3M Brownwood 2004 APR View/Print

OMB No. 2010-0032
Expiration Date 08/30/06

2004 Performance Track Annual Performance Report

3M Brownwood
A060018
Year 1 Annual Performance Report
Member Since 2001 (2nd Member Term)

SECTION A: GENERAL FACILITY INFORMATION

A.1

Name of your facility:

3M Brownwood

A.2

Name of your parent company:

3M Company

A.3

Facility contact person for the Performance Track program:

Name:	Mr. Fred Kelly
Title:	Environmental Engineering Specialist
Phone:	(325) 646-3551 (2311)
Fax:	(325) 646-6731
Email:	fbkelly2@mmm.com

A.4

Facility location:

Street Address:	4501 US Highway 377
Address Cont:
City:	Brownwood
State:	TX
Zip Code:	76801
Mailing address (if different from above):
Mailing Address:	P.O. Box 1669
Address Cont:
City:	Brownwood
State:	TX
Zip Code:	76804
If your facility has multiple street addresses, please list any other addresses for its sites or buildings.

A.5

Facility's website address (if any):

http://mmm.com

A.6

Number of employees (full-time equivalents) who currently work in the facility:

500-1,000

A.7

North American Industrial Classification System (NAICS) Code(s) that is(are) used to classify business at the facility:

326113 327212

A.8

In your application and, perhaps, in previous annual performance reports, you described what your facility does or makes. Have there been any (additional) changes to your facility's list of products and/or activities?

If yes, please list them here:

A.9

Have the environmental requirements applicable to your facility changed during this reporting period?

If yes, please describe these changes here:

Section B: ENVIRONMENTAL MANAGEMENT SYSTEM

B.1.a	When was an EMS assessment last conducted by an independent party at your facility?
	2004
	If an assessment was conducted during 2004, please provide the type (e.g., ISO 14001 certification), the scope, and the month(s) of each assessment.

Type Scope Dates

ISO 14001 EMS Continuance Audit

UL Continuance audit was conducted at the 3M Brownwood facility to determine overall conformance to the ISO 14001 EMS standard.
November 2004

B.1.b When was an internal EMS assessment last conducted at your facility?

2004

If an assessment was conducted during 2004, please provide the scope and month(s) of each assessment.

Scope Dates

Signing, OH&ES/SSD, Quality Assurance, and Beads
  May  2004

VRS, Resident Engineering/Contract Workers, Diamond Grade, Plant Engineering, EHS Department, Mix/Mill, Landfill, Material Handling
  August  2004

Waste Disposal/Solvent Recovery, Security Guards, EMS Internal Auditing, Human Resources/Plant Management
  October  2004

B.1.c When was an internal or corporate compliance audit last conducted at your facility?

2004

If an audit was conducted during 2004, please provide the scope and the month(s) of each audit, and indicate who conducted the audit(s) (e.g., facility staff, corporate groups, third party). (Don't include audits, inspections, or site visits by regulatory or external organizations).

Scope Dates Who conducted the audit

3M Brownwood environmental compliance audit of entire 3M Brownwood environmental management system.
November 2004 3M Corporate Internal Auditing Group

B.1.d (Optional) If you would like to describe any other audits or inspections that were conducted at your facility, please do so here.

City of Brownwood Waste Water Pretreatment compliance inspection, February 2004.

B.1.e Briefly summarize corrective actions taken and other improvements made as a result of your EMS assessments and compliance audits.

Secondary containment added for water treatment chemicals stored in plant chiller building.

B.1.f Has your facility corrected all instances of potential non-compliance and EMS non-conformance identified during your audits and other assessments?

Yes

If no, please explain your plans to correct these instances.

B.1.g When was the last Senior Management review of your EMS completed?

November  04

Who was the senior manager present at the review?

Name: Mr.  Steve James

  Title: Plant Manager

B.2.a ISO 14001 Certification. Is your facility currently certified to ISO 14001?

Yes

B.2.b Is your facility a Responsible Care-certified facility?

No

B.3 Environmental Aspects Identification. When did your facility last conduct a systematic identification and/or review of your environmental aspects?

November 04

SECTION C: ENVIRONMENTAL PERFORMANCE RESULTS

C.1 COMMITMENT 1

3M Brownwood's first commitment is to reduce the facility's generation of non-hazardous waste.

C.1.a Briefly describe your activities and achievements related to this commitment or, if relevant, any circumstances that delayed progress this year.

Reduce non-hazardous waste generation in the facility by process yield improvements, reformulations, product reconstruction, recycling/reuse, etc. Overall waste generation went up due to increases in production.

C.1.b Please report your facility's actual performance.

Performance Data

Waste Management Method Baseline Year 1 Year 2 Year 3 Units

2003 2004 2005 2006

Landfill

Specify other:
14,128,763 16,566,000 Pounds

Specify other:

Reused/recycled off-site

Specify other:
3,180,142 3,208,625 Pounds

Specify other:

Specify other:

Specify other:

Specify other:

Specify other:

Specify other:

Specify other:

C.1.c Summarized progress toward goal.

Actual Total Baseline Year 1 Year 2 Year 3 Perform.
Goal Units

Total Non Hazardous Waste 8,654.45 9,887.31 7,590.07 Tons

Specify other:

Normalized Total Baseline Year 1 Year 2 Year 3 Perform.
Goal Units

Normalizing Factor 1.0 1.1707

Total Non Hazardous Waste 8,654.45 8,445.64 n/a Tons

Specify other:

Basis for your Normalizing Factor:
Pounds of good product produced facility wide annually

C.1.d Please list any other EPA voluntary programs to which you are reporting these data.

Clean Texas Program

C.2 COMMITMENT 2

3M Brownwood's second commitment is to reduce the facility's VOC emissions.

C.2.a Briefly describe your activities and achievements related to this commitment or, if relevant, any circumstances that delayed progress this year.

Reduction of VOC emissions by in the facility by improved capture of fugitive emissions in production areas, reformulations, product migration, pollution control optimization, etc.

An error was corrected in Commitment #2 (Emissions of VOC's) for the baseline year VOC emissions due to an accounting error. Significant reductions took place in 2004 down to 365,000 pounds, even though the production increased significantly (by 17%). The goal year estimate also required a correction from 299,000 pounds to 328,100 pounds, due to the change in the baseline emissions. However, the original goal estimate was based on a reduction of 10%, but 3M now believes that a more ambitious estimate of 15% can be realized down to 328,100 pounds.

C.2.b Please report your facility's actual performance.

Performance Data

Baseline Year 1 Year 2 Year 3 Performance

Calendar Year 2003 2004 2005 2006 Commitment Units

Actual Quantity (per year) 386,000 365,000 328,100 Pounds

Specify other:

C.2.c Normalized progress toward goal.

Normalized Total Baseline Year 1 Year 2 Year 3 Perform.
Goal Units

Normalizing Factor 1.0 1.1707

Normalized Quantity 386,000 311,779.28 n/a Pounds

Specify other:

Basis for your Normalizing Factor:
Pounds of good product produced facility wide annually

C.2.d Please list any other EPA voluntary programs to which you are reporting these data.

Clean Texas program

C.3 COMMITMENT 3

3M Brownwood's third commitment is to reduce the facility's hazardous materials use.

C.3.a Briefly describe your activities and achievements related to this commitment or, if relevant, any circumstances that delayed progress this year.

Reduce hazardous material usage by implementing a mixing vessel cleaning system on 5 units that will allow the plant to use considerably less solvent for cleaning. This commitment is based on the installation of a number of new cleaning systems that will reduce the amount of cleaning solutions that are used on our major mixing vessels. Most of the cleaning systems had not been installed so the improvements have not yet been realized. The plant should begin to start seeing improvements in Year 2.

C.3.b Please report your facility's actual performance.

Performance Data

Baseline Year 1 Year 2 Year 3 Performance

Calendar Year 2003 2004 2005 2006 Commitment Units

Actual Quantity (per year) 3,292,167 3,412,853 1,870,000 Pounds

Specify other:

C.3.c Normalized progress toward goal.

Normalized Total Baseline Year 1 Year 2 Year 3 Perform.
Goal Units

Normalizing Factor 1.0 1.1707

Normalized Quantity 3,292,167 2,915,224.22 n/a Pounds

Specify other:

Basis for your Normalizing Factor:
Pounds good product produced facility wide annually

C.3.d Please list any other EPA voluntary programs to which you are reporting these data.

Clean Texas Program

C.4 COMMITMENT 4

3M Brownwood's fourth commitment is to reduce the facility's generation of hazardous waste.

C.4.a Briefly describe your activities and achievements related to this commitment or, if relevant, any circumstances that delayed progress this year.

Reduce hazardous waste generation in the plant by reformulations, product migration, cleanup methodologies, etc..

C.4.b Please report your facility's actual performance.

Performance Data

Waste Management Method Baseline Year 1 Year 2 Year 3 Units

2003 2004 2005 2006

Incineration

Specify other:
2,860,000 2,492,630 Pounds

Specify other:

Specify other:
Tons

Specify other:

Specify other:

Specify other:

Specify other:

Specify other:

Specify other:

Specify other:

C.4.c Summarized progress toward goal.

Actual Total Baseline Year 1 Year 2 Year 3 Perform.
Goal Units

Total Hazardous Waste 1,430.00 1,246.32 1,150.00 Tons

Specify other:

Normalized Total Baseline Year 1 Year 2 Year 3 Perform.
Goal Units

Normalizing Factor 1.0 1.1707

Total Hazardous Waste 1,430.00 1,064.59 n/a Tons

Specify other:

Basis for your Normalizing Factor:
Pounds good product produced facility wide annually

C.4.d Please list any other EPA voluntary programs to which you are reporting these data.

Clean Texas Program

Progress Towards Other Significant Aspects of your EMS

In the table below, please provide a narrative summary of progress made toward EMS objectives and targets other than those reported as Environmental Performance Commitments. You may limit the summary to environmental aspects that are significant and towards which progress has been made during the reporting year. Do you have additional environmental aspects to report?No

Attachments (if applicable) :

SECTION D: PUBLIC OUTREACH AND PERFORMANCE REPORTING

D.1 Please briefly describe the activities that your facility conducted during the year to interact with the community on environmental issues and to report publicly on environmental performance.

3M Brownwood Citizen's Advisory Committee was held on December 14, 2004. The plants' environmental performance was communicated to the group and the meeting allowed the advisory committee to provide feedback to 3M. In addition, several newspaper articles were printed in the newspaper that provided the public with information on 3M Brownwood environmental activities.

D.2 Please indicate which of the following methods your facility plans to use to make its Performance Track Annual Performance Report available to the public. Please check all that apply.

Community Advisory Panel

Attachments (if applicable):

OMB No. 2010-0032

SECTION E: SELF-CERTIFICATION OF CONTINUED PROGRAM PARTICIPATION

The U.S. Environmental Protection Agency is not yet in a position to accept electronic signatures and therefore requests a faxed, signed copy of the Section E page. Please complete Section E online, then print Section E using the link on the Overview page.Section E should be signed by the senior manager of your facility and faxed it to the Performance Track Information Center at (617) 354-0463.
On behalf of 3M Brownwood, I certify that: I have read and agree to the terms and conditions as specified in the National Enviromental Performance Track Program Guide. This facility, to the best of my knowledge, continues to meet all program criteria; I have personally examined and am familiar with the information contained in this Annual Performance Report. The information contained in this report is, to the best of my knowledge and based on reasonable inquiry, true, accurate, and complete; My facility has an environmental management system (EMS), as defined in the Performance Track EMS criteria, including systems to maintain compliance with all applicable federal, state, tribal, and local environmental requirements, in place at the facility, and the EMS will be maintained for the duration of the facility's participation in the program; My facility has conducted an objective assessment of its compliance with all applicable federal, state, tribal, and local environmental requirements; and the facility has corrected all identified instances of potential or actual noncompliance; and Based on the foregoing compliance assessments and subsequent corrective actions (if any were necessary), my facility is, to the best of my knowledge and based on reasonable inquiry, currently in compliance with applicable federal, state, tribal, and local environmental requirements. I agree that EPA's decision whether to accept participants into or remove them from the National Environment Performance Track is wholly discretionary, and I waive any right that may exist under any law to challenge EPA's acceptance or removal decision. I am the senior manager with responsibility for the facility and am fully authorized to execute this statement on behalf of the corporation or other legal entity whose facility is part of the National Environmental Performance Track program.
Signature/Date:	______________________________________________________
Name:	Mr. Steve James
Title:	Plant Manager
Phone Number:	325 646 3551
E-Mail Address:	scjames@mmm.com
Facility Name:	3M Brownwood
Facility Street Address:	4501 US Highway 377 Brownwood, TX 76801
Mailing Address:	P.O. Box 1669 Brownwood, TX 76804
Performance Track ID#:	A060018

Type	Scope	Dates
ISO 14001 EMS Continuance Audit	UL Continuance audit was conducted at the 3M Brownwood facility to determine overall conformance to the ISO 14001 EMS standard.	November 2004

B.1.b	When was an internal EMS assessment last conducted at your facility?
	2004
	If an assessment was conducted during 2004, please provide the scope and month(s) of each assessment.

Scope	Dates
Signing, OH&ES/SSD, Quality Assurance, and Beads	May 2004
VRS, Resident Engineering/Contract Workers, Diamond Grade, Plant Engineering, EHS Department, Mix/Mill, Landfill, Material Handling	August 2004
Waste Disposal/Solvent Recovery, Security Guards, EMS Internal Auditing, Human Resources/Plant Management	October 2004

B.1.c	When was an internal or corporate compliance audit last conducted at your facility?
	2004
	If an audit was conducted during 2004, please provide the scope and the month(s) of each audit, and indicate who conducted the audit(s) (e.g., facility staff, corporate groups, third party). (Don't include audits, inspections, or site visits by regulatory or external organizations).

Scope	Dates	Who conducted the audit
3M Brownwood environmental compliance audit of entire 3M Brownwood environmental management system.	November 2004	3M Corporate Internal Auditing Group

B.1.d	(Optional) If you would like to describe any other audits or inspections that were conducted at your facility, please do so here.
	City of Brownwood Waste Water Pretreatment compliance inspection, February 2004.
B.1.e	Briefly summarize corrective actions taken and other improvements made as a result of your EMS assessments and compliance audits.
	Secondary containment added for water treatment chemicals stored in plant chiller building.
B.1.f	Has your facility corrected all instances of potential non-compliance and EMS non-conformance identified during your audits and other assessments?
	Yes
	If no, please explain your plans to correct these instances.

B.1.g	When was the last Senior Management review of your EMS completed?
	November 04
	Who was the senior manager present at the review?
	Name: Mr. Steve James
	Title: Plant Manager

B.2.a	ISO 14001 Certification. Is your facility currently certified to ISO 14001?
	Yes
B.2.b	Is your facility a Responsible Care-certified facility?
	No

B.3	Environmental Aspects Identification. When did your facility last conduct a systematic identification and/or review of your environmental aspects?
	November 04

3M Brownwood's first commitment is to reduce the facility's generation of non-hazardous waste.
C.1.a	Briefly describe your activities and achievements related to this commitment or, if relevant, any circumstances that delayed progress this year.
	Reduce non-hazardous waste generation in the facility by process yield improvements, reformulations, product reconstruction, recycling/reuse, etc. Overall waste generation went up due to increases in production.
C.1.b	Please report your facility's actual performance.

Performance Data
Waste Management Method	Baseline	Year 1	Year 2	Year 3	Units
Waste Management Method	2003	2004	2005	2006	Units
Landfill Specify other:	14,128,763	16,566,000			Pounds Specify other:
Reused/recycled off-site Specify other:	3,180,142	3,208,625			Pounds Specify other:
Specify other:					Specify other:
Specify other:					Specify other:
Specify other:					Specify other:

Actual Total	Baseline	Year 1	Year 2	Year 3	Perform. Goal	Units
Total Non Hazardous Waste	8,654.45	9,887.31			7,590.07	Tons Specify other:

Normalized Total	Baseline	Year 1	Year 2	Year 3	Perform. Goal	Units
Normalizing Factor	1.0	1.1707
Total Non Hazardous Waste	8,654.45	8,445.64			n/a	Tons Specify other:
Basis for your Normalizing Factor:	Pounds of good product produced facility wide annually

C.1.d	Please list any other EPA voluntary programs to which you are reporting these data.
	Clean Texas Program

3M Brownwood's second commitment is to reduce the facility's VOC emissions.
C.2.a	Briefly describe your activities and achievements related to this commitment or, if relevant, any circumstances that delayed progress this year.
	Reduction of VOC emissions by in the facility by improved capture of fugitive emissions in production areas, reformulations, product migration, pollution control optimization, etc. An error was corrected in Commitment #2 (Emissions of VOC's) for the baseline year VOC emissions due to an accounting error. Significant reductions took place in 2004 down to 365,000 pounds, even though the production increased significantly (by 17%). The goal year estimate also required a correction from 299,000 pounds to 328,100 pounds, due to the change in the baseline emissions. However, the original goal estimate was based on a reduction of 10%, but 3M now believes that a more ambitious estimate of 15% can be realized down to 328,100 pounds.
C.2.b	Please report your facility's actual performance.

C.2.d	Please list any other EPA voluntary programs to which you are reporting these data.
	Clean Texas program

3M Brownwood's third commitment is to reduce the facility's hazardous materials use.
C.3.a	Briefly describe your activities and achievements related to this commitment or, if relevant, any circumstances that delayed progress this year.
	Reduce hazardous material usage by implementing a mixing vessel cleaning system on 5 units that will allow the plant to use considerably less solvent for cleaning. This commitment is based on the installation of a number of new cleaning systems that will reduce the amount of cleaning solutions that are used on our major mixing vessels. Most of the cleaning systems had not been installed so the improvements have not yet been realized. The plant should begin to start seeing improvements in Year 2.
C.3.b	Please report your facility's actual performance.

C.3.d	Please list any other EPA voluntary programs to which you are reporting these data.
	Clean Texas Program

3M Brownwood's fourth commitment is to reduce the facility's generation of hazardous waste.
C.4.a	Briefly describe your activities and achievements related to this commitment or, if relevant, any circumstances that delayed progress this year.
	Reduce hazardous waste generation in the plant by reformulations, product migration, cleanup methodologies, etc..
C.4.b	Please report your facility's actual performance.

C.4.d	Please list any other EPA voluntary programs to which you are reporting these data.
	Clean Texas Program

D.1	Please briefly describe the activities that your facility conducted during the year to interact with the community on environmental issues and to report publicly on environmental performance.
	3M Brownwood Citizen's Advisory Committee was held on December 14, 2004. The plants' environmental performance was communicated to the group and the meeting allowed the advisory committee to provide feedback to 3M. In addition, several newspaper articles were printed in the newspaper that provided the public with information on 3M Brownwood environmental activities.
D.2	Please indicate which of the following methods your facility plans to use to make its Performance Track Annual Performance Report available to the public. Please check all that apply.
	Community Advisory Panel
	Attachments (if applicable):