Springfield - 3M Company - Executive Summary |
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1. Introduction This Executive Summary briefly reviews the major elements of the Risk Management Plan of Springfield - 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 personnel are at ha nd 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 At this location, we manufacture adhesive systems for use in a wide variety of products from aerosols to structural adhesives films. We have one regulated substance at our facility in quantities regulated by EPA's Risk Management Program. 3M employees are trained and experienced in working with this substance and we contribute to safety by providing high quality manufacturing processes, equipment and maintenance. The following regulated substance is used at Springfield - 3M Company: - TDI (Toluene diisocyanate) is a chemical used in the production of urethanes. It is stored in a dedicated tank. Raw TDI usage is limited to one room in one building in the facility. 4. Worst Case Release S cenarios EPA has directed all affected facilities to share with their communities 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 Springfield-3M Company, the worst case spill would be a full tanker. Analysis was performed per EPA guidelines and the results show containment well within the limits of our fenced properity. The results of the worst case release analysis, combined with the five year history showing no accidental releases, qualify this as a Program Level 1 process. Therefore, alternative release scenarios are not required. It should be noted that because of the properities of the regulated substance at this facility, the data reported in the scenario as release rate is the smallest value enterable in RMP* Submit. The true value is acually less than the reported number. 5. Program to Prevent Accide ntal Releases At Springfield - 3M Company, 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 accident history showing no accidental releases, EPA criteria for program 1... 6. Five-year Accident History At Springfield- 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 Springfield 3M , 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 Springfield 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 Springfield - 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, Springfield - 3M is implementing an updated Corporate policy to make safety a part of every employee's responsibility. Thi s policy encourages employees to identify any situations they perceive to be unsafe, as well as any opportunities to improve safety. |