Union Carbide Corporation - UCAR Emulsion Systems - Executive Summary |
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UNION CARBIDE CORPORATION SOMERSET, NJ PLANT 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. The Somerset Latex Plant is committed to operating and maintaining 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 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 Somerset Plant is a manufacturing facility that produce s more than 100 million pounds of water based latex polymer per year. These products are sold to customers for use in the manufacture of latex paint, water based adhesives and construction products such as caulks 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 Somerset plant does not maintain specified quantities of any RMP regulated flammable substances, but does utilize the following RMP regulated toxic substances: 7 Acrylonitrile 7 Vinyl Acetate 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. Worst-Case Release Scenario This scenario assumes a rupture of the acrylonitrile storage tank, releasing 67,600 pounds of acrylonitrile as a liquid into the containment area around the tank. According to EPAs Off-site Consequence Analysis (OCA) Guidance Table, this release could impact the public. The following administrative control and passive mitigation measure were used in this analysis: 7 Secondary Containment: The acrylonitrile tank is part of an underground storage tank system. The tank is enclosed inside a sealed plastic liner, which is completely contained inside a 9300 square foot, 3 high concrete dike. Any material released from the tank will remain inside of the containment area until manually pumped out. 7 Mounded Tanks: As part of the underground storage tank system described above, the acrylonitrile tank is also mounded. The covered tank minimize leaks and any effects on the surrounding community. Specific steps to prevent this scenario from occurring, and/or to mitigate the effects should they occur, include: 7 Flammable Gas Detectors: This system is designed to detect flammable vapors within the underground tank storage area. An alarm will sound when flammable vapors are detected to alert personnel of a possible emergency situation. 7 Deluge System: A water spray system is designed to help suppress acrylonitrile vapors and wash spilled material to the spill containment basin. 7 Fire Water Monitors: In addition to the sprinkler-deluge system, area fire water spray monitors can be used to help suppress acrylonitrile vapors and wash spilled material to the spill containment basin. 7 Vapor Suppression: Vapor suppressing foam can be applied to the contents of the spill basin described above to reduce the amount of vapors released to the atmosphere. 7 Reaction Prevention: A system is in place to ensure that the material stored in the acrylonitrile tank is inhibited. Turnover requirements ensure that material is us ed before the activity of the inhibitor is depleted. 7 Pressure Relief Systems: Pressure relief systems on the acrylonitrile storage tank ensure that overpressure within the tank is mitigated. Alternative Release Scenarios Acrylonitrile This scenario assumes an open >" drain valve failure on the discharge side of the acrylonitrile transfer pump during transfer of acrylonitrile to a monomer mix tank. The largest charge of acrylonitrile to a monomer mix tank takes a maximum of 10 minutes to complete. This scenario leads to a 3400 lb. release of acrylonitrile in 10 minutes. The scenario assumes that the released material flows onto the concrete pad in the transfer pump area then flows through an underground drainage pipe to the spill containment basin. According to the OCA Guidance Table, this release could impact the public. Steps to prevent this scenario from occurring, and/or to mitigate its effects should they occur, include: 7 Flammable Gas Detectors: A flammable gas detecto r in the sump near the transfer pump will alarm when flammable vapors are detected to alert personnel of a possible emergency situation. Personnel may then activate shutdown and/or deluge systems as described below. 7 Deluge System: A water spray system is designed to help suppress acrylonitrile vapors and wash spilled material to the spill containment basin. 7 Emergency Shutdown System: A manually activated emergency shutdown system is designed to stop all monomer transfer pumps. 7 Fire Water Monitors: In addition to the sprinkler-deluge system, fire water spray monitors can be used to help suppress acrylonitrile vapors and wash spilled material to the spill containment basin. 7 Spill Basin: Chemical spills in the acrylonitrile handling and storage areas flow to a 90,000 gallon, concrete lined, containment basin. 7 Vapor Suppression: Vapor suppressing foam can be applied to the contents of the spill containment basin to reduce the amount of vapors released to the atmosphere . Vinyl Acetate This scenario assumes an open >" drain valve on the discharge side of the vinyl acetate transfer pump during transfer of vinyl acetate to a monomer mix tank. The largest charge of vinyl acetate to a monomer mix tank takes a maximum of 30 minutes to complete. This scenario leads to a 11,800 lb. release over 30 minutes. The scenario assumes that the released material flows onto the concrete pad in the transfer pump area then flows through an underground drainage pipe to the spill containment basin. According to the OCA Guidance Table, this release could impact the public. Steps to prevent this scenario from occurring, and/or to mitigate its effects should they occur, include: 7 Flammable Gas Detector: A flammable gas detector in the sump near the transfer pump will alarm when flammable vapors are detected to alert personnel of a possible emergency situation. Personnel may then activate shutdown and/or deluge systems as described below. 7 Deluge System: A water s pray system is designed to help suppress vinyl acetate vapors and wash spilled material to the spill containment basin. 7 Emergency Shutdown System: A manually activated emergency shutdown system is designed to stop all monomer transfer pumps. 7 Fire Water Monitors: In addition to the sprinkler-deluge system, fire water spray monitors can be used to help suppress vinyl acetate vapors and wash spilled material to the spill containment basin. 7 Spill Basin: Chemical spills in the vinyl acetate handling and storage areas flow to a 90,000 gallon, concrete lined, containment basin. 7 Vapor Suppression: Vapor suppressing foam can be applied to the contents of the spill containment basin to reduce the amount of vapors released to the atmosphere. 4.General Accidental Release Prevention Program Union Carbides general accident prevention program consists of compliance with the EPA RMP rule, OSHA's PSM standard and implementation of Union Carbide's Operational Safety Program and Episod ic Risk Management System. Key elements include: Compliance Audits: Periodic Corporate and plant-led audits are conducted to ensure that process operations comply with governmental and Union Carbide requirements. Contractor Safety Program: The plant has a program to ensure that contractors are properly trained and perform their work in compliance with safety requirements. Employee Participation: The plant has a program to involve employees in prevention program elements. 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. Equipment Design: Vessels (including shipping containers) and other process equipment are designed according to recognized industry standards and/or governmental requirements. Hazardous Work Permit: The plant has a procedure to ensure that w elding, cutting and brazing are safely performed in areas where flammable or combustible material may be present. 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. Maintenance Procedures: The plant has specific procedures for maintaining process equipment so that it operates safely. Maintenance Training: The plant trains persons who perform maintenance tasks on process equipment. Management of Change: The plant has a management system to ensure that modified facilities and processes will be safe to operate. 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. Operating Procedures: Operating p rocedures provide detail on how to safely operate a process and are maintained up-to-date. 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. Operational Safety Standards: Design requirements for active and passive mitigation controls used to prevent major process hazards are documented in operational safety standards. 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. Pre-startup Safety Reviews: Reviews are conducted just prior to startup to ensure that modified facilities and processes are safe for operation. Process Hazard Analysis: Process hazard analyses are conducted every five years to identify major proc ess hazard scenarios and to recommend corrective action(s) needed to prevent their occurrence. Process Safety Information: Chemical hazard, process technology, and equipment information is documented, maintained up-to-date, and available to operating personnel. Technical Staff Training and Support: Trained technical staff employees are available 24 hours a day to support operations. These general prevention elements and the 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 Somerset Plant that resulted in an on-site death, injury, or property dama ge; or a known off-site death, injury, evacuation, shelter-in-place, property damage or environmental damage. 6.EMERGENCY RESPONSE PROGRAM The Somerset Plant 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, 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. The S omerset Plant uses local emergency responders to handle fires, explosions, toxic vapor releases, spills, and medical emergencies. Plant personnel receive training and conduct drills to enhance their skills and tactics for responding to an accidental chemical release. Critiques are held on drills and actual events. 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 Somerset 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 ade quate protection 7 A new Corporate program designed to ensure that process safety information is kept up to date. 7 Centralized and improved controls for emergency response systems activation. By centralizing activation points for emergency shutdowns, deluge and foam systems we can provide more immediate response to emergency situations. 7 Improved process automation and control through the installation of a computerized process automation system to improve response to process deviations. 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. |