FMC Corporation - AOD Tonawanda - Executive Summary
The FMC Corporation's Tonawanda, NY manufacturing facility is committed to conducting business in a manner that protects the safety and health of its employees, contractors, customers, and the environment. Furthermore, it is committed to conducting business in a manner that is compatible with the balanced environmental needs of the community in which it operates. This commitment requires compliance with all applicable laws and regulations, facilities which are designed and operated to high standards, and systematic identification and management of safety, health, and environmental risks. In keeping with this commitment, FMC Corporation's Tonawanda Plant has established a comprehensive Safety Management System that strives to identify and eliminate all potential exposures that include, but are not limited to, personal injury/illness, property damage, fires, process incidents, and breaches of security. The Safety Management System embodies and employs the spirit and intent of the con |
cepts found in the ACC Responsible Care Initiative, the OSHA PSM Standard, all other applicable regulatory standards, and FMC Corporation's Corporate Safety and Industrial Hygiene Policies and strategies.
The Plant's Safety Policy:
In everything we do, the safety of our employees, visitors, the community, our customers, and the environment is imperative. We are committed to: A) Providing a safe and healthy work environment at FMC Tonawanda; B) The belief that all injuries are preventable and that an injury free workplace is acheivable; C) The STRIDE behavioral-based safety process as the key to continuous safety improvement; D) Fostering a work environment where all employees feel free to discuss their safety and health concerns and to participate in improving our plant work conditions and safe work behaviors; E) Open communication and mutual trust ro meet our safety and health goals; and F) A Process Safety Management Program that ensures the mechanical integrity and effective oper
ation of all company facilities.
Every employee is responsible and will be held accountable for working safely, knowing and following plant rules and procedures, and maintaining a safe work environment. The company will provide and maintain safe equipment, processes, procedures, safety training, and will comply with safety regulations.
Management at FMC Corporation's Tonawanda Plant has authorized specific risk management programs and activities in compliance with EPA's Risk Management Program ruling (40 CFR Part 68) that assesses the hazards of processes which handle or store more than the threshold quantity of substances regulated by the EPA, prevent accidental releases of these hazardous substances, and effectively respond to emergencies if a release occurs.
Description - FMC Corporation's Tonawanda Plant produces active oxidant products for shipment to external users. The covered process is the storage and handling of anhydrous ammonia (CAS Number 07664-41-7).
Worst Case Sce
nario - RMP regulations require a consequence analysis for worst case scenarios in each regulated process, estimated to present the greatest distance in any direction to a toxic endpoint.
The worst case scenario selected for this process was the complete loss of the contents of one full ammonia railcar of 161,000 lbs within 10 minutes. The distance to toxic endpoint (200 ppm) is 6.9 miles. The estimated residential population within the area is 328,400. Modeling was performed using RMP Comp V1.01 assuming rural conditions and a wind speed of 1.5 m/sec. Rural conditions were deliberately chosen to create a more conservative approach as was the F class stability. Public impacts include schools, residences, hospitals, recreational areas, and major commercial office or industrial areas. Environmental impacts include state parks and wildlife sanctuaries, preserves, or refuges.
Alternative Release Scenarios - RMP regulations require that at least one alternative release scenario be i
dentified and analyzed for each regulated toxic chemical present. A scenario that is more realistic than the worst case scenario was selected as the alternative release case.
The alternative release scenario simulates an ammonia railcar transfer line rupture. The event is assumed to release 6,840 lbs of ammonia during a 20 minute period at a rate of 342 lb.min. The estimated distance to the toxic endpoint (200 ppm) is 0.3 miles. This scenario was modeled using RMP Comp (V1.01) and assumed a complete rupture of the liquid transfer hose during a railcar unloading. The loss was assumed to be for 20 minutes duration with a manual response to close the railcar unloading valve and did not account for the excess flow valve in place on the railcar in order to keep the model conservative. The estimated residential population within the area is 3,700 persons. Public impacts include parks and recreational areas, and major commercial office and industrial buildings. The institutions, park
s, and recreational areas within the 0.3 mile radius from the release source were located using WNY street maps from Map Works, Inc. No environmental contacts are impacted.
Five Year Accident History - During the five years immediately prior to the date of this report, no accidental releases were experienced at the FMC Corporation Tonawanda Plant under the RMP definition.
Prevention Program - FMC Corporation's Tonawanda Plant has established a comprehensive Safety Management System that strives to identify and eliminate all potential exposures that include, but are not limited to, personal injury/illness, property damage, fires, process incidents, and breaches of security. The Safety Management System embodies and employs the spirit and intent of the concepts found in the ACC Responsible Care Initiative, the OSHA PSM Standard, all other applicable regulatory standards, and FMC Corporation's Corporate Safety and Industrial Hygiene Policies and strategies.
Prevention of accidental r
eleases of hazardous substances at the Tonawanda Plant involves a unified approach that integrates technologies, procedures, and management practices. These prevention programs comply with all applicable requirements of OSHA PSM regulations, as stipulated in 26 CFR 1910.199, and all applicable EPA Risk Management Program (RMP) requirements, as stipulated in 40 CFR Part 68. The nature of the processes and the types and quantities of hazardous substances present require that these processes be considered as "Program 3" processes for EPA RMP regulations. The following elements are included in the Safety Management system at Tonawanda: 1. Process Safety Information (General information - MSDSs, SOPs, Safety Procedures, Process Controls, Equipment Manuals, Design Files, Product Safety, Process Technology, and Equipment Safety); 2. Process Hazard Reviews; 3. Operating Procedures; 4. Training; 5. Mechanical Integrity; 6. Management of Change; 7. Pre-Start-Up Safety Review; 8. Compliance A
udits; 9. Incident Investigations; 10. Employee Participation; 11. Hot Work Permits; and, 12. Contractor Safety.
Emergency Response Program - The FMC Corporation Tonawanda Plant Emergency Response Program involves the preparation of an Emergency Response Plan tailored to each process and the emergency response services that are available in the nearby community. The Emergency Response Plan complies with EPA Emergency Response Program requirements stipulated in 40 CFR Part 68.