U.S. Marine Corps Base, Camp Lejeune - Executive Summary

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   Marine Corps Base (MCB), Camp Lejeune's accidental release prevention and  
emergency response policies are to maintain safe conditions for base personnel and the  
inhabitants of the surrounding communities.  These policies are to be enforced through  
compliance with applicable regulations, physical safeguards, training, and deployment of  
adequate resources.  MCB, Camp Lejeune gives accidental release prevention and emergency  
response the highest priority. 
   The Clean Air Act (CAA) Amendments of 1990 required the U.S. Environmental  
Protection Agency (EPA) to formulate regulations for managing and reducing the  
probability of the release of highly hazardous chemicals.  On June 20, 1996, EPA  
promulgated the Risk Management Program (RMP) rule (40 CFR 68).  The RMP rules requires  
any stationary source utilizing greater than a specified threshold quantity of a regulated  
substance to develop and submit a Risk Management Plan to regulatory authorities on o 
before June 21, 1999.  Regulated substances include 77 air toxics and 63 flammable gases  
or liquids. 
   MCB, Camp Lejeune, has four processes subject to EPA RMP regulations: 
   * Chlorine storage, handling, and use at the Holcomb Boulevard water treatment  
       plant (WTP) (Bldg. HP-670); 
   * Chlorine storage, handling, and use at the Hadnot Point WTP (Bldg. HP-20) 
   * Chlorine storage, handling, and use at the Marine Corps Air Station (MCAS),  
       New River WTP (Bldg. AS-110); and 
   * Chlorine storage and handling at the open storage area (Lot 201). 
   Chlorine is the only substance at MCB, Camp Lejeune in excess of its threshold  
quantity established in 40 CFR 68.130.  The threshold quantity for chlorine is 2,500  
pounds.  Chlorine is stored in one-ton containers and used in the treatment of drinking  
water at the three WTPs.  Historically, as many as 180, 150-pound cylinders of chlorine  
have been stored (not used) at Lot 201 prior to being transported to Base swimming pools  
for chlorina 
tion.  However, the number of cylinders stored at Lot 201 has decreased  
significantly since MCB, Camp Lejeune recently switched from chlorine to sodium  
hypochlorite for disinfection at all Base pools.  Sodium hypochlorite is not subject to the  
EPA RMP regulations.  Chlorine storage at Lot 201 is planned to be discontinued by  
December 31, 2000.  The Courthouse Bay and Onslow Beach water treatment plants that continue to use  
the 150-pound cylinders will store the material onsite in amounts well below the RMP  
threshold quantity of less than 2,500 pounds. 
Hazard Assessments 
   The modeling methodology used in this study conforms to the RMP Offsite  
Consequence Analyses (OCA) Guidance recommended in the final RMP rule.  The  
release scenarios were modeled using RMP*CompTM, an accidental release dispersion  
modeling package developed by the CAMEO Team at the Hazardous Materials Response  
and Assessment Division, NOAA, and the Chemical Emergency  
Prevention and Preparedness Office (CEPP 
O) of the EPA.  All hazard assessments had  
offsite impacts.   
   The worst-case scenario (WCS) for the three WTPs is a catastrophic release of  
2,000 pounds of chlorine gas.  This scenario assumed a container valve failure releasing  
all of the contents of the one-ton container over a 10-minute period.  No administrative  
controls or passive mitigation measures were taken into account for the release.  The  
distance to the toxic endpoint of 3 parts per million (ppm) was 1.3 miles under worst-case  
atmospheric conditions.  The WCS for Lot 201 modeled the catastrophic failure of one,  
150-pound chlorine cylinder over a 10-minute period.  No administrative controls or  
passive mitigation measures were taken into account for the release.  The distance to the  
toxic endpoint of 3 ppm was 0.4 miles. 
   The alternative release scenario (ARS) for the three WTPs modeled the full  
release of a single, one-ton container due to a hole in the piping from the container.  The  
release was modeled over 2 
0 minutes for each WTP to reflect an offsite impact, as  
specified in the RMP OCA Guidance.  No administrative controls or passive mitigation  
measures were taken into account for the release.  The excess flow valve on the stand-by  
tank was considered active mitigation.  The distance to the toxic endpoint of 3 ppm was  
0.2 miles.  The ARS for Lot 201 entailed the release of 150 pounds of chlorine gas due to  
a hole in the tank.  The release was also modeled over a 20-minute period.  No  
administrative controls, passive mitigation, or active mitigation measures were taken into  
account for the release.  The distance to the toxic endpoint of 3 ppm was 0.1 miles. 
Accidental Release History and Prevention Program 
   No accidental releases resulting in deaths, injuries, or significant property damage  
on-site, or known offsite deaths, injuries, evacuations, sheltering in place, property  
damage, or environmental damage have occurred in the previous five years from the  
covered processes at 
the three WTPs or Lot 201.  Moreover, no accidents have ever  
occurred resulting in this type of damage or human impact.  
   All four chlorine processes are subject to the U.S. Occupational Safety and Health  
Administration's (OSHA's) Process Safety Management (PSM) standard and have offsite  
impacts in the case of accidental release.  Therefore, MCB, Camp Lejeune has developed and  
implemented a RMP compliant with all Program level 3 process requirements established by  
   An emergency Response Plan (ERP) has also been developed and implemented for all  
four chlorine processes.  The purpose of the ERP is to promptly respond to a chlorine  
release to minimize injuries, lessen the impact in the community, minimize environmental  
impacts, and provide guidance to local emergency response personnel.  The ERP contains  
procedures for emergency response after an accidental chlorine release due to equipment  
failure, accident, or bomb threat.  The plan includes procedures for notification 
public and local emergency response agencies, documentation of emergency response  
equipment, emergency response training, and procedures to review the ERP.  An  
Integrated Contingency Plan is being developed for MCB, Camp Lejeune.  This  
"One-Plan" will consolidate all emergency and contingency plans at the Base and will meet  
all the requirements for the ERP in the EPA RMP rule. 
   As part of MCB, Camp Lejeune's RMP, a Process Hazard Analysis  
(PHA) was conducted at all four chlorine processes.  The PHA involved a systematic  
evaluation of the hazards posed by each process and risk reduction recommendations were  
made.  Based on these recommendations, money has been programmed to upgrade the chlorine  
storage facilities with temperature controlled structures, dedicated chlorine alarms, fire  
protections equipment, and improved chlorine storage area access.  This project has an  
expected completion date of December 1, 2000.
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