Union Carbide Corporation - UCAR Emulsion Systems - Executive Summary |
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UNION CARBIDE CORPORATION UES GARLAND, TX PLANT RISK MANAGEMENT PLAN EXECUTIVE SUMMARY 1. Accidental Release Prevention and Emergency Response Policies The Union Carbide UCAR Emulsion Systems Garland 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 as to protect the environment. These programs include both Union Carbide's Responsible CareO 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 UES Garland Plant is a manufacturing facility that produces synthetic latex polymer products, which ar e sold to customers that convert them into finished products such as latex paint, caulk and adhesives. The RMP rule requires that if a facility, such as the UES Garland 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 UES Garland Plant has the following RMP-regulated toxic substances at levels above threshold quantities: ? Acrylonitrile (2-Propenenitrile) ? Vinyl Acetate Monomer (Acetic acid ethenyl ester) The Garland plant has no RMP-regulated flammable substances. 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-si te 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 ? Acrylonitrile: This scenario assumes storage tank failure, releasing 67,600 pounds of acrylonitrile as a liquid to the spill containment basin. Written operating procedures and a high-level shutdown system limit the maximum filling capacity of this storage tank to 84 percent ( 56,784 pounds). According to EPA?s Offsite Consequence Analysis (OCA) Guidance Table, this release could impact off-site public receptors. The following administrative control and passive mitigation are used in this analysis: ? Inventory Restriction: Written operating procedures and a high-level shutdown system limits the maximum filling capacity of this storage tank to 84 percent (56,784 pounds). ? Secondary Containment: The tank is located in above ground, concrete secondary containment. The containment consist of poured, steel reinforced concrete floor with pour, steel reinforced concrete walls. Cast in place were the walls meet the floor slab is a rubber water stop to prevent lateral leakage of a released compound. The containment is large enough to hold the contents of the acrylonitrile tank. In addition, specific steps to prevent this scenario from occurring, and to mitigate its effects should they occur, include: ? Tank Construction: The tank is constructed of material that is not degraded by the stored material or the crushed rock located on the tank exterior. ? Mounded Tanks: The limestone covered tanks inhibit the spread of vapors and the pH of the limestone prevents any tendency for corrosion of the tank.. ? Hydrocarbon Detectors: This system is designed to continuously detect the presence of hydrocarbons from a storage tank and sound an alarm, so appropriate action, such as actuation of the deluge system, can be taken. ? Emergency Shutdown System: A manual emergency shutdown system is designed to shut down the pumps associated with the tank, place transfer valves in fail safe position, actuate the deluge system, and actuate the plantwide alarm system. ? Deluge System: A water spray system is designed to help suppress acrylonitrile vapors. It is actuated by the emergency shutdown system or manual pull. Alternative Release Scenarios ? Vinyl Acetate: This scenario assumes a drain valve is open on the transfer pump moving vinyl acetate to a process preparation tank. The ?" drain valve releases 10,700 lb. of vinyl acetate over 25 minutes into a containment basin. This senerio leads to a 10,700 pound realease of vinyl acetate in 25 minutes, the time it would take to complete the entire transfer from the storage tank to the intermidiate mix tank. According to the OCA Guidance Table, this release could impact off-site pu blic receptors. The following passive and active mitigation measures are used in this analysis: ? Emergency Shutdown System: A manual emergency shutdown system is designed to shut down the pumps and put the transfer valves in a fail-safe position. This scenario assumes that the operator detects the release and actuates the emergency shutdown system within 25 minutes. ? Secondary Containment: The tank is located inside a concrete dike which is designed to contain any leaks from the tank and to limit evaporation. ? Surveillance: Operators and maintenance employees monitor the work area while working on the pump. This senerio asumes the operator detects the release and actuates the Emergency Shutdown System within 25 minutes. Other specific steps to prevent this scenario from occurring, and to mitigate its effects should they occur, include: ? Control Devices: Each drain valve is equipped and checked for a solid valve plug in case the primary valve leaks. Acrylonitrile: This scenario assumes a drain valve is open on the transfer pump moving acrlyonitrile to a process preparation tank. The ?" drain valve releases 2,470 lb. of acrylonitrile over 6 minutes into a containment basin. This senerio leads to a 2,400 pound realease of acrylonitrile in 6 minutes, the time it would take to complete the entire transfer from the storage tank to the intermidiate mix tank. According to the OCA Guidance Table, this release could impact off-site public receptors. The following passive and active mitigation measures are used in this analysis: ? Emergency Shutdown System: A manual emergency shutdown system is designed to shut down the pumps and put the transfer valves in a fail-safe position. This scenario assumes that the operator detects the release and actuates the emergency shutdown system within 6 minutes. ? Secondary Containment: The tank is located inside a concrete dike which is designed to contain any leaks from the tank and to limit evaporation. ? Surveillance: Operato rs and maintenance employees monitor the work area while working on the pump. This senerio asumes the operator detects the release and actuates the Emergency Shutdown System within 6 minutes. Other specific steps to prevent this scenario from occurring, and to mitigate its effects should they occur, include: ? Control Devices: Each drain valve is equipped and checked for a solid valve plug in case the primary valve leaks. 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, mai ntained 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) 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 allow ing 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 prog ram 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 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 accountabilitie s 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. 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 UES Garland Plant 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 UES Garland plant maintains a written emergency response program to protect worker and public safety, as well as the environment. The program consists of pr ocedures 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. ? Inspecting, testing, maintaining, and using emergency response equipment. The emergency response program is updated when necessary based on modifications made to facility processes. 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 Garland UES Plant 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 fire and evacuation alarm system designed to ensure that personnel safety is kept up-to-date. ? Foam enduction on area fire water monitors to help suppress vapors. ? 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. |