US Army National Training Center and Fort Irwin - Executive Summary |
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EXECUTIVE SUMMARY RISK MANAGEMENT PROGRAM DOCUMENTATION FOR U.S. ARMY NATIONAL TRAINING CENTER AND FORT IRWIN 1. BACKGROUND. Section 112 (r) of the Clean Air Act Amendments of 1990 (CAAA-90) is entitled "Accidental Release Prevention." This Section, commonly referred to as the "Risk Management Plan" or RMP, is designed to both prevent and prepare for releases of chemicals or flammable substances that would have an impact on the surrounding public. The California Accidental Release Prevention Program (CalARP) is a merging of the Federal Section 112(r) and State program for the prevention of accidental release of regulated toxic and flammable substances. The Bhopal, India release of methyl isocyanate is an example of such a catastrophic event. Under the regulations, certain facilities are required to submit a RMP that summarizes their Risk Management Program to the U.S. Environmental Protection Agency (USEPA) and appropriate California Administering Agency (AA) or Certified Unifi ed Program Agency (CUPA). Army installations which store/use toxic chemical and flammable substances in quantities meeting the rules' thresholds, are required to develop a Risk Management Program and submit a RMP to the USEPA and AA or CUPA on or before 20 June 1999. Toxic chemicals such as chlorine, sulfur dioxide, ammonia, hydrochloric acid and nitric acid are expected to exist in reportable quantities at Army installations. Flammable substances such as butane or propane are also found in reportable quantities at many installations. Because of the similarities in the California and Federal programs, references to the Section 112 (r) in this report will also refer to the CalARP requirements unless otherwise noted. 2. PURPOSE. This document meets the initial planning requirements for the U.S. Army National Training Center and Fort Irwin to develop a Risk Management Program as required by the CAAA-90. It describes elements of the program, assigns responsibilities and tasks for im plementation, and clearly communicates Fort Irwin's commitment to its workers and surrounding community that the risk of catastrophic release of chlorine, propane, and ammonia is present. 3. CONCLUSIONS. a. The quantity of chlorine stored at the wastewater treatment plant (WWTP) and booster stations, and the quantity of propane stored at the propane tank farms will require the National Training Center and Fort Irwin to develop a Risk Management Program as required by the CAAA-90. The amount of ammonia at the Cold Storage Facility will require the National Training Center and Fort Irwin to develop a Risk Management Program as required by the CalARP. These are the only chemicals on the installation which exceed threshold quantities and trigger the requirements of the applicable risk management regulations. b. A worst-case release analysis has been performed using USEPA required parameters. Results of this analysis indicate that the area of concern, or footprint, from a worst-case release of chlorine from the WWTP would impact approximately 8,000 people in a circle 3.0 miles in radius. A worst-case release of chlorine from the Bicycle Lake and Langford Lake Booster Stations would not impact any populated areas or have a direct impact on the residential population in the circles 0.8 miles in radius. The area of concern, or footprint, from a worst-case release of propane from the Goldstone Propane Tank Farm would impact approximately 5,500 people in a circle 0.75 miles in radius. Propane from the Langford Lake Propane Tank Farm would not impact any residential areas in its circle of 0.69 miles in radius. The area of concern for the Langford Lake Propane Tank Farm would impact several public receptors. The area of concern, or footprint, from a worst-case release of ammonia from the Cold Storage Facility (Bldg 882) would not impact any residential areas in its circle of 0.61 miles in radius. The area of concern for the Cold Storage Facility would impact sever al public receptors. These circles include the Fort Irwin cantonement area and portions of the surrounding open desert training areas. c. The Risk Management Program at Fort Irwin is designed to help insure that catastrophic release of chlorine gas, propane, and ammonia will not occur. This is done via the development and implementation of a comprehensive program to manage chemical process risk. Key participants in this program include Fort Irwin Command Council, Directorate of Public Works Environmental Division (DPWE), Safety, Preventive Medicine (Industrial Hygiene)[PM(IH)], G-3, Staff Judge Advocate (SJA), Facility Maintenance Division (FMD), Fire Department, Public Affairs Office (PAO), and the Provost Marshall. d. The USEPA endorses the philosophy that Risk Management Planning is never complete and always subject to review. With the Process Hazard Analysis (PHA), the U.S. Army Center for Health Promotion and Preventive Medicine (USACHPPM) study has generated suggestions f or Fort Irwin with regard to the chlorine wastewater disinfection process, drinking water disinfection process, propane storage, and ammonia refrigeration process. Implementing these suggestions will require prioritization and consideration of human, fiscal, and experiential resources available. The RMP subcommittee to the Environmental Quality Control Committee (EQCC) is charged with making these decisions. Additionally, the Fort Irwin personnel on the RMP subcommittee represent a vast array of experience and routinely implement improvement measures. e. The DPWE has taken a positive approach to reducing or eliminating the chlorine at the Wastewater Treatment Plant and the two booster stations. In the fall of 1999, these facilities are scheduled to convert the disinfection process to sodium hypochloride (Clorox, 15% solution). |