Tonawanda - 3M Company - Executive Summary |
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Tonawanda 3M Risk Management Program Executive Summary 1. Introduction This Executive Summary briefly reviews the major elements of the Risk Management Plan of Tonawanda 3M . 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 m aterials 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 hand to control the effects of the release until the Town of Tonawanda Fire Department and/or Brighton Hazmat emergency response organization arrives. 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 We manufacture cellulose sponges at a facility located on a 19 acre site within an industrial zoned area of Tonawanda, New York. The approximately 275,000 square foot plant includes manufacturing, converting and warehouse facilities and employs approximately 325 people. We use one regulated substances at our facility in quantities regulated by EPA's Risk Management Program. 3M employees are trained and experi enced 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 Tonawanda 3M: 7 Carbon Disulfide is used in the production of viscose. Viscose is used in the production of cellulose sponges. 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 might be, and an alternative, more realistic, accident scenario. To evaluate our worst case release scenarios, Tonawanda 3M used RMP*Comp, an air modeling program provided by the EPA. Our worst case scenario is the release of the entire contents of the carbon disulfide storage tank over a 23.7 minute time frame. Our analysis does not take into account the use of a water filled dike which would limit the impact of a release under the worst case scenario. Carbon disulfide is heavier than water and would be completely coverd by the water during a release into the dike. To evaluate our alternative release scenarios, Tonawanda 3M used RMP*Comp, an air modeling program provided by the EPA. The alternative release scenario for carbon disulfide is a release of the chemical in liquid form over 25 seconds. Our analysis includes operating procedures, alarms, and a redundant control system which will shut down the operation within 25 seconds following the detection of a leak. The analysis also takes into account the use of a dike to assist in limiting the potential of a release with off site consequences. 5. Tonawanda 3M Program to Prevent Accidental Releases At Tonawanda 3M, 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 f rom OSHA, and all notification requirements of EPA's Emergency Response and Community Right To Know regulations. Beyond government requirements, we have our own standards for continuously improving safety at our plant. Additional mitagation measures we have in place but did not take credit for in our alternative case scanario are: - a water filled dike system (the CS2 is heavier than water), a water deludge system, a sprinkler system, a relief panel, an enclosure, check valves, a manual shutoff system, an automatic shutoff system, alarms, sumps, a video camera monitoring system, procedures, and grounding system. Following is a brief description of the steps we take to prevent accidental releases: 7 Process Safety Information - At Tonawanda 3M, we maintain a record of safety information that helps us conduct our operations safely. This information describes the chemical hazards, operating parameters and equipment designs associated with appropriate processes. The information is u sed in process training for employees and is readily accessible to operators involved in the processes. The information is reviewed for any appropriate improvements 7 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. 7 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 shutdow n, emergency operations, normal shutdown and startup after a turnaround. 7 Training - At Tonawanda 3M, 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. 7 Mechanical Integrity - We conduct and documentl 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 timely manner. 7 Management of Change - We have established written procedures at Tonawanda 3M 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 7 Pre-startup Reviews - These safety reviews for new processes and modifications to established processes are conducted as a regular practice at Tonawanda 3M. 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. 7 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. 7 Incident Investigation - We have proced ures to promptly investigate any incident that has resulted in, or could reasonably result in a substantial release of a regulated substance. Investigations will be undertaken to identify the situation leading to the incident as well as any corrective actions to prevent a similar release in the future. 7 Employee Participation - At Tonawanda 3M, we have found through experience that managing process safety and preventing accidents are team efforts. We strongly encourage 3M employees to express their views concerning accident prevention issues and to recommend improvements. 7 Contractors - On occasion, Tonawanda 3M hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, 3M conducts a thorough evaluation of the contractor's safety performance. At Tonawanda 3M, we have a policy of informing contractors of known potential hazards related to 3M processes and the contractor's work. Contractors are also informed of 3M pro cedures for emergency response should an accidental release of a regulated substance occur. 6. Five-year Accident History At Tonawanda 3M , no level of accident is acceptable. We work continually to reduce the number and severity of accidents at our operations. In the 50 year history of the facility there has been no accidential releases with off site or on site consequences meeting EPA criteria for inclusion in the plan. 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, at Tonawanda 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-including joint training with the Town of Tonawanda Fire Department and Hazmat Team -- 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. Tonawanda 3M participates in the Local Emergency Preparedeness Committee, the Hazardous Material Advisory Council and the Community Advisory Panel. 8. Planned Changes to Improve Safety At Tonawanda 3M, 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. An important new elements in Tonawanda 3M's continuous improvement program is to install additional innovative pollution-control equipment to reduce air emissions by 50 to 70 percent. In addition, Tonawanda 3M has implemented 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. This policy has also been incorporated into the Tonawanda 3M Safety Mission Statement. |