place in case the 95% volume level of the tank is exceeded.  This system is designed to shut down the pumps associated with the tank, as well as close valves to the tank, stopping any material transfer being made to the tank. 
 Pressure/Vacuum Relief Valves:  The VAM storage tank is equipped with two pressure/vacuum relief valves which are intended to prevent the collapse of the tank due to an overpressure or a vacuum condition. 
 Pressure Equalizing Line & Detector:  Vapors generated during the VAM tank truck unloading operation are balanced between the storage tank and the tank truck such that the pressure in both systems are the same throughout the operation.  Also there is a sensor placed in the equalizing line which triggers an alarm whenever a vacuum condition is detected by it. 
7 Surveillance:  Operators continuously monitor the monomer transfer process as well as the perimeter of the facility for visual leaks or for monomer smell, since VAM has a low odor threshold (can be easily detected or noticed). 
Alternative Release Scenarios: 
Vinyl Acetate Monomer (VAM):  This scenario assumes a drain valve is open on the transfer pump moving VAM to a process preparation/feed vessel.  The 1" drain valve releases 8,650 pounds. of VAM over 462 minutes into a containment basin.  According to the OCA Guidance Tables provided by the EPA, this release could impact off-site public receptors. The following passive mitigation measure was used in this analysis 
7- Secondary Containment: The tank is located inside a concrete dike sufficiently impervious to contain and prevent permeation of any liquid leaks from the tank.  
In addition, specific steps to prevent this scenario from occurring, and to mitigate its effects, should they occur, include: 
7 Surveillance: Operators moni 
tor the work area while the pump is operating.  This scenario assumes the operator detects the leak and stops the transfer within 462 minutes 
7 Control Devices: Each drain valve is equipped and checked for a solid valve plug as a secondary control measure in case the primary valve leaks. 
 Pump Relief Device: The transfer pump has a pressure relief device which discharge the monomer back to the storage tank whenever the pressure at the pump exceeds 100 psig. 
4. General Accidental Release Prevention Program  
Our general accident prevention program consists of compliance with the EPA RMP rule and Occupational Safety and Health Administration (OSHA) PSM standard and implementation of Union Carbide's Operational Safety Program (OSP) and Episodic Risk Management System (ERMS).  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 Saf 
ety 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 two 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 facilitie 
s 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 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 internal 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 imp 
lemented 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 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. 
In the last five years, there has not been an accident or incident involving an EPA RMP chemical at UCAR Resinas Caribe, Inc. 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. 
UCAR Resinas Caribe, Inc. 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. 
7 Inspecting, testing, maintaining, and using emergency response equipment. 
The emergency response program is updated when necessary based on modifications made to facility processes.  
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  
UCAR Resinas Caribe, Inc. 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. 
 - A new meteorological monitoring station to determine trends in weather patterns which can help us to better respond and to notify potential off-site receptors in the event of an emergency. 
 - A new chemical foam ejection system to suppress the generation of hazardous vapors from a pool of monomer during a spill, as well as to suffocate any fire resulting from ignition of a flammable source. 
- 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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