Document QXGzpx5pxkzOO4BRyNpDdERd8

UNION CARBIDE CORPORATION CHEMICALS AND PLASTICS O, SOX 4/1, TTXASClIY, TtXAS 77i9( October 27, 1977 Mr. Howard G. Bergman Director, Enforcement Division U. S. Environmental Protection Agency First International Bank Building 1201 Elm Street Dallas, TX 75270 Subject: Status Reports on Compliance Schedules for Waivers for Polyvinyl Chloride Plants, Union Carbide Corporation, Texas City, Texas Dear Mr. Bergman: This is the seventh report on the status of our progress on projects for the waiver of compliance schedules as sent to us In your letter of March 11, 1977. This report covers the compliance date of October 15, 1977 for the attached compliance schedules. Two of the schedules (pages 5 and 8) have Start of Construction dates of October IS, 1977, but both were started on the dates Indicated on the attached sheets. The third schedule (page 16) for the Suspension process has not been met because of the explosion reported in our last status report of September 20th. Both the Non-Solvent and Suspension processes have been shut down since the explosion at the Non-Solvent Unit on September 5, 1977. Presently, evaluations are underway to determine if these facilities should be repaired or permanently shut down. All further construction work in these process units has been post poned until this decision has been reached. If you have any questions, please refer them to me. Very trujy yours Attachments: Compliance Schedules, pages 5, 8 and 16 cc: Mr. Cecil Bradford Texas Air Control Board 8520 Shoal Creek Boulevard Austin, TX 78758 bcc: Complete Copy Cover Letter Only Mr. H. P- Brady Mr. R. L. Frantz/M. E. Eisenhour Mr. W. A. Mazzolini/W. T. Gray, Jr. Mr. R. M. Ewbank Mr. J. C. Smith - 124 Mr. D. D. Robinson Ms. R. M. Guardiola Mr. J. B. Leverton/F. S. Provenzano Mr. R. N. Wheeler - 514 ucc 051940 UNION CARBIDE CORPORATION {off** ?? - (oV*^ 'yjt.cti CHEMICALS AND PLASTICS ttsdf it t* Ctyif $zu'# October 11 , 1977 stJwS 1f/(L tt* ^^ t Mr. Howard G. Bergman Director, Enforcement Division 0. S. Environmental Protection Agency First International Bank Building 2101 Elm Street Dallas, TX 75270 Dear Mr. Bergman: Subject: Autoclave Explosion and Fire, Non-Solvent Resins Process September 5, 1977, Texas City Plant In leeping with our intention to keep you and other agencies informed about this incident, the attached Forecaster-Gram was issued last Friday, October 7, 1977. Additional pertinent information will be issued as it becomes available. If you have any questions, please contact me. Very truly yours, .. /" , '/f'Vr'lT -> -(/J. F. Erdmann ^ Environmental Protection Coordinator (713) 945-7411, ext. 1126 & ^C:ir Attachment cc: Mr. Lloyd Stewart, TACB, Bellaire Mr. Clark Benson, GCACD, La Marque bcc: Mr. R. N. Wheeler - 514 Mr. J. D. Martin - 510 Mr. F. S. Provenzano/D. L. Engle (cover only) Mr. J. B. Leverton/R. E. O'Bryan/EP Files Mr. M. E. Eisenhour (cover only) Mr. R. L. Frantz/A. A. Peterson (cover only) Mr. W. T. Gray, Jr. Mr. D. D. Robinson y ucc 051941 FORECASTER-GRAM Texas City Plant __ October 7, 1977 A Message from the Plant Manager to All Employees Regarding The Labor Immediately after the Labor Day explosion and fire, we promised to report to you as early as practical. WE HAVE PRODUCED NON-SOLVENT VINYL RESINS AT TEXAS CITY FOR 29 YEARS, AND OPERATORS HAVE SUCCESSFULLY HANDLED ABOUT 3,500 AUTOCLAVE START-UPS. The Corporation has operated other similar units at South Charleston and Aycliff, England, dating back to the early 1940's. NOWHERE IN OUR VINYLS HIS TORY HAS THERE BEEN ANYTHING LIKE OUR LABOR DAY EXPLOSION. IT WAS A UNIQUE AND TOTALLY UNEXPECTED HAPPENING. As reported previously in The Forecaster, a Process Investigation Team has been working to reconstruct the situation and determine the cause. The team has issued its preliminary report to me as follows: Day Fire mmrm TO (name I . I am looking at a belt buckle which some plant employees made and gave me marking 5 million safe work hours. This record of 377 days was reached on January 27, 1977. IF ALL OF US CONTINUE OUR COMMITMENT TO PRO VIDE GOOD TRAINING, EFFECTIVE PROCE DURES, TIMELY RE SPONSE TO DEFICIEN CIES AND CONSTANT AWARENESS, VIE CAN REESTABLISH THAT RE CORD AND THAT SPIRIT. Let's get on with the job. CHEMICALS AND PLASTICS INTERNAL CORRESPONDENCE "J To All Texas City Plant Employees September 27, 1977 "A reaction was experienced of such extreme intensity that it could not be contained by our standard design and operating practices, which are more stringent than those of the Industry. Once it was initiated, normal operating actions or emergency procedures could not have brought the reaction under control. The principal cause of the violent reaction was a targe overcharge of catalyst solution - at least 20 times the normal charge of one gallon. There are ways excess catalyst could have been intro duced, but the team is unable now, and may never be able, to verify exactly how it happened. In addition, the possible lack of agitation could have been a contributing factor. However, strict adherence to the Standard Operating Pro cedure would have prevented introduction of excess catalyst and the incident. The team found no mechanical defects in the equipment, and all safety devices functioned as designed. To confirm the team's findings, additional inves tigations are in progress at the Union Carbide South Charleston Technical Canter." As you know, we will transmit the team's final report to the Occupational Health and Safety Administra tion (OSHA) and to the Industry in hope of pre venting another such incident. It's also important to ask ourselves what this accident says about our plant safety program. Wc asked Dick Graebcrt, C&P Divi sion Safety Director that question, and he responded with the letter to each of you which is reproduced here. SUBJECT ___ 1977 Safety Goals A tragic incident, such as the one recently ex perienced in the Non-Solvent Vinyl Unit, often causes many to doubt the effectiveness of the plant's overall safety program. This doubt, in turn can cause a temporary loss in the level of SAFETY AWARENESS and it is for this reason that I am writing this letter to each of you. The well organized teams assigned to evaluate all information associated with the incident should enable us to understand the causes. Knowledge of the causes of the incident can be used to improve the total program where defi ciencies are found. This specific incident, how ever, should not be used as a basis for justifying broad changes in the entire program. ALL OF THE EMPLOYEES OF THE TEXAS CITY PLANT have demonstrated their ability to work safely over extended periods of time. This ability to work safely is reflected in a steady improvement in performance over re cent years. THE EXPERT MANNER IN WHICH SO MANY EMPLOYEES PARTICIPATED IN EMERGENCY ACTIVITIES required by the Vinyl Unit incident is a good example of the effectiveness of Texas City's safety program. The incident does serve to remind us again how alett everyone must be to avoid the combina tion of events which lead to any accident, large or small. A GOOD SAFETY PROGRAM RE QUIRES THE CONSTANT ATTENTION OF ALL EMPLOYEES. With management's demon strated commitment to provide good training, effective procedures, and sound design, an ever present attitude of awareness on the part of each employee will get the job done. / d jSafety Director. Chemicals and Plastics ucc 05A942