FMC Corporation Agricultural Products Group - Executive Summary

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The FMC Corporation Agricultural Products Baltimore manufacturing facility is committed to protecting the safety and health of employees, contractors, its 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 Baltimore Plant has established a comprehensive Safety Management System that strives to identify and eliminate potential exposures that include, but are not limited to, personal injury/illness, property damage, fires, process incidents, and breaches of security. The employees at FMC Corporation Baltimore are dedicated to developing, implementing, and operating sound p 
rocess safety programs, maintaining compliance with both internal corporate and external requirements, improving process safety performance using a risk-benefit approach, and addressing process safety and risk management issues and concerns in a timely manner.  
 
The Safety Management System embodies and employs the spirit and intent of the concepts found in the CMA Responsible Care Initiative, the OSHA Process Safety Management Standard, all other applicable regulatory standards, and FMC Corporation's Corporate Safety and Industrial Hygiene Policies and Strategies.  FMC Corporation Baltimore is fully committed to the CMA Responsible Care initiatives: Process Safety, Employee Safety and Health, Distribution, Pollution Prevention, Community Awareness and Emergency Response (CAER), and Product Stewardship.  FMC Corporation Baltimore achieves compliance with Responsible Care codes through workplace health and safety programs as well as release and waste generation reduction programs.  Thes 
e programs ensure that FMC Corporation Baltimore is operated in a manner that protects the environment and the health and safety of personnel and the public.  
 
The Safety Management System includes the following Safety Policy statement: 
 
"We are all personally responsible, at the Baltimore Plant, to take the necessary steps to eliminate or reduce exposure to accidental injury and conditions that may adversely affect our health and safety.  No job is so important that we cannot take time to perform our work safely."  
 
The Safety Management System also includes the following Safety Vision statement: 
 
"Our shared vision is a workplace where all employees accept responsibility for their personal safety and the safety of other employees, the community, and our environment." 
 
Management at FMC Corporation's Baltimore Plant has authorized specific risk management programs and activities in compliance with EPA's Risk Management Program ruling (40 CFR Part 68) that assess the hazards of process 
es 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 of FMC Corporation Baltimore Plant  
The FMC Corporation Baltimore Plant produces agricultural products for shipment to external users. The covered processes are the Sulfentrazone Process, TMOA (trimethyl orthoacetate) Process, MAC (methallyl chloride) Process, and the Clomazone Process.    
 
The Sulfentrazone Process includes the regulated chemicals chlorine (CAS Number 007782-50-5), nitric acid (CAS Number 007697-37-2), oleum (CAS Number 008014-95-7), and acetaldehyde (CAS Number 000075-07-0).  The TMOA Process includes the regulated chemical anhydrous hydrogen chloride (CAS Number 007647-01-0).  The MAC Process includes the regulated chemicals chlorine (CAS Number 007782-50-5) and isobutylene (CAS Number 000115-11-7).  The Clomazone Process includes the regulated 
chemical anhydrous hydrogen chloride (CAS Number 007647-01-0).  
 
Worst Case Release Scenarios 
RMP regulations for Program 3 processes require performing a consequence analysis for one worst case release scenario, estimated to present the greatest distance in any direction to a toxic endpoint. The toxic endpoint is the emergency response planning guideline value (ERPG-2) intended to provide an estimate of the maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms that could impair their abilities to take protective action.  The worst case scenarios presented in this document were chosen based on a knowledge of the regulated processes and chemicals, and through comparison of potential hazards associated with the regulated chemicals. A worst case scenario must also be performed for the flammable substance having the greatest potent 
ial for offsite impacts.  
 
Toxic Worst Case Scenario: Anhydrous Hydrogen Chloride in the TMOA and Clomazone Processes 
The worst case release scenario selected was the complete loss of the contents of one full anhydrous hydrogen chloride railcar.  The release scenario assumed loss of 140,000 pounds of anhydrous hydrogen chloride through a toxic gas release in 10 minutes. The distance to toxic endpoint (0.0300 mg/l) reached by anhydrous hydrogen chloride concentrations generated by a 10 minute release of 140,000 pounds of anhydrous hydrochloric acid is 16.0 miles. The residential population estimated for the area as obtained from census data is 1,700,000. Public receptors identified include institutions (schools, hospitals, prisons), parks and recreational areas, and major commercial, office and industrial buildings.  
 
Flammable Worst Case Scenario: Isobutylene in the MAC Process 
The worst case release scenario selected for the RMP-regulated flammable substances was the complete loss of  
the contents of one isobutylene storage vessel with vapor cloud explosion.  The release scenario assumed loss of 285,000 pounds of isobutylene. The distance to endpoint (1 psi overpressure) reached by isobutylene generated by a release and vapor cloud explosion of 285,000 pounds of isobutylene is 0.5 miles. The residential population estimated for the area as obtained from census data is 10.  Public receptors identified include major commercial, office and industrial buildings. 
 
Alternative Release Scenarios 
RMP regulations require that at least one alternative release scenario be identified and analyzed for each regulated toxic chemical present. Scenarios that are more realistic than the worst case scenario were selected as the alternative release. One alternative case scenario is presented and is representative of the regulated flammables at the site.  
 
Alternative Scenario Toxics: Chlorine in the Sulfentrazone and MAC Processes 
The alternative release scenario simulates a chlorine r 
ail car transfer line rupture. The estimated distance to the toxic endpoint (0.0087 mg/L) was found to be 0.4 miles. The residential population estimated for the area as obtained from census data is 10.  Public receptors identified include major commercial, office and industrial buildings.  
 
Alternative Scenario Toxics: Nitric Acid in the Sulfentrazone Process 
The alternative release scenario simulates a nitric acid tanker truck transfer line rupture. The estimated distance to the toxic endpoint (0.0260 mg/L) was found to be 0.2 miles. The residential population estimated for the area as obtained from census data is 10.  Public receptors identified include major commercial, office and industrial buildings.  
 
Alternative Scenario Toxics: Oleum in the Sulfentrazone Process 
The alternative release scenario simulates an oleum tanker truck transfer line rupture. The estimated distance to the toxic endpoint (0.0100 mg/L) was found to be 0.2 miles. The residential population estimated for the 
area as obtained from census data is 10.  Public receptors identified include major commercial, office and industrial buildings.  
 
Alternative Scenario Toxics: Anhydrous Hydrogen Chloride in the TMOA and Clomazone Processes 
The alternative release scenario simulates an anhydrous hydrogen chloride rail car transfer line rupture. The estimated distance to the toxic endpoint (0.0300 mg/L) was found to be 0.3 miles. The residential population estimated for the area as obtained from census data is 10.  Public receptors identified include major commercial, office and industrial buildings.  
 
Alternative Scenario Flammables: Isobutylene in the MAC Process 
The alternative release scenario for flammables simulates an isobutylene rail car transfer line rupture and vapor cloud fire. The distance to endpoint was found to be less than 0.1 miles. The residential population estimated for the area as obtained from census data is 0.  Public receptors identified include major commercial, office and indu 
strial buildings.  
 
Five-Year Accident History  
During the five years immediately prior to the date of this report, the following accidental releases were experienced at the FMC Corporation Baltimore Plant.  None of the reported releases went beyond the plant boundaries. 
 
                    Chemical  
Date              Released    Amount       Source                      Weather                  Damages              
02/17/94        chlorine      <1.0 lb.        gasket leak               unknown                one injury (first aid) 
05/20/96        chlorine      <0.5 lb.        valve                        unknown                one injury (first aid) 
09/19/97        chlorine      <0.5 lb.        piping                       unknown                 two injuries (first aid) 
01/16/98        chlorine      < 25 lbs.      transfer hose           rain                         one injury (first aid) 
10/18/98        nitric acid   < 5.0 lb.       gasket leak               unknown                 
one injury (first aid) 
 
Emergency Response Program  
The FMC Corporation Baltimore Plant emergency response policy 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. 
 
The emergency response program consists of an emergency response plan, emergency response equipment procedures, employee training, and procedures to ensure the program is up to date. 
 
The key elements of FMC's emergency response program are: 
 
Emergency Response Plan that is updated annually or more frequently based on incident investigation or drills; 
 
Employee Training conducted jointly with local, state, and federal agencies; 
 
Coordination of the emergency response program with local, state, and federal agencies through area drills, and LEPC/SERC participation; 
 
Coordination of the emergency response 
program with SBIMAP, the area-wide mutual aid organization sharing materials, supplies and expertise to its 90+ members, including assistance to Fire Departments dealing with non-member emergencies;  
 
Plant tours for Fire Department and response agency responders; and 
 
On-site Incident Command System with HAZWOPER trained employees.
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