MPM TECHNOLOGY RESOURCES - Executive Summary |
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MPM Technology Resources is committed to providing a safe workplace for its employees and a safe environment for the community surrounding its facility. As such, we plan to continue and reinforce the policies and procedures implemented by the previous owners of the facility. MPMs main goal is to train employees and implement programs to prevent all accidental spills and to provide employees with adequate training for quick emergency response in the event of a natural disaster which may increase the amount of hydrofluoric acid vapors dispersed in the air. MPM is a producer of titanium castings and ingot. A process within our manufacturing operations involves the chemical etching of titanium metal. Hydrofluoric acid is an ingredient of the chemical etching solution. The maximum concentration of hydrofluoric acid in the solution is 6%, but normally runs at 4%. The total quantity in all tanks in the process is 1,000 lbs, with the largest individual tank holding approximately 325 lbs. In addition, we have an inventory of up to three 55-gallon drums of 70% hydrofluoric acid. In order to reduce potential for harm to our employees and the community, all employees working in the area are thoroughly trained in acid handling. A specially designed storage area for the 55-gallon drums, which includes secondary containment, provides additional safety for the community. The tanks used for the etching solution are specially designed and manufactured for this process. The entire system for this process is built within a secondary containment area and is covered by a roof. Equipment is inspected weekly for signs of corrosion and leaks. Written procedures for the area are reviewed, and updated as necessary, on a annual basis or whenever a change to the process occurs. There have been no accidental releases of hydrofluoric acid since MPM purchased the facility in February, 1999. The records from the previous owners indicate that no release has occurred within the last fi ve years. In fact, there is no record in the files of there ever being an accidental release at this facility. On doing an analysis of several possible scenarios for the accidental release of hydrofluoric acid, the one event that appears to present the most hazard to the community would be the spilling of an entire 55-gallon drum of 70% hydrofluoric acid in the open on a concrete slab. The off-site impact would extend up to .3 of a mile and includes no residential areas. Several businesses, including employees at the SPADRA landfill, would also be affected by such a release. Since human error would be the most likely cause for this type of accidental release, MPM is committed to ensuring that each employee that is involved in moving the acid is thoroughly trained and is provided with proper equipment. Forklift training is an integral part of this process. As an alternative accidental release scenario, we concluded that cracking of the largest chem mill tank would present th e next largest hazard to the community and would be more likely to occur than the drum spillage. The off-site impact would extend up to .2 of a mile and include no residential areas. Several businesses, including employees at the SPADRA landfill, would also be affected by such a release. A spill from the largest tank would be completely contained in the pit within the secondary containment area. There is enough room in the containment area to increase the water percentage and thus decrease the hydrofluoric acid concentration of the spill. In addition, MPM has a system for neutralizing spent acid. The acid from any accidental spill in this area can be pumped to the neutralization storage tank or directly to the neutralization tank, reducing the possibility of harm to the community. To minimize hazards to the community, MPM has established an emergency response program based on the previous facility owners plan. This plan includes responsibilities and procedures to handle the spill, location of medical facilities in the event of injury, and governmental agency notification requirements. MPM is committed to improving safety and reducing risks to its employees and to the community. MPM plans to continue training programs, including refresher courses, preventive maintenance, weekly inspections, and process audits in an on-going effort to provide a safe workplace within the community. |