Massey Rail Yard - Executive Summary

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UNION CARBIDE CORPORATION 
MASSEY RAIL YARD 
RISK MANAGEMENT PLAN 
 
EXECUTIVE SUMMARY 
 
1 Accidental Release Prevention and Emergency Response Policies 
The Union Carbide South Charleston Massey Rail Yard is committed to storing chemical tank cars 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 Environmental Protection Agency?s (EPA) Risk Management Program (RMP). 
2    Stationary Source and Regulated Substances 
The Union Carbide Massey Rail Yard is used to temporarily store tank cars for eventual processing at the South Charleston Plant or for eventual transport to other locations.  The rail yard is managed by the South Charleston Plant, but is not considered contiguous  with the 
South Charleston Plant.  No chemical loading or unloading takes place at the Massey Rail Yard.  The RMP rule requires that if a facility, such as the Massey Rail Yard, has a specific amount (threshold) or more of any one of 140 toxic and flammable chemicals, the facility must follow the RMP rule requirements.   
 
There are no Union Carbide-owned EPA RMP regulated toxic chemicals stored in the Massey Rail Yard. 
 
Union Carbide owns and stores threshold quantities of the following EPA RMP-regulated flammable substances in the Massey Rail Yard: 
 
Dimethylamine 
Methylamine:     
Vinyl Methyl Ether:       
Acetaldehyde:     
3    Key Offsite Consequence Analysis Scenarios 
EPA?s 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 rail yard's general accident prevention program is described in Section 4. 
 
A)  Regulated Toxic Substances 
 
Worst-Case Release Scenario  
 
There are no Union Carbide-owned EPA RMP regulated toxic chemicals stored in the Massey Rail Yard. 
 
Alternative Release Scenario 
 
There are no Union Carbide-owned EPA RMP regulated toxic chemicals stored in the Massey Rail Yard. 
 
B)  Regulated Flammable Substances 
 
Worst-Case Release Scenario  
 
This scenario assumes catastrophic failure of a railroad tank car that releases 163,000 lbs. of dimethylamine as a gas to the atmosphere, leading to a vapor cloud explosion.  According to EPA?s Off-Site Consequence Analysis (OCA) Guidance Table, this release could impact off-site public receptors.  
Specific steps to prevent this scenario from occurring include: 
 
? Safety Relief Device:  These devices relieve pressure at a pre-determined set point to prevent over pressurization of the railroad tank car. 
? Cameras:  These cameras can be used by security to detect leaks. 
? Surveillance: Yard clerks, RESCAR employees and security routinely monitor the rail yard. 
? Fire Water Spray Monitors: Area fire water spray monitors can be used to help suppress dimethylamine vapors. 
 
Alternative Release Scenario  
 
This scenario assumes a safety relief valve fails and prematurely opens on a railroad tank car, releasing methylamine at a rate of 9,940 lbs. per minute for 16.4 minutes as a gas to the atmosphere (entire tank contents), leading to a vapor cloud explosion.  According to the OCA Guidance Table, this release could impact off-site public receptors. 
Specific steps to prevent this scenario from occurring include: 
? Cameras:  These cameras can be used by security to detect leaks. 
? Surveillance:  Yard clerks, RESCAR employees and security routinely monito 
r the rail yard. 
? Fire Water Spray Monitors:  Area fire water spray monitors can be used to help suppress methylamine vapors. 
This scenario assumes the entire contents of the railroad tank car is lost through the relief valve in 16.4 minutes.   
 
4    General Accidental Release Prevention Program  
 
General Program 
 
Our general accident prevention program consists of compliance with the EPA RMP rule and  implementation of Union Carbide?s Operational Safety Program and Episodic Risk Management System.  Key elements include: 
 
Equipment Design: Tank cars and associated 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) n 
eeded 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. 
Operating Procedures:  Operating procedures provide detail on how to safely operate a rail yard and are maintained up-to-date. 
Operator Training:  All rail equipment operators are trained according to government requirements. 
Maintenance Procedures:  Procedures exist for maintaining tank cars and railroad track. 
Mechanical Integrity Program:  Tank cars and associated equipment are periodically tested and inspected, following recognized standards and/or government requirements. 
Management of Change:  Management systems exist  to ensure that modified tank cars and rail track meet government requirements and are safe for operation. 
Pre-Startup Safety Reviews:  Reviews are conducted 
just prior to startup to ensure that modified tank cars and rail track are safe for operation. 
Incident Investigation:  The rail yard 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. 
Hot Work Permit:  The rail yard 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 rail yard 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 rail 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.  Th 
is program includes accountabilities for timely and proper implementation of the program elements. 
Contractor Safety Program:  A program exists to assure that contractors perform their work in compliance with safety requirements. 
 
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. 
 
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 Massey Rail Yard 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 South Charleston Plant, which provides emergency response services to Massey Rail Yard, 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: 
? 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 the facility. 
 
The South Charleston Plant maintains a trained emergency squad to handle fires, explosi 
ons, 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: 
None
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