Cottage Grove - 3M Company - Executive Summary
Risk Management Program |
This Executive Summary briefly reviews the major elements of the Risk Management Plan of Cottage Grove - 3M Company. We take seriously our safety, health and environmental responsibilities to our employees and to the community. As an operating unit of 3M Company, we share in a tradition of environmental, health and safety responsibility going back through much of the company's history. 3M Company was an early pioneer in pollution prevention and created its environmental policy in 1975. Since 1990, 3M Company 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 r
elease should occur, our trained emergency response personnel are at hand to control the effects of the release until the Cottage Grove Fire Department 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 specialty chemicals for internal and external customers for use in making a wide variety of products from sandpaper to medical imaging materials. We use 2 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 Cottage Grove - 3M Company:
7 Hydrogen fluoride/hyrodfluoric acid, a non-flammable, corrosive acid, is a key raw material used to make such products as replace
ments for ozone-depleting chlorofluorocarbons (CFCs). These CFC replacements are used in the manufacture of semiconductors and in depositing special lubricants on memory discs for computers.
7 Toluene Diisocyanate, a liquid used in making products such as resins, adhesives, and coating materials. These products may be used to manufacture items such as sandpaper and tape.
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 and alternative release scenarios, we used look-up tables and equations provided by the EPA. The look-up tables indicate the worst case release scenario from Cottage Grove - 3M Company is a release of hydrogen fluoride in a gaseous form over a ten minute period, and includes the use of
a building to limit the size of the release.
The worst case scenario for toluene diisocyanate was the release of material from an inside storage tank. Analysis was performed using ALOHA release modeling. Results show containment well within the site boundary. The results of the worst case analysis analysis, combined with the 5 year history showing no accidental releases, qualify this as a Program 1 process. Alternative release scenarios are not required for Program 1 processes.
The alternative release scenario for hydrogen fluoride is a release for 10 minutes in a liquid form from an outside transfer pipe.
5. Cottage Grove - 3M Company Program to Prevent Accidental Releases
At Cottage Grove - 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 notificatio
n 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. Following is a brief description of the steps we take to prevent accidental releases:
- Installation of water detection, deluge, diking, and enclosure systems. Implementation of administrative controls.
7 Process Safety Information - At Cottage Grove - 3M Company, 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 used 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 Company corporate specialists, we conduct comprehensive studies to ensure that po
tential 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 shutdown, emergency operations, normal shutdown and startup after a turnaround.
7 Training - At Cottage Grove - 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 procedur
es. Refresher training is provided.
7 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 timely manner. Two error messages appear in the mechanical integrity section of this report. These are for equipment that installation will be completed at a later date. At that time mechanical integrity testing will be completed for this equipment.
7 Management of Change - We have established written procedures at Cottage Grove - 3M Company 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 Cottage Grove - 3M Company. 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 procedures 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 Cottage Grove - 3M Company, 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, Cottage Grove - 3M Company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, 3M Company conducts a thorough evaluation of the contractor's safety performance. At Cottage Grove - 3M, Company we have a policy of informing contractors of known potential hazards related to 3M Company processes and the contractor's work. Contractors are also informed of 3M procedures for emergency response should an accidental release of a regulated substance occur.
r Accident History
At Cottage Grove - 3M Company, no level of accident is acceptable. We work continually to reduce the number and severity of accidents at our operations. Wiith respect to the current operations in our facility (covered by this submittal) there were no significant releases of RMP regulated substances within the past five years.
7. Emergency Response Plan
3M Company's first line of defense against accidents is to take action to prevent them, as described elsewhere in this executive summary. However, at Cottage Grove - 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-including joint training with the Cottage Grove Fire De
partment 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.
Cottage Grove - 3M Company participates in the Chemical Manufacturers Association's Responsible Care Program.
8. Planned Changes to Improve Safety
At Cottage Grove - 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. Cottage Grove - 3M Company performs regular safety inspections of the facility, and makes improvements based on these evaluations.
In addition, Cottage Grove - 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 situatio
ns they perceive to be unsafe, as well as any opportunities to improve safety.