Union Carbide Corporation - UCAR Emulsion Systems - Executive Summary |
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1. Accidental Release Prevention and Emergency Response Policies The Union Carbide Tucker 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 Tucker Plant is a manufacturing facility that annually produces more than 100 million pounds of latex. Latex is sold primarily to customers who use the material in the making of latex interior and exte rior paints and coatings. The RMP rule requires that if a facility, such as the Tucker 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 Tucker Plant has the following RMP-regulated toxic substances at levels above the threshold amounts: 7 Acrylonitrile 7 Vinyl Acetate The Tucker plant has no RMP-regulated flammable substances. 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 -- This scenario assumes an catastrophic release of the entire contents of the acrylonitrile storage tank. This would result in a release of 73,900 pounds of acrylonitrile. Written operating procedures and a high-level shutdown system limit the maximum filling capacity of this storage tank to 95 percent (73,900 pounds). 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 the effects should they occur include: 7 Inventory Restriction: Written operating procedures and a high-level shutdown system limits the maximum filling capacity of this storage tank to 95 percent (73,900 pounds). 7 Secondary Containment: The tank and is located in an above-ground, concre te secondary containment structure and is connected to the spill containment basin. The spill containment basin consists of a poured, steel-reinforced concrete floor with poured steel- reinforced concrete walls. Cast in place where the walls meet the floor slab is a rubber water stop to prevent lateral leakage of any released material. The spill containment is covered and large enough to hold the contents of the acrylonitrile tank. 7 Reaction Prevention: Systems are in place to ensure reactivity of material stored in the tank is inhibited. 7 Equipment Design and Construction: Design and construction codes and standards are met or exceeded. 7 Pressure relief systems: Pressure relief systems help to ensure that over-pressures within tanks are mitigated. 7 Hydrocarbon Detectors: This system is designed to continuously detect the presence of hydrocarbons from a storage tank and sound an alarm, so that appropriate action, such as actuation of the deluge system, can be taken. 7 Emergency S hutdown System: A manual emergency shutdown system is designed to shut down the pumps, place transfer valves in fail-safe position, and actuate the deluge system. 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 10,800 pounds of vinyl acetate over 24 minutes into a covered spill containment basin. The 24 minutes is the time it takes to complete the entire transfer. According to the 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: 7 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 24 minutes. 7 Spill containment: The facilitys spill containment basin, which would receive the liquid release, limits the surface area available for evaporation and is equipped with a cover to further restrict the spread of any vapors. The spill containment basin has provisions for the application of vapor suppression foam from a safe, remote location to further reduce evaporation. 7 Hydrocarbon detectors: This system is designed to continuously detect the presence of hydrocarbons from a storage tank and sound an alarm, so that appropriate action, such as actuation of the deluge system, can be taken. 7 Deluge System: A water spray system at the vinyl acetate transfer pump is designed to help suppress vinyl acetate vapors. 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. Acrylonitrile: This scenario assumes a drain valve is open on the transfer pump moving acrylonitrile to a process preparation ta nk. The >" drain valve releases 2680 pounds of acrylonitrile over five [5] minutes into a covered spill containment basin. The five [5] minutes is the time it takes to complete the entire transfer. According to the 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: 7 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 five (5) minutes. 7 Spill containment: The facilitys spill containment basin, which would receive the liquid release, limits the surface area available for evaporation and is equipped with a cover to further restrict the spread of any vapors. The spill containment basin has provisions for the application of vapor suppression f oam from a safe, remote location to further reduce evaporation. 7 Hydrocarbon detectors: This system is designed to detect the presence of hydrocarbon vapors. The presence of hydrocarbon vapors activates the alarm which notifies operations personnel. 7 Deluge System: A water spray system at the acrylonitrile transfer pump is designed to help suppress acrylonitrile vapors. 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. 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 Sa fety 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) 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 an d 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 facilit ies 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 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 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 Tucker 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 Tucker Plant maintains a written emergency response program to protect worker a nd 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, and 7 Using emergency response equipment. The emergency response program is updated when necessary based on modifications made to facility processes. The Tucker Plant routinely practices emergency drills and includes the Dekalb County Fire and Rescue Department when possible. In addition to the plant emergency drills, the plant sponsors at least two Dekalb county firemen to Union Carbide's Hazardous Emergency Leaks Preven tion (HELP ) training when offered. This training allows the firemen to get hands-on experience and to the opportunity to learn more about the materials used at the facility. The emergency response program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. 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 Tucker 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 A plant capital project pl anned to upgrade and automate the remainder of the plant reactor systems. The automated systems will provide better process control and further prevent the risk of runaway reactions in the reactor system. 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. |