Wyman-Gordon Titanium Castings - Executive Summary |
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Executive Summary Wyman-Gordon Titanium Castings Albany, OR 1. Accidental Release Prevention and Emergency Response Policies The primary function of Wyman-Gordon Titanium Castings is to produce specialized titanium castings for the aerospace industry using the investment (or lost wax) casting process. As part of the manufacturing process, hydrogen fluoride (HF) is used as an ingredient in a chemical milling process. By virtue of the toxic effects associated with HF, it is necessary to observe certain safety precautions in handling the chemical to prevent unnecessary human exposure, to reduce the threat to employees of Wyman-Gordon, and to reduce the threat to nearby members of the community. Wyman-Gordon is strongly committed to employee, public and environmental safety. Safety at the facility depends upon the manner in which HF is handled as well as on the various safety devices incorporated into equipment design. Furthermore, comprehensive training received by Wyman-Gordon em ployees adds to the inherent safety of HF storage and use at the facility. 2. The Stationary Source and the Regulated Substances Handled HF is the only chemical used or stored at Wyman-Gordon that is technically subject to the 40 CFR Part 68 Chemical Accident Prevention Provisions because it is stored above the threshold amount and concentration. Nitric acid, hydrochloric acid and anhydrous ammonia are also used at the facility, but are not subject to the Chemical Accident Prevention Provisions because less than threshold quantities and/or less than threshold concentrations of each chemical are used/stored on site. Although the Risk Management Plan (RMP) submitted for this facility only specifically addresses HF, Wyman-Gordon has elected to develop a risk management program under the General Duty provisions that does address nitric acid, hydrochloric acid and anhydrous ammonia. As part of that program, worst-case and alternative release scenarios have been evaluated and prevention program documentation is maintained on site. HF (70% solution) raw material containers (55-gallon drums) are received at the facility's shipping and receiving area on pallets, containing four (4) drums that are banded together. The pallets are placed on top of 4 ft. x 4 ft. spill containment pallets and are transported in this manner by fork lifts to the Hazmat-type storage container. When makeup to the Chem Mill tanks is required, the HF containers are transported from the Hazmat container to the Chem Mill via forklifts. The four containers remain banded together and on top of the spill pallet throughout their transport through the facility. Four containers are pumped at a time into the Chem Mill tanks. Access to this site is restricted to authorized facility employees, authorized management personnel and authorized contractors. The maximum amount of HF that can be stored at this plant is approximately 8,100 pounds, based on inventory records and the capacity of the storage a reas. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s) The worst-case scenario involves the release of one (1) 55-gallon container of 70% hydrofluoric acid onto the ground, outside, with no containment. This scenario assumes that a drum is knocked off its containment pan/transport pallet, that the container fails, and that the entire contents of the container (577 pounds) forms a 1 centimeter deep pool that evaporates at 770F. The estimated distance to toxic endpoint, determined using the procedures in EPA's Offsite Consequence Analysis Guidance, is 0.6 miles. According to Landview III (U.S. Department of Census 1990 database), approximately 4,700 people live within the worst-case impact radius of 0.6 miles. Public receptors identified within the distance to toxic endpoint include residences and commercial, office or industrial areas. No environmental receptors were identified within the distance to endpoint. The alternative case scenario assumes th at one (1) raw material container (55-gallons) is pierced with a fork from a fork truck during transport to the Chem Mill tanks. The entire contents of the container is assumed to be released, but contained in the 4 ft. x 4 ft. spill pan, which is used to transport four (4) HF containers within the plant boundaries. The release rate is determined based on the evaporation of HF from the containment pan at 770F. The estimated distance to toxic endpoint, estimated in accordance with EPA OCA Guidance is 0.1 miles. According to Landview III's census database, there are 130 people living within the alternative case impact radius of 0.1 miles. Public receptors identified within the distance to toxic endpoint include residences and commercial, office or industrial areas. No environmental receptors were identified within the distance to enpoint. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Wyman-Gordon has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. The following sections briefly describe the release prevention program that is in place at Wyman-Gordon. Safety Information Wyman-Gordon maintains a detailed record of written safety information, which describes the chemical hazards, operating parameters and equipment designs associated with all aspects of the HF storage and transfer processes. Hazard Review A checklist methodology is used to carry out hazard reviews at the facility. The reviews focus on operating procedures, equipment functions and handling practices to identify possible hazards. The studies are undertaken by a qualified personnel with extensive knowledge of facility operations and are revalidated at a regular interval of five years. Any findings related to the hazard reviews are addressed in a safe and timely manner. Operating Procedures For the purposes of safely conducting activities within the covered proce ss, Wyman-Gordon maintains 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. The information is regularly reviewed and is readily accessible to operators involved with the processes. Training Wyman-Gordon has a comprehensive training program in place to ensure that employees that are operating processes are completely competent in the operating procedures associated with this process. New employees receive basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently. Refresher training is provided at least every three years and more frequently as needed. Maintenance Wyman-Gordon carries out highly documented maintenance checks on process equipment to ensure proper functioning. Maintenance activities are carried out by qualified personnel with previous training in these practices. Furthermore, personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Compliance Audits Wyman-Gordon conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Historically, there have been no incidents resulting in offsite impacts due to HF releases. However, in the event of a release, Wyman-Gordon has a program in place to promptly investigates any incident that has resulted in, or could reasonably result in, a catastrophic release of HF. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release fro m recurring. All reports will be retained for a minimum of 5 years. 5. Five-year Accident History Wyman-Gordon has had an excellent record of preventing accidental releases since it began operations in 1968. Due to Wyman-Gordon's stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan Wyman-Gordon's response to an accidental release involving HF is to immediately contact the Albany Fire Department. Other than responding to a minor HF leak that can be addressed by on-site personnel, all major leaks will only be handled by outside emergency responders. Because Wyman-Gordon will not be responding to such releases, a written emergency response plan for HF is not required under EPA's Accident Prevention Provisions. The Local Emergency Planning Committee (LEPC) is located at the Oregon Office of Emergency Management, 595 Cottage Street Northeast, Salem, OR 97310. Wyman-Gordon's emergency response procedure has been co ordinated and verified with the Chairperson of the LEPC. 7. Planned Changes to Improve Safety Any recommendations coming from development of the Risk Management Plan have been implemented as of the date indicated below. |