MCAS Yuma - Executive Summary |
|
1.0 Executive Summary The Southwest Division (SWDIV) Naval Facilities Engineering Command contracted Radian International (Radian) to support the Marine Corps Air Station (MCAS) Yuma in its effort to comply with the federal Risk Management Plan (RMP) regulations. This document represents the RMP prepared by Radian for MCAS Yuma. The RMP summarizes the management, administrative, procedural, and technological controls that work together to minimize the risk to the community of a hazardous chemical release. This section provides overviews of the following: 7 Background and facility description; 7 MCAS Yuma's accidental release prevention and emergency policies; 7 Hazard Assessment (e.g., worst-case accidental release and alternative release scenarios); 7 General accidental release prevention program; 7 Five-year accident history; 7 Emergency Response Plan; and 7 Planned changes to improve safety. 1.1 Background and Facility Description The federal RMP rule requires covered fa cilities to submit an RMP to the U.S. Environmental Protection Agency (EPA) and the local Administering Agency, which, in Yuma County, is the Arizona Department of Environmental Quality (ADEQ), by 21 June 1999. Facilities must comply with these requirements if they have processes involving regulated substances in excess of specified threshold levels. According to the Code of Federal Regulations (CFR), the RMP rule applies to an owner or operator of a stationary source that has more than a threshold quantity of a regulated substance in a process (40 CFR 68.10). The term stationary source "does not apply to transportation, including storage incident to transportation, of any regulated substance" (40 CFR 68.3). It should be noted that the General Duty Clause of Section 112(r) of the Clean Air Act Amendments requires all facilities, covered or not, to identify hazards that may result from accidental releases, design and maintain a safe facility, and minimize the consequences of any rel eases that occur. Penalties for non-compliance are significant. Under Section 113 of the Clean Air Act, the EPA has the authority to bring administrative and judicial actions against violators. Judicial actions can be civil and criminal in nature. Section 113(a)(3) authorizes the EPA to order violators to comply with the RMP regulations. Under Section 113(b), the EPA may initiate civil judicial enforcement for violations of the RMP to assess penalties up to $25,000 per day for each violation. MCAS Yuma is subject to the federal RMP requirements because of its chlorination process at the Water Treatment Plant (WTP). This process consists of nine one-ton chlorine cylinders and sixteen 150-pound cylinders that support the MCAS Yuma WTP. The total quantity of chlorine in the process is 20,400 pounds, which exceeds the 2,500-pound RMP threshold for chlorine. RMP covered processes are eligible for different program levels depending on the degree of risk they pose. Program Level 1 is the l east stringent RMP. A process can qualify for Program Level 1 only if there are no public receptors within the worst-case zone of impact, if there have been no accidents that meet specific criteria, and if emergency response efforts are coordinated with outside agencies. Program Level 2 is the default program. Program Level 3 is for processes that are in certain industry categories or that are subject to Occupational Safety and Health Administration's (OSHA's) Process Safety Management (PSM) standard. MCAS Yuma's chlorination process at the WTP is subject to Program Level 2 RMP requirements because there are public receptors within the worst-case zone of impact. 1.2 MCAS Yuma's Accidental Release Prevention and Emergency Policies MCAS Yuma is committed to conducting its operations in a safe and responsible manner. The WTP chlorination system is equipped with numerous safety features intended to reduce risks to human health and to the environment. In addition to the safety systems in place, the MCAS Yuma WTP has written procedures to ensure that the system is operated and maintained in a safe manner. The procedures include the following: 7 Maintenance and preventive maintenance are performed regularly. Chlorine cylinders are inspected and documented daily, and the chlorine detectors and alarms are inspected and tested monthly. 7 MCAS Yuma WTP personnel are present during chlorine receiving and change-out activities. The chlorine cylinder receiving and change-out procedures are supervised by the Senior WTP Operator who follows a written checklist. The MCAS Yuma Fire Department on station is notified before deliveries are made, and the parking lot is closed during cylinder receiving operations. 1.3 Hazard Assessment - Worst-Case Accidental Release Scenario The worst-case accidental release scenario (WCS) is a catastrophic failure of a one-ton chlorine cylinder. Chlorine is a gas at normal temperatures and pressures. It is liquefied by storing it in a closed con tainer at pressures higher than its equilibrium vapor pressure. In a WCS, it is assumed that the entire mass of material contained in the one-ton cylinder is released as a gas over a 10-minute period. Hazard assessment modeling, using the RMP*COMP program (v 1.06), was used to determine the downwind impact from the potential accidental release. The RMP*COMP program is an off-site consequence analysis (OCA) program equivalent to the EPA lookup tables developed by the EPA and the National Oceanic and Atmospheric Administration. This program shows that the release of a one-ton chlorine cylinder would impact receptors an estimated 2.2 miles downwind from the point source based upon the rural terrain. According to Landview III, a Census database computer program, there are approximately 1,700 persons within the 2.2-mile radius worst-case zone of impact. The nearest public receptors are a baseball diamond located approximately 100 feet from the WTP and military housing to the north and wes t of the plant. Although some buildings/areas are within the MCAS Yuma installation boundary, they are considered public receptors because non-employees (e.g., retirees, dependents, etc.) may be present. Additionally, the presence of sensitive receptors must be identified within the zone of impact of the WCS. They are defined as "schools, hospitals, long-term health care facilities and child day-care facilities" (40 CFR 68.3). The WCS of chlorine would impact the Medical Clinic (Building 1175) and Child Development Center on station, as well as the Behavioral Health Center located directly outside MCAS Yuma main gate. Both the Medical Clinic and the Behavioral Health Center have 24-hour patient care. The likelihood of such a worst-case release occurring at the MCAS Yuma WTP is extremely remote. For the WCS, the numerous safety systems and alarms designed to prevent such a release are all assumed to fail. However, for the WTP chlorine cylinders, many of the safety systems are designed to fail into a safe mode. For example, the WTP operates at a reduced risk by using chlorine gas instead of liquid and maintaining the chlorination system under negative pressure. Therefore, the WCS is not considered a credible event. Nonetheless, the federal regulations require facilities to complete a WCS analysis. 1.4 Hazard Assessment - Alternative Release Scenario An alternative release scenario (ARS) represents an event that is more likely to occur than the WCS and has off-site impacts (if such a scenario exists). The federal regulations require facilities to develop one ARS for all flammable substances and one ARS for each regulated toxic substance. As MCAS Yuma has only one covered process, only one ARS is required. A failure of a gasket on the connection to the one-ton cylinders has been identified as the ARS for the MCAS Yuma WTP. This scenario assumes that approximately 30 pounds of gaseous chlorine are released at a rate of 1.0 pound per minute for 30 minutes. According to RMP*COMP, the chlorine ARS release would impact an estimated 0.1 mile downwind distance from the point source. 1.5 General Accidental Release Prevention Program MCAS Yuma has a Prevention Program in place to minimize the risk of hazardous chemical releases in accordance with the EPA requirements. The Prevention Program covers the chlorine process and provides a structured approach to preventing accidents. Some of the specific elements of the Prevention Program include the following: 7 Process safety information is provided to all employees upon hire and is accessible at all times. 7 On 25 and 26 February 1999, Radian performed an in-depth Hazard Review of the chlorination process at the MCAS Yuma WTP. Radian used a Hazard Review checklist based on the EPA's Risk Management Program Guidance for Wastewater Treatment Plants (October 1998). 7 A process Hazard Review will be performed by qualified personnel every five years or more frequently if changes to the process take place. 7 Written Standard Operating Procedures (SOPs) are used for training and guiding the work of operators and are updated periodically. 7 WTP operators are licensed by the state of Arizona. 7 Operators, plumbers, and contractor personnel are qualified, trained in the general hazards in the facility, and informed of any temporary situations affecting safety. 7 Training is provided to all employees upon hire, and refresher training is given annually. 7 A program is in place to maintain the mechanical integrity of the process, which includes written procedures, training requirements, work orders, scheduled maintenance, and documentation. 7 Incidents are investigated and actions are taken to reduce the likelihood of reoccurrence as part of a continuous improvement effort. 7 Routine audits are conducted to assure that safe practices are being followed. 1.6 Five-Year Accident History The RMP regulations require facilities to compile a five-year accident history. This is defined as "all ac cidental releases from covered processes that resulted in death, injuries, or significant property damage on site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage" (40 CFR 68.3). There have been no accidents or incidents at the MCAS Yuma WTP within the last five years that meet the above definition. 1.7 Emergency Response Plan Overall safety at MCAS Yuma is a function not only of programs to prevent accidental releases from occurring, but also of programs to mitigate the effects of accidental releases should they occur. MCAS Yuma has an emergency response program that is designed to protect lives, the environment, and property in the area. The MCAS Yuma Fire Department personnel reside on station 24 hours a day, 365 days a year. At a minimum, all MCAS Yuma Fire Department response personnel at MCAS Yuma are trained to the Hazardous Materials First Responder Operations level. Several are trained to the Hazardous Materials Technician level, and others to the Incident Command level. When creating emergency response procedures, MCAS Yuma considers Spill Prevention Control and Countermeasure (SPCC) Plans, the Storm Water Monitoring Plan and Reports, the Emissions Inventory Report (EIR), Title V Reports, the Oil Pollution Act of 1990 (OPA 90), Emergency Response Action Plans (ERAPs), and Facility Response Plans (FRPs). These documents delineate the responsibilities and interrelationships of the responding departments, describe their response capabilities, and provide incident-specific guidance in order to ensure timely resolution of an emergency incident. This RMP will serve as an additional reference for this information. Chlorine-specific response and first-aid information is contained in this RMP document and in reference documents available to MCAS Yuma response personnel. The MCAS Yuma Fire Department has a longstanding relationship with outside response agencies. The MCAS Yuma Fire Department also has a City of Yuma Engine Company status. The City of Yuma Fire Department coordinates with the MCAS Yuma Fire Department for city-wide emergencies, as well as disaster plans. This includes a Mutual Aid Agreement with the City of Yuma Fire Department. The Local Emergency Planning Commission (LEPC) works closely with the MCAS Yuma Fire Department performing annual major disaster drills. Additionally, the MCAS Yuma Fire Department coordinates with the MCAS Security for emergency response actions specific to the MCAS Yuma WTP. 1.8 Planned Changes to Improve Safety Chemical safety is an important part of the MCAS Yuma WTP operations. The health and safety efforts at the facility, as well as regulatory requirements, have minimized chemical exposure risks to employees and the public through ongoing internal risk reduction efforts. As a result of the Hazard Review, the following changes will be implemented to improve the safety of the chlorine process at the WTP: 7 Provide consistent labeli ng of process lines; 7 Establish additional preventative maintenance procedures; 7 Provide better structural support to plastic riser pipes in Building 1959; 7 Install windsocks at locations where chlorine is stored; 7 Ensure local and remote alarms have consistent warning methods at all locations; 7 Reprogram alarms to ring directly at the MCAS Yuma Fire Department; and 7 Make ventilation system switches consistent among all chlorine storage buildings. |