United States
                          Environmental Protection
                          Agency
                        Office of Solid
                        Waste and Emergency
                        Response (OS-120)
               EPA  550-F-93-004
               October 1993
                          HAZARDS  ANALYSIS
                                  ON THE  MOVE
       Between 1987 and 1989,U.S.
       Department of Transportation
       (DOT)  officials reported
almost  60,000 transportation incidents
that resulted in an unintentional release
of hazardous materials. How can you
assess the transportation risks facing
your community? Is your community
prepared to face these risks'?

The purpose of this document is to
help you as local planners (e.g., tribal
and state LEPCs, and other planners)
and responders, develop a method to
determine what hazardous materials
are being transported through your
community and the priority areas of
       SARA  Title III
       (EPCRA)  and
       Conducting  a
    Commodity  Flow
            Study
  risk that warrant further analysis and
  study. By doing so, you can assess and
  improve existing  strategies to
  minimize risk (both public and private)
  and the response capabilities within
  your  jurisdiction.
                   Number of Hazmat Accidents
                by Transportation Mode (1981-1989)
      Mode of
   Transportation
 Number    Associated  Associated
of Incidents   Deaths*    Injuries*
                   Highway
                      Rail
           Other (includes freight
                forwarders and
             water transportation)

                   TOTAL
                                   48.907
                                   8,620
                                    1.177
                                    1.108
                                               113
                                                         1.762
                                                         611
                                                         127
                                   59,812
                                               114
                                                         2,611
  * Directly attributable to the presence of hazardous hiaterials.
  Svurcr: [•'. S. DOT statistics on incidents reported as required liy the Hazardous Materials Transportation Act of 1975
In the Emergency Planning and
Community Right-to-Know Act
(EPCRA), Congress recognized the
risk to communities posed by the
transportation of hazardous materials
and required that emergency response
plans developed by LEPCs identify the
"routes likely to be used for the
transportation of substances on the list
of extremely hazardous substances...."

One way to approach this requirement.
and to address all of the hazardous
materials being transported through
your community, is to conduct a
hazardous materials commodity flow
study (CFS). A CFS is an assessment
of the types and volumes of materials
moving  through your community.
For some communities, especially
those in  rural areas, transportation may
pose the  only hazardous materials risk.
In light of the number of accidents that
occur (see chart at left), identifying and
understanding   transportation-related
risks are critical components of
emergency preparedness  and
prevention.  The goal of the CFS is to
use the  information collected to
increase   your  preparedness,
prevention, and response capabilities.

          (continued on next page)
                       Chemical Emergency Preparedness and Prevention Office (CEPPO)

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                            HAZARDS  ANALYSIS  ON  THE   MOVE
(continued from previous page)

What are  the objectives.

A CFS is the  hazards identification
step of transportation hazards analysis,
described in Technical Guidance for
Hazards Analysis,  an EPA, DOT,
FEMA publication (see page 7).  A
CFS is the collection of existing and
new data on transportation patterns in
your jurisdiction. Combined with
accident histories, geography, and
other local conditions, a CFS will help
you characterize  hazardous materials
transport, identify locations of risk and
other vulnerable areas, and formulate
emergency planning, prevention, and
response measures.  Some  specific
objectives of performing the CFS are:
Identify major hazardous materials
traffic  corridors:

Characterize types  of substances,
shipment  frequencies, container
types,  and  container  capacities;

Specify the location,  length, and
nature of priority highways, rail

          (continued on next page)
                                                Lessons Learned
 The National Institute for Chemical Studies (NICS) is in the process of conducting a CFS as part of a comprehensive hazards analysis
 in the Kanawha Valley region of West Virginia an area with a very high concentration of chemical facilities. NICS is characterizing
 hazardous  materials transportation and the potential risk it presents in order to improve emergency response plans in the vulnerable areas
 of the region. A specific goal of the NICS study is to develop lessons learned for other communities that might conduct a CFS. How
 can NICS' experience help your CFS? Although the study is not yet complete, several helpful suggestions can be made from the work
 completed to date. There are several points to keep in mind.

 The effort put into a CFS should match the community's goals and its resources. In some cases, a great deal of detail or expense may
 not be needed for useful emergency planning.  NICS' CFS indicates that there are many different types of hazardous materials being
 transported through the study area. In othercommunities, hazardous materials transportation may be dominated by a few specific classes
 of chemicals, such as flammables or corrosive liquids. In these cases, focused hazards analysis and emergency planning efforts may
 be possible by addressing each of these classes,  rather than all of the individual chemicals  in each  class. A CFS, however, could show
 that specific  hazardous materials, such as spent nuclear rods or military munitions, are transported infrequently through the community,
 but pose enough hazard to warrant special attention from emergency planners. Other helpful hints from the NICS study include:

    0   Hazardous materials transportation can vary by the time of day and the day of the week. Be sure to account for this when planning
        field surveys.

     0   Questionnaires mailed to facilities will often  require  follow-up telephone calls for clarification and to improve the rate of response

     0   A CFS that includes many field observation efforts, such as placard or waybill surveys; can generate large quantities of data -
        computerized data management may be needed or you may wish to scale back the focus of your study.

     Q   Effective training and supervision of field survey personnel will improve the quality of the observations and data collected.

     0   Shipping papers are often in many different formats. Decide what  data you will need and develop a standardized table for entering
       the information.

     Q  Police and other emergency responders can identify highways and intersections where accidents have occurred in  the past to  guide
       data gathering and hazards analysis efforts.

     ^   Incorporate the results of other data gathering efforts. For example, total traffic volume figures developed by transportation
        agencies can be used to estimate  the percentage of vehicles carrying hazardous materials over a given route. These  figures can
        help you address  planning issues such as the  potential exposure to drivers should a hazmat accident occur during peak travel  times.

     0  Access existing databases and  inventories, such as those developed by  railroad companies and district offices of the Army  Corps
       of Engineers.

   A final guidance document based on the NICS study will he developed upon  completion.  Contact Dr. Jan Taylor or Dr. Paul Hill at (304)
    346-6264  for more information.

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   SARA  TITLE  III (EPCRA) AND  CONDUCTING A COMMODITY FLOW  STUDY
(continued from previous page)

    tracks, and other routes (paying
    special attention to those that pass
    through or along densely
    populated or sensitive
    environmental  areas);

•   Characterize any local  terminals or
    other gathering areas for
    hazardous  materials transport
    vehicles such as truck stops and
    weigh stations; and

•   Compile data on any travel and
    route restrictions in effect for the
    region.

Many communities have  conducted
CFSs that identify the types, amounts,
and routes of hazardous materials
being transported in and through their
region. You can leam from their
experiences, several of which are
discussed throughout this document.

You will see that conducting a CFS
involves some methods different from
those  used for hazards  identification at
your fixed facilities.  Instead of
referring to information on
conventional facility reports such as
Material Safely Data Sheets or Tier II
Reports, you will need  to collect data
that may or may not be readily
available from public or private
sources. You must account for
different modes of transportation (e.g.,
railways, highways, pipelines,
waterways), and develop an estimate of
    A  New Funding Opportunity: Utilizing HMTA
   Section 17 of the Hazardous Materials Transportation Act (HMTA) provides
   funds to states to enhance the consideration of transportation-related risks in
   current chemical  emergency planning efforts, and to support the implementation
   of EPCRA. (There is also an HMTA training grants program, available to both
   states and tribes.) Conducting a commodity flow study is one of the activities
   identified by Congress as eligible for funding under the HMTA planning grants
   program,  and could lead to other HMTA activities  such as assessing local
   responsecapabilities, improving the comprehensive emergency plans required
   under EPCRA, and  assessing the need for regional hazmat teams.

   LEPCs should contact the agency selected by their Governor as the "designated
   agency"  for  implementation of the  HMTA program to leam more  about
   developing a proposal for receiving grant funds  under the new law. Call the
   U.S. DOT HMTA Grants Manager at (202) 366-0001 if you are unsure as to
   which state agency has been selected to head the effort. Because of HMTA,
   the, number of commodity flow studies conducted will increase. Keep an eye
   out for other communities in your area who receive these funds so that you can
   leam from their  experiences as well.
the types and amounts of hazardous
materials being transported in and
through your region.

Our discussion begins by presenting
tips for getting organized, looks at
methods for gathering the necessary
data, and then examines the ways in
which you can apply the results of a
CFS. Finally, we consider some
technological and legislative  changes
that may be of help to your
transportation planning efforts. 9
                                      Getting  Organized

                                      Who needs  to be  involved?

                                      As an LEPC, you may wish to form a
                                      separate transportation hazards
                                      advisory committee to lead the effort,
                                      or the LEPC as a whole may take the
                                      lead role.  Whether or not you are able
                                      to form a committee that meets
                                      regularly, the LEPC should identify
                                      state and local professionals to assist in
                                      identifying sources of information and
                                      to review drafts.

                                      To cultivate broad-based support, an
                                      advisory committee should reflect local
                                      conditions and include representatives
                                      from the LEPC, local planning
                                                   (continued on next page)

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                             HAZARDS ANALYSIS  ON  THE  MOVE
Getting Organized
(continued from previous page)

councils, the public works department
the State Department of
Transportation, the U.S. Coast Guard,
airport and port authorities, industry,
police and fire departments, and the
SERC.

Once the advisory committee has  been
formed, it must formulate  a workplan
for the study itself. In  developing this
workplan, the advisory committee
should take the time to determine
specific objectives, what data are
available,  and what data are needed in
order to accomplish the goals of the
CFS quickly  and efficiently. This will
give the CFS a clear focus and give the
committee a better idea of what
resources  will be necessary to
complete the study. Throughout  this
document different methods are
suggested. You should evaluate your
needs against available resources,
and modify your approach
accordingly.

Don't  re-invent the wheel!

Several agencies at the national and
state level compile some of the data
that you will need. The advisory
committee should identify these
agencies and determine what data
already exist. This is why having a
broad-based advisory committee is so
important. Everyone,  especially the
state DOT representative,  will have
access to  different and valuable
information.  Industry  associations
such as the  Chemical Manufacturers
Association, the Association of
American Railroads, the American
Trucking Association, and others may
have already collected and analyzed
additional data.

Nearby municipalities may have
already completed a CFS or may want
to join forces and combine resources.
For example, LEPC representatives
from Alexandria. Virginia, serve on  a
multi-jurisdictional task force that is an
important forum for addressing
resource-sharing issues and is
developing a transportation hazards-
based emergency  response plan. The
task force is devising a set of response
procedures, but is also working to
reduce the amount of hazardous
materials transported through, and the
number of accidents in, the region.

You can also integrate your CFS data
collection efforts with other on-going
data collection or inspection  programs.
Once again, Alexandria, Virginia,
provides an example of effective inter-
agency coordination in its policy of
using fire department Title III Facility
Data Sheets to highlight likely
transportation routes for carriers of
extremely hazardous substances. The
LEPC incorporates this information  on
transportation routes and chemicals
transported into its emergency
planning process to better respond to
transportation incidents.

Recruiting outside help.

Using volunteer personnel, students,
and local environmental groups  can  be
a great cost and time saver for the
LEPC. The Hancock County, Ohio,
LEPC took advantage of an innovative
program in environmental and
hazardous materials management at  a
nearby university to obtain qualified
volunteers for its study on hazardous
materials transportation on the
county's highways.  Following initial
training sessions, a total of 37 students
from the University of Findlay's
"Hazmat Club" were assigned survey
times and locations to conduct placard
surveys. Their assistance  proved to be
an important tune saver for the LEPC.

A prison inmate volunteering for the
Butler County, Kansas, health office,
developed and implemented  the
county's emergency response plan,
which included identification of the
transportation-related hazards in the
county. He spent over 800 hours
working on the plan and aiding other
counties in developing their  plans. He
recommends the use not only of
inmates, but also senior citizens, who
possess the necessary time and
knowledge of the region to assist in
CFS efforts. Industry is another
(perhaps more traditional) potential
resource - local industry  might be
persuaded to contribute personnel and
equipment to  the  study.  •

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SARA  TITLE  III  (EPCRA) AND  CONDUCTING A  COMMODITY  FLOW  STUDY
 Gathering the Data

 What 's the big picture ?

 Begin by identifying the major
 hazardous materials transportation
 patterns: determine the general types of
 hazardous materials moving
 throughout the community, how  they
 are moved, and when they are moved.
 A CFS doesn't have  to provide a lot
 of detail to be useful - given budget
 constraints, collecting exhaustive
 data on every chemical and every
 mode of transportation will be
 nearly impossible to accomplish.
 Complicated risk analyses using
 intricate mathematical formulas are
 probably not  necessary. Rough
 estimates of hazardous materials traffic
 can provide valuable  information in
 determining where risk lies.

 Priority risk areas can be found at the
 points of origin or destination of
 hazardous materials, as well as at
 intermediate locations. For most  areas,
 data for one month, or even one week,
 may prove sufficient to project the
 year-round flow of hazardous
 materials.  You can focus on  general
 classes of chemicals (e.g., flammables,
 corrosives), unless you know that large
 quantities of specific  chemicals are
 manufactured or stored in the  area.
Some areas will experience seasonal
changes (e.g., a rural community may
experience an increased flow of
fertilizers and pesticides during a
portion of the year) that should be
evaluated separately from typical
flows. Seasonal patterns may be easy
to determine for local industry, but
keep in mind that such pat terns will be
extremely difficult to track for
interstate traffic. You should weigh
the costs and benefits of studying
seasonal transportation patterns in your
area.

Your next step.

Reviewing all of your facilities'  Tier
II reports and the amount of
hazardous chemicals they store,
handle, or use annually  will give you
an idea of the quantity and type of
materials transported through your
jurisdiction. A fixed facility
representative may be able to provide
you with a rough estimate of the types
and quantities of materials transported
through these facilities,  or you may
decide to prepare a facility
questionnaire.

NICS prepared a comprehensive fixed
facility survey as a starting point for its
hazardous materials transportation
survey.  NICS asked fixed facilities
about specific trends in the amount of
hazardous chemicals shipped over the
past few years,  the exact mode of
transport, and the usual hours and days
of the week for shipping and receiving.
Facilities were asked to list the major
carriers for each chemical and the most
frequent origins and destinations of
loads. This information provided data
on the actual amounts and types of
hazardous materials shipped from or
received by facilities in the region. It
provided valuable information on the
general routes utilized by these
facilities and yielded transportation
data which could be compared to data
obtained by the field  surveys. See
page 6 for the specific steps taken  by
the Taylor County, Wisconsin
LEPC.

There are transportation depots that
are not necessarily captured under the
fixed facility definition in EPCRA, yet
hazardous materials are channeled
through them every day. Make sure
that your CFS includes truck
terminals, seaports, airports and rail
yards. Such depots may also warrant
study in the CFS because of the
potentially diverse types and  amounts
of substances that are distributed from
them. Many of these facilities
voluntarily participate in the planning
efforts of the communities in which
they are located. If you feel more
formal mechanisms are needed,
however, there are provisions of
EPCRA that can help.

Section  302(b)(2) of  EPCRA
authorizes the Governor and/or the
SERC to designate "additional
facilities which shall be subject to the
requirements of [section 302]...."
Railyards, sea ports, and airports are
examples of transportation depots that
can be included under section 302.
You should review your state and local
ordinances for provisions (similar to
EPCRA section 303(d)(3)) that provide
access to the information you need to
adequately address the transportation-
related risks facing your community.

                (continued on page 8)

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                      HAZARDS  ANALYSIS ON THE MOVE
                    On a Shoe-String  Budget — Collecting the Data
 Taylor County, Wisconsin, is a primarily rural community, with a small city and several villages. There are three state highways,
one railway, one small airport, and two pipelines within the county. The Taylor County, Wisconsin LEPC conducted a CFS and
transporation hazards analysis using the steps outlined below. You might find them useful when setting out to collect data for your
community. As Taylor County learned, conducting a CFS is a time-consuming process, but certainly manageable once priorities
have been set. By working on the project as time allowed, Taylor County was able to keep the total costs down. Over the course
of twelve months, two people worked a total of approximately 450 - 500 man hours. For more information on the Taylor county
study, contact Mr. Donald Albers, Community Emergency Coordinator, at (715) 748-3503.
    1
      Identify HAZMAT Routes
       Taylor County started by pulling out local maps to determine which routes warranted study. You
can use state highway maps, county  aeronautical charts,  and municipal street maps to name a few.
Remember that pipelines might not appear on a map, but need to be included in your CFS. Taylor County
contacted pipeline companies directly, after obtaining contact information from the County  Emergency
Government Office and the  State Office for Emergency Preparedness.
  2
       Determine What HAZMATs Are Carried on Each of These Routes

       Taylor County used the following methods to determine hazmat traffic volume and flow.
    Route:
    HIGHWAYS
    RAILROADS
     PIPELINES
    AIRPORTS
                             Method of Determining HAZMATs:
                             0   Sent questionnaires/surveys to trucking companies, weigh stations, and known hazmat
                                suppliers/users;
                             0   Determined data collection points  (priority/high-risk points); and
                             0   Performed traffic counts (placard survey).

                             0   Contacted the local representative  from railway  companies;
                             0   Researched waybills  and  manifests;  and
                             0   Contacted the District Office of the Federal Railroad Administration in your area.
                             0  Contacted local pipeline companies; and
                             0  Contacted local utility commission for permitting records and "digsafe" programs.
                             0  Contacted airport managers to determine which airlines carry hazmats; and
                             0  Contacted local representatives for  each  airline identified.
  There are no navigable waters within Taylor County. The LEPC suggests, however, that you contact shipping companies
  and the district offices of the U.S. Coast Guard and the Army Corps of Engineers to obtain information on the hazardous
  materials transported through your jurisdiction via waterways. (Check your phone book for local listings.)
  3
       Compile Accident Records
       Finally, Taylor County examined accident histories to identify any recurring problems or severe
risks in the area. The following agencies can assist you in collecting information on your area's accident history:
          State Department of Transportation
          Police Department
          Local hospitals and physicians
          News media
                                               State Emergency Management Agency
                                               Public Health Department
                                               Local industry
  HMIS reports can be obtained by contacting DOTs Research and Special Programs Administration (see page 11 for contact information).

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SARA TITLE III  (EPCRA)  AND CONDUCTING A COMMODITY  FLOW STUDY
                                      Want  More Information?
The following materials can give you technical information on conducting commodity flow studies and hazards analysis, as well as some
background  on transportation issues.

         Community Teamwork: Working Together to Promote Hazardous Materials Transportation Safety provides ideas
                  on how to develop a hazardous materials transportation safety program in the most economical manner.
                 Examples are presented of how various state and  local agencies are sharing the cost of providing personnel, equipment,
and materials. In addition  ways in which private industry have supported state/local safety programs are illustrated. Publications and other
sources of information are  also identified. Published by the U.S. Department of Transportation  (DOT), free copies of Community Teamwork
may be obtained by calling the EPCRA Hotline at (800) 535-0202 / FAX: 703-412-3333.  The Hotline is staffed Monday through Friday, 830
a.m. to 7:30 p.m. EST.

          The 1990 Emergency Response Guidebook was developed by DOT for use by first responders such as firefighters
                  and police officers. It is  a  guide for initial  action when called to  handle incidents involving hazardous
                 materials. Hundreds  of chemicals are cross-referenced with the specific hazards they pose to human health, and the steps
to take in case of spills, leaks,  fires, or explosions.  You can obtain a free copy of  the Guidebook by calling (800)  PLAN-FOR.  In Illinois.
call (800)  367-9592.

            The Successful Practices in Title III Implementation series, published by EPA's Chemical Emergency  Preparedness
                  and Prevention Office, describes  innovative projects undertaken by SERCs and LEPCs across the country.
                  Issue #8, October 1991, included the first subject index of the series, to which local planners can refer in order to find
projects undertaken on hazards analysis, transportation-related risk, and other important issues. Each profile contains the  names of individuals
who may be  contacted for more information on the efforts described. Contact the EPCRA Hotline  at (800) 535-0202 / FAX: 703-412-3333
to obtain free copies of Successful Practices bulletins.

              Transportation Community Awareness & Emergency Response (TRANSCAER® Guidance Manual is part of
                an inter-industry program to assist with the planning efforts for  transportation  emergencies involving hazardous materials.
                Integrating industry and LEPC  efforts, the manual outlines the processes to evaluate the current status of emergency
planning within a community.  Suggestions  are provided to further improve the planning process. For more information on the TRANSCAER
Program contact the Chemical  Manufacturers Association at 2501 M  Street, NW,  Washington, DC 20037, or at (202) 887-1100.

              Technical Guidance for Hazards Analysis ("Green Book"), published  by EPA, DOT,  and FEMA, describes
                  a methodology  and provides equations  and  tables for  screening possible airborne  releases of extremely
                  hazardous  substances based on accident scenarios developed by local planners. The Green Book is a tool for emergency
preparedness  and is not designed for direct use in a "real  time" response  situation.  Contact the  EPCRA Hotline at (800) 535-0202 /FAX: 703-
412-3333  to obtain  a free copy.
         CAMEO™  -  Computer Aided Management  of Emergency  Operations  is a  computer  program  that  has the
                 capability to manage transportation data, estimate vulnerable zones, and compile risk analysis results. For
 ••••II.         more  information on CAMEO, contact the EPCRA Hotline at (800) 535-0202 / FAX: 703-412-3333 or your regional
EPA office (see page 11).

         The Handbook of Chemical Hazards Analysis Procedures ("Brown Book"), published by FEMA, EPA, and DOT,
                 addresses hazards analysis and introduces the Automated Resource for Chemical Hazard Incident Evaluation
                 (ARCHIE) computer software package. More specifically, chapters 10 and 11 offer extensive  information to aid you in
assessing rail, highway,  water, and pipeline transportation. The Brown Book tells you who to contact and what to look for. You can obtain
a free copy of the Brown  Book by writing the FEMA Publications Office,  500 C Street, SW, Washington, DC 20472, or by contacting the
EPCRA Hotline at (800) 535-0202 / FAX:  703-412-3333.

         The Institute of Transportation  Engineers'  (ITE) Transportation Planning Handbook is  a handy reference for
                 planners involved in  the broader issues of transportation planning and traffic engineering. The Handbook
                 includes guidance  concerning:  transportation planning  studies, environmental and energy considerations,  regulatory and
legal considerations, transportation systems  management, and several other transportation topics.  ITE is  located  at Suite 410, 525 School
Street,  SW, Washington, DC 20024-2797. Call ITE at (202) 554-8050 for more  information on ordering the Handbook.

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                            HAZARDS ANALYSTS ON THE  MOVE
 Gathering the Data
 (continued from page 5)

 Other facilities that can generate
 substantial highway hazardous
 materials traffic include oil-fired, coal,
 and nuclear power plants; large
 manufacturing  facilities; agricultural
 warehouses;  waste  management
 companies: and public facilities. Keep
 in mind that  the lack of standardized
 shipping manifests, not to mention
 receiving them in different languages+
 will complicate your analysis.

 Your area's accident history is
 another key starting point for
 information. Federal and state
 agencies compile accident data that can
 be used to get a sense of what and
 where the priority points are and what
 kind of accidents your community
 typically faces. You can use this
 information, along with your
 knowledge of local conditions, to help
 identify high-risk areas.

 The U.S. Department of Transportation
 Hazardous Materials Information
 System (HMIS) contains a variety of
 data regarding the transportation of
 hazardous materials by air, highway,
 rail,  and water. HMIS also contains a
 data base on shipping routes for high
 level radioactive materials that may be
 of interest in assessing your
 transportation-related hazards. The
 HMIS  Incident Report Data Base is
 composed of carrier-reported
 accidental release data from 1971 to
 the present, as  required by the Code of
 Federal Regulations (49  CFR Part
 171). The incident data include the
 date of incident, chemical(s) involved,
quantity, location and land-use, cause
of release, mode of transportation, and
other information. The information
box on page 11 lists the DOT address
and telephone number for receiving
information on HMIS reports.

Addressing Your Additional
Data Needs

Once you have tracked down existing
information, how do you obtain the
data that are  missing? Again,
assembling the proper team is crucial.
A data collection team may be
composed of members of the advisory
committee; or, if resources allow, it
might be wise to develop an "outside"
team. Whether it is made up of private
organizations, volunteers from
environmental groups and local
universities, or contractors, the data
collection team should receive a clear
mission, adequate training, a timetable,
and responsibilities from the advisory
committee.

Commodity flow studies commonly
involve a road-side placard survey.
These surveys identify what materials
are being transported and also give you
an idea of the quantity involved.
Usually, these surveys last for a few
days  or weeks  - observers note the
number of trucks that pass by, their
placards, the time, and the type of
container used.  Although a great deal
of effort may be needed to make such  a
survey  statistically accurate,  even a
modest program of field  observation
can form a solid foundation for
conducting a transportation hazards
analysis.

The table on page 9 describes this and
other collection  methods that have
been used in the past by communities
identifying transportation-related risk.
These methods can be adapted to local
conditions and specific modes of
transportation. The resources
identified on page 7 can help you
determine which methods are
appropriate for your  study.  Whatever
method you choose, the advisory
committee should organize the raw
data that have been collected into a
form that is conducive to continuing
analysis.    •
What to Do With the
Results

Improving  response;  preventing
accidents

Many communities have conducted
hazards analyses to develop and revise
emergency response plans based on the
specific hazards found at fixed
facilities within their jurisdiction.  The
hazards analysis process can also be
applied to transportation-related risk.
The  Technical Guidance for Hazards
Analysis ("Green Book") describes the
hazards analysis process in detail. It
can be summarized in three basic steps:

•    Hazards identification pinpoints
     the location, quantity,  storage
     conditions, and the specific

              (continued on next page)

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   SARA TITLE III (EPCRA)  AND  CONDUCTING A COMMODITY  FLOW STUDY
What to Do With the Results
(continued from previous page)

    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
    release.
  Risk analysis provides a basis for
  LEPCs to rank specific release
  scenarios or locations based on the
  likelihood and severity of the
  release. The hazards analysis
  method described in the Handbook
  of Chemical Hazard Analysis
  Procedures ("Brown Book")
  separates this step into two steps,
  consequence analysis and risk
  analysis. The additional step  is
  simply an elaboration of the
  process explained in me Green
  Book.
A commodity flow study is, in effect,
the hazards identification step of the
hazards analysis process conducted for
transportation-related hazards. Once
the CFS has been completed, you will
have a good sense of what major
categories of hazardous materials are
transported through your region and
what the priority areas are - you will
have identified the transportation
hazards facing your community.
Plotting the information on a map can

             (continued on next page)
                                           Survey Methods
  METHOD
ADVANTAGES
                                                                             DISADVANTAGES
           Review and analyze
           existing data
              Placard survey
     r
            Photocopy survey
           (Photocopying  shipping
                   manifests of
                   carriers passing
                   through toll  booths,
                   etc.)
           Fixed facility survey
  Weigh station survey
Inexpensive, shows major highway,
rail, air, and water routes. Good
starting point.
Provides approximate counts for
trucks on major highways and rail
lines at reasonable cost. Can be
combined with existing data to
estimate proportion of trucks with
hazardous materials on major
highways.

Can provide detailed data on volume
and nature of hazardous materials
shipped by truck.
Good data on routing, volume, and
nature of hazardous materials.
Good data on routing, volume, and
nature of hazardous materials.
  There is no single source for all
  existing data.  Allow time for
  integrating various electronic
  formats.
  Limited number of
  roads/rail lines can be covered.
  Shipping papers are not
  standardized; requires a lengthy
  review process. Cost may be
  prohibitive.
  Only covers shipments
  originating or  terminating locally.
  Allow for lengthy dam review
  sessions.
  Only covers a portion of
  shipments on selected highways;
  must be supplemented to obtain
  local shipments.

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                       HAZARDS   ANALYSIS   ON   THE   MOVE
 What to Do With the Results
 (continued from previous page)

 provide  a picture of where the
 hazardous materials are and which are
 the major routes of concern for
 planning purposes.

 You can use the vulnerability and risk
 analysis  steps described in the Green
 Book to  translate the results of the CFS
 into recommendations for revising
 your emergency response plan and
 determining your  community's
 specific  preparedness, prevention, and
 response needs. This evaluation will
 help answer important planning
 questions such as:

 0   Just how vulnerable is your
    community to these risks?

 0   How can risks be reduced?

 0   How can accidents  be prevented?

 0   What special populations (e.g..
    schools, hospitals) are located
    near these priority routes?

 0   Are  any of these routes marked by
    significant congestion at certain
    times of the day?

 0   What is the response time of the
    closest hazardous materials team?

 0   How accessible is the area to
    emergency vehicles?

 0   What is a realistic scenario, given
    the risks and probabilities ?

Once the remaining steps in the
hazards analysis process  have been
 completed, you can then turn to
 assessing your level of preparedness
 and revising your emergency response
 plan to reflect the highest
 transportation-related risks. Depending
 on your circumstances, you may not be
 able to tailor your emergency response
 plan to focus on specific chemicals or
 routes.

 Just as with fixed facility planning,
 budget constraints come into play as
 the number of chemicals and hazards
 increase. It is important, however, that
 your plan addresses the risks that you
 have identified to the best of your
 ability. For example, if you discovered
 that the local railroad terminal stores
 hazardous materials cars in  special
 holding areas, obtain a map  of the
 facility, mark the holding areas, and
 attach it to your emergency  response
 plan: then work with the railyard to
 reduce the risks.   Another example is
 segregating incompatible cargoes and
 establishing buffer zones between
 holding areas and nearby communities.

 After developing a realistic  picture of
 the hazards that your community faces,
you can begin to re-evaluate your
community's prevention strategies.
Are current measures appropriate?
Would traffic control on priority routes
make a difference'? Do accident
records suggest a need for driver safely
training'? Would commodity flow
restrictions during severe weather
alerts make sense? Be  sure to identify
all of your community's prevention
concerns so you can ask the  "right"
questions.

The CFS may also point to a need for
additional resources to increase the
 community's level of preparedness (e.g.,
 training, equipment, and on-going
 planning). Again, it is most important to
 have general response capabilities, rather
 than trying to address every specific
 chemical and/or transport route.   •
 Looking Ahead

 Transportation-related risks are
 continually changing, and to meet the
 challenges that these hazards present, it is
 important to look forward. With
 construction of new highways, changes in
 the composition of local industry, and the
 enactment of new federal, state, and local
 laws, there may be a change in the flow of
 hazardous shipments through your
 community.  The commodity flow study
 should not "sit on a shelf:" it should be
 updated periodically and the community
 emergency response plan revised
 accordingly.

 It is important to keep abreast of new
 tools (both technological and legislative)
that are being developed and refined to
address many of the problems you may be
facing. Keeping these and other factors in
mind will help  you with long-term
planning  and future updates of the CFS
and the overall emergency response plan
Let's look at a  couple of these
innovations and see how they might be
applied to your needs.

             (continued on next page)

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   SARA TITLE III (EPCRA) AND CONDUCTING A  COMMODITY FLOW STUDY
Looking Ahead
(continued from previous page)


Metropolitan   Planning
Organizations  (MPOs)


Section 134 of the Intermodal Surface
Transportation Efficiency Act of 1991
(ISTEA) calls for  me designation of an
MPO for each urbanized area of
greater than 50,000 people. The
primary responsibility of these MPOs
is to conduct the transportation
planning process for the area that it
covers. This process will include
developing transportation plans and
programs  to promote comprehensive
solutions to regional problems.
MPOs represent a potentially
invaluable resource for your LEPC
when preparing a CFS. They will
have data and expertise that will make
your task easier, and they may even
be able to provide access to
equipment and techniques, such as
transportation-specific Geographic
Information Systems (GIS), that will
simplify  the work and enhance the
form of your final product. Keep in
mind that the MPOs will be working
closely with state and local
transportation authorities, so that they
will likely have information for your
area.
Intelligent Vehicle/Highway Systems
(IVHS)


IVHS are a family of technologies that
are presently being developed to
improve transportation safely and
efficiency.  By bringing high-tech
solutions in the form of advanced
computers, sensors, and communication
systems to  some of the complex
transportation problems that confront
us, IVHS holds the promise of
mitigating  congestion, enhancing
safety, promoting economic
productivity, and minimizing
environmental hazards.


             (continued on next page)
                                 Contacts at the Federal Level
  U.S. DEPARTMENT OF
  TRANSPORTATION

   General  Information
   Research and Special Programs
   Administration (RSPA)
   400 7th Street, SW
   Washington, DC 20590
   (202)  366-4474

   HMIS Reports
   Information  Systems Manager
   RSPA
   400 7th Street, SW
   Washington, DC 20590
   (202) 366-4555

  U.S. ENVIRONMENTAL  PROTECTION
  AGENCY

   General Information
   Chemical Emergency Preparedness and
   Prevention Office (CEPPO) (OS-120)
   401 M Street, SW
   Washington, DC 20460
   (202)  260-5338
   To Order Documents
   EPCRA  Hotline
   (800) 535-02027 FAX: (703) 412-3333
   Monday-Friday 8:30 a.m. - 730 p.m. EST
                           EPA Regions
    EPA - Region 1
    New England Regional Lab
    60 Westview Street
    Lexington, MA 02173
    617-860-4301

    EPA - Region 2
    2890 Woodbridge Avenue
    Edison, NJ 08837-3679
    908-321-6620

    EPA - Region 3
    Oil & Title III Section
    841 Chestnut Street
    Philadelphia, PA  19107
    215-597-5998

    EPA - Region 4
    345 Courtland Street, NE
    Atlanta, GA 30365
    404-347-1033

    EPA - Region 5
    77 West Jackson HSC-9J
    Chicago, IE  60604-3590
    312-353-1964
 EPA - Region 6
 Allied Bank Tower
 1445 Ross Avenue
 Dallas, TX 75202-2733
 214-655-2270

 EPA - Region 7
 ARTX/TOPE/TSCS
 726 Minnesota Avenue
 Kansas City, KS 66101
 913-551-7308

 EPA - Region 8
 One Denver Place
 999 18th Street, Suite 500
 Denver, CO 80202-2466
 303-293-  1723

 EPA - Region 9
 75 Hawthorne Street (H-l-2)
 San Francisco. CA 94105
 415-744-2100

 EPA - Region 10
 1200 6th Avenue (HW-114
 Seattle, WA  98101
 206-553-4349

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                                  HAZARDS ANALYSIS
Looking Ahead
(continued from previous page)

"Great," you might say, "but how will
this sci-fi stuff help me?" In the near
future, trucks and trains traveling
through your community could be
carrying electronic equipment  that
identifies the cargo, keeps track of the
vehicle's location, and even projects
the intended route through your
district.  Shipments of hazardous
materials could be tracked in "real-
time" by a traffic control center,  and
sensors on the vehicle itself will be
constantly monitoring the condition of
the cargo.

Currently, there are over  20 operational
programs in the U.S. testing various
elements of IVHS, including those
directly  applicable to hazardous
                                        ON THE MOVE
materials transport. Remember that
transportation planning is an evolving
discipline, and that new tools are
constantly being developed to help you
safeguard your community. •
In Summary-

Even though the transportation of
hazardous materials presents substantial
risks, these risks may seem difficult to
quantify.  The commodity flow  study
process should be tailored to meet your
needs and available resources as you
identify and address the particular
hazards facing your community.
In this document, we have:

0   Outlined the steps necessary to
    conduct a comprehensive
    commodity flow study:
0   Explained how each of these steps
    relate to the emergency planning
    process:
0   Pointed out some resources you may
    want to tap once you have decided
    to go ahead with a CFS; and
0   Examined the technologies and
    issues that will play a role in
    identifying transportation hazards in
    the future.

Use this information as a guideline, but
remember that there is no one right way
of doing this job. The particulars of your
community will ultimately determine
your best course of action. •
United States
Environmental Protection Agency
Chemical Emergency Preparedness and
Prevention Office (CEPPO)
(OS-120)
Washington, DC 20460

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