Decatur - 3M Company - Executive Summary |
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Risk Management Program Executive Summary 3M/Dyeon - Decatur, AL 1. Introduction This Executive Summary briefly reviews the major elements of the Risk Management Plan for Decatur - 3M Company in Decatur AL. We take seriously our safety, health and environmental responsibilities for our employees and the community. As an operating unit of 3M, we share in a tradition of environmental, health and safety responsibility. 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 r esponse personnel are at hand to control the effects of the release. We also maintain an excellent working relationship with the Decatur Fire Department who can provide additional rapid and effective response. 3. The Stationary Source and The Regulated Substances Handled We manufacture specialty films and specialty chemicals for use in making a wide variety of products from video cassette duplicator tape to fabric protection products. We use 10 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. We contribute to their safety and health by providing high quality manufacturing processes, equipment and maintenance. The following regulated substances are used at Decatur - 3M Company: Hydrogen fluoride, Chlorine, Epichlorohydrin, Ethyl Amine, Methyl Amine, and Phosphorus Oxychloride are all key raw materials used to make various products such as fabric pro tection products, as well as replacements for ozone depleting chlorofluorocarbons (CFCs). These CFC replacements may be used in the manufacture of semiconductors and in depositing special lubricants on memory discs for computers. Propylene and Vinylidene fluoride are used as raw materials in the production of synthetic rubber products that are used in the production of many automobiles. Sulfur dioxide (anhydrous) is used as a reactant in a scrubber system in order to help control chlorine emissions. Although Propane is not curently regulated under RMP, we are voluntarily including our use of propane in this Risk Management Plan. Propane is used as a backup fuel source for various processes that typically use natural gas. 4. Worst Case Release Scenario(s) and Alternative Release Scenario(s) 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 mig ht be, and an alternative, more realistic, accident scenario. To evaluate accidental release scenarios, we have used the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance as well as Equations from Appendix D of the EPA's Offsite Consequence Analysis Guidance. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 3 toxic substances as a class involves a gaseous release of Hydrogen Fluoride for a duration of 10 minutes. One alternative release scenario will be submitted for each toxic substance present in Program 3 processes cumulatively. In taking a conservative approach to choosing the alternate case scenarios, credit was not given to all potential mitigation measures that are inherent to the processes. The alternative release scenario for Hydrogen fluoride involves a gaseous release from process piping in the Hydrogen Fluoride process for a duration of 10 minutes . The release is assumed to be controlled by passive mitigation which includes a building enclosure. The alternative release scenario for Chlorine involves a gaseous release resulting from a scrubber malfunction in the Continuous Chlorination System. The alternative release scenario for Epichlorohydrin involves a liquid release from a transfer line in the Epichlorohydrin Storage and Transfer process. Toxic liquid is assumed to be immediately released to form a pool 1 cm high from which evaporation takes place. Passive mitigation in the form of a dike is taken into account to calculate the scenario. The alternative release scenario for Sulfur dioxide (anhydrous) involves a gaseous release from a blown rupture disk in the Continuous Chlorination System. The alternative release scenario for Phosphorus oxychloride involves a liquid release from a drum. Toxic Liquid is assumed to be immediately released to form a pool of height 1 cm, from which evaporation takes place. Passive mitigation in the way of an enclosure is taken into account to calculate the scenario. The worst case release scenario for Program 3 flammable substances as a class involves a catastrophic release from the Propylene Storage Tank in the Propylene storage and transfer process. It is assumed that the entire quantity is released as a vapor, which finds an ignition source. The alternative release scenario for Program 3 flammable substances involves a release from the Propylene Storage Tank transfer line. The release is assumed to result in a Vapor Cloud Explosion. 5. Decatur - 3M Company Program to Prevent Accidental Releases At Decatur - 3M Company, we take great care to prevent accidents, including those not covered under the EPA's Risk Management Program. We have programs in place to address accidental release prevention measures required by EPA, Process Safety Management requirements from OSHA, and all notification requirements of EPA's Emergency Response and Comm unity Right To Know regulations. Beyond government requirements, we have our own standards for continuously improving safety at our plant. Some process controls and mitigation systems typically found in our processes include: vents, relief valves, check valves, scrubbers, manual shutoffs, automantic shutoffs, interlocks, alarms and procedures, emergency power, backup pumps, grounding equipment, rupture disks, excess flow devices, purge systems, dikes, deluge systems, sprinkler systems, enclosures, etc. Following is a brief description of the steps we take to prevent accidental releases: Storage Volume Reduction - At Decatur - 3M Company we examine opportunities to reduce the volume of chemicals stored on our site, thereby reducing the potential impact of an accident involving those chemicals. Process Safety Information - We maintain a record of safety information that helps us conduct our operations safely. This information describes the chemical hazards, operating par ameters and equipment designs associated with appropriate processes. The information is used in process training for employees and is readily accessible to operators involved in the processes. The information is reviewed for any appropriate improvements. Process Hazard Analysis - With the support of 3M corporate specialists, we conduct comprehensive studies to ensure that potential hazards associated with certain hazardous processes are identified and controlled effectively. These studies are undertaken by a team of qualified personnel with expertise in engineering and process operations. These studies are revalidated at regular intervals of no more than five years or whenever significant changes are made in affected operations. Findings from the hazard analysis are presented so that they can be addressed in a timely manner. Operating Procedures - To conduct our manufacturing processes safely, we maintain written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. Training - At Decatur - 3M Company, we have a comprehensive training program to ensure that employees who are operating hazardous processes understand and are well trained in the correct operating procedures. Refresher training is provided. Mechanical Integrity - We conduct and document maintenance checks on hazardous process equipment to ensure proper operations. Process equipment examined by these checks includes, among others: pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and instrumentation, and pumps. Maintenance operations are conducted by qualified personnel with training in maintenance practices or other specialized subjects as needed. Equipment deficiencies are identified so that they can be corrected in a safe and time ly manner. Management of Change - We have established written procedures to manage changes in process materials, technology, equipment and procedures. Process operators, maintenance personnel or any other appropriate employees whose job tasks are affected by a modification in process conditions are notified and provided any needed training. Pre-startup Review - These safety reviews for new processes and modifications to established processes are conducted as a regular practice. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing certain equipment into operation. Compliance Audits - Utilizing accepted audit practices, we regularly conduct audits to determine whether the procedures identified above are being properly implemented. Required corrections are identified. Incident Investigation - We promptly investigate any incident that has resulted in, or could reasonably result in a substantial release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent a similar release in the future. Employee Participation - At Decatur - 3M Company, we have found through experience that managing process safety and preventing accidents are team efforts. We encourage 3M employees to express their views concerning accident prevention issues and to recommend improvements. Contractors - On occasion, Decatur - 3M Company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, we conduct a thorough evaluation of the contractor's safety performance. We have a policy of informing contractors of known potential hazards related to our processes and the contractor's work. Contractors are also informed of our procedures for emergency response should an accidental release of a regulated su bstance occur. 6. Five-year Accident History At Decatur - 3M Company, no level of accident is acceptable. We work continually to reduce the number and severity of accidents at our operations. Within the past five years there were two significant releases of regulated substances from our facility. The first took place on 06/12/95, involving 80 pounds of hydrogen fluoride and injuring one employee. There was no impact on anyone offsite or on the environment. Another release, of 20 pounds of sulfur dioxide (anhydrous), occurred on 04/28/98, injuring one employee. There was no offsite impact. As part of our effort to eliminate accidents, both accidents were investigated by 3M and actions were taken to reduce the risk of similar accidents in the future. 7. Emergency Response Plan 3M's first line of defense against accidents is to take action to prevent them, as described elsewhere in this executive summary. However, we also work to ensure that we are prepared for any acciden t 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 including joint training with the Decatur Fire Department and Morgan County Emergency Management Agency (EMA) to ensure the proper execution of our plan. Further, our emergency response equipment is regularly inspected and serviced. Our emergency response plan is updated to reflect any pertinent changes in our processes that would require a modified emergency response. Decatur - 3M Company participates in the Chemical Manufacturers Assosciatio's Responsible Care Program. 8. Planned Changes to Improve Safety At Decatur - 3M Company, we strive to continually improve safety at the plant. Our efforts range from designing safety into our manufacturing operations to regular assessments identifying opportunities for safety improvements. Important new elements in our continuous improvements programs are: 1) Construct a Hydrogen Fluoride (HF) unloading facility that will help mitigate an HF release from the unloading operation in the unlikely event that such a release should occur. 2) Introduce a process that distills HF from process waste material for recycling which reduces waste and minimizes the hazardous nature of the waste. In addition, Decatur - 3M Company is implementing an updated corporate policy to make safety a greater 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. |