Guides to Chemical
 Risk Management
EPA 550-B-99-015
May 1999
 Evaluating Chemical
 Hazards in the Community:

      Using an RMP's Offsite Consequence Analysis
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  Permission to reproduce  this guide is
granted with the accompanying credit line:
"Reproduced from Guides  to Chemical
Risk Management, Evaluating Chemical
Hazards in the Community: Using an RMP's
Off site Consequence Analysis, with permis-
sion from the National Safety Council's
Environmental Health Center, May 1999."
              May 1999
The Current Status of the Risk Management
Program Rule
  As of the publication date of this backgrounder, key
elements of EPA's Risk Management Program Rule are still
not final. Public access to the offsite consequence
analysis data continues to be debated. EPA has not
officially decided on how it will respond to Freedom of
Information Act requests. The agency has said that while
the offsite consequence  analysis data will not be distrib-
uted to the public on the Internet, it will supply paper
copies of the data upon request. Also, EPA intends to
increase the reportable quantity of hydrocarbon fuels
(i.e., propane). Concurrently, the U.S. Court of Appeals
granted an interim stay of the Risk Management Program
Rule as it applies to facilities using propane in a process.
For the most current information, see http://www.epa.gov/
ceppo.

For More Information
  The National Safety Council is maintaining the Chemi-
cal Emergency Management Web site at www.nsc.org/
xroads.htm as a resource supplement to this series of
publications. The site is a directory of Risk Management
Program-related links to organizations, regulations,
chemicals, rules, and regulations involved in emergency
management and the safe handling of chemicals. A
selection of articles and papers written about the  Risk
Management Program Rule and local efforts to identify
and analyze risk in the community is also included. The
site will be constantly expanding as industry and commu-
nities develop new information required under the Risk
Management Program Rule.

Other Publications in this Series
  Other documents in the Guides to Environmental Risk
Management Series are listed below:

U New Ways to Prevent Chemical Incidents
U How Safe Am I? Helping Communities Evaluate
  Chemical Risks
U What Makes a Hazard Hazardous: Working with
  Chemical Information
U Chemical Safety in Your Community: EPA's New
  Risk Management Program

  These documents can be downloaded for free from the
Chemical Emergency Management Web site at
www.nsc.org/xroads.htm.

About this Document
  The Environmental Health Center produced this guide
under cooperative agreement CX 826604-01-0 with the
U.S. Environmental Protection Agency. It is part of a
series of publications on the Risk Management Program
Rule and issues related to chemical emergency manage-
ment.

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Evaluating  Chemical
Hazards  in  the  Community:
Using an RMP's  Offsite Consequence Analysis
  Chemical incidents that
cause fatalities, injuries,
and property damage occur
all too frequently. Fortu-
nately, catastrophic
incidents such as the 1984
methyl isocyanante release
in Bhopal, India, are
extremely rare. But the
potential for disaster is
always present.
  According to the Chemi-
cal Safety and Accident
Investigation Board (CSB),
for the years 1987 through
1996, an average of 60,000
chemical releases, spills,
and fires occurred annu-
ally—42 percent of the
incidents occurred at fixed
facilities (Figure 1). The
CSB estimates that during
this 10-year period, 2,565
people were killed or
injured by chemical
incidents.
  Hazardous substances in
the community present
both reporting opportuni-
ties and challenges.
Chemical names, quanti-
ties, locations, and health
effects, as well as popula-
tions vulnerable to a
release, are key story
elements. But frequently
this information is difficult
to obtain. The Risk Man-
agement Program Rule
(RMP Rule), a new U.S.
Environmental Protection
Agency (EPA) regulation
set to take effect June 21,
1999, will provide some
answers by (1) requiring
regulated facilities to
conduct a hazard assess-
ment and (2) making it
available to the public.
  The hazard assessment
will consist of an inventory
of listed substances,  a five-
year history of releases,
and an offsite consequence
analysis (OCA). The OCA
is the  centerpiece of the
hazard assessment; it is an
estimate of harm to people
and the environment
beyond the facility's
fenceline that can result
from a chemical release.
The OCA answers four
basic questions  needed to
understand a chemical
hazard:

Q What hazardous
  substance(s) could be
  released?
i_) How much of the
  substance(s) could be
  released?
Q How large is the hazard
  zone created by the
  release?
L) How many people could
  be injured?
        Total Transportation and Fixed-Facility Incidents
                         1987-1996
   1996
   1995
             10,000   20.000   30.000   40.000   50.000   60,000
                Fixed Facility Incidents [  Transportation Incidents
                                      Figure 1: The CSB reported
                                      that an average of approxi-
                                      mately 60,000 hazardous
                                      materials incidents occurred
                                      annually between 1 987 and
                                      1996—42 percent of the
                                      incidents occur at fixed
                                      facilities. These incidents
                                      were placed into five
                                      categories: fixed-facility
                                      transportation, outside,
                                      other, and no data. This
                                      chart only reflects data on
                                      two categories and repre-
                                      sents 85 percent of the total
                                      incidents (Chemical Safety
                                      and Hazard Investigation
                                      Board April 1999).

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                Types of Facilities Regulated by the
                  Risk Management Program Rule
                        Chemical
                      Distributors 7 ':•
         Electric/Gas Utilities
             5%
   Chemical/Petrochemica I
    Refineries and Allied
      Industry 5%
                                                      Propane Retailers
                                                       and Users 44%
      Ammonia Refrigeration
            9%
            Agriculture Retailers
                 10%
                                                  Other 11%
                               Drinking Water and
                             Municipal Waste Treatment
                                 Facilities 14%
Figure 2: Facilities that have more than specified threshold quantities of
any of 77 acutely toxic substances or 63  flammable substances must submit
an RMP Initially 44 percent of the  66,000 facilities affected by the Risk
Management Program Rule were propane distributors and users. This
number could change dramatically if proposed legislation to exempt
propane from the RMP or an EPA proposal to raise the reporting threshold
for hydrocarbon fuels become effective.
              The History of the
              RMP Rule
                The RMP Rule builds on
              the  earlier emergency
              planning and community
              right-to-know efforts
              implemented under the
              Emergency Planning and
              Community Right To Know
              Act of 1986 (EPGRA).
              Under EPGRA, facilities are
              required to file reports if
              the  quantities of the
              hazardous chemicals
              exceed specified thresh-
              olds. In 1987, EPGRA
              launched another impor-
              tant right-to-know program
              called the Toxics Release
              Inventory. Under this
              program, facilities report
              emissions of hazardous
              substances to EPA.  With
              these programs, EPGRA
              extended right-to-know
              beyond the workplace and
              into the community.
                In 1990, Congress took
              additional measures to
              protect communities from
hazardous chemicals by
including accident preven-
tion and emergency
preparedness measures in
the Glean Air Act Amend-
ments of 1990. Section
112(r) of the Glean Air Act
authorizes EPA to develop
regulations that prevent
and prepare for accidental
releases. These regulations
are contained in the
Accidental  Release Preven-
tion Requirements: Risk
Management Program Rule,
also known as the RMP
Rule (40 GFR Part 68). The
RMP Rule focuses on
preventing  accidental
chemical releases, reduc-
ing risk  to the community
from exposure to hazardous
chemicals, and minimizing
the consequences  of
releases on the environ-
ment. The RMP's primary
goal is to protect communi-
ties from releases of toxic
or flammable chemicals
that are prone to cause
immediate, serious harm to
public and environmental
health. Flammable and
toxic chemicals that can
cause severe, acute health
effects are covered under
the rule; pyrotechnic and
explosive chemicals are not.
   Facilities such as
chemical plants, oil
refineries, propane retail-
ers, fertilizer warehouses,
ammonia users, and water
treatment plants, must
comply with the EPA's RMP
Rule by submitting a
summary of their risk
management plans (RMPs)
to EPA by June 21,1999
(Figure 2). The RMPs must
be submitted if any process
at a site contains more
than specified amounts of
140 hazardous substances,
such as propane, ammonia,
or chlorine.

Hazard Versus Risk
   Understanding the
distinction between hazard
and risk is central to using
the OGA  as one of the tools
for determining how a
community can manage
hazardous chemicals. The
OGA analyzes hazards. The
RMP Rule does not require a
risk assessment.
   A hazard is something
that is capable  of causing
harm. The bigger the
hazard, the greater the
capacity to cause harm
(DiNardi 1997). The hazard
is based on properties
intrinsic to the material and
the level and duration of
exposure. For example,
hydrofluoric acid is toxic,
propane is flammable. Little
can be done to change
these characteristics.
   The severity of the
hazard often depends on
exposure. The extent of
exposure can be influenced
by the quantity of the
substance released, the
circumstances  of the
release (for example,

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Figure 3: This is a typical map found in an RMF? showing hazardous areas, vulnerable populations, and
sensitive environments. This map shows the endpoint, distance to endpoint, and the hazard zone for one
possible scenario. The hazard zone is a circle because wind variability could cause the toxic cloud or fire
effects to go in a number of directions.
weather conditions,
topography, mitigation
measures), and the proxim-
ity to the point of release.
The severity of the hazard
can be reduced, for ex-
ample, by lowering the
quantity of the chemical
stored onsite or by improv-
ing facility  or process
design.
  Risk is a measure of
probability. The greater the
risk, the more likely the
hazard will cause  harm
(DiNardi 1997). Ideally, risk
should be quantified—for
example, a 10 percent
probability that a certain
event will occur. Too
frequently,  however, data
on rates of equipment
failure and human error are
unavailable, so it  is not
possible to  reliably quantify
the risk of a chemical
release.
  Nevertheless, we know
from experience that
certain events happen
more frequently than
others do—for example,
releases frequently occur
during transfer operations
or process startups.
Catastrophic events, like
the Bhopal tragedy, occur
rarely and would be
considered high-hazard,
low-risk events. An inci-
dent that occurs fre-
quently but does not
generate an offsite conse-
quence would be consid-
ered a low-hazard,
high-risk event.

Predicting the Distance
to Endpoint
  Potential offsite conse-
quences of accidental
chemical releases are
predicted by air dispersion
models, which estimate the
area that may become
hazardous under certain
conditions. The models
integrate information about
chemical properties and
release conditions
and forecast the scenario's
distance to endpoint.
  Though the flow of some
dense gases and vapors will
be guided by terrain
features, wind direction
will generally control
movement, creating
hazards downwind from the
point of release. Since it is
not possible to reliably
predict when accidents will
occur or what the wind
direction will be when they
do occur, released gases
and vapors may travel in
any direction. Therefore,
the total area that may be
affected by a release is
represented by  a circle
with its center at the point
of release. The radius of
the circle  represents the
distance to endpoint
(Figure 3).
  The area within the
circle is the hazard zone.
The OCA identifies vulner-
able populations and
sensitive environmental
areas within this circle.
Hazard zones can easily be
displayed graphically on
local maps that show
vulnerable populations,
such as nearby  homes,
schools, nursing homes,
businesses, or parks and
recreational areas. These

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6
vulnerable populations are
referred to in the RMP Rule
as public receptors. Envi-
ronmental receptors, such
as vulnerable parks and
designated wildlife and
wilderness areas, may also
be identified.

Models in the Real
World
   A facility can use EPA's
chemical-specific end-
points or other emergency
air dispersion models  to
calculate the distance to
endpoint. The RMP Rule
does not specify which
model should be used other
than the model should be
one that (1) is publicly
available, (2) accounts for
the required modeling
conditions, and (3) is
recognized by industry as
acceptable.
   The advantage of using
an air dispersion model is
that it may be more
accurate than EPA's meth-
odology for predicting the
mixing of pollutants in air
and the distance to end-
point. However, the results
of any model should be
viewed cautiously since few
of the fundamental algo-
rithms used by all of the
models can be verified in
actual field tests.
  Models are designed to
simulate reality—a very
complicated set of vari-
ables and interrelations
that is difficult to under-
stand and replicate.
Differences in the methods
used to combine the effects
of each variable can result
in hazard distances that
vary widely; predicted
hazard distances often lie
within a band of uncer-
tainty.
  Some OGA's will predict a
very large distance to
endpoint. Facilities must
quantify distances up to 25
miles. Still, estimating
distances beyond six miles
tends to be particularly
uncertain because of local
variations in meteorological
conditions and topography.
For example, atmospheric
turbulence is a major factor
in determining how quickly
a toxic cloud will mix with
the surrounding air and be
diluted. And how quickly a
cloud will be diluted to
below the endpoint value
will affect the distance it
travels. It is dangerous to
assume that atmospheric
turbulence  and wind speed
and direction will remain
constant from the point
where a pollutant is being
released (Evans 1998).

Worst-Case and
Alternative Release
Scenarios
  All RMPs are required to
contain an OCA for a
worst-case  release sce-
nario (Figure 4). If both
regulated toxic and flam-
mable substances are
present in  a process,
separate scenarios for
each  type of substances
must be prepared. Many
facilities will also need to
prepare alternative release
scenarios.
  Worst-case scenarios
assume there is a rapid,
       Figure 4: This map shows a worst-case scenario and a more likely alternative scenario for a typical facility. The
       differences between the size of the hazard zone in a worst-case and an alternative scenario can be based on
       a number of factors, including the facility's emergency response capability, accident history, or design improve-
       ments.

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ground-level release of
the greatest possible
amount of a chemical
from a single vessel or
pipe. Passive mitigation
devices, such as dikes
and containment walls
around the process, may
be assumed to capture or
control the release if
they would be likely to
survive the incident.
  However, active mitiga-
tion devices that require
human, mechanical, or
other energy to manage
releases must be assumed
to fail in the worst-case
scenario. In addition,
weather conditions are
assumed to be very mild,
producing minimal mixing
of the toxic gas or vapor
cloud. These conditions
produce a large, stable
cloud with a persistent,
high chemical concentra-
tion—the  most severe type
of hazard. EPA states that
the maximum hazard zone
for worst-case scenarios
may be quantified for
distances up to 25 miles.
(Note: Some scenarios may
extend further than 25
miles, but will not be
quantified beyond that
point.)
  Alternative release
scenarios  are based on
more realistic factors and
must have an offsite
endpoint,  if possible.
Facilities are given more
latitude in designing these
events. Alternative sce-
narios may be based on
the facility's five-year
accident history or on a
review of process hazards
conducted as part of the
RMP Rule's accident
prevention requirements.
Unlike worst-case sce-
narios, the weather
conditions are assumed to
be typical for the area. In
addition, these more likely
scenarios  assume that
both active  and passive
             Where to Find EPAS  Chemical-
                     Specific  Endpoints
    Many facilities appear to be using EPAs chemical-specific endpoints
 for toxics and flammables. EPAs RMP Offsite Consequence Analysis
 Guidance includes a table of values for chemical-specific endpoints.
 EPAs endpoints are intentionally designed to be conservative, erring on
 the side of greater public protection. EPAs methodology is automated in
 a computerized application called  RMP*Comp™. The program can  be
 downloaded from EPAs Web page for Chemical Accident Prevention
 and Risk Management Planning at http://www.epa.gov/swercepp/ds-
 epds.htm.
    The ready availability of these tools will help to standardize the
 results provided from various facilities and will enable emergency
 planners, community members, and facilities to more easily compare
 and evaluate RMP data from various processes.
mitigation systems operate
as intended.
   Facilities that do not
maintain any chemicals
that could cause an offsite
impact and that have not
had any accidents with an
offsite consequence in the
past five years are consid-
ered low hazard and are
not required to submit the
alternative scenario
analysis.

The Value of Worst-
Case Scenarios
   Characterizing danger
only by using worst-case
scenarios can be mislead-
ing and unnecessarily
alarming. Worst-case
scenarios estimate the
maximum possible area
that might be affected by
an accidental release.
They help ensure that
potential hazards to public
health are not overlooked.
They are not intended to
represent a "public danger
zone." Nor do worst-case
scenarios reflect whether
processes are safe. Both
safe and unsafe processes
using the same chemicals
at the same quantity will
have similar hazards.
  The objectives of the
worst-case scenario are
(1) to create an awareness
                          Endpoints
    The term "endpoint" is frequently used in the RMP Rule. Endpoints are
 used when facilities and emergency planners perform OCAs to predict
 areas that may become hazardous if dangerous chemicals are released.
    For accidents involving flammable chemicals, the distance to endpoint
 represents the area in which people could  be hurt. An explosion could
 shatter windows and damage buildings, possibly causing injuries
 because of flying glass or falling debris. Therefore, a flammable endpoint
 represents a blast wave capable of breaking glass (one pound per square
 inch of pressure) or radiant heat intense enough to blister human skin.
    A toxic endpoint defines the outer boundary of a concentration
 considered hazardous to the community. For accidents involving toxic
 chemicals, the distance is based on the ability of a victim to escape the
 area. Most people can be exposed to an endpoint concentration  for one
 hour without suffering irreversible health effects or other symptoms that
 would make it  difficult to escape.  People within the distance to endpoint
 are likely to be exposed to higher concentrations and greater hazards.
 Individuals exposed to higher concentrations for an extended period may
 be seriously injured.

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Worst-Case and Alternative Release Scenario Parameters
Factor
Event selection
Mitigation
Toxic endpoint
Flammable endpoint
Wind speed/atmospheric
stability class
Outdoor temperature/
humidity
Temperature of released
substance
Surface roughness/nearby
obstacles
Dense or neutrally
buoyant gases
Height of release
Amount released
Toxic gas release rate
Toxic liquid releases
Distance to endpoint
Worst-Case
Release Scenario
Produces greatest distance to
an offsite endpoint
Can consider the effect of
passive systems that survive the
event
From Appendix A of RMP Rule
Blast wave pressure from the
explosion of the vapor cloud
3.4 miles per hour and F class
stability, unless higher wind or
less stable atmosphere can be
shown at all times in last 3 years
Highest daily maximum
temperature in the prior 3 years
and average humidity
Liquids, other than gases
liquefied by refrigeration, are
released at highest outdoor
temperature during the prior 3
years or the process tempera-
ture, whichever is higher
Urban or rural, as appropriate
Model accounts for gas density
Ground level
Greatest possible amount from a
single vessel or pipe
All in 1 0 minutes
• Instantaneous release
• Pool area is 1 centimeter deep
or size of passive mitigation
area
• Rate at which it evaporates
must be calculated
Greatest offsite distance, up to
25 miles
Alternative
Release Scenario
More likely than worst-case
scenario based on the 5-year
accident history or failures
identified in analysis of process
hazards
Can consider effect of passive
and active systems that survive
the event
From AppendixAof RMP Rule
Blast wave from the explosion of
the vapor cloud or radiant heat
6.7 miles per hour and D class
stability or typical conditions for
the site
Typical conditions for the site
The appropriate process or
outdoor temperature
Urban or rural, as appropriate
Model accounts for gas density
Determined by scenario
Determined by scenario
Determined by scenario
Determined by scenario
Offsite, if appropriate

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about potential hazards at
the facility and in the
community and (2) to
motivate a reduction of
these hazards. Tim
Gablehouse of the
Jefferson County, Colo-
rado, Local Emergency
Planning Committee
(LEPC) stressed that the
issue of worst-
case  scenarios should not
be the focus of public
discussion. Instead, it
should lead to an emphasis
on emergency response,
risk communication, and
prevention efforts. The
purpose of the RMP  is not
to generate unnecessary
fear,  but to educate  the
public about hazard reduc-
tion  and emergency
response.
  Local emergency plan-
ning  organizations can use
RMPs to prepare response
plans and allocate re-
sources. Knowing who is
vulnerable saves  time and
resources when preparing
communications strategies;
locating equipment;  and
establishing industry,
community, and govern-
ment working relationships.

Alternative Release
Scenarios
  Based on more likely
conditions, alternative
release scenarios offer
more realistic, useful
emergency planning
information for the facility
and the public. Facilities
are given latitude in
selecting credible release
conditions for these
scenarios and can use
accident history informa-
tion or other  knowledge of
the process for selecting
the hypothetical incident.
                Questions  Reporters
          Might Ask a Facility  Manager
     What hazardous chemicals  do you have at the site that
     could endanger workers and the community? What quanti-
     ties are  kept onsite? What are their health effects?
     How many people could be  injured in a worst-case release
     scenario and in a more likely alternative release? What
     public receptors (e.g., schools, nursing homes,  and resi-
     dences) did you identify? Are local emergency  responders
     capable of handling  the number of people that could be
     injured  by such incidents?  What environmental receptors
     (e.g., parks, wildlife sanctuaries, and wetlands) did you
     identify?
     What have you done to minimize Y2K and other computer
     problems  that could  affect  process controls and result in a
     release?
     Have you secured your computer systems from outside
     sabotage?
     What steps have you taken to ensure site security? To fortify
     chemical  stores?
     Did you use EPAs methodology to determine your worst-
     case and  alternative  scenario  distances to endpoint?  If not,
     what method did you use,  and why is  it better than EPAs?
     How do the distances compare with the ones based on
     EPAs  guidance?
     Can you provide a tour of the site to show how you  are
     reducing the likelihood of a release? Can we bring our own
     experts?
     How is  the facility reducing its hazards? By substituting less
     hazardous chemicals? By reducing chemical quantities? By
     improving safety designs and worker/contractor training?
     How will  these hazard reduction initiatives increase safety?
     Is the facility willing to share its OCAs and process hazard
     analysis with the community?
     Do you have an uninhabited buffer zone around the sites
     borders to protect neighbors?
Annotated List of Accident Prevention
References and Links
  References and links to documents or Internet sites
should not be construed as an endorsement of the views
contained therein.

Federal Information
EPAs Chemical Emergency Preparedness and Prevention Office
http ://www. epa. g ov/ceppo
  This EPA office maintains a comprehensive Web page
that includes chemical accident prevention and risk
management planning information. EPA will maintain an
online database of all RMPs—in RMP*Info. However,
RMP*Info will not contain the OCA data.

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1O
  RMP Off site Consequence Analysis Guidance (http://
www.epa.gov/swercepp/acc-pre.html) is for owners and
operators to use when analyzing OGAs. RMP*Gomp™
(http://response.restoration.noaa.gov/chemaids/rmp/
rmp.html) is a software package that performs the calcula-
tions described in the BMP Off site Consequence Analysis
Guidance. These are available free through the Internet.
  Another useful EPA publication is General Guidance for
Risk Management Programs (http://www.epa.gov/
swercepp/acc-pre.html). Chapter 4 of this guidance
specifically addresses OGAs. Chapter 11, Communication
with the Public, includes information on how facilities
can address public questions  about OCAs and hazards.
  In addition to model RMPs developed by other entities,
a section of EPA's Web site for Chemical Accident Preven-
tion and Risk Management Planning (http://www.epa.gov/
swercepp/ap-ingu.htm) provides guidance documents
regarding model risk management program plans for
specific industries. These documents contain chapters
that are similar to Chapter 4 of General Guidance for
Risk Management Programs, instructing industries how to
conduct OCAs for the specific chemicals they typically
use. Already available model  plans include the following:

Q Risk Management Program Guidance for Ammonia
  Refrigeration
Q Risk Management Program for Propane Users and Small
  Retailers
Q Risk Management Program Guidance for Propane
  Storage Facilities
Q Risk Management Program Guidance for Chemical
  Distributors
Q Risk Management Program Guidance for Warehouses
Q Risk Management Program Guidance for Wastewater
  Treatment Plants
                                                EPAs Resource Conservation and Recovery Act, Underground
                                                Storage Tank, Superfund, and EPCRA Hotline
                                                http://www.epa.gov/epaoswer/hotline
                                                  This site provides information on how to contact the
                                                EPA-sponsored Hotline that addresses the Risk Manage-
                                                ment Program Rule. Other information resources are also
                                                provided. Many related documents, including those listed
                                                on the EPA site above, can be ordered by calling (800)
                                                424-9346 or (703) 412-9810 in the Washington, B.C., area.

                                                Chemical Safety and Hazard Investigation Board (CSB)
                                                http://www. chemsafety gov
                                                  The Chemical Safety and Hazard Investigation Board
                                                Web site has information about incidents investigated by
                                                the  board, as well as a library of chemical safety docu-
                                                ments and information on the year 2000 issue.

                                                Background Documents
                                                The 600K Report:  Commercial Chemical Incidents  in the
                                                United States, 1987-1 996
                                                http://www.csb.gov/! 999/news/n9916.htm
                                                  Chemical Safety and Hazard Investigation Board.  1999.
                                                The 600KReport: Commercial Chemical Incidents in the
                                                United States, 1987-1996.

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Why the 1 0-Kilometer and 1 -Hour Limits?
www. nsc. org/xroads. htm
  Evans, Mary. 1999. Dr. ALOHA: Why the 10-kilometer
and 1-hour limits? CAMEO Today (May/June 1998).

The Occupational Environment: Its Evaluation and Control
  DiNardi, S.R. 1997. The occupational environment: Its
evaluation and control. AIAH.

Organizational Contacts
Chemical Manufacturers Association
Contact:  James Solyst, Team Leader, Information
         Management/Right-To-Know
Address:   Chemical Manufacturers Association
         1300 Wilson Boulevard
         Arlington, VA 22209
Phone:    (703)741-5233
E-mail:    j im_soly st@mail. cmahq. com

U.S. Environmental Protection Agency
Contact:  Carole Macko, Communications Team
         Leader, Chemical Emergency
         Preparedness and Prevention Office
Address:   U.S. Environmental Protection Agency
         401 M Street, SW 5104
         Washington, DC 20461
Phone:    (202) 260-7938
E-mail:    macko.carole@epamail.epa.gov

Working Group on Community Right-to-Know
Contact:  Paul Orum, Coordinator
Address:   Working Group on Community Right-to-Know
         218 D Street, SE
         Washington, DC 20003
Phone:    (202) 544-9586
Web site:  www.rtk.net/wcs
E-mail:    orum@rtk.net

Gablehouse & Epel
Position: Timothy R. Gablehouse, Attorney and
        Counselor at Law
Address:  Gablehouse & Epel
        1050 Seventeenth Street, Suite 1730
        Denver, CO 80265
Phone:   (800) 818-0050
Web site: http://www.gablehouse-epel.com
E-mail:   Gablehouse@aol.com
        44The OCA is the
       centerpiece of the
hazard assessment; it is
an estimate of harm  to
           people and the
   environment beyond
   the facility's fenceline
  that can  result from a
     chemical release.
                                   11
                                                              Printed on
                                                             Recycled Paper

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  The  Environmental  Health Center  (EHC)  is a division of the
National Safety Council, an 85-year-old nonprofit, nongovernmental or-
ganization. The National Safety Council is a national leader on accident
prevention and home, workplace, auto, and highway safety issues.
  The National Safety Council established EHC  in 1 988 to undertake
environmental  communications activities  aimed at helping society and
citizens better understand and act knowledgeably and responsibly in
the face of potential environmental health risks. Since that start, EHC has
built a strong record of effective, nonpartisan communication on envi-
ronmental health risks and challenges.
                         May 1999
             ENVIRONMENTAL HEALTH CENTER
            A Division of the National Safety Council
           1025 Connecticut Avenue, NW • Suite 1200
                    Washington, DC 20036
                     www.nsc.org/ehc.htm
                        (202) 293-2270

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