Fort Riley - Executive Summary |
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EXECUTIVE SUMMARY AIR PROGRAMS CONSULTATION NO. 42-EK-7746 RISK MANAGEMENT PROGRAM DOCUMENTATION FOR FORT RILEY 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 (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 Bhopal, India release of methyl isocyanate is an example of such a catastrophic event. Under the regulation, certain facilities would be required to submit a RMP that summarizes their Risk Management Program, to the U.S. Environmental Protection Agency (EPA). Army installations, which store/use toxic chemical and flammable substances in quantities meeting the rule's thresholds are required to develop a risk management program and submit risk management plan to the EPA. Toxic chemicals such as chlorine, sulfur dioxide, ammonia, hydrochloric acid and nitric acid and flammable substances such as butane or propane are examples of chemicals that may require reporting. 2. PURPOSE. Fort Riley's Risk Management Program meets the planning requirements required by the CAAA-90. It describes elements of the program, assigns responsibilities and tasks for implementation, and communicates clearly Fort Riley's commitment to its workers and surrounding communities that the risk of catastrophic releases of chlorine are minimized. The electronic submission is a summary of Fort Riley's program. 3. REPORTABLE HAZARDS. There are only two sites on Fort Riley where EPA deemed potentially dangerous chemicals are used/stored that meet the requirements for reporting to the EPA under the provisions of the CAAA-90. These sites are the Water Treatment Plant (WTP) and the Custer Hill outdoor swimming pool. 4. DISCUSSION. a. Water Treatment Plant. The WTP stores and uses chlorine for the purification of drinking water. The WTP has an average daily flow rate of 2.5 million gallons and serves approximately 20,000 people. It uses a conventional treatment process of purification that is in common use throughout the United States. This process normally requires the use of 140-200 pounds of chlorine daily. The chlorine is stored in eight one-ton cylinders. One of these containers is exhausted every 7-10 days. The WTP has been operating since December 1992 and has had no chlorine release incidents. (1) A worst case analysis was conducted using the EPA recommended parameters of a 10-minute release of all material in a single container into the air. This would effect a 3.1 mile radius and approximately 3,000 people. This scenario assumes a full cylinde r fails and, at almost any time, the cylinder being used will likely be somewhat depleted. It is also important to note that this scenario is extremely unlikely to occur. It would require one of these cylinders to be catastrophically ruptured. The cylinders in this scenario are all tested to withstand the force of being dropped while full from a height of ten feet. This test is designed to replicate what could happen if a cylinder were to fall from a truck while being transported. Any type of smaller leak would be much less dangerous as it would require much more time to release the chlorine, thereby allowing it to be dissipated and allowing emergency crews more time to detect the failure and stop the leakage. (2) The WTP is similar in operation to those in common use by municipalities everywhere. In fact, the Fort Riley WTP is more remotely located than most. The fact that chlorine leaks are not a widespread problem in society is an indication that the likelihoo d of a chlorine leak endangering large numbers of people is highly unlikely. (3) The cylinders at the WTP are inspected by Directorate of Public Works technicians a minimum of three times daily. All technicians are Class 4 certified by the Kansas Department of Health and Environment, which exceeds both state and federal regulations for certification. Additionally, there are chlorine detectors with alarms placed in the chlorine feed room and the chlorine storage areas. The Fort Riley Fire Department is prepared to deal with virtually any HAZMAT situation. Fort Riley maintains a 38-person department, the largest in the local area. All of the department personnel undergo a minimum of 80 hours of HAZMAT training (many have more, some as many as 240 hours) and also undergo 24 hours of annual recertification training. The department also has mutual aid agreements with all of the local fire departments and maintains contingency spill plans of potentially hazardous sites. b. Custer Hill outdoor swimming pool. The Custer Hill pool is a typical outdoor recreational swimming pool. It holds 550,000 gallons of water and is open from Memorial Day until Labor Day. A one-ton container is emptied every 25 days. Chlorine is stored in four one-ton containers and is used to disinfect the water. A worst-case scenario involves the same EPA parameters of release of one container into the air in 10 minutes. This scenario would effect a 1.3 mile radius and 563 people. As is the case with the WTP, this scenario is highly unlikely. The cylinders used for storing chlorine at the pool are similar to those used in the WTP, and are subjected to the same 10-foot drop test. Chlorine is only present on site during the summer months, so the potential hazard is non-existent during most of the year. Likewise, the cylinders are inspected a minimum of twice daily by Directorate of Public Works technicians who have all the same qualifications as those inspectin g the WTP. In addition, there are chlorine detectors with alarms placed in the chlorine feed room and the chlorine storage area. The Fort Riley Fire Department maintains contingency spill plans and is prepared for virtually any HAZMAT emergency that may arise. The pool has had no chlorine release incidents. 5. CONCLUSIONS. a. The dangers presented by each of these reportable facilities to the local population are minimal. Water treatment facilities, both for drinking water and for recreational pools are common place throughout society and the procedures used on Fort Riley facilities are similar to those in use everywhere. b. The RMP at Fort Riley is designed to help ensure that catastrophic releases of chlorine gases do 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 Riley's Environmental Quality Control Committee, Directorate of Environment a nd Safety (Pollution Prevention and Safety Divisions), Preventive Medicine (Industrial Hygiene), Staff Judge Advocate, Directorate of Public Works, Public Affairs Office and Directorate of Law Enforcement and Security. c. Fort Riley is committed to being a safe neighbor and employer. Prevention of accidents, employee safety and emergency response are all operations which have command support and visibility. Fort Riley follows all applicable regulations, requirements and policies designed to provide a safe work environment. Larry M. Brom Colonel, U.S. Army Garrison Commander |