Naval Air Station (NAS) Pensacola - Executive Summary

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NAS Pensacola is located in Escambia County, which is situated near the westernmost part of the Florida panhandle. This base is approximately 12 miles southwest of the Pensacola Regional Airport. The main gate to the base can be accessed from Interstate (I-)10 via SR 295 South. The primary mission of NAS Pensacola is to provide quality support to tenants and several training commands housed at the base, enabling them to meet mission requirements. 
NAS Pensacola is deeply committed to chemical safety. This commitment is exemplified by a full time safety staff, regular inspections of all facilities within the station, and strict adherence to applicable federal, state, and local laws regarding the storage, handling and use of chemicals.  In addition, all activities at NAS are required to abide by stringent regulations (NAVOSH) adopted and enforced by the Navy. 
Per Section 112(r) of the Clean Air Act, NAS Pensacola is submitting this Risk Management Plan (RMP) for the chlorination/dechlor 
ination process at the Waste Water Treatment Plant (WWTP). The maximum intended inventory of chlorine and sulfur dioxide stored at the plant is 16,000 pounds (8,000 pounds of each). The chlorine is used to disinfect the waste stream, while the sulfur dioxide is used to control chlorine content of the discharge in order to protect the environment. 
As mandated by EPA, the worst-case release scenario (WRS) involves the catastrophic failure of one of the chemical containers at the WWTP. The resultant gas cloud is predicted to have offsite impacts. A catastrophic failure of a container is extremely unlikely due to the rigid DOT-mandated construction specifications of the container, and the Chlorine Institute requirements covering the refilling and inspections of containers (by the chemical supply company prior to delivery). Further, the Emergency Action Plan (EAP) in place at the base provides protection from an external event which could lead to a catastrophic failure (i.e. fire). NAS Pen 
sacola has its own fully trained and capable fire department located within 0.5 mile from the WWTP. 
The alternative release scenario (ARS) involves the release of a much smaller quantity of chlorine through a failure of the container valve. No public receptors were identified within the offsite vulnerable zone of the alternative release.  
There have been no reportable accidents within the past five years at the plant. 
The process is subject to OSHA Process Safety Management Standard (29 CFR 1910.119), which mandates a specific and detailed program to ensure the safe handling of hazardous substances. All operators are trained in the safe handling of chlorine and sulfur dioxide, chemical safety is discussed at weekly safety meetings, the equipment is inspected on a daily basis, and a preventative maintenance program is in place. The system is equipped with alarms to monitor for leaks and alert the plant personnel to take corrective action. The system is also equipped with vacuum regul 
ators, which would stop the supply of chemical at the container, thereby limiting the chemical release to a very small amount. 
NAS Pensacola has an EPA-approved Facility Response Plan (FRP) which contains a section addressing emergencies associated with the WWTP. The plant EAP outlines procedures for the mitigation of minor leaks, details a notification process for emergency responders and the public. The base fire department personnel are trained in responding to chemical emergencies and have the specialized equipment to repair a leaking container. The base has mutual aid agreements with the surrounding community emergency departments and is included in the Community Emergency Response Plan (CERP), which is coordinated through the Escambia County Local Emergency Planning Committee (LEPC). 
NAS Pensacola is in the process of instituting several enhancements to its existing chemical safety program.
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