Johnson Space Center White Sands Test Facility - Executive Summary
EXECUTIVE SUMMARY |
Submission Type: First-Time Risk Management Program (RMP) Submission
Facility Name: NASA Johnson Space Center White Sands Test Facility
The NASA White Sands Test Facility (WSTF) is subject to Program 3 requirements of CFR Title 40, Part 68, Chemical Accident Prevention Provisions. Four process areas at the facility contain regulated toxic substances above the threshold quantity listed in Table 1 to Sec. 68.130. Worst-case and alternative toxic release scenarios have been modeled for the four processes using TRACE( (Toxic Release Analysis of Chemical Emissions) chemical release modeling software, a commercially available product from DuPont SAFER Systems, Inc.
It was determined that none of the worst-case or alternative toxic release scenario endpoints threatened off-site public or environmental receptors. All scenarios were modeled using Subpart B input requirements. There are no regulated flammable substances above threshold quantities at WS
2.0 WSTF DESCRIPTION AND BACKGROUND
WSTF was established in 1962 to support certification of Apollo spacecraft propulsion and power systems and association subsystems for the Manned Space Center, now the Lyndon B. Johnson Space Center (JSC). WSTF remains a facility operated under the direction of JSC. The mission of WSTF is to provide the expertise and infrastructure to test and evaluate spacecraft materials, components, and propulsion systems to enable the safe human exploration and utilization of space. Although a majority of the work of WSTF is in direct support of JSC programs, we also perform work for other NASA Centers, other Government entities, commercial customers, and foreign governments.
The facility is located 20 miles northeast of Las Cruces, New Mexico, and 65 miles north of El Paso, Texas. This site was chosen for its isolated location and topography, which minimize the inherent hazards of aerospace propulsion testing to the general population. Meteorological
and geographical conditions were emphasized in determining the location of the site as well as the anticipated hazards associated with each process. The direction of prevailing winds, which flow in a northeasterly direction away from WSTF and population centers and over the San Andres Mountains, offer ideal conditions to protect employees and the public. In the three decades that WSTF has been in operation, the city of Las Cruces and the surrounding areas have grown, but WSTF remains well away from large population bases.
A security force that is on duty on a 24-hour, 365-day per year basis controls access to the WSTF site. Security guards control access to the industrial complex and also patrol the site boundaries.
3.0 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES
The White Sands Test Facility is committed to providing a safe place of employment by meeting or exceeding applicable health and safety requirements to assure personnel, community, and environmental sa
fety and preservation of resources. The WSTF Safety Management System is based on the concept that safety is the individual and personal responsibility of everyone at WSTF. Imbedded within the management system are procedures for control of processes containing hazardous substances during the design, buildup, and test phases of programs, and emergency protocols to be followed in the event of an accidental release of a hazardous substance. The management system assures that WSTF is compliant with applicable State, Federal, and NASA regulations.
The primary accidental release prevention measures are provided in the Process Safety Management (PSM) program. The PSM instruction, written in compliance to 29 CFR (OSHA) 1910.119, Process Safety Management of Highly Hazardous Chemicals, outlines the steps necessary to design, build, verify, and perform testing operations using highly hazardous chemicals as defined by the standard. Included in the PSM program are provisions for training o
f personnel, employee participation, design control, written operating procedures, mechanical integrity and compliance to ASME codes, management of change, process hazards analyses, accident investigations, and periodic compliance audits.
The WSTF Emergency Preparedness Plan (EPP) is designed to manage activities to eliminate or reduce the probability of disaster, to prepare for measures to be taken which will preserve life and minimize damage to the facility and the environment, to respond appropriately during emergencies, and to establish a recovery system in order to return the facility to normal or improved operation following an emergency. WSTF has chartered an EPP Board, whose principle responsibility is the continuous review and update of the plan, assuring its effective maintenance.
WSTF recognizes the need for public awareness where hazardous chemicals are concerned. Representatives from the site participate in the Dona Ana County Local Emergency Planning Committee (LEPC
). Representatives from the WSTF site brief the committee on what chemicals are located on site, what processes they are involved in, and what safety precautions are taken to ensure the safety of employees as well as the public. The representatives report mishaps and releases in the LEPC annual report, if any occur.
4.0 WSTF FACILITIES REGULATED SUBSTANCES
Several hazardous chemicals are essential in testing propulsion systems at WSTF. The EPA regulates two of these chemicals that WSTF possesses in an amount over the regulated threshold, the rocket propulsion fuels hydrazine and monomethyl hydrazine (MMH). These fuels are used in several Space Shuttle and Space Station propulsion subsystems. Hydrazine and MMH are stored in regulated quantities in four test areas within the site.
* The 300 Area Hydrazine System - 2,000 gallons of hydrazine
* The 300 Area MMH System - 3,197 gallons contained in the ready storage units (RSU's) and 3,585 gallons contained in dump tanks
* The 400
Area MMH System - 5,200 gallons contained in the RSU's and 1,800 gallons contained in dump tanks
* 500 Area Propellant Storage - Up to 100 55-gallon drums of MMH, approximately 5,000 gallons total
The rocket propulsion oxidizer nitrogen tetroxide is also contained on site, and although it is not a currently regulated chemical in CFR Title 40, Part 68, it is included in WSTF PSM program. WSTF has modeled worst-case oxidizer plume dispersion in a manner consistent with the EPA-regulated chemicals. No off-site consequences were evident in the plume models. The precautions used in handling the oxidizer nitrogen tetroxide are similar to the regulated fuels hydrazine and MMH.
5.0 WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS
Toxic plume dispersion models for WSTF's four identified regulated processes were modeled using the software program TRACE(. For the worst-case scenarios, EPA-mandated atmospheric conditions were used. For the alternative release scenarios, representative atmosphe
ric conditions were obtained from the Environment section of the WSTF Facilities Master Plan.
The alternative release endpoints did not cross WSTF boundaries. The endpoint for the worst-case scenario, however, extended beyond the WSTF site boundary and encroached onto three off-site areas: (1) Bureau of Land Management (BLM) land, (2) WSTF-BLM Joint-Use Agreement land, and (3) White Sands Missile Range (WSMR) - Department of Agriculture Jornada Experimental Range land. The three areas encroached are not considered public or environmental receptors.
The BLM land is not intended for public, residential, commercial, or recreational uses and is not considered a public or environmental receptor. The WSTF-BLM Joint-Use Agreement land is specifically designated as a buffer zone to keep the public isolated from the WSTF site. A WSTF-BLM joint use Memorandum-of-Understanding (MOU) governs this area. The MOU states that the BLM management objective is for land uses to continue at their p
resent low level of intensity. BLM will consult with NASA prior to any disposition or land use authorization, and no construction will be authorized other than range improvements connected with livestock operations. Access will be limited to existing roads and trails. The joint-use land is not considered a public or environmental receptor. The WSMR - Department of Agriculture Jornada Experimental Range land is not intended for public, residential, commercial, or recreational uses and is also not considered a public or environmental receptor.
Administrative controls and mitigation measures used for the worst-case (Section 5.1) and process piping failure alternative release scenarios (Sections 5.2.2 and 5.2.3) to prevent and minimize the effects of a release are listed below. The administrative controls and mitigation measures for the shipping container mishandling alternative scenario are listed within Section 5.2.1.
* Administrative controls include preparation of a Process Ha
zard Analysis for each system, training of employees, and step-by-step work instructions. Included in the training are protocols for reporting and responding to emergency situations.
* Portable chemical detection monitors are used when technicians are working in proximity to hydrazine or MMH systems. If the operation involves breaking into a system that may contain hydrazine or MMH vapors/liquid, then airline fed, totally encapsulating chemical protective ensembles are used. In the event of an emergency situation, self-contained Level "A" chemical protective ensembles are available for use.
* Mechanical and electrical controls include vent systems, relief valves, manual shut-off valves, rupture discs, grounding equipment, check valves, and interlocks.
* Tanks are situated on concrete and are surrounded by concrete barriers. In the event of a propellant release at the tanks, the material would remain in the secondary containment barrier rather than drain to grade. The tanks are als
o protected by a remote-activated FIREX water deluge system.
* Testing activities in the 300 and 400 Areas are controlled from hardened blockhouses that protect employees from potential explosions or toxic releases. The blockhouses are designated as a safe haven for toxic releases. The blockhouse monitors are stationed at the safety console during propellant operations so that activation of safety systems such as intercoms, sirens, and FIREX systems can be accomplished quickly. The monitor can readily communicate with WSTF Fire Department personnel in the event of an accident during testing operations.
5.1 WORST-CASE SCENARIO
All four EPA-regulated processes were modeled to determine the one that had the greatest risk of exposure to public or environmental receptors. It was found that the 400 Area MMH System posed the greatest risk of the four regulated processes and is the process that will be reported. The meteorological conditions used were those specified by EPA regulations.
The ambient and in-vessel fluid temperature used was 112 oF; humidity was set at 50 percent with a wind speed of 1.5 m/s, and an atmospheric stability class of "F" (very stable). The release was an instantaneous release at ground level onto a 900-square-foot concrete diked area.
Administrative controls and mitigation measures used for the 400 Area MMH processes to prevent and minimize the effects of a release are listed in Section 5.0.
5.2 ALTERNATIVE RELEASE SCENARIOS
In determining the most probable alternative release scenarios, WSTF propulsion personnel were consulted. Three major types of credible releases were consistently given: (1) a transportation handling accident, (2) process piping failure during circulation of propellant at one of the Ready Storage Units (RSU's), and (3) process piping failure during transfer of propellant from an RSU to one of the Test Stand Auxiliary Conditioning Units (ACU's).
Upon consideration of the credible releases, a shipping container m
ishandling scenario was selected for the 500 Area Propellant Storage area. A process piping release scenario during transfer of propellant from an RSU to an ACU was selected for the 300 and 400 Area MMH systems and the 300 Area Hydrazine system.
The meteorological conditions for all the alternative releases were the same. Each scenario was modeled as a liquid stream released continuously at 70 oF at ground level into a concrete substrate with a pool area of 900 square feet. The wind speed was chosen to be 15 mph, an ambient temperature of 75 oF, a stability class of "C" (slightly unstable), and a humidity of 30 percent. These conditions were selected as representative based on data from the WSTF Facility Master Plan, Section 5, Environment.
5.2.1 500 Area Propellant Storage - Shipping Container Mishandling Scenario
The scenario chosen involves a 55-gallon drum of MMH being transported from the 500 Area Propellant Storage to the 300 or 400 Area MMH Systems. A traffic accident c
auses the drum to be physically dropped off the transport vehicle, resulting in a release of the entire contents. Since a continuous model was used, the inputs used were a release rate of 25 pounds per minute and time duration of 15 minutes.
Administrative controls and mitigation measures used during propellant transport to prevent and minimize the effects of a release include the following:
* Administrative controls include preparation of a Process Hazard Analysis, training of employees, and step-by-step work instructions. Included in the training are protocols for reporting and responding to emergency situations.
* Portable chemical detection monitors are available during transport operations.
* Mechanical and electrical controls include grounding equipment.
* WSTF Fire Department personnel are alerted before transport operations begin and are on standby for emergency intervention.
5.2.2 Transfer of MMH from the 300 or 400 Area RSU to Test Stand ACU - Process Piping Failure Scena
The following alternative scenario was used for the 300 and 400 Area MMH Systems. During a transfer operation from the fuel RSU to a Test Stand ACU, mechanical failure of a section of line downstream of the RSU and upstream of the ACU occurs. The approximate flow rate for this operation is 50-60 gallons per minute. The response by the technicians performing this manual operation was estimated to be within 30 seconds, but a conservative value of a 1-minute response was selected. In this case, 50-60 gallons may be released plus the quantity of propellant in the
2-inch-diameter line. Given a 50-foot section of line, the quantity released would be an additional 10 gallons (rounded up from 8.16 gallons), resulting in a total release of 60-70 gallons of MMH. Since a continuous release toxic model was selected, the inputs used were the release rate at 400 pounds per minute and time duration of 1 minute.
Administrative controls and mitigation measures used for the 300 and 400 Area
MMH processes to prevent and minimize the effects of a release are listed in Section 5.0.
5.2.3 Transfer of Hydrazine from the 300 Hydrazine Conditioning Unit (HCU) to Test Stand 303 - Process Piping Failure Scenario
The following scenario was used for the 300 Area Hydrazine System: During a transfer operation from the 300 HCU to Test Stand 303, mechanical failure of a section of line occurs. Most likely the leak would be detected and the main shutoff valve turned off within 30 seconds. Given a 25-foot section of 2-inch line, an additional 4.1 gallons of hydrazine would be drained, resulting in a total release of approximately 10 gallons. Since a continuous toxic release model was selected, the inputs used were the release rate at 100 pounds per minute and time duration of 1 minute (30 seconds rounded to the nearest minute).
Administrative controls and mitigation measures used for the 300 Area Hydrazine Conditioning Unit and Test Stand 303 processes to prevent and minimize effect
s of a release are listed in Section 5.0.
6.0 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS
WSTF Policy Directive 25-01, Safety Management System, provides the framework for the accidental release prevention program. Two lower level documents, WSTF Standard Procedure (WSP) 25-0001, Safety Planning, and WSTF Standard Instruction (WSI) 25-SW-0005, Process Safety Management of Highly Hazardous Chemicals, are the primary documents to ensure prevention of accidental releases. The lower-level documents, in turn, reference relevant portions of the WSTF Quality System, including Design Control, Process Control, and Training.
In general, the accidental release prevention program in WSP 25-0001 and WSI 25-SW-0005 can be summarized as follows:
* Training of employees, from new hire status through in-depth system training, is accomplished and tracked within the WSTF Training Database.
* System safety is accomplished in the design stages of programs thro
ugh design review, system safety analyses, operational readiness inspections, and test readiness reviews. Integral to these reviews are the presentation of Failure Modes and Effects Analyses and Process Hazard Analyses. Changes to existing systems or processes require review and approval by appropriate personnel to ensure continued safe operations.
* Process control is accomplished in the buildup and test phases of projects through step-by-step work instructions that are reviewed and authorized by project leaders and project managers. Emergency procedures are imbedded within any instruction involving the use or handling of hazardous chemicals. WSTF pressure systems engineers approve appropriate standards of system construction, such as ASME pressure and piping codes for fluid systems.
Chemical-specific prevention steps for hydrazine and MMH are detailed in several site documents referenced in the Safety Management System. For example, WSI 09-SW-0012, Control of Materials Used i
n Hypergol Systems, details the materials of construction for fluid system piping and specifies the type of valve softgoods that may be used for the hydrazine family of fuels.
WSI 09-SW-0013, Chemical and Particulate Cleanliness For WSTF Fluids, specifies the level of cleanliness that must be obtained and maintained before wetting a system with hydrazine or MMH. In addition, the type of personal protective equipment used when working near hydrazine and MMH is specified in WSI 25-SW-0007, Personal Protective Equipment.
7.0 FIVE-YEAR ACCIDENT HISTORY
There has not been an accidental release at WSTF in the last 5 years that has resulted in death, injury, or significant property damage.
8.0 EMERGENCY RESPONSE PROGRAM
The WSTF Emergency Preparedness Plan is the basis for the emergency response program. The plan establishes the Executive Group, top-level managers who are responsible for consultation of site issues and allocation of resources to contend with an emergency. The plan al
so establishes an Emergency Preparedness Coordinator, who is responsible for direction and control of emergency response elements at WSTF.
The Emergency Services Section, which includes the WSTF Fire Department, provides the resources to deal with an emergency situation with firefighters, auxiliary firefighters, emergency medical technicians, hazardous materials response personnel, security personnel, and medical staff personnel. For hazardous chemical spills, a siren is utilized to warn employees of a chemical release requiring evacuation to a designated safe haven area. WSTF also uses a "ring-down" phone system for notification and communication between test areas and Emergency Services Section. If an emergency situation is progressing towards a neighboring community and has the potential to place them at risk, local authorities will be notified promptly by the NASA Public Affairs Officer or WSTF Fire Chief as directed by the WSTF Emergency Group. All components of the warning
system are tested at least monthly. Mock exercises of the Emergency Response Program are performed annually.
Detailed response to a release of a hazardous substance is as follows:
* The local test area or work site will exercise emergency procedures that identify the responsible person in charge.
* The responsible person in charge will assess the situation. If it is an incidental release, they will perform control and cleanup with appropriately trained personnel equipped with appropriate personal protection equipment (PPE).
* If the incident is beyond the control of local area personnel and resources, then the hazardous materials (HAZMAT) response team will be called.
* A formal turnover of command from the local test area person in charge to the WSTF Incident Commander must take place.
* The local test area person in charge becomes an advisor to the Incident Commander.
HAZMAT response is implemented in three phases:
* Phase I Initial Response: This phase identifies and contains
hazardous substance releases, and includes the following actions to save lives, reduce injuries, and protect the environment: evacuation of nonessential personnel; cordoning off the danger area; performing fire and rescue operations; stopping the release if possible; and preventing the spread of the released material into the environment.
* Phase II Recovery of Released Hazardous Substances: In this phase, cleanup operations and recovery of spilled substance and materials contaminated by the release are performed.
* Phase III Short- and Long-Term Site Restoration (Post-Emergency): In this phase, contaminated soil is removed, the site is restored to permit personnel to resume normal activities, and further contamination of the environment is prevented.
The HAZMAT Emergency Response Team consists of all WSTF Fire Department personnel and selected personnel from the operational areas who are trained to the HAZMAT Technician level.
The WSTF Fire Department is responsible for the traini
ng and equipment of the team and performs Phase I and Phase II operations. Coverage is provided full-time, 24-hours a day. The NASA Environmental Program Manager and the contractor Environmental Department are responsible for the approval and oversight of Phase III operations.
9.0 PLANNED SAFETY IMPROVEMENTS
WSTF continuously works at improving safety on every aspect of the site. While all current safety and emergency systems protect WSTF employees and the community, a number of future improvements and maintenance programs are planned. The two primary initiatives to improve safety at WSTF are: (1) Construction of Facilities (CoF) and (2) Maintenance, Construction, Repair, and Renovation (MCRR). CoF initiatives tend to be large scale, and specific initiatives are planned out over a 6-year period. MCRR initiatives tend to be smaller scale and lower dollar amounts.
9.1 MAINTENANCE, CONSTRUCTION, REPAIR, AND RENOVATION (MCRR) INITIATIVES
Current projects include:
* Repair Came
ra and Upgrade Software for SpillCam Systems. This will aid in the triangulation of a cloud formed by the release of a hazardous chemical and allow the cloud to be tracked accurately.
* Correct Facility-Related Safety Deficiencies. This project includes identification and correction of any safety deficiencies that may be identified during the performance of a detailed walk-around.
* Provide Power for Communications Room. This project provides full-radio and radiotelephone communication capability in the event of a power outage.
* Relocation of Fire Detectors throughout the Laboratories. This project is dedicated to ensure more efficient operation of the fire system detectors throughout the laboratories.
9.2 CONSTRUCTION OF FACILITIES (CoF) PROJECTS
Current projects include:
* Repair of Test Area Grounding in the 300 and 400 Area MMH Systems. This project is needed to ensure that critical facilities are protected against lightning and electrical hazards. It is scheduled for ini
tiation in 2002 and budgeted for $2.0M.
* Rehabilitation of the Emergency Electrical Systems. These systems are located in several areas, including the 400 Area MMH System and the 300 Area substation, and are required to maintain reliable and safe emergency and uninterruptible electrical power sources. It is scheduled for initiation in 2005 and budgeted for $1.8M.
* Revitalization of the 300 and 400 Areas. Architectural, electrical, and mechanical upgrades and repairs are planned for the existing facilities, which will correct any previously identified deficiencies and ensure reliable support to current and future NASA missions without jeopardy to the health and safety of personnel. This project will ensure compliance to OSHA standards. It is scheduled for initiation in 2002 and budgeted for $1.5M per area. Rehabilitation and Modification of the Fire Protection Systems. This project includes removing and replacing any combustible building materials, upgrading and extending the e
xisting fire sprinkler system, providing protection of computer and essential electronic equipment, installing fire walls and doors, providing fire protection for stairs and exits, and extending the fire detection systems. This project will ensure that fire protection systems adhere to NASA Safety Standards and the National Fire Protection Association codes and standards. It is scheduled for initiation in 2002 and budgeted for $0.6M.
* Repair of Personnel Warning and Notification Systems in the 300 and 400 Areas. This project is necessary to ensure that warning systems operate adequately to protect personnel from the hazardous chemicals contained in these areas. Revitalization will enable all employees at remote sites to receive clear warning and instructions regarding hazardous operations. The project is scheduled for initiation in 2006 and budgeted for $1.1M.
* Rehabilitation of Fire Alarm Systems. This project includes the installation of an intelligent and addressable system,
including smart initiating and detecting devices. This represents a significant improvement of existing systems, which currently do not provide a definitive location of an active alarm. A new addressable system will enable faster response to emergencies. It is scheduled for initiation in 2003 and budgeted for $1.5M.
* Modifications to the Uninterruptible Power System. This project includes adding one assembly of batteries to the existing configuration and ensuring proper electrical power service. This will add a level of redundancy to emergency power systems. It is scheduled for initiation in 2005 and budgeted for $1.5M.
There are many additional projects performed and funded on an organizational level that are not detailed here. All of these improvements not only protect personnel but also enable them to respond faster to emergency situations. This, in turn, helps to prevent off-site consequences from occurring that may affect the surrounding communities.