SIFCO Forge Group, Inc. - Executive Summary

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Accidental Release Prevention and Emergency Response Policies 
 
SIFCO Forge Group is committed to chemical safety. Each process is reviewed prior to any process changes. Safety concerns arising during the process review are evaluated and mitigated by either implementing engineering controls or safety checks in operating procedures. Employees are trained in safe operating procedures and in emergency response. The facility is committed to safety from senior management to line operators. 
 
Facility and Regulated Substances 
 
SIFCO Forge Group's primary business is iron, steel, and non-ferrous forging. The facility had a one time storage of hydrofluoric acid of 1019 pounds, triggering the RMP plan requirements. The facility has changes internal management controls and will no longer accept hydrofluoric acid in concentrations greater than or equal to 50 %. Therefore, the facility is no longer subject to the standard. 
 
Worst Case Scenario 
 
The worst case scenario would result from a spill of th 
ree drums of 70% hydrofluoric acid at the loading dock. This scenario is no longer likely since the facility will not stores hydrofluoric acid above regulated thresholds.  
 
The distance to toxic endpoint for the worst case scenario is 0.3 miles. The residential population in this radius is estimated to be 2,800 persons. 
 
Alternative Scenario 
 
The alternative scenario would result if a hole was punched in the bottom of one drum by activity such as collision with a fork lift. 
 
The rate of release to the atmosphere for the alternative scenario is 3.1lb./min compared to 6.1 lb./minute for the worst case scenario. The distance to the toxic endpoint is 0.2 miles for the alternative scenario. The residential population in this radius is estimated to be 1,300 persons. 
 
Release Prevention and Emergency Response Program 
 
The facility complies with the spill prevention and emergency response provisions contained in the following regulations: 40 CFR 262.34, 40 CFR 265 subparts C and D, 29 CFR 1910 
.38, and 29 CFR 1910.120 The facility has integrated the emergency response elements of these regulations into its Safety Plan and Procedures.  
 
The emergency response plan included in the safety plan details the actions to be taken in the event of an emergency occurring at the SIFCO Forge Group Cleveland, Ohio facility. The emergency procedures within this plan must be carried out whenever there is an emergency situation such as fire, explosion, or release of regulated substances. The plan is coordinated with the local fire department. 
 
The facility complies with the training requirements of Federal regulation 29 CFR 1910.120. Employees involved in emergency response activities receive training commensurate with the level of response.   
 
All employees will receive at least awareness level training to understand the response activity limitations imposed on them by this regulation.  A HAZMAT Team is  being organized and trained to perform offensive spill response activities.  
 
The safet 
y plan details the procedures for notification of off-site emergency response officials including the LEPC and the fire department in the event that a hazardous material is released to the environment or the community. 
 
Five Year Accident History 
 
There have been no accidents in the last five years that have resulted in an off-site impact.
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