Union Carbide Corporation - UCAR Emulsion Systems - Executive Summary |
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Union Carbide Corporation UCAR Emulsion Systems, Torrance Risk Management Plan Executive Summary 1. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Union Carbide Corporation has a long-standing commitment to worker and public safety. We are committed to operating and maintaining all of our processes in a safe and responsible manner. We have implemented a combination of accident 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. DESCRIPTION OF THE FACILITY AND REGULATED SUBSTANCES Union Carbide Corporation, UCAR Emulsion Systems, located in Torrance, Cali fornia, operates a latex emulsion manufacturing facility that produces more than 100 million pounds of latex per year. The water-borne latex produced at this site is utilized by the coatings industry to make latex-based paints, caulks, adhesives and sealants. The facility is recognized as a covered source under the RMP rule as the facility maintains quantities of regulated substances listed in the RMP rule. The UCAR Emulsion Systems Torrance facility does not maintain specified quantities of any RMP regulated flammable substances, but does utilize the following RMP regulated toxic substances at levels above threshold limits: 7 Acrylonitrile (2-Propenenitrile) 7 Vinyl Acetate (Acetic Acid ethenyl ester) 3. HAZARD ASSESSMENT RESULTS 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 cred it was taken for administrative controls or mitigation measures in evaluating the off-site impact of the scenarios. 3A. WORST CASE RELEASE SCENARIO The worst case scenario associated with the toxic substances at the facility is a failure of the acrylonitrile storage tank, resulting in an instantaneous release of 67,600 pounds of acrylonitrile. The acrylonitrile liquid is released into a 40 foot by 20 foot dike, which acts as passive mitigation for the release. According to EPAs Off-site Consequence Analysis Guidance Table, this release could impact off-site public receptors. Credit for administrative controls was not taken into account in evaluating this scenario. Specific systems to prevent this scenario from occurring, as well as mitigate its effects should they occur, include: Hydrocarbon Gas Detector and Alarm Systems: This system is designed to detect toxic vapor releases and to automatically activate alarm systems to alert operations personnel of a possible emergency s ituation. Sprinkler Deluge System (water spray): This system is designed to mitigate and suppress toxic vapor clouds from migrating from the facility boundaries. Inventory Restriction: Written operating procedures, which include an operating checklist, and a high-level shutdown system limits the maximum filling capacity of this storage tank to 84%. A high level alarm would sound if the tank were filled to 84% capacity. At this point, procedures require operations to stop all transfers into the tank. An additional high-high level alarm is set at 90%, which would automatically stop all transfers into the tank when the volume reaches this level. Reaction Prevention: Systems in place to ensure reactivity of material stored in tanks is inhibited. Pressure Relief Systems: Pressure relief systems help to ensure that over-pressures within tanks are mitigated. Operator Certification: Only trained and certified Union Carbide employees are permitted to unload Acrylonitrile into the storage tank. Equipment Design and Construction: Design and construction codes & standards are met or exceeded. Surveillance: Operations personnel routinely monitor the process and facility perimeters. 3B. ALTERNATIVE RELEASE SCENARIOS Acrylonitrile: The alternative case scenario for acrylonitrile assumes an open >" drain valve on the discharge side of a pump while transferring acrylonitrile to an intermediate mix tank. This scenario leads to an 800 pound release of acrylonitrile in 2 minutes, the time it would take to complete the entire transfer from the storage tank to the intermediate mix tank. The scenario assumes that the release is contained in spill containment trenching and enclosure, which mitigates the release. Although active mitigation measures do exist if this scenario were to occur, no active mitigation measures were taken into account in evaluating this scenario. According to EPAs Off-site Consequence Analysis Guidance Table, this release could impact off-s ite public receptors. Specific systems to prevent this scenario from occurring, as well as mitigate its effects should they occur, include: Automated Containment Systems: A system is in place to automatically pump any releases in this spill containment area to a closed storage tank. This would mitigate the release of toxic material into the atmosphere. Emergency Shutdown Systems: A manual emergency shutdown system is designed to shut down the pumps and put the transfer valves in a fail-safe position. Hydrocarbon Gas Detector and Alarm Systems: This system is designed to detect toxic vapor releases and to automatically activate alarm systems to alert operations personnel of a possible emergency situation. Sprinkler Deluge System (water spray): This system is designed to mitigate and suppress toxic vapor clouds from migrating from the facility boundaries. Surveillance: Operations personnel routinely monitor the process and facility perimeters. Vinyl Acetate: The alternati ve case scenario for vinyl acetate assumes an open >" drain valve on the discharge side of a pump while transferring vinyl acetate to an intermediate mix tank. This scenario leads to a 21,500 pound release of vinyl acetate in 19 minutes, the time it would take to complete the entire transfer from the storage tank to the intermediate mix tank. The scenario assumes that the release is contained in spill containment trenching and sump systems, which mitigates the release. Although active mitigation measures do exist if this scenario were to occur, no active mitigation measures were taken into account in evaluating this scenario. According to EPAs Off-site Consequence Analysis (OCA) Guidance Table, this release could impact off-site public receptors. Specific systems to prevent this scenario from occurring, as well as mitigate its effects should they occur, include: Emergency Shutdown Systems: A manual emergency shutdown system is designed to shut down the pumps and put the transfer valves in a fail-safe position. Surveillance: Operations personnel routinely monitor the process and facility perimeters. 4. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM The following is a summary of the general accident prevention program in place at Union Carbide UCAR Emulsion Systems in Torrance, California. Our general accident prevention program consists of compliance with the EPA RMP rule and OSHAs PSM standard as well as implementation of Union Carbides Operational Safety Program and Episodic Risk Management System. Key elements include: 4A. Compliance Audits To help ensure that the accident prevention program is functioning properly, Union Carbide periodically conducts corporate and plant-led audits to ensure that process operations comply with governmental and Union Carbide requirements. 4B. Contractor Safety Program Union Carbide uses contractors to supplement its work force during periods of increased maintenance or construction activities. Due to the fact that some contractors work on or near process equipment, the facility has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform facility personnel of any hazards that they find during their work. 4C. Employee Participation Union Carbide encourages employees to participate in all facets of process safety management and accident prevention. Employees have access to all information created as part of the facility accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that is maintained at the facility and addresses each accident prevention program element. In addition, employees participate in keeping process safety informatio n up to date by making periodic inspections, having an active role in writing operating procedures and being involved in many other aspects of the accident prevention program, such as incident investigations. 4D. 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. 4E. Equipment Design Vessels (including shipping containers) and other process equipment are designed according to recognized industry standards and/or governmental requirements. 4F. Incident Investigation Union Carbide promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the root cause of the incident by reviewing facts and developing corrective actions to prevent a recurrence of the incident or a similar incident. 4G. Management of Change Union Carbide has a comprehensive system to ensure that modified facilities and processes will be safe to operate. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. 4H. Mechanical Integrity Union Carbide has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process equipment. 4I. Operating Procedures Union Carbide maintains written procedures that provide detail on how to safely operate a process, including various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. These procedures are periodically reviewed and annually certified as current and accurate. The procedures are maintained up-to-date by revising them as necessary. In addition, the plant maintains specific procedures for maintaining process equipment so that it operates safely. The plant also trains persons who perform routine or complex maintenance tasks on process equipment. 4J. Operational Safety Program Union Carbide has a comprehensive program to ensure that all the elements listed within this accidental release prevention program are implemented at every Union Carbide location. This Program includes accountabilities for timely and proper implementation of the program elements. 4K. Operational Safety Standards Design requirements for active and passive mitigation controls used to prevent major process hazards are documented in operational safety standards. 4L. Pre-startup Safety Reviews (PSSRs) Union Carbide conducts reviews just prior to startup to ensure that new and modified facilities and processes are safe for operation. A PSSR involves field verification of the construction and serves as a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. 4M. Process Hazard Analysis Union Carbide has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. Process hazard analyses are conducted every five years to identify major process hazard scenarios and to recommend corrective action(s) if needed to prevent their occurrence. Union Carbide primarily uses the What-If/Checklist analysis as well as Fault Tree Analysis techniques to perform these evaluations. These analyses are recognized as some of the most systematic and thorough hazard evaluation techniques. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. 4N. Process Safety Information Union Carbide keeps a variety of technical documents that are used to help maintain safe operation of the processes. Chemical hazard, process technology, and equipment information is documented, maintained up-to-date and available to operating personnel. Chemical-specific information, including exp osure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). For specific process areas, the facility has documented safety-related limits for specific process parameters (e.g., temperature, pressure and level control) in the Operational Safety Standard (OSS) documents. The facility ensures that the process is maintained within these limits using process controls and monitoring instruments, automated operating systems, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems). The facility maintains numerous technical documents that provide information about the design and construction of process equipment. This information, in combination with written procedures and trained personnel, provides a means for establishing inspection and maintenance activities. 4O. Safe Work Practices Union Carbide has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout - tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. 4P. Training/Certification Programs To complement the written procedures for process operations, Union Carbide has implemented a comprehensive training and certification program for all employees involved in operating a process. After employees demonstrate (e.g., through tests, skills demonstration) having adequate knowledge to p erform the duties and tasks in a safe manner on their own, they are certified to work independently. In addition, trained technical staff employees are available 24 hours a day to support operations. 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 UCAR Emulsion Systems facility in Torrance, California 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 INFORMATION The Union Carbide UCAR Emulsion Systems facility in Torrance 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 a ddress 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. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The overall emergency response program for Union Carbide in Torrance is coordinated with the Torrance Fire Department (Administering Agency) and the Local Emergency Planning Committee (LEPC). Union Carbide conducts periodic emergency drills that involve the appropriate emergency response organizations. In addition, Union Carbide's Hazardous Emergency Leaks Prevention (HEL P) team located in Torrance responds to accidental releases from transportation incidents occurring in the continental U.S. 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 Torrance Fire Department. 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 UCAR Emulsion Systems plant in Torrance 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 p rocess safety information is kept up-to-date. 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. 7 Upgrade equipment and systems as specified by recent seismic assessment report conducted in May 1999. |