U.S. Marine Corps Base, Camp Lejeune - Executive Summary |
EXECUTIVE SUMMARY Background 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 r 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 EPA. 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 of 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. |