town of vermont report client draft 20160706 of vermont report... · the town of vermont has...

Operational Risk Management • Process Improvement • Management Systems • Compliance Assurance • Business Continuity

DRAFT TOWN OF VERMONT RISK ASSESSMENT REPORT

July 6, 2016 Prepared for Town of Vermont

Town of Vermont Risk Assessment Report

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Table of Contents

1. BACKGROUND .................................................................................. 2

2. OBJECTIVES ....................................................................................... 2

3. APPROACH/METHODOLOGY ............................................................ 2

4. OBSERVATIONS/FINDINGS ................................................................ 4

Environmental .................................................................................................................... 5

Noise ........................................................................................................................... 5

Fuel Storage and Spill Prevention ........................................................................... 6

Water and Wastewater ........................................................................................... 7

Air emission sources .................................................................................................. 7

Safety ................................................................................................................................. 7

Heavy Vehicle Traffic ................................................................................................ 7

Fire and Explosion Hazard ....................................................................................... 8

Findings Summary ............................................................................................................. 8

5. RECOMMENDATIONS ........................................................................ 9

APPENDIX A: PHOTOS ............................................................................ 11


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1. BACKGROUND Kestrel was retained by the Town of Vermont to conduct a risk assessment for due diligence purposes of the proposed rezoning (Ag-1 (EX) to Commercial 2) of ~22 acres of farmland located at 4710 Cedar Hill Land, Black Earth, Wisconsin by Cedar Hill Forestry LLC (Photo 1). Cedar Hill Forestry would be leasing property to Orbital Technologies Corporation (Orbitec) for the development of an engine test facility, initially for reaction control engines (RCS engines) and eventually upper stage engines (Photo 2).

The risk assessment included a review of Orbitec’s proposed development plans and operations to assess what activities have potential for impact to the environment and surrounding properties. Risk concerning the following areas were assessed:

Environmental

Noise Fuel storage and spill prevention Water and wastewater Air emission sources

Safety

Heavy vehicle traffic Fire and explosion hazard

The report concludes with a table containing recommendations to the Town of Vermont for addressing the major risks associated with the construction and operation of the proposed engine testing facility.

2. OBJECTIVES The Town of Vermont has requested that Kestrel provide information, based on our initial proposal, to undertake due diligence measures to assess whether there are outstanding environmental or public safety impacts to the proposed site or the surrounding properties that would affect/prevent further negotiations with Cedar Hill Forestry concerning the proposed development opportunity with Orbitec.

3. APPROACH/METHODOLOGY Kestrel conducted a pre-assessment conference call with Town of Vermont representative(s) Barbara Grenlie (Town Board Chairperson) and Karen Carlock (Town Clerk). This interview established the perspective of the of the client and helped define the deliverable for this scope of work. After this meeting, Town of Vermont provided many documents for Kestrel’s review. Key contacts from both parties were identified and an onsite visit with Orbitec and their representatives was scheduled.

Jack Anderson and Jake Taylor from Kestrel, along with Barbara Grenlie, participated in an onsite visit with Orbitec representatives on Friday, June 3, 2016. Paul Pignet, Chip Sauer, and Joey Rideout of Orbitec, and Ben Meneker of ACS attended to represent Orbitec. This visit allowed Kestrel to gain a


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better understanding of the topography of the proposed site (Photo 3) and proximity of surrounding properties. It proved beneficial as it also provided better insight into Orbitec’s vision for the property and allowed the opportunity to ask technical questions to their staff scientists. It is important to note that only conceptual drawings/figures were available at the time of this risk assessment. No detailed design/construction drawings of the facility were available to Kestrel.

Kestrel reviewed the following documents, which were requested and provided by others, or researched by Kestrel:

Table 1: Documentation Reviewed

Orbitec Testing Campus Rezoning Application Narrative (Orbitec, May 2016)

Orbitec Test Campus Supplemental Environmental/Safety Information (Orbitec, June 2, 2016)

Access Dane Property Owner Information (County of Dane website)

Overall Layout Plan Drawing, Topographic Contour Map Drawing, (Graef, April 21, 2016)

State of Wisconsin Applicable Statutes (email from Paul Pignet, Orbitec, May 11, 2016)

Propulsion Systems (Oribitec slide deck, April 2016)

Fuel Information – proposed propellant type and quantities (email from Karen Carlock, Town of Vermont, May 26, 2016)

Proposed Material Delivery Route Options (Orbitec – sketch using Google Maps base)

Sources and Effects of Low-frequency Noise (Berglund, B. et. al., Journal of the Acoustical Society of America, May 1996) The Costs of Chronic Noise Exposure for Terrestrial Organisms (Barber, J.R. et. al., Trends in Ecology and Evolution, Vol. 25 No. 3, September 15, 2009)

Summary of Acoustics and Sound Transmission (narrative by Patricia McConnell, Ph.D.)

Summary of Regulations and Codes Guiding the Plans for the Test Site (email from Chip Sauer, Orbitec, June 13, 2016)

“Why the Ludolph Farm?” (miscellaneous informational slide deck by Orbitec)

HS Series Horizontal Bulk Tank General Specification Sheet (Chart, Inc.)

OSHA Form 300 and 300A, Log and Summary of Injuries and Illnesses (Orbital Technologies Co., 2013, 2014 and 2015)

EPA FRS - Facility Detail Report (Orbital Technologies Co., June 24, 2016)

ECHO – Enforcement and Compliance History Online, Detailed Facility Report (Orbital Technologies Co., June 24, 2016)

NAICS (North American Industry Classification System) Codes Website (July 5, 2016)


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4. OBSERVATIONS/FINDINGS As part of the assessment process, it was important to identify the major codes, regulations, and requirements that regulate Orbitec in how their facility is to be designed and constructed, as well as how they operate the test facility. The following is a sample of the various federal, national and state codes and regulations that are applicable to the construction of the testing facility or to Orbitec’s operations at the facility.

Table 2: Applicable Requirements

DOD DOD 4145.26-M Contractors Safety Manual for Ammunition and Explosives

Defense Contract Management Agency (DCMA) Performance Requirements

Guidance from NASA and Air Force Safety Manuals and Requirements

EPA 40 CFR 112 Spill Prevention Control and Countermeasure (SPCC) Plan

40 CFR 68 Risk Management Plan (RMP)

OSHA 29 CFR 1903, 1904, 1910 (all relevant) 29 CFR 1910.119 Process Safety Management (PSM) General Duty Clause

State of Wisconsin Statutes

ATCP 93 Flammable, Combustible and Hazardous Liquids ATCP 94 Petroleum and Other Liquid Fuel Products SPS 101 Regulation of Industry Buildings and Safety

WDNR NR 100-199, NR 200-299, NR 400-499, NR 500-599, NR 600-699

NFPA NFPA Chapter 30 Flammable and Combustible Liquids NFPA Chapter 55 Compressed Gases and Cryogenic Fluids NFPA Chapter 70 National Electrical Code Industrial Gas Supplier Requirements

ASME ASME B31.3 Process Piping Code ASME Boiler and Pressure Vessel Code (BPVC)


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As previously mentioned, risk was assessed in the environmental areas of noise, fuel storage and spill prevention, water and wastewater management, air emission sources, as well as the safety areas of heavy vehicle traffic and fire/explosion hazards. Observations related to these categories are discussed below.

Environmental

Noise

A major consideration during the assessment regards the potential noise created during testing and how it may affect the surrounding environment and property owners. While Orbitec focuses on being a propulsion provider to the aerospace industry, it is important to note that the engines they develop and test are not considered “rocket” or “booster” engines, which may be the initial assumption of one first learning that they are in the aerospace industry. The classes of engines Orbitec develops and tests are smaller engines used to orient satellites while in orbit (Reaction Control engine, or RSC to be tested beginning in late 2016 or early 2017), or to propel a satellite into orbit after its carrier has ascended to the appropriate elevation (Upper Stage engine, anticipated to be tested beginning 2025). Below are tables that summarize the maximum sound pressure levels expected to be produced by the two classes of engines projected to be tested, and duration of those tests. The data are based on information received from Orbitec through interviews or documentation received.

Table 3: Noise - RSC Engine Testing (beginning late 2016 or 2017)

Test Phase Typical Maximum Projected Maximums

Sound 80 dba 90 dba 90 dba

Developmental Testing

5-10 test/day 3-4 days/week 5-10 seconds/test

< 15 tests/day 5 days/week10-20 seconds/test

5 minutes/day 25 minutes/week 21.6 hours/year

Qualification Testing

10-40 tests/year 10-20 minutes/test

40 tests/year 20 minutes/test

13.3 hours/year


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Kestrel reviewed several articles and technical papers regarding research and opinions related to sound/noise transmission and its potential effects on humans, as well as wild and domesticated animals. The literature was provided by Orbitec; Patricia McConnell, Ph.D. via Town of Vermont; and our own additional Internet research (see Table 1 above). While the literature reviewed did not speak directly to the specific situation and conditions at the testing site (rural area with significant topographic relief, densely forested surroundings, engine testing for relatively short periods of time), most of the researchers/authors posed questions as to the effects of aircraft or highway-produced noise to both wild and domestic animals. But, most studies concluded that there was little to no effect on animal behavior. With regard to sonic boom studies, all domesticated farm and wild animals showed a behavioral startle when first experiencing a sonic boom, but their reaction was usually slight and they seemed to adapt readily to further booms. Orbitec plans to construct and operate an active sound suppression system to be used when the upper stage engines are tested. The active sound suppression system uses jets of water that absorb sound energy when converting to steam. The topographic setting of the proposed test facility (Photo 3) lends itself well to shielding noise from most neighboring properties, deflecting sound vertically instead of propagating it horizontally. Based on this setting, the maximum sound pressure levels expected, the relatively brief and infrequent nature of the tests, and the future implementation of an active sound suppression system for upper stage engine testing, it appears that noise concerns are/can be successfully mitigated at the site by Orbitec.

Fuel Storage and Spill Prevention

Fuels and other fluids used during testing will be stored in bulk at the site. One particular fuel, RP-1, is essentially kerosene, a petroleum oil product, while all others are liquefied gases such as liquid oxygen, liquid hydrogen, liquid methane, and liquid nitrogen. Water for sound suppression and propane for building heating will also be stored onsite. Tanks to store these liquids will be purchased from tank vendors or fuel/gas providers and will be designed and constructed using the materials, accessories,

Table 4: Noise - Upper Stage Engine Testins (beginning approx. 2025)

Test Phase Typical Maximum Projected Maximums

Sound 90 - 95 dba 100 dba 100 dba

Developmental Testing

1-2 test/day 3-4 days/week 10-20 seconds/test

3 tests/day 5 days/week30 seconds/test

1.5 minutes/day 7.5 minutes/week 6.5 hours/year

Qualification Testing

10-20 tests/year 5-10 minutes/test

25 tests/year 10 minutes/test

4.2 hours/year


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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


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road. Heavy vehicle traffic during testing operations is expected to be sporadic (~1 delivery/week) but based on the size of tankers used could overload the rated weight capacity of Cedar Hill Lane and other area roads. Information regarding plans to consider tanker size and delivery frequency were unavailable at the time of this report. Potential delivery routes have been established in provided map below.

Fire and Explosion Hazard

Fuels and other fluids used during testing will be stored in bulk at the site. Tanks to store these liquids will be designed and constructed using the materials and accessories 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 and accessories appropriate and required by code based on the product conveyed in them. The fuels stored onsite in bulk and used during testing in smaller quantities are combustible and/or flammable. Based on the quantities and types of products stored, a Risk Management Plan per 40 CFR 68 must be developed and implemented, and Process Safety Management regulations (20 CFR 1910.119) must be followed. These requirements and the General Duty Clause requirements, not to mention standard fire, electrical and building codes, will ensure that the new testing facilities are constructed and operated in a safe manner. Further to this topic, Kestrel requested and reviewed Orbitec’s OSHA 301 summary of injuries and illnesses reports for 2013 through 2015 and no injuries were noted on any of the reports for the last three years of operations at their present testing facility at Badger Army Ammunition Plant (BAAP) in Baraboo. Orbitec also confirmed that they have not experienced any unplanned fires or explosions at BAAP.

Findings Summary Engine testing for the aerospace industry has the potential for impacts to the environment and neighboring properties, as do more conventional operations such as small manufacturing and even farming. Using the information available, we have examined the most significant environmental and safety risks associated with the construction and operation of the proposed engine testing facility at 4710 Cedar Hill Lane in the Town of Vermont, Black Earth, Wisconsin. As a result of this process, we have found no significant risks for which mitigation measures have not been planned by Orbitec.


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5. RECOMMENDATIONS The table below summarizes Kestrel’s recommendations to Town of Vermont based on the information reviewed during this due diligence risk assessment.

Issues Observations Recommendations

Noise related concerns

Project noise levels at property boundaries of 80-90db for RSC engine testing are projected by Orbitec. Cannot fully determine actual noise levels without additional study.

Monitor noise levels during the initial testing events and document. Communicate periodically with neighbors and collect feedback regarding noise levels.

Spills

The RP-1 storage tank and the test cell facilities/run tanks will require secondary containment. The RP-1 storage tank will require an SPCC Plan.

Review construction plans and inspect final constructed facility to ensure adequate containment facilities are in place before operations begin. Review the SPCC Plan for the RP-1 storage tank.

Air emissions

Carbon monoxide is anticipated to be emitted while testing when combusting three of four fuel mixtures at the site.

Determine requirements for an air permit.

Fire and explosion hazard

Hazardous materials (fuels) are stored in bulk storage tanks and in run tanks at the test cells during operations.

Review construction plans and inspect final constructed facility to ensure that applicable safety regulations, codes and guidelines are followed and incorporated into the design and operating plans for the facility. Also ensure that a Risk Management Plan (RMP) is in place and that Process Safety Management and General Duty Clause regulations are followed.

Road weight capacity

Construction traffic will include concrete trucks, stone haulers, equipment and structural steel haulers. Frequency and type of fuel product deliveries is uncertain at

Truck / tanker weight should be limited to weight capacities for township roads being utilized. Alternately, impacted township roads such as Cedar Hill Lane should be upgraded or repaired to meet requirements of modern heavy truck traffic.


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this time.

Neighbor’s awareness of engine testing schedule

Information currently available indicates that the frequency and duration of engine testing is sporadic.

Develop a notification method to provide advance notice to township personnel of the testing schedule (e.g., email, newsletter, newspaper, radio, website, etc.).

Neighboring land used for hunting

No information provided on tank storage specifications

Storage tank design should be double lined and capable of withstanding a bullet at close range.


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APPENDIX A: PHOTOS


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Photo 1: Blue shading represents the proposed rezoning (Ag-1 (EX) to Commercial 2) of 22 acres of farmland located at 4710 Cedar Hill Land, Black Earth, Wisconsin. The entire property is outlined in red.


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Photo 2: Rendering of Orbitec’s proposed engine testing facilities at the Ludolph Farm in the Town of Vermont.


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Photo 3: View of the Ludolph Farm, looking northeast. The proposed engine testing facilities would be constructed along the woodline to the right.


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Photo 4: View is to the southwest. Cedar Hill Lane as it approaches the Ludolph Farm is shown to the right.

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