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<title>Making it Work:  Hazardous Analysis, Why Conduct A Hazardous Analysis?</title>
<type>single page tiff</type>
<keyword>hazards analysis emergency lepc community facilities planners planning release hazardous local information chemical chemicals title facility lepcs response vulnerability fire</keyword>

                     United States
                     Environmental Protection
                        Solid Waste
                        and .Emergency
                        Response (OS-120)
                     September 1992
                     OSWER-92 -009.1
                     Series 9, No. 2
 &EPA       Making It Work
                     Hazards  Analysis
      Are your community
      planners trying to
 answer the following
. questions:

 • What are the major  •
  chemical hazards in
  our community?

 • How can we
  determine the area
  or population likely
  to be affected by a

 • What emergency
  response resources
  (personnel and
  equipment) does our
  community need?  "

 •What kind of
 . training do local
  responders -need?

 • How can we help
  prevent chemical

 The hazards analysis
 process described in this
 bulletin can assist local
 planners in answering
 these and pther important
 planning questions.

 Hazards analysis is a way
 of identifying the threats
 that hazardous substances
 such as ammonia,
chlorine, and other
chemicals pose in the
community. Under the
Emergency Planning and
Community Right-to-
Know Act (commonly
known as EPCRA or
Title III), communities
conduct hazards analyses
to develop and revise
emergency plans.. These
plans are based on
facilities where
extremely hazardous
substances (EHSs) are
present in amounts
exceeding the threshold
planning quantity (TPQ),
and for other facilities or
transportation routes that
the Local Emergency
Planning Committee
 The Making It Work bulletins are intended to provide
 technical assistance to those responsible for implementing
 the Emergency Planning and Community Right-to-Know
 Act of 1986, commonly known as EPCRA or Title III.

 Hazards Analysis, the second in the series, is intended for
 members of Local Emergency  Planning Committees
 (LEPCs), State Emergency  Response Commissions
 (SERCs),fire departments, andotheragenciesresponsible
 for emergency planning and hazards analysis.  The first
 bulletin addressed Tide III compliance and future bulletins
 will cover such subjects as SERC operations and funding.

 Inside you' 11 find practical information on hazards analysis,
 with examples drawn from successful or unique state and
 local programs. You'll also find information on resources
 available to help you establish your own hazards analysis
 program. If you know of Qther innovative hazards analysis
 programs, we'd like to hear about them. Contact your
 EPA Regional Title III office  (see page 15) or the
 Emergency Planning and Community  Right-to-Know
 Information Hotline at 1-800-535-0202.
 (LEPC) identifies as a
 focus of planning efforts.
 The following three steps
 to a community-level
 hazards analysis are
 described in the
 Technical Guidance for
 Hazards Analysis, or
 "Green Book."

 • Hazards identification
  identifies the location,
  quantity, storage
  conditions, and the
  specific hazards posed
  by the hazardous
  chemicals transported,
  manufactured, stored,
  processed, and used in
  the community.

 • Vulnerability analysis
  locates geographical
  areas and the people, .
  property, services, and
 . natural areas that may
  be affected by a

 • Risk analysis provides
  a ranking of specific
  release scenarios (e.g.,
  X pounds of chemical
  Y released from facility
  Z under certain
  conditions) based on
  the likelihood and
  severity of the release.

(continued on page 2)

 Why Conduct a Hazards
 (continued from page 1)

The Handbook of
Chemical Hazard
Analysis Procedures, or
"Brown Book,"
describes four steps
within the hazards
analysis process. The
extra step, consequence
analysis, is simply an
elaboration of the risk
analysis step discussed

To be'successful, hazards
"analysis must be an
 ongoing process — the
 three steps should be
 repeated to address
 changes in the hazards
 arid other circumstances
 in the community that
 affect emergency
 planning and response.
 Coordination between
 facilities and local
 emergency planners and
 responders during the
 process will ensure a
 thorough evaluation of  •
 the community's hazards
 and allow planners to
 focus their efforts on the
 greatest potential threats
 to the community.

 Local emergency
 planners should consider
 conducting the hazards
 analysis process in
 phases. This "phased"
approach will allow
planners to reduce the
initial expenditure of
valuable resources on
analyzing less significant
hazards and instead
focus their efforts on the
most important hazards
in the community. There
are three phases, as

• Screening phase.
  Using readily available
  information and worst-
  case assumptions,
  determine which
  facilities and hazards in
  the community should
  be the subject of a more
  detailed analysis.
  LEPCs can use
  Technical Guidance for
 Hazards Analysis to
 complete this phase
 rather quickly.

1 Planning phase.
 Refine the initial
 assumptions and get
 up-to-date information
 from the priority
 facilities identified in
 the screening phase and
 begin to develop the
 local emergency plan.

• Scenario phase. For
 priority facilities and
 transportation routes,
 develop a range of
 specific release
 scenarios that could
 pose the highest risk to
 the community. These
 more detailed scenarios
 can be used to develop
 site-specific emergency
 response plans.

The Hazards Analysis
Training Systems
(HATS) illustrated below
and elsewhere in this
publication, is a computer
program developed by
EPA to introduce local
planners to the hazards
analysis process, the
planning process,
vulnerable zone
calculations, and scenario
development. Various
screens from the program
appear throughout this
document. Contact your
Regional Title III office
or the Title III Hotline for
more information about
obtaining HATS.  •
       Hazards Analysis Training  System
                 D   Hazard Identification
                 D   Vulnerability Analysis
                 D   RiskAnatysis

      As illustrated by
      another screen
from HATS, identifying
the hazardous chemicals:
that pose a serious threat
to the community is the
first stage of hazards
analysis (see below).
Communities of all sizes
can develop simple
programs, which meet
their needs and match
their resources; to locate
these chemicals and to
identify specific
information on
hazardous situations and
the risks they pose.

Using information
submitted to LEPCs,
planners should first
identify the facilities that
use, produce, process, or
store hazardous
chemicals. Under Title
III, facilities that have
EHSs in amounts
exceeding a TPQ are
required to notify the
LEPC and designate a
facility emergency
coordinator to serve as
.the contact between the
facility and die LEPC.

Planners may also
consider identifying
other hazardous
chemicals that may pose
significant hazards to the
community. These
include flammable,
reactive, and explosive
substances; pesticides in
rural areas; other
chemicals present in
substantial quantities;
and even EHSs present
in smaller quantities.

Contacting Facilities

The first step is to
determine which
facilities have hazardous.
chemicals. Conducting a
survey of facilities in the
community that handle
hazardous chemicals can
be a time-consuming
process. Developing a
comprehensive list of
facilities to contact can
be difficult if there is no
unified source of
information about
companies in the
community. Local, state,
     Hazards  Analysis Training System
   Hazard Identification - Purpose
   Provide the planning committee with information on:

   - Chemical Identity
   - Physical and Chemical Properties
   - Storage Conditions
   - Transportation Routes
   - Potential Hazards (e.g., taxirity, flammability, reactivity)
and federal
environmental records;
Dun and Bradstreet and
Chamber of Commerce
listings; telephone
directories; tax rolls;
police and fire
department records; and
industry itself can be
sources for compiling
this list.

Once a list has been
compiled, cpmmunities
with a Small number of
facilities may find it
more effective to take a
more personal approach:
contacting facilities by
telephone, or visiting in

For most communities,
success will depend upon
the involvement of the
fire service. Fire
departments conduct fire
prevention inspections,
develop pre-incident
plans, approve
occupancy permits, serve
on the LEPC, and are
usually the first
responders during an
incident. As seen in the
examples cited below,
fire departments can play
a critical role in
gathering information for
Tide III plans.

If facility cooperation is
a problem, fire
departments have the
authority under Title III
section 312(f) to conduct
bn-site inspections and

(continued on page 4)

Know the Hazards
(continued from page 3)

obtain specific location
information on
hazardous chemicals.

.For instance, in Prince
George's County,
Maryland, fire stations
conduct inspections and
hazards analyses and
prepare response plans at
facilities covered under
section 302.

An Alexandria,
Virginia, ordinance
requires businesses that
store, use, or handle
hazardous chemicals to
obtain a hazardous  -
substances use permit
 from the fire department
 As part of the review and
 approval process, the fire
 department conducts a
 facility inspection to
 verify the types and
 quantities of the
 hazardous chemicals
 present at the facility;
 this process provides an
 accurate record for
 hazards identification

 Communities with a
 more extensive list of
 facilities could create
 outreach materials  to
 maximize the response
 from industry and the
 usefulness of the
 information that is
 provided. .Mailing out a
 comprehensive survey •
 may be necessary.  For
• example, the Wyandotte
County, Kansas, LEPC
developed a chemical
hazards survey to
identify the facilities in
the county that handled
EHSs. Facilities were
issued a questionnaire
that addressed EHSs and
26 other potentially
hazardous chemicals. If
any of these chemicals
were present, the facility
was asked to supply
information on quantity;
conditions of handling
and use; special safety
precautions and control
devices; transportation;
and facility
preparedness, such as
contingency planning,
employee safety training,
and response equipment.

The success of the Title
III planning process
depends upon the active
involvement of both
public and private
individuals; local
. planners should support
facility involvement in
 emergency planning, not
 simply as an attempt to
 force facilities to provide
 the required information
 — although Title III
 section 303(d)(3)
 authority can be
 referenced if necessary
 — but to tap into
 industry's resources in
 prevention and response
 efforts. Local planners
 may want to designate a .
 contact person for
facilities that may be
unfamiliar with the
requirements of Title III.
Some facilities have
developed community
outreach programs as a
part of the Chemical
Responsible Care
program. Responsible
Care facilities are
committed to effective
public dialogue and
addressing public
concerns by improving
facility performance.
Local planners should
strive to coordinate
efforts with these
companies and
encourage other facilities
 to become involved.


 For each facility,
 planners should identify
 the quantity of each
 hazardous chemical
 present at any storage or
 processing location, the
 physical and chemical
 properties of each
 substance of interest, and
 the conditions of storage.
 This information may be
 drawn from Title III
• reports under sections
 31 lor 312, as well as
 inspection and permitting
..records of state and local
 agencies; additional data
 may be requested from
 the facility itself.-  As part
 of Title Ill's "Right-to-
Know" concept, section
303(d)(3) requires
facilities reporting under
section 302 to provide
the LEPC, upon request,
with any information
necessary for developing
the local emergency
plan, and can serve as
compliance leverage for
uncooperative facilities
throughout the planning


Emergency planners also
need to identify the
various routes through a
community over which
EHSs are transported.
Identifying the dangers
associated with the
transportation of
hazardous chemicals will
be more difficult than for
fixed facilities because
transporters are not
required to report under
the planning provisions
of Title III.

hazardous chemical
incidents are a
significant hazard, and
such spills and releases
pose an immediate threat
to the public since they
usually occur along
normal traffic routes.
Representatives of
trucking, railroad, air
 freight, and shipping
industries, as well as
 representatives of the

 (continued on page 5) .

Know the Hazards
(continued from page 4)

facilities that receive or
produce transported
products may be able to
provide the following  .

• the hazardous chemical

• the frequency of
 shipments (daily,
 weekly, or irregular

• the form of shipment
 (tank truck, tank car,
 drums, boxes, carboys
 in trucks or vans,
 pipelines, barges); and

• the quantity of each
 shipment (tons or
 gallons), and/or the
 number of drums,
 tanks, vats, or carboys.

Planners in Butler
County, Kansas, a
relatively rural area,
initially assumed that
few hazardous chemicals
were used or stored in
their community. The
county, however, has
five major highways, two
railroad lines, and 800
miles of pipelines, so the
LEPC conducted a
survey to identify the
hazardous chemicals
transported into, out of,
or through the county.
The LEPC developed a
form for traffic watchers
asking for the type of
vehicle carrying a
hazardous chemical  and
its placard number.
Eight major entrance
points to the county, as
well as seven points
within the county, were
surveyed over 12 hours
to determine peak
transportation times.
When the survey was
completed, the
information was plotted
on a large map to give
the LEPC a picture of
where the hazardous
chemicals are and which
are the major routes of
concern for planning

Planners may also want
to coordinate with
adjoining communities to
share transportation
information and reduce
their collective
workload. For example,
although Alexandria;
Virginia, does not have
any heavy industry, it is
part of the major
transportation corridor
through and around
Washington, D.C. An
Alexandria  LEPC
representative serves on
a multi-jurisdictional
task force on hazardous
chemicals transportation
which is exploring ways
to reduce the likelihood
of hazardous chemical
accidents and developing
incident response
procedures for multi-
jurisdictional events. In
addition, the Alexandria
LEPC requests
transportation route
information from
facilities as part of its
hazards identification
program under the
authority of Title III
section 303(d)(3).

The Hazardous Materials
Transportation Uniform
Safety Act of 1990
(HMTUSA) provides
funding for determining
flow patterns of
hazardous materials.
Contact your SERC and/
or the state HMTUSA
contact for more
information. •

      After identifying the
      chemical hazards
in the community, but
before making an       :
assessment of the overall
risk they pose, local
planners should conduct
a vulnerability analysis
to estimate who is at risk
from a potential
hazardous .chemical
incident (see below).
Using specific
vulnerability analysis
estimates the
•geographical area that
may be affected as a
result of a spill or
release.  Specific-ally, the
vulnerability analysis
identifies people
(numbers, density, and
types — facility
employees, local
residents, and special
populations) within the
vulnerable zone; private
  and public property and
  essential support systems
  (water, food, power, and
  communications sources,
  as well as facilities such
  as hospitals, police, and
  fire stations) that could
  be damaged; and
  sensitive natural areas
  and endangered species
  that could be affected.

  In Pierce County,
  Washington, the LEPC
  also incorporates natural
  hazards, such as fault
  lines and floodplains,
  into the mapping system
 that identifies vulnerable

 During an actual
 incident, the area
 potentially affected by a
 release is simply the area
 downwind. But because
 the wind direction at the
 time of the release
 cannot be predicted,
 planners must consider
 all possible wind
 directions and
 subsequent toxic plume
 paths. Consequently,
 vulnerable zones are
. circles with the release
         abiUty Analysis
of our community that maybe affected by
     The geographic
   airborne release erf a hazardous chem
     The populations within the zone that may be subject to harm
           hospitals) that are. at risk
     Critical faH1iH«*t in the zone (e.g.
site located at the center.

Estimating vulnerable
zones for toxic hazard?
may be done by hand, or
with the assistance of a
computer modelling
program. If the task is to
be completed by hand,
the Technical Guidance
for Hazards Analysis
provides complete step-
by-step instructions,
including the
mathematical formulas
and tables for calculating
the radius of the zone.

Planners will also need to
gather maps of the
planning district and
surroundings, and
information sources (e.g.,
Material Safety Data
Sheets and section 312
Tier n reports) on the
hazardous chemicals

Always keep in mind that
the vulnerability analysis
results are only as good
as the assumptions that
were made throughout
the process.  The results
are estimates, best used
for planning and training,
and not to be relied on
during an actual

If sufficient resources are
available, a computer
modelling system will
reduce the time spent
calculating vulnerability
zones. Plume modelling
                                                                        (continued on page 8)

The federal government provides guidance, technical assistance, and training related to hazards analysis. The Technical
Guidance for Hazards Analysis (EPA, FEMA, DOT) (OSWER-88-001,1987) describes a methodology and provides
equations and tables for screening possible airborne releases of extremely hazardous substances. This guidance is a tool
for emergency preparedness and is not designed for direct use in a response situation.

EPA's Successful Practices in Title III Implementation series describes innovative projects undertaken by SERCs and
LEPCs across the country, and is designed to disseminate information on successful practices with LEPCs, SERCs, fire
departments, and other Title III agencies. Issue #8 from October 1991 (OSWER 91-006.2) includes a subject index that
outlines all of the hazards analysis and other Title Ill-related efforts described in this series. In addition, each LEPC or
SERC profile contains the names of individuals who may be contacted for more information.

Contact theEPCRA Hotline at (800) 535-0202 to obtain free copies of these Successful Practicesbulletins and the Technical
Guidance for Hazards Analysis, or write:

                                        Emergency Planning and
                              Community Right-to-Know Information Service
                                           Mail Stop OS-120
                                           401 M Street, SW
                                        Washington, DC 20460

CAMEO (Computer-Aided Management of Emergency Operations), designed by the National Oceanic and Atmospheric
Administration (NOAA) and EPA, is available in two formats — for Macintosh and IBM-compatible computers. The
CAMEO system includes databases for chemical name and synonyms; Response Information Data Sheets for more than
4,000 chemicals; the capability to manage data about response resources, emergency contacts, facilities, transportation
routes, special populations, and Title in reports; the capability to calculate screening zones as well as to develop incident
scenarios; mapping software which allows plotting of the data base information; and an air dispersion model. CAMEO
is available for approximately $345 for government and non-profit organizations (county maps with 1990 US Census
data are available at an additional charge) from:    .                                            .

                                         National Safety Council
                                       Attn: Ms. Sabrina Radford
                                       444 North Michigan Avenue
                                        Chicago,-IL 60611-3991      .

The Handbookof Chemical HazardAnalysis Procedures (FEMA/DOT/EPA, 1988) addresses hazards analysis on a site-
specific basis and introduces the Automated Resource for Chemical Hazard Incident Evaluation (ARCHIE) computer
software package.  ARCHIE  can help emergency planners  understand the magnitude of potential toxic, explosive,
reactive, and flammable hazards (e.g., the size of fireballs, the distance at which explosion effects will be felt, and the
size of toxic plumes and their dispersion rates), the sequence of events likely to produce an incident, and the response
actions necessary to mitigate the release at a specific site. ARCHIE and the Handbook of Chemical Hazards Analysis
Procedures are available upon written request free of charge from:

                                 Federal Emergency Management Agency
                                        Publications Department
                                            500 C Street, SW
                                         Washington, DC 20472

                 Protective Actions: Evacuation and In-Place Protection
  Although decisions on personal protection must be made at the time of an actual event, effective hazards analysis will
  assist in training and planning for protective actions. Short-term releases, fast-moving plumes, or unstable weather
  conditions can make evacuation difficult; often the danger is over before an evacuation can be completed. In these cases,
  in-place protection may be the most appropriate action during the release of a chemical. On the other hand, if the release
  occurs over an extended period of time, or if a fire cannot be quickly controlled, an evacuation may be the appropriate
  option. Decisions should be based on several important factors:

       •      Physical and chemical properties of the hazardous substance;

       •      Short-term exposure effects;

       •      Dispersion patterns;

              Weather conditions;

       •      Anticipated size, duration, and rate of the release; and

       •      Concentration of the release in the surrounding air, water, or land.

  The emergency planning process can help build a sense of trust between citizens and emergency responders to improve
  public understanding of the need and methods for conducting effective protective actions. For example, parents must
  be confident that local school officials will take appropriate protective measures during an incident, so that their first
  action is not to rush outside to pick up the children at school, but to protect themselves.  In St. Charles Parish,
  Louisiana, the LEPC annually issues a brochure to all citizens on protective action procedures, and takes a pro-active
  approach to communicating this message to the public. Full community emergency siren drills are held annually, and
  three full-scale chemical release exercises are held at local facilities during the course of the year. The Har ford County,
  Maryland, LEPC, in conjunction with a local cable television company, produced a video to identify the proper steps
  to take in response to a potential hazardous materials incident The video also suggests that families should conduct
  hazardous material release drills just like a family fire drill.
Know the Potential •
(continued from page 6)

software packages are
often included as part of
a more complete
emergency planning
system designed to .
address many elements
of the emergency
planning process.
are two computer
systems that the federal
government has designed
and made available to
assist local emergency
planners in preparing for
and responding to an
airborne release of a
hazardous chemical.

•CAMEO also provides
the tools necessary  to
manage and. use
.information collected
under Tide III. The
system was developed by
the National Oceanic and
Administration (NOAA)
 and EPA to assist
 LEPCs, emergency
 responders, emergency
 planners, and others
 involved in activities
 concerned with the safe
 handling of chemicals
 (seepage?).  CAMEO is
 being used by local
 governments, fire
 departments, and
. industry throughout the
 United States, including
 the cities of Miami
 (Florida) and Portland
Several other systems are
also available and have
been documented in
EPA's CEPP Technical
Assistance Bulletin:
Environmental Computer
Systems for Planning
Purposes (OSWER-89-
005). Contact your
Regional Title III office
fora copy (see page 15).i

      Once the chemical
      hazards in the
community and the
potential areas of impact
for their release have
been identified, the third
stage in a hazards
analysis, risk analysis,
can be conducted. Risk
analysis is a judgment .
made by the LEPC based
on an estimate of:
(1) Likelihood of an
accidental release, based
on various factors such
as the history of releases
at fixed facilities and in
transport, current
conditions and controls
at facilities, unusual
conditions, and the
possibility of
simultaneous emergency
incidents (such as
flooding or fire) resulting
in the release of
hazardous chemicals;

(2) Severity of
consequences — the
people, places,  and
things located within the
vulnerable zone. Risk
analysis  does not require
extensive mathematical
analysis  (although
probabilistic risk analysis
can provide valuable
information to
community planners),
but instead relies on the
knowledge, experience,
and common sense of
local emergency planners
and responders using
information gained from
        KNOW THE ODDS:
hazards identification
and vulnerability

In Wyandotte County,
Kansas, for example, the
LEPC ranked facilities
based on the ratio .
between the total amount
of the hazardous
chemical on site and the
quantity of concern (a
measure of a substance's
acute toxicity).  The
ranking was thus a
measure of the relative
health threat that a
release might pose to the
surrounding community.
Facilities that had at least
1,000 times the quantity
of concern for a chemical
were given first priority
in .the planning process; a
second tier of facilities
with a smaller multiple
of the quantity of
concern were addressed
in a second phase of the


Across the country, there
are several thousand  - .-
LEPCs and tens of
thousands of facilities
that have made the  •
required notification
under section 302 of
Title III.  Inevitably,
there will be differences
between the hazards
analysis process in one
community and that of
another, but any
successful program will
be driven by three

• Focus on the most
  severe threats to the

• Responsiveness to the
  community's chemical
  preparedness and
  prevention concerns
  and interests and the
  community's right-to-
  know; arid

• Effective coordination
  and involvement
  among  planners,
  responders (e.g., the
  fire service), and

Address Priority

Because  planners are
usually not able to
evaluate  and address the
risks posed by every
facility at the same time
or to the same extent,
priorities must be set
among the potential
hazards in the
community. The
Technical Guidance for
Hazards Analysis
suggests that planners
perform an initial
screening of hazards   •
using readily available
information (e.g., Tier II
reports) and certain
credible worst-case

Once this initial three-
step hazards analysis
(i.e., hazard
vulnerability analysis,
and risk analysis) has
been completed,
planning officials should
consider redoing the
analysis based on the  •
priority ranking obtained
from the initial round of
risk analysis. These
revised analyses will be
. based on more realistic
assumptions about site-
specific conditions
derived from consulting
with facility!
representatives and other
local officials.

To perform such
analysis, local planners
may want to request
additional information to
evaluate specific release
scenarios for each
priority facility,
including the adverse
health effects of each

 (continued on page 10)

Know the Odds
(continued from page 9)

substance; successful
mitigation approaches
used in the past; lessons
learned from past events;
and facility process
hazard analyses. In
addition, e-xisting
emergency response
plans may also be a
valuable information
source.  Planners may
want to review:

• Their community's
 FEMA local multi-
 hazard emergency
 operations plans
 (required and funded
 by FEMA);

• Facilities'
 hazard plans;

• Facilities' emergency
 response planning
 required by OSHA's
 section 126) and
 process "safety
 management standards;

• Facilities' emergency
 response program
 required as part of the
 risk management plan
 under section 112(r) of
 the Clean Air Act;

• The Spill Prevention,-
 Control, and
 Countermeasures plans
 (required under the
 Clean Water Act), if
 they are available; and

• State and local
 planning requirements.

HATS (see below) also
provides additional
guidance on the phased
approach to hazards

The Hamilton County,
Ohio, LEPC identified
ten priority facilities and •
requested that they
conduct the hazards
analysis themselves,
using the Technical
Guidance for Hazards
Analysis and ah LEPC
worksheet for
vulnerability and risk
analyses. After LEPC
review, the initial facility
risk analyses appeared to
underestimate both the
likelihood and the
severity of consequences
of an accidental release,
so the LEPC developed a
second, more
quantitative risk
evaluation form.
Probability is estimated
     Hazards Analysis Training  System
                O  Introduction
                    Screen and Set Priorities
                Q  Use More Realistic Assumptions for Planning
                     Develop Scenarios for Site Spedfic Planning
.based on contingency
planning, storage
conditions, monitoring
and inspection
procedures, history of
leaks and spills, and
employee hazardous
chemical awareness.
Severity of potential
.consequences is rated
based on the capacity of
on- and off-site response
personnel and the
anticipated property
damage and
environmental effects.
Points are assigned for
factors that reduce the
probability and severity
of a release — the lower
the score, the higher the
probability or severity of
a release.

Adapt Analysis to
Local Circumstances

Even though the federal
government has provided
guidance and-software to
assist SERCs and
LEPCs, Title III is a
local program  and
decisions about relative
risk and planning
priorities are local
decisions that will differ
from place to place,
depending upon
circumstances. For
example, the availability
of resources (i.e.,
equipment, expertise,
volunteer time, and
dollars, as well as the
creativity and
 resourcefulness of LEPC

 (continued on page 11)

                       Maximizing Your Hazards Analysis Resources
  Coordinate to Avoid Duplicative Efforts

        Use existing Title IE, inspection, and permitting records to avoid time-consuming data collection efforts.

  •     Share computer resources to avoid expensive purchases.

  •  '   Coordinate with adjacent localities to share the burden of evaluating hazards.

  •     Identify and use chemical-specific and hazards analysis expertise of local industry.

  •     feeview existing emergency operations plans to identify hazards.

  •    ' Support chemical emergency prevention and other emergency preparedness efforts to maximize value of hazards
        analysis task.

  Take Advantage of Free or Inexpensive Federal Resources

  •     Technical Guidance for Hazards Analysis ("Green Book")

  •     Computer-Aided Management of Emergency Operations (CAMEO)

  •     Handbook of Chemical Hazards Analysis Procedures

        Automated Resource for Chemical Hazard, Incident Eyaluatioa..(ARCHIE).-,^.   . ,.-.      ,,;i«il ,  SJ.,—^
                                 ~"^:'--';:. vfW*^^£^«-x..;n^v -^^ .^^z^?<>y,^..-,^f^^:^^z,i

  •     Training and workshops on hazardiFanalysisi^gp HATS-program)," --_;''~     < r  "  *~~™:.;i~ "'  E^;.   L
                                   -'"•^SV^ -  '"•  J-^:».c~-—•--.-- *'-" . •'"- T* •- ,- •—      " "  -*•—,* •"'"•• i-" '  ~-rr- -^ ., '-• -v -.- -  . L"lnj,     * •
                                     -- - - -'-  - --.-" -. -    -  • r -  . ~~—    ..   .  ,    .  --    t...  .if -   ~~~—— • v- - ~~  _ -  >
  •     Emergency Planning and Comm.unity Right-to-Know Information Hotline: 1-800-535-0202.

  Apply for Grants under HMTUS A

  The Hazardous Materials Transportation Uniform Safety Actof 1990 (HMTUSA) provides for grants to support LEPCs
  in conducting hazards analyses. Hazards analysis is identified as one of the activities eligible for funding under  the
  planning grant program. These grants, and grants for training efforts, will be available through 1996.  LEPCs should
  contact the state agency designated by the Governor as the primary lead for the HMTUSA program to learn more about
  the state's planning grant application.
Know the Odds
(continued from page 10)

members and the
willingness of facilities
to cooperate with
LEPCs) will play a major
role in shaping the scope
of local planning
activities. A number of
ways to stretch local
resources are highlighted
in the box. on the
preceding page.

Rather than ranking
facilities or release
locations, the Pasadena,
Texas, LEPC focused its
hazards analysis on
fifteen priority chemicals
manufactured or stored
in the community that
facilities judged to be of
major concern in the
event of a release. For
each chemical, the LEPC
identified locations and
quantities, modes of
transportation, and the
substance's hazardous
properties. The LEPC
then conducted a
vulnerability analysis for

(continued on page 12)

Know the Odds.
(continued from page 11)

each chemical location
using typical weather
conditions.  Next, the
LEPC determined which
people and services a
release could affect and
the specific hazards they
might face.

In addition to the
chemicals classified as
airborne toxics, Pasadena
examined chemicals that
present flammability or
        Flammables and Ex
 Although none of the current EHSs was designated based
 upon its flammableand explosiveproperties, EPA recently
 published an Advanced Notice of Proposed Rulemaking
 to add commercial explosives and blasting agents, and is
 evaluating- options for flammable substances.  This
 addition, if enacted, would provide fire departments and
 LEPCs with information on explosive hazards that is not
 currently being provided under sections 311 and 312
 because'these substances are dangerous in quantities
 below  the 10,000  pound reporting threshold. Local
 contingency  planners could then formally address
 substances beyond  those currently listed under section
 302. For the present, however, communities that wish to
 evaluate flammable and explosive hazards should use
 existingpermittingorlicensing information or theauthority
 of section 303(d)(3) of Title IE.

 Because the Technical Guidance for Hazards Analysis
 does not address flammable and explosiye.hazards, the4?
 evaluation of additional hazards that these substances"
 pose can be formally conducted using the Handbook of-
 Cliemical Hazards Analysis Procedures and. ARGHIEr
 Reviewing these hazards can direct planning efforts to
 additional sites, or indicate that a specific site deserves
 priority because itposesmultiple hazards to thecommunity.
 ARCHIE has modelling programs for fires and explosions
 of flammable liquids and gases and detonations of solid
 and liquid explosives.  In order to model these  release
 scenarios, planners must identify certain physical and
 chemical properties of the substance, the quantity involved,
 the type of release, the existing temperature and pressure
 conditions prior .to  the release, and weather conditions.
 Some of these data may be available from sections 311--
 312 reports,, fire department records, or from the facility,
 if reporting is not required.
explosivity hazards (for
more information on
these hazards, see
below). The.LEPC theri
ranked the fifteen
chemicals so that
planners could identify
the community's
response needs.

The State of Idaho used
Technical Guidance for
Hazards Analysis as a
starting point and
developed a "blueprint"
for LEPC hazards
analysis efforts. The
step-by-step guidance to
hazards analysis explains
how to incorporate the
use of such programs as
but focuses on planning
and information
management methods
that do not require a
computer.' •

      Once the LEPC has
evaluating the hazards in
the community, the
hazards analysis
information can be used
to support other local
chemical emergency
preparedness and
chemical accident
prevention efforts.
The realistic release
scenarios for the priority
hazards in the
community, refined from
initial worst-case
assumptions, can be
communicated to the
community to help
improve awareness of
chemical hazards. The
local emergency
response plan can then
be designed to address
specific incidents
.described in these

In the event of an actual
incident, current weather
conditions (e.g., wind
direction and speed,
atmospheric stability)
and accurate release data
(e.g., quantity and rate of
release) can be entered in
the appropriate pre-
existing scenario-to
derive realistic estimates
of possible off-site
impacts of the release.
In addition to planning
and real-time response
applications, scenarios'
can be used to develop
realistic exercises to test
. local emergency
response capabilities.
LEPCs, SERCs, and
facilities are also
applying hazards
analysis to help facilities
prevent of chemical

Getting the Word Out

The LEPC has a
responsibility under
section 324 of Title III to
inform the public about
its right to know. Many
LEPCs have gone
beyond the modest
mandate to publish the
fact that the various
facility reporting forms
and LEPC plans are
available for public

During EPCRA   .
Awareness Week
(January 1992), the
District XI LEPC in
Florida, serving
B reward, Dade, and
Monroe, counties, held
public outreach
workshops focusing on
citizen information. The
workshops included
presentations explaining
the hazards
vulnerability and risk
analysis process, and
graphically showed
citizens sample facilities
and their respective
vulnerability zones.

In addition, the Sun-
Sentinel published a
feature story and a two-
page article that named
and located on a county
map the over 80 facilities
reporting under section
302 and listed the   .
extremely hazardous
substances at those
facilities in Broward
County (Ft. Lauderdale
metro area).  All of the
LEPCs in Florida
reported a measurable
increase of public
requests for EPCRA
information as "a result of
the Awareness Week


Knowledge of the
hazards  present in  the
community will enable
planners to identify what
response personnel and
equipment are needed for
the community, as well
as what training will be
The identification of the
health threats in the
community will support
the development of
necessary emergency
medical care procedures.

Public notification and
alarm systems in the
community should
reflect the results of
vulnerability analyses.
Public education efforts
may be needed to
describe evacuation and
in-place protection

The Alaska SERC is
providing technical and
financial assistance to its
LEPCs as part of a state-
wide hazards analysis
project The project
generally will follow the
airborne toxics approach
outlined in the Technical
Guidance for Hazards
Analysis, but the analysis
has been expanded to
include facilities with
flammables and
explosives, as well as the
potential for chemical
and petroleum spills to
impact the drinking
water supply or sensitive
ecosystems.  Once the
information has been
compiled at the local
level, it will be
transferred into a state-
wide CAMEO  system,
and eventually
incorporated into a
Information Systems

(continued on page 14)

Using the Results
(continued from page 13)

format along with data  -
from other state
environmental programs.

'The hazards analysis
data will also be used as
the basis for evaluating
emergency response
capabilities as part of an
effort to establish
volunteer response teams
and equipment depots
across Alaska.

As part of the hazards
analysis process, local
fire departments and
other planning officials
may want to inspect
facilities to collect
specific information and
develop a working
knowledge of the facility
in order to pre-plan for
an emergency response
situation. The
emergency dispatcher
can be made aware of
locations with extra
hazard potential in the
event of an emergency
 (e.g., incompatible
materials stored in close
 proximity or extremely
 flammable or explosive
 substances.) A special
 notation can be included
 to indicate that the local
 hazardous materials team
 should be dispatched
 immediately of placed on

 Under the Clean Air Act
. Amendments of 1990,
 many facilities in your
community may be
required to provide
information on the ways
they manage risks posed
by certain substances
listed by EPA and
indicate, by submitting a
risk management plan
(RMP), what they are
dqing to minimize risk to
the community. These
provisions are likely to
generate more detailed
information useful for  •
LEPC planning purposes-.

One component of the
RMP will require
facilities to prepare
detailed off-site
consequence analyses.
The RMPs, with their
analysis of off-site  •
impacts, will help LEPCs
update their community
plans. LEPCs will also
be better able to
coordinate community
plans with facility plans.

The Chandler Fire
Department in Arizona
requires facilities with
certain categories of
hazardous chemicals to
file a hazardous materials
management plan
(HMMP) when applying
for a hazardous materials
permit. The HMMP
includes a section
requiring completion of a
vulnerability analysis.
Their guidance for
preparation of a
 vulnerability analysis
 suggests using the
 Technical Guidance For
 Hazards Analysis for
 information regarding
 vulnerable areas.  This
 HMMP is similar to the
 RMP that is required by
 the Clean Air Act


 Hazards analysis allows
 local emergency planners
 and industry to work
 together to reduce
 hazards in the community
 and prevent future
 accidents. As with the
 implications for planning
 efforts (see page 13), the
• LEPC, or specific
 members such as the fire
 departments, can identify
 prevention strategies
 while gathering the
 information to conduct
 the hazards analysis.
 Some important
 questions to keep in mind
 when looking at a
 specific facility are:

 • What possibilities exist
   for substituting less   .
   dangerous chemicals for
   any hazardous
   chemicals at the

 • What possibilities exist
   for reducing the
   quantity of the
   hazardous substances in
 use or stored at the
 facility? Can this be
 done without increasing
1 Have operation or
 storage procedures
 been modified to
 reduce the probability
 of a release and
 minimize potential

• What  is. the overall
 layout and spacing of
 the storage  area,
 process areas; and other
 positions with respect
 to the plant property
 line?  What is the
 spacing'between the
 individual equipment
 both in storage and
 process areas?  Are
 incompatible chemicals
 separated sufficiently?
 What areas and
 pathways will be
 available for the
 movement  of personnel
 'and vehicles in the
 event of an emergency?
 Are placards describing
 the hazard of the
 chemical displayed

• How  are the hazardous
 substances received/
 shipped? How often
 and in what quantities?
 Are there dedicated
 personnel trained, in the
 handling of these
(continued on page 15)

Using the Results
(continued from page 14)
The role of hazards
analysis in a chemical
accident prevention
program can vary from
influencing a single
facility's inventory
decisions to serving as
the basis for a state-wide
initiative. The
Washington, B.C., LEPC
and the State of
California are examples
at each end of the
spectrum. After
receiving a section 302
notification from a local
water treatment plant, the
Washington, D.C.
LEPC encouraged the
facility to reduce its
storage of large
quantities of chlorine.
The company did not
realize the potential
hazards such storage
posed to the surrounding
community, and   ....•:  ~.
' volunteered tolreduee.its.
on-site  inventory.  .:  . ""
           ^SKsT^"" > •- *• _,.^- - ,.,,'z
On the other hand, the
State of California has
developed, as part of its
implementation of state
legislation, the Risk
Management and
Prevention Program
(RMPP).  The program is
designed to reduce the
number of releases and
the potential for
casualties and
evacuations; to reduce
facility expenses for
equipment breakdown,
materials loss, cleanup
 costs, and claims
 litigation; and to improve

 Facilities with the
 potential for a significant
 off-site impact from an
 EHS release are required
 to develop an RMPP.  A
 comprehensive facility
 RMPP report includes a
 record of EHS accidents;
 a description of the
 equipment used in
 conjunction with EHSs;
 facility controls to
 minimize the risks of  a
 release; monitoring,
 backup, mitigation, and
 transportation and
 storage procedures and
 systems; and the facility
 safety audit, inspection,
 and recordkeeping
 policy. The final step in
•thefaciUty^RMPPJsj -
' as trie basis f0r"'""
 developing a facility
 prevention program
 consisting of release
 reduction techniques,
 systems, and procedures,
 and a schedule for their


 Hazards analysis is an"-
 ongoing process.
 Unfamiliar hazards and ,
 inaccurate records can
 seriously undercut the
effectiveness of
contingency planning
and emergency response
procedures. Records
must be regularly
updated to account for
new chemicals and
facilities in the
community, changes in
the quantity of chemicals
at facilities, or even the
movement of chemical
storage and process
locations within .
facilities. As a result of
these changes in the
hazards environment,
local planners may need
to revise individual
scenarios for
vulnerability and- risk.

(continued on page 16)
        EPA Regional Title HI Offices
 EPA - Region 1
 New England Regional Lab
 60 Westview Street
 Lexington, MA 02173
 (CT, MA, ME, NH, RI,

 EPA - Region 2
 2890 Woodbridge Avenue
 Edison, NJ 08837-3679
 (NJ. NY, PR, VI)

 EPA-Region 3    •
 OE& Title -M Section
 841 Chestnuts tree?
 Philadelphia, PA 19107
 (DE, DC, MD. PA, VA,

 EPA - Region 4
 345 Courtland Street, NE
 Atlanta, GA 3.0365
 (AL, FL, GA, KY, MS,

 EPA - Region 5
 77 West Jackson HSC-9J
 Chicago, IL 60604-3590
 (IL, IN, MI, MN, OH, WI)
EPA-Region 6 '
Allied Bank Tower
1445 Ross Avenue
Dallas, TX 75202-2733
(AR, LA, NM, OK, TX)

EPA - Region 7
726 Minnesota Avenue
Kansas City, KS 66101
(IA, KS, MO, NE)  •

EPA - Region 8
One Denver Place
999 18th Street, Suite 500
Denver, CO 80202-2466
(CO, MT, ND, SD, UT,

EPA - Region 9
75 Hawthorne Street (H-1-2)
San Francisco, CA 94105
(AS, AZ, CA, HI, NP, NV,

EPA - Region 10
1200 6th Avenue (HW-114)
Seattle, WA 98101
(AK, ID,  OR, WA)

Using the Results
(continued from page 15)

Thus, the additional
infonnation required for"
these stages in a hazards
analysis (e.g., the
identification of schools,
hospitals, and other
special populations;
community emergency
response capability; and
facility release
prevention and
mitigation procedures)
should also be updated
regularly.  .

Although hazards
analysis can seem at first
a highly resource-
intensive and complex
task, it is the
responsibility of the
'  LEPC to put the process-
  of hazards identification,
  vulnerability analysis,
  and risk analysis into
  practice in the
  community so that
  vulnerable populations
  can be protected.  As
  described in this bulletin,
  each of these steps can
  be, and have been,
  conducted in a fashion
  that matches LEPC
  resources and concerns,
  and the process itself can
  be used to support a
  variety of other chemical
  emergency preparedness
  and prevention
  activities.  •
       Read More About It
The examples used in this bulletin are drawn
from EPA's series, Successful Practices in Title
III Implementation, which is  available from
your regional Title III office (see list on page
15), or by calling the Emergency Planning and
Community Right-to-Know Information Hotline
at 800-535-0202. Nine bulletins are currently
available in this series, covering a wide variety
of Title HI implementation practices successfully
employed by a large number of SERCs and
     United States      -
     Environmental Protection
     Agency (OS-120)
     Washington, DC 20460
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