Dallas Sales Center - 3M Company - Executive Summary |
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1. Introduction This Executive Summary briefly reviews the major elements of the Risk Management Plan for Dallas Sales Center - 3M Company. We take seriously our safety, health and environmental responsibilities to our employees and to the community. As an operating unit of 3M, we share in a tradition of environmental, health and safety responsibility going back through much of the company's history. 3M was an early pioneer in pollution prevention and created its environmental policy in 1975. Since 1990, 3M has cut its worldwide volatile organic air emissions 80 percent, and releases to water 75 percent. 2. Accidental Release Prevention and Emergency Response Policies It is our goal to prevent accidental releases of regulated and other materials through the proper design, installation, operation and maintenance of our manufacturing processes and the proper training of our employees. If, despite our efforts, such a release should occur, our trained emergency response personne l are at hand to control the effects of the release until the local Fire Department and other emergency responders arrive. We maintain an excellent working relationship with the emergency responders to ensure rapid and effective response. 3. The Stationary Source and The Regulated Substances Handled This location is a distribution center and warehouse for finished goods, primarily in small containers intended for consumer use. We have five regulated substances at our facility in quantities regulated by EPA's Risk Management Program. 3M employees are trained and experienced in working with these substances and we contribute to safety by providing high quality manufacturing processes, equipment and maintenance. The following regulated substances are used at Dallas Sales Center - 3M Company: - Isobutane, pentane and methyl ether are all flammable gases that are used as propellants in aerosol cans. The maximum container size for this substance is approximately twenty ounces. Al though these materials are not currently present at this site above the Threshold Quantity, they are included in this plan under the predictive filing option. - Ethylene oxide is used in the medical profession to sterilize surgical equipment. It is a listed RMP toxic substance. The maximum container size for this substance is approximately six ounces. Although propane is not currently regulated under RMP, 3M has voluntarily included propane in this plan. This Risk Management plan includes predictive filing for three additional flammable gasses also used as propellants in aerosol cans - isobutane, pentane and methyl ether. Although current inventory data shows that these are not stored at this site, or are stored at levels below the Threshold Quantity, previous data show that they can at times be present above the Threshold Quantity, and they are therefore included in the plan. 4. Worst Case Release Scenarios EPA has directed all affected facilities to share with their communiti es a look at the worst possible accident that could happen at the facility, as unlikely as that might be. EPA has defined the worst case scenario as the release of the entire contents of the single largest container. For Dallas Sales Center - 3M Company, two scenarios were analyzed, one for flammables and one for toxics. The worst case scenario analyzed for flammables was the release of the total contents of the largest aerosol can with the highest flammable content. Propane was selected because it has the highest heat of combustion of the materials stored, and therefore the greatest distance to endpoint. Analysis was performed using equations provided in EPA guidance documents. The results show containment well within the limits of the building. Although there is significant passive mitigation designed into this facility, including red label storage rooms, blast walls, and the building itself, additional credit was not taken for these passive mitigation measures in our scenari o analysis. The worst case scenario analyzed for toxics was the release of the total contents of the largest ethylene oxide cartridge stored at the site. The results show containment well within the limits of the building. Although the building itself would serve as passive mitigation, no additional credit was taken for mitigation measures in our scenario analysis. The results of the worst case release analyses, combined with the five year history showing no accidental releases, qualify this as a Program 1 process. Therefore, alternative release scenarios are not required. It should be noted that because the regulated substances at this facility are in small containers, the data reported in the scenarios - quantity released, release rate, and distance to endpoint - are the smallest values enterable in RMP*Submit. The true values are actually less than the reported numbers. 5. Dallas Sales Center - 3M Company Program to Prevent Accidental Releases At Dallas Sales Center - 3M , we take great care to prevent accidents, including those not covered under the EPA's Risk Management Program. Programs are in place to address accidental release prevention measures consistent with appropriate federal, state, and local requirements. Beyond government requirements, we have 3M internal standards for continuously improving safety at our facility. Reflecting the low risk and the five year history showing no accidental releases at this facility, EPA criteria for Program 1 designation are met and specific prevention program elements are not addressed in this plan. 6. Five-year Accident History At Dallas Sales Center - 3M Company, no level of accident is acceptable. We work continually to reduce the number and severity of accidents at our operations. In the five years preceding submittal of this plan, there were no accidental releases with on-site or off-site consequences meeting EPA criteria for inclusion in this plan. 7. Emergency Response Plan 3M's first line of defense against accidents is prevention. At Dallas Sales Center - 3M Company we also work to ensure that we are prepared for any accident that might happen. We maintain a written emergency response plan that includes arrangements for immediate response from employees, notification of local emergency response agencies and the public, first aid and medical treatment, evacuations, and post-incident decontamination of affected areas. We conduct regular drills and work with the Dallas Fire Department to ensure the proper execution of our plan. Our emergency response plan is updated to reflect any pertinent changes that would require a modified emergency response. 8. Planned Changes to Improve Safety At Dallas Sales Center - 3M Company, we strive to continually improve safety at our facility. Our efforts range from designing safety into our operations to regular assessments identifying opportunities for safety improvements. In addition, Dallas Sales Center - 3M Company is impl ementing an updated corporate policy to make safety a part of every employee's responsibility. This policy encourages employees to identify any situations they perceive to be unsafe, as well as any opportunities to improve safety. |