Vandenberg Air Force Base - Executive Summary
Vandenberg Air Force Base (AFB) is the third largest Air Force installation in the nation encompassing over 98,400 acres in Santa Barbara County, California. Its unique geography provides America with its primary means to launch polar orbiting satellites without overflying populated areas. This mission-which is crucial to national security as well as the burgeoning interest in communications, land resources surveillance, and space research-is dependent on the continued launching of an array of space boosters. Additionally, the Air Force conducts operational testing of Minuteman and Peacekeeper intercontinental ballistic missiles (ICBMs) at Vandenberg AFB; these ICBMs are launched into broad ocean area targets or toward instrumented target sites on the Marshall Islands. Vandenberg AFB also manages the Western Range-a vast network of radar, telemetry, and optical sensors stretching across the Pacific Ocean-in which all three services conduct a variety of aeronautical and missile flig |
While Vandenberg AFB comprises more than 2,000 buildings and 2,075 homes for military personnel, only 15 percent of its total area is developed. The remainder provides the buffer needed to preclude encroachment by local development and to protect outlying communities from launch anomalies and associated operational hazards. Restrictive easements affecting development on adjacent private land further limit potential risk to the public. Significantly, over the last 40 years, more than 1,773 launches of space boosters and ICBMs have been conducted at Vandenberg AFB, and there is no known instance of serious injury or death to anyone in the surrounding communities as a result of a chemical release due to the launches themselves or supporting operations.
With this submittal, Vandenberg AFB is making a conscientious effort to fully comply with Section 112(r) of the Clean Air Act Amendments of 1990 and 40 Code of Federal Regulations (CFR) Part 68 as well as California Code
of Regulations (CCR) Title 19, Division 2, Chapter 4.5, California Accidental Release Prevention (CalARP) Program. The format developed by the Environmental Protection Agency (EPA) for this submittal is generally oriented toward accommodating commercial or government operated stationary sources that differ significantly from Vandenberg AFB in terms of their physical size, complexity, emergency response capability, and organizational make-up. Accordingly, additional detail and clarification are incorporated in this Executive Summary to provide the public clearer, more complete insight into the scope and effectiveness of Vandenberg AFB's accidental release prevention and emergency response policies.
Scope of the Vandenberg AFB Risk Management Plan
This Risk Management Plan (RMP) includes all covered process within the borders of Vandenberg AFB that are subject to Department of the Air Force oversight and control. Under the Commercial Space Act, excess facilities on the base may be
leased by private entities to conduct commercial activities that are not under the purview of the Department of the Air Force. Compliance with EPA RMP and CalARP requirements for covered processes that solely support such commercial activities is the responsibility of the respective commercial owner and operator; such covered processes are not included in this RMP.
This RMP includes 4 processes in which the EPA threshold of a regulated toxic or flammable substance is exceeded. Three of these processes-the Hypergolic Storage Facility (HSF), Space Launch Complex (SLC) 4 East, and SLC-4 West-all involve the regulated toxic liquids 1,1-Dimethylhydrazine (UDMH) and Hydrazine, collectively referred to as hypergolic propellants. The fourth process, at SLC-3 East, involves liquid Hydrogen, a flammable. The worst-case release scenarios for the processes at the HSF, SLC-4 East, and SLC-4 West had off-site consequences and are accordingly designated Program 3 processes. The worst-case releas
e scenario SLC-3 East did not have an offsite consequence and satisfies the criteria for Program 1 processes. Eleven other processes on Vandenberg AFB involve propane in quantities greater than the 10,000 pound RMP threshold for propane, but less than the 67,000 pound threshold for propane below which the EPA has announced a stay for RMP filing requirements. Accordingly, propane storage vessels have not been included in this submittal pending final resolution of propane reporting requirements by the EPA.
Emergency Response Program
Vandenberg AFB possesses significant emergency response capabilities that include its own Fire Department, Disaster Control Group, and Security Police Force, in addition to contracted support for handling accidental releases of regulated, hypergolic propellants and other hazardous substances.
The overall base emergency response program is managed by the Readiness Flight (30 CES/CEX), which is responsible for developing and updating the Vandenberg AFB Haz
ardous Material Emergency Response Plan. Additionally, the Readiness Flight chairs the Hazardous Materials Planning Team, ensures that follow-on elements of the Disaster Control Group are assembled as required by the On-Scene Commander in the event of a release response, and maintains training certificates for spill response team members.
The Vandenberg AFB Fire Department (30 CES/CEF) is the "local agency" that responds as First Responder at the Operational Level to an accidental release of hazardous materials on the base. This fire department comprises over 100 firefighters who staff five fire stations strategically positioned across the base. One fire station is located within a three-minute response time of all Program 3 processes described in this submittal. During the dry summer months, the Fire Department is augmented by a 20-person "Hot-Shot" crew specially trained to respond to wildland fires.
The Vandenberg AFB Fire Department is fully compliant with National Fire Prote
ction Agency standards, and has mutual aid agreements with Santa Barbara County, the City of Lompoc, the City of Santa Maria, the California Forestry Department, and the Los Padres National Forest. Per the Santa Barbara County Integrated Hazardous Materials Management System (IHMMS) Operation Agreement, the base Fire Department approves and maintains the business plans and hazardous material inventories-prescribed by the California Health and Safety Code, Chapter 6.95-that are developed by organizations assigned to or doing business on the base. This information can be retrieved electronically in the event of an emergency. Additionally, the base Fire Department conducts onsite facility inspections, as required, to identify potentially hazardous conditions that could lead to an accidental release. It should be noted that the Vandenberg AFB Fire Department is advised of all operations involving the transfer of hypergolic propellants, which comprise the regulated substances in all Pro
gram 3 processes on the base. During launch operations, Fire Department response elements are pre-positioned to expedite response in the event of an anomaly.
Vandenberg AFB also contracts for a Hypergolic Emergency Response Team (HERT) that can respond within 60 minutes of notification with scapesuit-qualified technicians; this emergency response team is capable of handling the hypergolic propellants described in this submittal. It should be noted that scapesuit-qualified technicians are pre-positioned on location for hypergolic propellant transfer operations.
The Vandenberg AFB Command Post is staffed 24 hours a day, every day of the year, and provides a central point of contact in the event of an emergency on the base. Its extensive suite of communications equipment includes hotlines to both the Santa Barbara County Emergency Services and the Lompoc Fire Dispatch control centers.
The Disaster Control Group (DCG) comprises experienced, senior personnel who represent a cross-sect
ion of technical, logistical, medical, and communications expertise. The DCG is headed by the On-Scene Commander who is responsible for managing onsite response to any major emergency on the base including an accidental release of hazardous materials. The DCG conducts exercises in accordance with the base's Hazardous Material Emergency Response Plan, 30 SW Plan 32-4002, Chapter 7. This plan requires at least two exercises annually that involve a simulated release of hazardous materials. One of these exercises is coordinated with the Local Emergency Planning Committee and must include participation by emergency response elements from the nearby communities.
Worst-Case Release Scenarios
Two worst-case release scenarios that have an offsite consequence, both involving a hypothetical release of UDMH, are included in this submittal. Two scenarios are included because modeling indicated the respective offsite consequence areas for two of the processes did not completely overlap. All
worst-case release scenarios analyzed in preparation of this submittal, whether with or without offsite consequences, were based on the total release of the greatest quantity of a regulated substance stored in a single vessel.
The first worst-case release that was modeled involved the release of 26,200 gallons of Aerozine-50, an approximately 50-50 by weight mixture of UDMH and Hydrazine, at the HSF. This hypothetical release would contain 14,173 gallons (92,977 pounds) of UDMH and 11,794 gallons (98,788 pounds) of Hydrazine. This analysis took into account written administrative controls that limit the quantity of Aerozine-50 in the storage vessels at the HSF to 26,200 gallons. The analysis also took into account passive mitigation measures including a 15,150-gallon sump into which released commodity can flow and a 6,450 square-foot diked area that would capture the overflow from the sump. In accordance with EPA guidance for modeling a worst-case release, the analysis assumed a 1
0-minute release; a wind speed of 1.5 meters per second and an F stability class; an ambient temperature of 93 degrees Fahrenheit, which is the highest recorded temperature on Vandenberg AFB over the past three years; a ground-level release height; and an urban topography to account for the very uneven terrain. Using the Degadis dispersion program and a net release of 39,356 pounds of UDMH, the toxic endpoint for the UDMH component extended 3.02 miles. This endpoint reached a recreational area on Vandenberg AFB-Ocean Park and Surf Beach-to which the public generally has routine, unrestricted access; however, no residences or other facilities to which the public has routine access were affected. The Hydrazine component did not have an offsite consequence. It should be noted that the Aerozine-50 storage area at the HSF is equipped with a water deluge system that is designed to dilute an accidental release by a factor of 10:1; this active mitigation measure would preclude the offsite i
mpact noted in this worst-case analysis.
The second worst-case release that was modeled involved the release of 25,500 gallons of Aerozine-50 at SLC-4 East containing 13,794 gallons (90,492 pounds) of UDMH and 11,479 gallons (96,148 pounds) of Hydrazine. This analysis took into account written administrative controls that limit the quantity of Aerozine-50 in the storage vessel at SLC-4 East to 25,500 gallons. The analysis also took into account a 1,570 square-foot diked area, which would contain such a release, as a passive mitigation measure. In accordance with EPA and CalARP guidance for modeling a worst-case release, the analysis assumed a 10-minute release; a wind speed of 1.5 meters per second and an F stability class; an ambient temperature of 93 degrees Fahrenheit, which is the highest recorded temperature on Vandenberg AFB over the past three years; a ground-level release height; and an urban topography to account for the surrounding structures and the very uneven terrain
. Using the Degadis dispersion program and a net release of 96,148 pounds of UDMH, the toxic endpoint for the UDMH component extended 1.5 miles. This endpoint reached a recreational area on Vandenberg AFB-Surf Beach-to which the public generally has routine, unrestricted access; however, no residences or other facilities to which the public has routine access were affected. The Hydrazine component did not have an offsite consequence. It should be noted that the Aerozine-50 storage area at SLC-4 East is equipped with a water deluge system that is designed to dilute an accidental release; this active mitigation measure would preclude the offsite impact noted in this worst-case analysis.
It should also be noted that public accesses to the affected recreational areas in these analyses are closed to the public when the hazard corridor for launch operations at Vandenberg AFB extends into these areas.
Although the second worst-case scenario described above involved the release of a great
er quantity of UDMH than the first scenario, it produced a shorter endpoint distance because the evaporative surface area (the diked area) was significantly smaller.
The worst-case release scenario for SLC-3 East involved the release of 33,000 gallons of liquid hydrogen and a subsequent vapor cloud explosion. This analysis took into account written administrative controls that limit the quantity of liquid Hydrogen in the storage vessel at SLC-3 East to 33,000 gallons (19,113 pounds). Using the RMP*Comp dispersion model, the endpoint to a one pound per square inch (psi) overpressure was determined to be 0.3 mile, which has no offsite consequence. Accordingly, this process satisfies the criteria for Program 1.
Alternate Release Scenarios
The alternate release scenarios evaluated for this RMP represent credible scenarios likely to generate the greatest release of regulated substances on Vandenberg AFB. Specifically, for the two toxic substances for which an alternate release scenar
io was developed, Hydrazine and UDMH, it was assumed that a 120 gallon Department of Transportation-approved container was punctured at the HSF during handling, allowing the contents to be released over a ten-minute time frame. It was conservatively presumed that the spill would occur over a flat, unbermed surface beyond the reach of any water deluge system. Average wind conditions and temperature for Vandenberg AFB were assumed. The alternate scenarios had no offsite consequence and did not affect any public receptors.
Alternative release scenarios involving the transfer of regulated substances from a delivery vehicle to the larger storage vessels were considered. However, such scenarios were rejected on the grounds that a release greater than the 120 gallon release presumed in the adopted scenario was not plausible. The transfer of hypergolic propellants to or from the large storage vessels is conducted under extremely controlled conditions. Personnel equipped with scapesuits
are stationed at both the delivery vehicle shutoff valve and the storage vessel intake valve to immediately close the respective valves in the event of a leak or rupture of the transfer line. Accordingly, a spill in such a scenario would, at worst, involve little more commodity than that contained in the transfer line itself; this would be less than the 120 gallons assumed in the adopted alternate scenario. Additionally, it should be noted that prior to each launch, space booster fueling operation, or propellant transfer operation, Vandenberg AFB determines the direction and extent of the toxic hazard corridor. The operation is allowed to proceed only when meteorological conditions are such that the surrounding communities are not placed at risk in the event of an accidental release.
Number of Full Time Employees: The number of full-time, on-base employees at Vandenberg AFB varies daily, but generally comprises 3,600 military personnel, 2,100 Civil Service p
ersonnel, and 3,100 contractor personnel, bringing the total number of full-time employees to 8,800.
North American Industrial Classification System (NAICS) Code: The activities at the HSF, SLC-3 East, SLC-4 East, and SLC-4 West support or involve satellite processing and space vehicle launching by Department of Defense contractors with the Air Force serving as the contracting agency. Historically, Vandenberg AFB assigned the Standard Industrial Classification (SIC) 8731 code, Commercial Physical and Biological Research, to these activities, even though the name does not adequately describe the activities. The SIC 9661 code, Space Research and Technology, has been interpreted to cover those satellite processing and space vehicle launch activities that are actually performed by a government agency (e.g., NASA). Accordingly, Vandenberg AFB has applied the SIC 8731 code to those satellite processing and space vehicle launch activities where the "customer" is the Air Force or other non
civilian government agency as distinguished from those activities that are actually performed by the government agency. The SIC 8731 code is equivalent to the NAICS 54171 code, Research and Development in the Physical, Engineering, and Life Sciences; this is the code that has been assigned to the processes described in this submittal.
Applicability of OSHA Process Safety Management (PSM) and EPCRA Section 302: Vandenberg AFB complies with the OSHA PSM standard and EPCRA Section 302 per Executive Orders 12196 and 12856, respectively. Notably, Air Force Space Command, the parent Major Command for Vandenberg AFB, has directed that the requirement for PSM be extended to include two substances not listed by OSHA: Hydrazine and Aerozine-50, with a threshold quantity of 100 pounds for both substances.
Date of Most Recent Emergency Response Training for Facility Employees: It should be noted that some aspect of emergency response training for facility employees occurs on average weekly on
Vandenberg AFB. Emergency response training for the cross section of base employees-to include firefighters, Disaster Control Group members, work-site employees, security police, newcomers, and first responders-overlaps considerably, culminating in periodic base-wide exercises. The date provided in this submittal for "the most recent emergency response training for facility employees" is the date of the most recent base wide exercise involving the simulated accidental release of a hazardous material.
General Duty Clause: Section 112(r)(1) of the Clean Air Act Amendments of 1990, the "General Duty Clause," makes it incumbent on owners and operators of stationary sources to identify hazards and to implement accidental release prevention measures relative to "any other extremely hazardous substance" that may not be included in the EPA list of regulated substances. Accordingly, Vandenberg AFB identifies Nitrogen Tetroxide as an extremely hazardous substance that is stored on the instal
lation in quantities that could pose a risk to the general public. Nitrogen Tetroxide is used primarily as the oxidizer component of the hypergolic propellants employed by the Titan and Delta classes of space boosters; it is also used in smaller quantities as a propellant for satellites launched from Vandenberg AFB and in the PSRE of certain ICBM's tested at the base.
All aspects of Vandenberg AFB's RMP and CalARP programs-to include OSHA Process Safety Management (PSM) standards and emergency response program planning and training-encompass Nitrogen Tetroxide storage and operations to the same extent that they apply to the regulated hydrazines as described in this submittal. It should be noted that a review of the base's five-year accident history reveals that there have been no reportable accidents involving either base employees, contractors or anyone in the general public as a result of exposure to a release of Nitrogen Tetroxide. In August 1997, 250 gallons of Nitrogen Tetroxi
de were released at SLC-4 East from the Thrust Vector Control (TVC) Tank on one of the Solid Rocket Motors (SRMs). However, there were no injuries. Since then, the SRM has been replaced with a new Solid Rocket Motor Upgrade (SRMU) that does not use Nitrogen Tetroxide. Vandenberg AFB fully intends to maintain every aspect of its current accidental release prevention program as it applies to Nitrogen Tetroxide as long as substantive quantities of this substance are stored or used at the base.