DCPREZ-2016-11027 - Laserfiche WebLink

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t Management' Town of Vermont Risk Assessment Report 1d+lanagement° and secondary containment appropriate and required by code based on the product stored in them. Piping to convey the fuels to the test pads will likewise be designed and constructed using the materials, accessories, and secondary containment appropriate and required by code based on the product conveyed in them. The RP-1 fuel is proposed to be stored in a 2,000-gallon tank. Based on this volume and because it is an oil product, this tank system will require a Spill Prevention, Control and Countermeasures (SPCC) Plan, and all that is required in its associated regulation (40 CFR 112). The proposed storage quantities of two other fuel products, liquid methane and liquid propane, trigger the requirement for an EPA Risk Management Plan (RMP) and the OSHA Process Safety Management (PSM) regulations. Both of these listed products will be stored in quantities greater than 10,000 pounds, which triggers their coverage under these regulations. When asked by Kestrel about their spills history, Orbitec stated that they have never experienced a release of fuel at their present testing facility at the former Badger Army Ammunition Plant near Baraboo. Water and Wastewater Water will be stored onsite in two 50,000 gallon tanks. Water will be provided via a proposed water supply well near the tanks. The majority of the water will be used for the active sound suppression system. A portion of this water will evaporate in the process. The balance will be contained near the testing pad. The wastewater that remains after use of the active sound suppression system is planned to be recycled and re-used. It is likely to contain small concentrations of petroleum that could build up over time and may require treatment. Orbitec stated that they plan to incorporate a water treatment system to address this concern. Air emission sources Orbitec provided information on the types of fuel mixtures expected to be used during testing, the anticipated quantities consumed in a year of testing, and the estimated quantities of compounds released into the atmosphere as a result of combustion during testing. Of the four types of fuel mixtures, three are expected to emit one of the six "criteria" air pollutants, carbon monoxide (CO) (NAAQS, 40 CFR 50). An air permit may be required for the facility, particularly when testing of Upper Stage engines begins. Safety Heavy Vehicle Traffic Heavy vehicle traffic on Cedar Hill Lane (a township road) (Photo 4) during construction of the site will likely include concrete trucks, dump trucks loaded with stone, and miscellaneous equipment transport (tanks, testing equipment, structural steel, etc). According to Town Patrolman Jack Schulenberg, the culverts under the road are in questionable condition and are likely 60 or more years old, and the road base material is not thick enough to support heavy traffic without sustaining considerable damage. Our understanding from Town of Vermont is that Orbitec has agreed to make any necessary repairs to the • --- Page 7 -- -