Wyman Gordon Titanium Castings, LLC - Executive Summary

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Wyman Gordon Titanium Castings, LLC (WGTC) is an investment casting operation located in Franklin, New Hampshire.  The facility casts titanium (and other metals) into parts used in the aeronautical, automotive and recreational industries.  Components cast at this facility are primarily used in jet aircraft engines. 
 
Due to the nature of titanium, the metal castings require specialized cleaning and degreasing processes prior to treating or finishing the pieces.  To accomplish this task, WGTC has worked with a consulting process engineering firm to develop a acid etching process, known as the Chem Mill Line.  The primary components of this cleaning process are acid baths of varying types and strengths.  One of the acids used in this process is hydrofluoric acid.  WGTC stores and utilizes three, 55 gallon drums of hydrofluoric acid at the Franklin facility.  It is the presence of this material that brings WGTC into the regulated community under the Clean Air Act Amendments and the Risk Ma 
nagement Program.  The Risk Management Program is described at 40 CFR part 68. 
 
Hydrofluoric acid is a toxic material.  The toxic characteristics of hydrofluoric acid can impact people through inhalation, ingestion or via dermal contact.  The presence of this material at WGTC does not equate to an extreme risk to the area.  The worst case scenario developed under this Risk Management Plan, using software developed by the United States Environmental Protection Agency indicates that based on a release of hydrofluoric acid, the distance to the "endpoint" or impact area is 0.4 miles, or approximately 2,100 feet.  Obviously, if a release were to occur at WGTC, it is imperative that the release be contained within the operating area of the chem mill line - a completely contained enclosure within the WGTC facility.  This area, and the remainder of the facility would require evacuation until such time as the release can be controlled and mitigated.  Should the release migrate to the exterior o 
f the facility, it may require movement of some personnel downwind of the facility.  Close coordination between the WGTC staff and the Franklin Fire Department would be required if any release were to occur. 
 
The Risk Management Program (RMP) requires that this executive summary addresses certain items.  This summary follows that format. 
 
The accidental release prevention and emergency response policies of your facility: the WGTC chem mill line, and hydrofluoric transport and containment systems have been designed utilizing up to date technologies.  This line went into service within the last six months.  The chem mill line area is under negative pressure, with air from the room treated through a scrubber system to neutralize acids in the room air or mists. 
 
WGTC has a proactive release prevention and emergency response program in place at the facility.  This program was developed by WGTC's parent company, and has been coordinated with the Franklin Fire Department.  The Franklin Fire D 
epartment is the local emergency planning committee (LEPC).  The Risk Management Plan that follows this summary goes into detail as to how WGTC shall operate in the event of a release of any hazardous material or waste, including hydrofluoric acid. 
 
Your facility and the regulated substances handled: as stated in the introductory paragraphs of this summary, WGTC handles and stores up to three, 55 gallon drums of hydrofluoric acid at any one time.  The hydrofluoric acid is used in the preparation and cleaning of titanium castings prior to plating or finishing the pieces.  The chem mill process is all contained within a specific area of the WGTC facility.  This area is maintained behind two sets of closed doors between the chem mill area and the remainder of the facility.  This segregates the chem mill line and other facility operations.  In addition to the hydrofluoric acid, nitric acid and hydrochloric acid are also used in the chem mill line.  All of the acids are diluted with large q 
uantities of water prior to immersing pieces in the acid baths, thus reducing the potentially harmful affects of the acids. 
 
The worst case release scenario and the alternative release scenario: The worst case release scenario is based on the release of 55 gallons of hydrofluoric acid over a ten minute period.  The release under this scenario requires that the acid be released into the atmosphere at the facility.  Wind is present, and moves a vapor cloud from the facility toward a populated area.  As stated above, the endpoint for this release is only 0.4 miles, and thus affects a small area.  The majority of the affected area is potentially to the adjacent businesses in the industrial park. 
 
The general accidental release prevention program and chemical-specific prevention steps: Due to the nature of operations at the WGTC facility, WGTC is subject to the Process Safety Management (PSM) requirements under the Occupational Safety and Health Administration (OSHA).  This document contain 
s the PSM requirements for the chem mill line and the facility.  The PSM also outlines what measures shall be taken should a release of any regulated material should occur at the WGTC facility.  Under the PSM, WGTC staff receive additional training in the handling of raw materials; how to identify potential hazards associated with the process; regular equipment inspections; release detection and monitoring; and, emergency response.  The PSM also describes how WGTC staff will react in an emergency situation, and how they will interact with the Franklin Fire Department, New Hampshire Department of Environmental Services, the United States Environmental Protection Agency, National Response Center, and emergency cleanup contractors. 
 
To aid in the specific identification of a release of hydrofluoric acid, the chem mill line is situated over a containment area.  The drums of raw product are also stored within a separate containment enclosure.  The chem mill area and the containment system a 
re monitored for releases of product. 
 
The five year accident history: During the preceding five years, there has not been a reportable quantity release of regulated materials at the WGTC facility. 
 
The emergency response program: As described above, a clearly defined emergency response program has been developed as part of the OSHA PSM program.  This is defined within this document, and also within WGTC's Hazardous Waste Contingency Plan.  This program calls for the training of staff for response to releases, and how to manage a release scenario and emergency response including evacuation measures, coordination with Franklin Fire Department and protecting the public. 
 
Planned changes to improve safety: WGTC is proud of their safety and environmental record.  With the advent of this Risk Management Plan and Program, WGTC is planning to continue training programs under the PSM and hazardous waste contingency program.  WGTC will continue coordinating training and response programs with t 
he Franklin Fire Department.
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