&EPA
         United States
         Environmental Protection
         Agency
             Office of Solid Waste
             and Emergency Response
             (OS-120)
September 1993
EPA-550-K-93-002
Series 6, No. 10
Successful Practices in
      III Implementation
         Chemical Emergency
         Preparedness and Prevention
         Technical Assistance Bulletin
         State of Florida
         District 5 LEPC, Florida
         Monroe County, Michigan
         State of Alaska
         Subject Index

-------

-------
                         ABOUT THIS BULLETIN


This is another in a series of bulletins that EPA is issuing to provide examples of implementation
programs and strategies of the Emergency Planning and Community Right-to-Know Act of 1986,
known as Title HI, that are innovative or have proven effective.  The purpose of these bulletins is to
share information on successful practices with Local Emergency Planning Committees (LEPCs),
State Emergency Response Commissions (SERCs), fire departments, and other Title HI
implementing agencies throughout the country in the hope that such information will prove useful to
other SERCs and LEPCs as their programs develop and evolve.

Elements from the programs featured here may be transferable to other programs in similar
communities or with similar situations. The bulletins provide information on a variety of practices
	for example, planning, compliance, information management, hazards analysis, and outreach.
The particular topics covered in each LEPC or SERC profile are listed in the box at the bottom of the
first page of the profile for easy reference, along with descriptions of the planning district or state
and LEPC or SERC membership.

The descriptions of the innovative and effective implementation programs and strategies are not
exhaustive.  They are meant to provide readers with enough information to determine if a particular
approach is applicable to their own situation. Each profile includes a contact person who can
provide more detailed information.

For your convenience, a subject index covering the contents of the ten Successful Practices
bulletins has been included in this bulletin. The index is designed to allow the reader to identify^
successful Title in implementation practices by topic area, and then locate the Successful Practices
bulletin in which the practice was profiled. Details on all ten bulletins, and how to order them, are
provided on page 21.

If you know of Title in implementation efforts you feel would be of interest to others and that we
should identify in Successful Practices, please contact your EPA Regional Chemical Emergency
Preparedness and Prevention coordinator (see the list on page 22), or the Emergency Planning and
Community Right-to-Know Information Hotline at (800) 535-0202.

-------

-------
Successful Practices
State of Florida
Pagel
                                                              State of
                                                              Florida
A       pre-existing state Hazardous Materials
       Task Force, consisting of representatives
       from various state agencies with
 emergency response duties, served as the
 foundation for the establishment of the Florida
 Emergency Response Commission. In 1988, the
 SARA Title HI program in Florida was enhanced
 by the passage of Senate Bill (S.B.) 954, the
 Florida Hazardous Materials Emergency
 Response and Community Right-to-Know Act.
 The law requires the Florida Department of
 Community Affairs (DCA) to provide
 administrative support to the Florida SERC.
 DCA's Division of Emergency Management
 (DEM) serves as the lead agency for chemical
 emergency preparedness and the implementation
 of SARA Title IE in Florida.
         Compliance

                Under the provisions of S.B. 954, DCA
                was required to establish a verification
                program to assess compliance with the
         Florida reporting requirements. The first step in
         this task was a cross-referencing check made
         with existing state databases (e.g., those of the
         Department of Revenue, Chamber of Commerce,
         Department of Citrus, Public Service
         Commission, and Health and Rehabilitative
         Services). DCA also used the list of Title in
         section 313 submissions, the fire marshall's
         liquid petroleum gas database, the Florida
         Department of Agriculture/Food and Drug
         Administration's list of ammonia freezers, and
         the underground storage tank database to
  Membership:  19 members, including representatives from the Departments of Community
                Affairs, Environmental Regulation, Natural Resources, Transportation, Labor, and
                Law Enforcement; State Fire Marshal; Fire Chief's Association; Governor's
                Office; Regional Planning Council Association; Emergency Preparedness
                Association; Association of Counties; League of Cities; Florida Power
                Corporation; Legal Environmental Assistance Foundation; and labor and trade
                associations (chair: secretary of the Department of Community Affairs).

   Organization: 11 LEfCs organized according to the pre-existing regional planning districts, each
                of which consists of three to eleven of the 67 counties in the state.
   Topics:
                Outreach
                Funding

-------
  Page 2
State of Florida
Successful Practices
 identify facilities. Potential non-compliers are
 sent a certified letter at addresses identified
 through the Florida Secretary of State's
 corporate database.  Under the law, the targeted
 facility is given thirty days to report before late
 fees are assessed. Over the last two years, nearly
 3,000 initial notices of violations and over 650.
 follow-up notices have been mailed to
 companies  statewide.

 During 1989 and 1990, the SERC conducted
 demonstration compliance projects in the cities
 of Tampa, Jacksonville, and Miami. Fire
 department personnel in Tampa and local
 environmental inspectors in Jacksonville and
 Miami conducted a door-to-door survey of
 facilities. As a result of this project, the SERC
 developed a better sense of the number of
 potentially  covered facilities. Many sites
 suspected of being subject to reporting did not
 actually qualify because they did not exceed the
 reporting thresholds. In addition, the SERC
 collaborated with EPA Region 4 in the final
 phase of an outreach project in Manatee County
 that was initiated in 1989. After two formal
 mailouts, approximately 25 facilities, suspected
 of being out of compliance, were visited to
 determine formally whether they were subject to
 Title IE.  In combination with an extensive
 media outreach effort, the entire project
 substantially increased the number of reporting
 facilities.

 Beyond the compliance program, S.B. 954 also
 authorizes the state to enforce and collect fines
 for failure to comply with the federally
, enforceable provisions of Title HI.  As of mid-
 1992, the SERC had issued 31 Notices of
 Violation regarding the provisions of section 304
 of Title in.  Settlement agreements with
 monetary penalties of over $140,000 have been
 entered into for sixteen of the enforcement
 actions. In  addition to monetary penalties, the
 SERC has required facilities to perform training,
 attend LEPC meetings, and prepare compliance
 articles for trade publications.
         Outreach

                To assist Florida facilities in complying
                with the requirements of the state and
                federal emergency planning and
         community right-to-know regulations, the SERC
         prepares a handbook on an annual basis.  The
         1991 handbook consists of a thorough section-
         by-section overview of the regulatory
         requirements, two consolidated Title El
         chemical lists (arranged both alphabetically and
         by Chemical Abstract Service number), and the
         Florida reporting forms and instructions for
         sections 302, 304, and 311-312 of Title HI.
         Florida requires the submission of a state Tier U
         form, which includes reporting of actual
         numbers, rather than ranges, for the average and
         maximum daily amounts of the hazardous
         chemical on site.

         The SERC has been involved in three outreach
         efforts aimed at specific industries —
         government contractors (federal government-
         owned, but  contractor-operated facilities are
         covered under Title in), agriculture, and
         compressed gas manufacturers and distributors
         — to improve both awareness and compliance.
         Because the definition of facility under Title III
         specifically does not include federal facilities,
         the SERC worked in 1988 and 1989 to increase
         awareness among government contractors
         operating federal facilities of their reporting
         obligations  under SARA Title III.  The program
         was initiated by a DCA presentation at Cape
         Canaveral for the National Aeronautics and
         Space Administration (NASA) and its
         contractors. Representing both NASA facilities
         as well  as other contractor-operated government
         facilities in the state, the contractor attendees are
         now in compliance with the requirements of
         Title III, and, if covered under section 302, have
         been the subject of a hazards analysis conducted
         in developing their regional LEPC's plan.

         Inspired by a document developed by the Kansas
         SERC, the Florida SERC developed and
         distributed through state agricultural trade

-------
Successful Practices
State of Florida
PageS
organizations a list to cross-reference Title III
section 302 extremely hazardous substances with
the trade names of common agricultural
chemical products. The SERC also assisted the
Compressed Gas Association in thepreparation
of detailed written guidance on compliance with
Title IE. The guidance was mailed in May 1990;
the state then sent a follow-up letter to 65
suppliers to solicit cooperation in identifying
potentially subject facilities. The information
provided resulted in the compilation of a list of
2,500 facilities, of which 1,000 were previously
unknown.  As a result, many suppliers
subsequently provided facilities with an
information package on Title III requirements.

The SERC also publishes HAZ MATTERS, a
quarterly newsletter describing the activities of
the state's 11 LEPCs. Distributed in advance of
the quarterly SERC meetings, the articles are
prepared by the LEPCs and serve as a basis for
discussion at a meeting of LEPC chairs and
SERC staff on the day before the official SERC
meeting. Outstanding issues can then be raised
at the SERC meeting the following day.

The SERC, in conjunction with the 11 LEPCs,
established January 26 - February 1,  1992, as
Emergency Planning and Community Right-to-
Know Week. Interviews with emergency
planning officials were held for local television
and radio stations, daily articles were prepared
for local newspapers, and facility compliance
seminars were conducted throughout the state.
The effort was designed to enhance awareness of
and increase compliance with the March 1
annual reporting deadline.  The SERC also
provides news articles for local papers in
February and June to advertise the Title ni
sections 312 and 313 reporting deadlines.

Funding

       B. 954 also established the initial Florida
     * fee system for Title HI submissions. The
       state charges a one-time fee of $50 for
filing under section 302. In addition, there is an
         annual registration fee for companies reporting
         under both sections 302 and 312 ranging from
         $25 to $2,000; the amount of the fee depends on
         the total number of persons employed by the
         company's owner or operator within the state.
         Those facilities only required to report under
         section 312 pay a reduced registration fee
         ranging from $25 to $500. Government entities
         are exempt from paying the annual registration
         fee.  The law also authorizes a late fee of up to
         $2,000 if a facility has not filed within 30 days
         of an initial notice and up to $4,000 after 150
         days. Under the provisions of House Bill 2337,
         which became effective October 1,1992, DCA is
         also authorized to assess facilities an annual
         reporting fee of up to $150 for each report filed
         under section 313; implementing regulations  for
         this law have not yet been issued.

         The 1988 law also created a Hazardous Materials
         Administration Trust Fund to support DCA
         activities. The trust fund receives all fees and
         penalties collected under the fee system; the
         money is used to support the implementation of
         Title IE by the SERC and the LEPCs in amounts
         authorized annually by the state legislature. The
         trust fund pays the DCA staff who support the
         SERC, covers all SERC supplies and other
         expenses, and provides  grants to the counties for
         emergency planning purposes.  The SERC used
         trust fund money to install the Hazardous
         Materials Management  Information System, a
         database system that manages all of the
         information reported under Title in (sections
         302, 304, 311-312, and  313) for 12,000 state
         facilities. The SERC receives no money out of
         general state revenues.

         The 11 Florida LEPCs were designated along the
         lines of the pre-existing Regional Planning
         Councils (RPCs), which are responsible for
         addressing land use policy and coordinating
         inter-governmental emergency planning. The
         SERC has a formal, performance-based
         agreement to provide funding to the LEPCs.  The
         LEPCs receive money from the trust fund if they
         meet specific criteria according to a pre-

-------
Page 4
State of Florida
Successful Practices
                          Pollution Prevention Through Toxics Use Reduction

  The Department of Environmental Regulation (DER)  sponsors a voluntary, cooperative, non-regulatory waste
  reduction program known as the Waste Reduction Assistance Program (WRAP). Retired engineers are sent out at the
  request of the facility to provide expertise in reducing the use of hazardous substances, the generation of hazardous
  wastes, and releases of air toxics. The program covers facilities handling chemicals reportable under section 313 of Title
  III, and focus on individual process units or even an entire facility.  Although the initial  focus of the visit is on
  housekeeping issues, inventory management, and preventive maintenance, potential process modifications are also
  examined. Upon completion of the facility visit, the engineers) provides the facility with a list of suggestions to reduce
  waste generation and save related expenses. Typical suggestions include material substitution, such as replacing 1,1,1-
  trichloroethane with less hazardous materials or non-toxic cleaners, or recycling used water in electroplating operations.

  Over the past four years, more than 184 facilities have participated in the program, including Department of Defense
  facilities (e.g., U.S. Air Force bases) and chemical manufacturers, as well as small facilities. More than $3.7 million
  in savings have been achieved by Florida businesses and government facilities as a'result of these source reduction
  efforts. To support the program, the SERC has coordinated with DER to mail letters to the chief executive officers of
  facilities reporting under section 313 to inform them of the program, and staff have made presentations on the program
  to various audiences. The SERC and local and state environmental regulatory staff refer businesses to the WRAP if
  they identify businesses interested in doing the right thing to protect the community. Many businesses volunteer for
  free pollution prevention technical assistance, thereby saving dollars while protecting environmental quality in Florida.
determined scope of work. These criteria
include holding regular LEPC meetings,
preparing an integrated LEPC hazardous
materials contingency plan from the individual
county plans, and conducting facility compliance
and Title IE training seminars. Over the last two
years, nearly $75,000 was provided to .each
LEPC to fund a full-time staff position.
LESSONS LEARNED

Prevention is Born Out of Preparedness.  One
of the key developments over the first few years
of the Title HI program in Florida has been the
positive impact of the reporting and fee system
burden on facilities. In addition to the successes
of WRAP, the burden imposed by these
regulations has helped convince a number of
facilities to modify their use of hazardous
substances, and thereby reduce the risk to the
community posed by an accidental release. Such
modifications have included reducing the
quantity of a hazardous substance onsite to fall
below the section 302 or 311-312 reporting
thresholds and substituting  less dangerous
chemicals in on-going processes.
          Title HI Efforts Serve as Foundation.
          Initially, the SERC believed that outreach and
          compliance efforts would be simplified by the
          use of pre-existing lists of subject facilities
          prepared under other government programs.
          When the required compliance verification
          program was initiated, however, it became
          apparent that the SERC would need to compile
          its own facility listing; various exemptions,
          threshold requirements, and other issues
          rendered existing lists only partially useful.
          Now that the compliance verification program
          has established a separate Title El list, other
          agencies have asked the SERC to use this list to
          identify potentially subject facilities under their
          own programs. For example, the Florida
          Department of Environmental Regulation was
          interested in data on facilities with significant
          tank storage volumes.

          Contact:

          Eve Rainey, Program Administrator
          Department of Community Affairs
          Hazardous Materials Planning Section
          2740 Centerview Drive
          Tallahassee, FL 32399-2149
          (904)488-1472

-------
Successful Practices
District 5 LEPC, Florida
PageS
       The District 5 LEPC is composed of five
       counties on or near the coast of the Gulf
       of Mexico in central Florida: Levy,
 Citrus, Marion, Sumter, and Hernando. The
 already existing Withlacoochee Regional
 Planning Council was used to provide the
 necessary staff support for the District 5 LEPC.
 Several standing committees address the
 principal responsibilities of the LEPC: the
 Regional Hazardous Materials Response
 Committee, the Hospital Preparedness
 Committee, the Public Relations and Education
 Committee, the Plan Review Committee, and the
 Plan Exercise Committee.  Through mutual-aid
                                                              District 5 LEPC,
                                                                    Florida
             agreements, the five counties have successfully
             combined their resources to prepare for and
             respond to hazardous materials release incidents,
             as well as to promote awareness of the
             Emergency Planning and Community Right-to-
             Know Act (EPCRA, also known as Title HI).

             Outreach

                    The LEPC works closely with the state to
                    encourage compliance with Title III
                    reporting requirements.  The Public
             Relations and Education Committee
             communicates to industry and the public the
  Membership:  25 members and 13 alternates, including representatives from local law
               enforcement, emergency management, fire departments, medical centers, the
               Department of Environmental Regulation, the news media, a community college,
               industry, and interested citizens.

  Population:    447,000

  Facilities:     175 facilities reporting under section 302, and 399 facilities reporting under
               sections 311-312, including waste water treatment plants, potable water utilities,
               phosphate mines, gasoline storage tanks, and an explosives manufacturer.

  Topics:       Outreach
               Compliance
               Funding
               Emergency Response
               Planning
               Exercises

-------
Pages
District 5 LEPC, Florida
Successful Practices
importance of reporting under Title ffl, helps
facilities report properly, and informs the public
that emergency planning is being done. The
committee has produced a slide and video
presentation about Title in and lias also procured
a television public service announcement from
another district to help meet these objectives.  In
addition, as part of an educational program, the
committee is producing a brochure for school
children regarding hazardous materials.

The most visible effort to increase  familiarity
with Title HI reporting requirements thus far has
been the state-sponsored EPCRA Awareness
Week: January 26-February 1,1992. The
District 5 LEPC publicized its own plans for the
week to alert the regulated community to related
activities.  Jeanne Schmotzer, principal planner
and staff for the LEPC, went on a radio talk
show to discuss the importance of Title III and
the events planned for the officially designated
week.  Newspaper articles also gave the event
visibility.  Schmotzer felt that participation from
EPA and the state Division of Community
Affairs enhanced the credibility of the LEPC.

The LEPC conducted "How to Comply"
seminars, a Computer-Aided Management of
Emergency Operations (CAMEO) presentation,
and a Title El slide presentation. They  also
produced a video on reporting requirements and
related issues for distribution to the Chamber of
Commerce and other organizations. These
activities were held in conjunction  with the
regularly scheduled LEPC meeting, and were
well attended by representatives from local
facilities and several concerned citizens. The
effort was such a success that the LEPC plans to
repeat  it next year.

Compliance

       The  State of Florida has taken a pro-active
       approach toward increasing compliance
       with Title UJ reporting requirements.
The Department of Community Affairs revised
             section 312 Tier II forms to include actual
             amounts of hazardous chemicals rather than less
             specific ranges of pounds requested by the
             federal forms.  They then took the initiative to
             mass mail the new forms to affected facilities.
             To assist the facilities, the state also sends them
             a reporting package. The package includes a
             compliance handbook and a map of the state
             indicating their district with the LEPC staff
             contact's name and address.

             As a direct result of its own outreach efforts
             combined with the state's efforts, the District 5
             LEPC has been deluged with requests for
             technical assistance. The LEPC is readily
             providing this assistance in completing the Tier
             II form. "The state is truly dedicated to this
             program," explains Jeanne Schmotzer, "and the
             facility owners and operators know that we care
             about them.  There's been a lot of frustration in
             the industry about the increased burden; the
             perception has been that these forms were not
             written with real people in mind. We have
             people coming in here with all of their
             paperwork and asking for help, so we sit down
             with them and guide them through the process.
             They're more willing to make the effort to
             comply if they know we're willing to help."

             The LEPC staff may also assist facilities in
             finding ways to reduce their inventory  of toxic
             chemicals  and in substituting less hazardous
             substances for chemicals when possible.  Many
             facilities have already taken the initiative to
             reduce toxic chemical inventories on their own.
             For those that have not, the LEPC suggests
             contacting other facilities who have an engineer
             on staff, or can easily contract with one, to
             examine their toxic chemical inventory.
             Facilities can also contact their suppliers for
             suggestions as to which chemicals can replace
             the more toxic ones they use and store. A simple
             reduction of a stockpile, such as storing a one-
             year supply of a chemical rather than a multi-
             year supply, can decrease the hazards within a
             facility.  Overall, the combined efforts  of the

-------
Successful Practices
District 5 LEPC, Florida
Page 7
state and the LEPC to assist facilities in reducing
their toxic chemical inventories have met with
success.

Funding

       The hazardous materials planning section
       of the state Division of Emergency
       Management collects fees from facilities
for filing under section 302 and section 312, a
portion of which are then divided up and
parcelled out equally to the LEPCs in order to
staff a position. Last year, the District 5
Regional Planning Council received
approximately $41,000 of the $450,000 LEPC
fund. Individual counties may also receive
grants from the state fund, based on their
percentage of the state population, their number
of facilities, and a fixed amount allocated to each
county. To qualify for grants from the state, the
counties must produce a county hazardous
materials emergency plan and provide a hazards
analysis of their facilities.  Last year, Hernando
County received approximately $8,000, used to
defray the expenses of personnel (the county
planner), equipment purchases, and overhead
(i.e., the cost of conducting a hazards analysis
for the regulated facilities in the county, etc.).

Emergency Response

       In early 1991, the counties in District 5
       amended the mutual aid agreements
       among their fire departments to include
provisions for a hazardous materials incident.
To keep expenses down, the counties decided to
buy equipment on a smaller scale and pool their
resources through a master equipment list. For
full-scale emergencies, Citrus County has a fully
equipped 20-foot response trailer, complete with
computers using CAMEO  software to provide a
site chemical inventory, and ABTROS software
to assess the hazards of certain chemicals if
inadvertently mixed together. Marion County is
developing a hazardous materials emergency
             response team comparable to the one in Citrus
             County.  The LEPC has addressed the need for a
             common radio frequency and compatible radio
             equipment among the counties to improve
             communications in an emergency. Although no
             new equipment has been bought, the regional
             hazardous materials emergency plan lists each
             county's radio frequencies for easy reference.

             Planning

                    Another interesting element of District 5's
                    activities is its attention to potential
                    transportation accidents involving
             hazardous materials. Interstate 75 and Routes
             441 and 301 serve a great number of trucks
             travelling north from the industrial areas in
             Tampa and St. Petersburg. Trucks transporting
             explosives, catalysts, fuel, and other hazardous
             materials used in manufacturing pose a danger to
             the community, but are not included in regional
             hazardous materials emergency plans.

             The need for such planning was demonstrated in
             the summer of 1988, when a truck carrying
             8,000 gallons of auto transmission fluid drove
             off of Interstate 75 into a ravine. The accident
             occurred in a rural area during the early hours of
             the morning, the busiest time of day for truck
             traffic. The emergency response team closed the
             highway, surrounded the truck, and allowed it to
             burn down.  The driver of the truck, who was
             killed, could not be identified until the trucking
             company was contacted. When the company
             was traced and could identify the contents of the
             truck, the emergency response team noted that
             such an accident could pose serious hazards to
             the community in slightly different
             circumstances.  If the truck had been carrying a
             more toxic chemical with explosive properties or
             a gaseous chemical that could spread beyond the
             interstate, or, if the accident had occurred in a
             more populous area,  local residents, livestock,
             and food crops could have been injured or
             destroyed.

-------
Pages
District 5 LEPC, Florida
Successful Practices
Railroads are another transportation concern to
District 5 emergency planners. In February
1992, two rail cars containing 179,000 pounds of
chlorine derailed from the train tracks running
through a residential area in Ocala, a large city in
Marion County. Railroads do not have to notify
the authorities of a derailment unless there is a
leak, so neither the city nor the county knew
about the accident until a neighbor reported it
several hours after it occurred. The LEPC
pointed out that even in the absence of a leak, a
derailed railroad car carrying a hazardous
substance poses risks to those attempting to get it
back on the tracks.  Since this incident,
government and railroad officials have agreed to
work with local fire departments to provide more
information to the counties about their
operations, in order to better prepare for a more
serious incident in the future.

As a result of these and other incidents,
Hernando County has included a transportation
section in its hazardous materials emergency
plan, the first county in the state to do so. The
LEPC intends to expand this approach to include
the other counties in District 5. The LEPC has
also made recommendations to local
governments to change accident reporting
regulations, so as to include incidents such as the
one described above. In addition, the LEPC has
submitted the name of a Florida Department of
              Transportation representative to the SERC for
              membership in the LEPC.

              Exercises

                     On September 21, 1991, the District 5
                     LEPC conducted one of Honda's first,
                     and certainly most ambitious, multi-
              jurisdictional field exercises for a toxic chemical
              release incident in the city of Dunnellon in
              Marion County. The LEPC's Plan Exercise
              Committee led an effort that culminated in a full-
              scale exercise involving more than 140 people
              from 27 organizations and all five counties. The
              scenario involved an urban area in which a
              tanker truck carrying sulfuric acid collided with
              a train. Diesel fuel was spilled as a result of the
              collision.  Possible hazards included the diesel
              fuel mixing with sulfuric acid, corrosion of
              metals causing a large release and chemical
              reaction with surrounding materials, a release to
              the Withlacoochee River through storm drains
              with a build-up of hydrogen gas, and an
              explosion in storm drains with damage to water
              mains.

              In its review of the exercise, the LEPC identified
              several areas for improvement, most notably the
              need for increased training for first responders,
              some of whom are volunteer fire fighters, and
              the need for better communication among the
                                Working with the Medical Community

  Local hospitals are onesegment of thecommunitythathavealready benefited from the LEPC's increasedoutreach efforts.
  The LEPC heard about another district's success in surveying area hospitals' chemical emergency preparedness and
  promptly adopted the idea. A committee was formed to assess each hospital's level of preparedness for treating victims
  of a toxic chemical release. The committee examined every phase of treatment, including ambulance services.
  Unfortunately, the resulting report concluded that the hospitals in the region were not well prepared for such an incident.

  In response to these findings, the LEPC developed a list of recommended practices and resources necessary for the
  hospitals to treat chemical accident victims. As a follow up to that effort, the LEPC visited area hospitals to assess what
  resources the hospitals actually had. During these visits, the LEPC emphasized that hospitals could upgrade their facilities
  to address deficiencies in existing capabilities without making huge expenditures. Recently, an emergency room doctor
  at a major hospital in Hernando County donated her time to assist the LEPC and the other area hospitals in developing
  procedures for treating potential medical emergencies associated with a chemical accident.  The Munroe Regional
  Medical Center in Marion County was undergoing major renovations, and at the suggestion of the LEPC, took the
  opportunity to install a special hazardous materials decontamination room.

-------
Successful Practices
District 5 LEPC, Florida
Page 9
counties. The exercise also exposed deficiencies  Contact:
in the understanding of the Incident Command
System. Each participating agency will review
its standard operating procedures, which they
believe fell short.
LESSONS LEARNED
             David Sloan, Director
             Hernando County Emergency Management
             Agency
             20 N. Main Street, Room 362
             Brooksville, PL 34601
             (904)754-4083
More Assistance Leads to More Compliance.   Jeanne Schmotzer, Principal Planner/LEPC Staff
Probably the most practical element of the
LEPC's SARA Title ffl implementation efforts
has been the technical assistance to facilities
attempting to comply with reporting regulations.
By meeting facilities half way in their efforts, the
LEPC has seen compliance increase
dramatically.  A strong commitment from the
state level has contributed notably to the LEPC's
successful outreach activities.

Cooperation Is the Key to a Successful LEPC.
Cooperation among the counties within the
LEPC and with other LEPCs has also been vital
to the success of the Title in program. New
ideas such as the hospital preparedness survey
are disseminated widely, adapted freely, and
implemented at both the state and local level.
Resources and outreach materials are also
shared. Thus, the regulatory community has
presented a coherent program to industry and to
the public.
             Withlacoochee Regional Planning Council
             1241 S.W. 10th Street
             Ocala,FL 34474
             (904) 732-1315

-------

-------
Successful Practices
Monroe County, Michigan
Page 11
       Monroe County is situated in the
       southeastern corner of Michigan,
       bordering Ohio to the south and Lake
Erie to the east. The county's 556 square miles
are primarily composed of farmland and small
towns.

Monroe County has set the standard in Michigan
and the nation for incorporating the farming
community into the larger web of the emergency
response community.  Although the Emergency
Planning and Community Right to Know Act of
1986 (EPCRA, or commonly known as Title HI)
                                                              Monroe County,
                                                                   Michigan
              did not specifically target farms, Monroe County
              contains a large number of farms that must
              comply with the emergency planning
              requirements in section 302 of Title HI. As a
              result, a model program was developed and
              implemented for the county that incorporates the
              specific needs of the farming community. The
              program, recently approved by Michigan's
              SERC, will ensure that farmers with extremely
              hazardous substances in quantities subject to the
              section 302 reporting requirements will be able
              to comply with Title III regulations in an easy,
              yet comprehensive manner.
  Membership:  16 members, including representatives from state and local government, law
               enforcement, emergency management, fire services, first aid, public health,
               environmental health, hospital services, transportation, media, community groups,
               facility owners/operators, education, agriculture, and organized labor.  The Monroe
               County LEPC is divided into 5 subcommittees: Budget, Right-to-Know/
               Notification, Planning, Training, and Resources.

  Population:   134,000

  Facilities:     Approximately 1,400 farms as well as a coal-fired power station, a wastewater
               treatment plant, a water treatment plant, paper companies, and several small
               manufacturing companies.

  Topics:       Outreach
               Planning
               Funding

-------
Page 12
Monroe County, Michigan
Successful Practices
Outreach

       One of the distinctive characteristics of
       Title HI is that emergency response plans
       must address the specific characteristics
of each community. Monroe County is
distinguished by the number of farms subject to
Title IE in comparison with other types of
facilities using hazardous substances. Modern
farming techniques pose a potential threat to the
community because they involve the controlled
use of a variety of chemicals on EPA's list of
extremely hazardous substances  (EHSs),
particularly anhydrous ammonia. In some
communities, the risks associated with farming
are generally ignored because of the seemingly
bigger dangers presented by industrial facilities.
Until recently, this phenomenon  was true in
Monroe County as well. However, the use of
EHSs, coupled with the rapidly increasing
number of housing subdivisions  built in the
county's rural areas, has created  a large potential
for accidents. Further, the storage of hazardous
chemicals on farms poses an even greater risk
when sensitive populations, such as day care
centers and nursing homes, are located in close
proximity to the farms.  As a result, an urgent
need arose for an emergency planning program
with a special emphasis on farms.

The initial attempt by the LEPC  to communicate
the Title HI reporting requirements to farmers
was a failure. A vague, one-page questionnaire
was poorly distributed by the area's
agribusinesses and, because it was distributed
during the harvest season, was poorly received.
The response was limited, and the questionnaires
that were received lacked the information the
LEPC needed for planning purposes.

After this initial attempt, a Geography and
Planning Masters Degree candidate at the
University of Toledo decided to focus on the
issue as the subject of a thesis project. A team of
representatives comprised of university, state,
and local representatives was formed to develop
              a completely new approach to the problem of
              outreach to the county's farmers. Among this
              team of representatives was a hazmat planning
              specialist from the Emergency Management
              Division of the Michigan State Police, the
              pesticide education coordinator of the Michigan
              State University Cooperative Extension Service,
              a member of the Michigan Department of
              Agriculture, a member of the Legislative Council
              for the Michigan Farm Bureau, the Agriculture
              Extension Agent in Monroe County, the fire
              chief of the Bedford Township Station 1, and
              two professors in the University of Toledo
              Geography and Planning Department. In
              addition, several members of the team also
              served on  the Michigan State Emergency
              Planning Committee (SERC).

              The philosophy behind setting up a new program
              was simplicity: the less the farmers had to do in
              order to comply, the more effective the program
              would be. If a farmer could provide the
              essential, site-specific details of the farm, then
              the LEPC could prepare comprehensive response
              plans.  The goal of the team was also to create a
              program that could be used by any planning
              district in  the nation with a significant farm
              population. "Together," explains Cyril Keiffer,
              Masters Degree candidate and team leader, "this
              eclectic group set its sights on a universal goal
              — to develop a plan to help not only Monroe
              County, but also any county across the country."

              The result was a standardized emergency
              planning questionnaire that overcame one of the
              largest obstacles to reporting compliance and
              effective planning.  Previously, each farmer
              started from scratch in providing the LEPC with
              the information needed for the emergency
              response plan.  Now, with the introduction of the
              standardized questionnaire, published by the
              Michigan State University Cooperative
              Extension  Service, farmers can comply with the
              reporting requirements and provide emergency
              response planning information in one step.
              Under the  new system, questionnaires, including

-------
Successful Practices
Monroe County, Michigan
Page 13
a brief explanation of Title HI and the farmer's
responsibilities under this statute, are distributed
to the farming operations.  The questionnaire
also includes a partial list of EHSs specific to
Michigan farms and requests site-specific
information necessary for the development of
site-specific plans. These plans are unique
because they also incorporate the requirements
of the Michigan Firefighters Right-To-Know
Act, which requires that the fire chief of each
fire district develop an emergency plan for all
places that store or use certain chemicals. The
list of chemicals in the Firefighters Right-To-
Know Act is broader than the EHS list; it
includes any hazardous chemicals used or
produced regardless of quantity.

Another unique aspect of Monroe County is the
extent to which the farmers are getting involved
and complying with the regulations. Initially,
farmers wanted to comply, but complicated
regulations and the absence of any outreach
made this difficult.  With the introduction of the
standardized questionnaire, compliance became
easy. To date, the packet has been sent to 1,400
farmers in the county and hundreds have already
been returned. Some farmers have even
voluntarily shown up at the LEPC office to fill
out the forms. The LEPC expects virtually all
the farms in the county to be subject to reporting
requirements because of the low threshold
planning quantity of anhydrous ammonia, a
substance used by most farmers.  In addition,
farmers seem to be taking the advice of the
LEPC and using a three-ring notebook to keep
an  updated list of the chemicals used and stored
on  the premises, the MSDSs for those chemicals,
and the response plan for their farm.

One reason for the success of this program is that
local and state groups bridged the gap between
the farmers and the LEPC. In part, this effort
consisted of changing the tone of the reporting
requirements from threats of enforcement to
positive outreach describing how the
               requirements could ultimately help to save the
               lives of the farmer's family and friends. By
               focusing on the risks involving the use of
               hazardous chemicals and the importance of
               planning, the perception of Title III was
               transformed from annoying paperwork to a
               beneficial program that identifies chemical
               hazards and prepares for potential emergencies
               involving these hazards.

               The Farm Bureau, a trusted agribusiness
               organization, and the Michigan State University
               Cooperative Extension Service promoted the
               goals of the team of representatives by providing
               the necessary outreach to the farmers. The
               Michigan State University Cooperative
               Extension Service provided several different
               publications to farmers explaining the
               requirements of Title HI.  The Farm Bureau
               helped provide the networking system needed to
               reach all the farmers by including a
               questionnaire in their newsletter sent to 45,000
               farms in Michigan. In addition, the Farm Bureau
               Network broadcast several statewide radio
               programs focusing on  Title III. Cyril Keiffer
               said that the effort with the Farm Bureau
               "portrays that it is important to approach Title III
               from the positive for its ultimate goal is to save
               lives."

               Planning

                      The identification of chemical hazards and
                      the planning for these hazards are two of
                      the major goals of Title in. The
               standardized questionnaire helps to meet both of
               these goals by  requiring farms to notify the
               LEPC if EHSs are present at or above threshold
               planning quantity and  by providing the LEPC
               with the necessary information for the planning
               process.  Therefore, the responsibility for
               emergency preparedness is shared by both the
               farmer and the LEPC.  As a result, it is essential
               that the farmer, the local fire department, the
               local agricultural agent, and the members of the

-------
Page 14
Monroe County, Michigan
Successful Practices
LEPC cooperate in order to guarantee the
implementation of a plan that addresses all
possible emergency scenarios.

Because the team's intention was to make Title
in requirements "farmer-friendly," all of the
material in the new questionnaire is written with
the farmer in mind. For example, the EHS list in
the brochure focuses on those chemicals relevant
to a farmer, herbicides, pesticides, and fertilizers
comprise the majority of the list. A glossary of
the chemicals was taken from the CAMEO
computer program, and presented to the farmers
with the facts about their chemicals along with
alternatives to the EHS substances they are
currently using. Another feature of the
questionnaire is that the chemical checklist is
subdivided so that the plan indicates seasonal
usage and storage so that emergency responders
know what to expect during an incident at a
specific site and during a specific season. This
feature is particularly useful because Monroe
County's LEPC will be able to determine the
differences in preparedness requirements from
one season to the next. Further, the questionnaire
asks for information relevant in assessing the
hazards of each farm including the nearest
crossroads, private wells that may be on the
farm, and the proximity to sensitive populations.
The questionnaire closes with a sketch of the
layout of the farm that must include all
buildings, wells, storage tanks (above and below
ground), and storage areas of chemicals.

By submitting the questionnaire, farmers have
met their obligation to notify the LEPC as well
as contributed significantly to the LEPC's task of
developing an effective emergency response
plan.  In the future, information will be entered
into the enhanced-911 computer system, so that
if a call comes in on a farm that has a plan
completed, EHS and other pertinent information
will be displayed.
               Once all the questionnaires are received from the
               farmers, emergency response plans will be
               developed for each fire district within the
               county. As of this point, a model plan has been
               written for the Temperance Fire Response
               District. After the completion of this model plan
               and its adaptation by the SERC, the Michigan
               State Police Emergency Management Division
               mailed a packet containing the questionnaire, the
               model plan, the glossary of chemicals, and an
               explanation of the process to all LEPCs in the
               state. This effort was part of the outreach to
               LEPCs by the State of Michigan to provide
               guidance in both gathering information and
               preparing contingency plans.

               The emergency response plan for each district is
               divided into two sections. The first part is a
               generic description of the fire department and its
               capabilities, resources, and responsibilities. The
               second part consists of site-specific plans that are
               custom-designed for each farm reporting  under
               section 302 within the district. The vulnerable
               zone calculations for site-specific plans were
               calculated using CAMEO based on the data
               regarding, chemical quantities and storage
               patterns supplied by the farmers.  After the
               response plan has been completed, each section
               302 farm receives a copy of the Response
               Information Data Sheet (RIDS) for each
               chemical on the farm, the Farm Hazard
               Description/Population Vulnerability report that
               applies to their farm site, and emergency
               notification procedures for the farm.

               If a spill occurs, the response will be a joint,
               cooperative effort between the farmer,
               agribusiness, and local government, and, if
               appropriate, state and federal agencies.  The
               Facility Emergency Coordinator for each  site is
               responsible for initially assessing the magnitude
               of the incident and notifying the Monroe County
               dispatch.  The fire department will then be
               responsible for reviewing the farmer's
               assessment and evaluating the initial

-------
Successful Practices
Monroe County, Michigan
Page 15
classification. If help is needed, the fire
department will notify the Monroe County
Health Department's Environmental Health
Division, and, if necessary, the Toledo Hazmat
Team across the border in Ohio. ,

Funding

       Much of the work planning and developing
       the Monroe County emergency response
       plan was accomplished because of the
commitment and dedication of a group of
individuals who did much of the work on their
own time. The LEPC has, however, received
funding from county funds through the county
commissioners in the form of-staff and supplies
and from Emergency Management Allocations
(EMA) from the state. In addition, the Michigan
Farm Bureau, the Michigan State Police
Emergency Management Division, and the
Monroe County Emergency Management
Division paid for the mailings to the farmers.
There is also a bill currently in the Michigan
Legislature that should provide money from
general funds.  In addition, Cyril Keiffer
suggested that other LEPCs, attempting to
initiate a similar plan, could offer students in
health or environmental departments in
universities the opportunity for paid or unpaid
internships with the LEPC.

LESSONS LEARNED

Reducing Reporting Burden Helps Increase
Compliance. The new model is successful in
part because Monroe County's plan incorporates
the requkements of Title III with the Michigan
Firefighters Right-to-Know Act. This Act
requires that the fire chief of each fire district
develop an emergency plan for all locations that
store or use hazardous chemicals, regardless of
quantity.  Because the Firefighters Right-to-
Know Act and Tide IE regulations request
similar information from the farmers, such as the
description of the types and locations of
hazardous chemicals stored on site, Monroe
               County combined the programs so that the
               information in the standardized questionnaire
               satisfies both requirements.  In addition, many
               volunteer firemen in the area are farmers in
               Monroe County, so they immediately saw the
               value in complying with both regulations by
               returning -the  site-specific information.

               Money Isn't  Everything. Lacking sufficient
               funding, the team of representatives sacrificed
               their personal time to develop a system that
               makes compliance for the farmers simpler and
               the writing of comprehensive response plans
               easier for the  LEPC. The success of this
               program is due in part to the dedication of those
               individuals who approached the problem of
               compliance within the farming community from
               a different angle. According to Cyril Keiffer,
               "this program just goes to show the things that
               can be accomplished without a lot of money."

               "Yes, It's Legislation,  But Here's The Good
               Side..." One of the true lessons learned from the
               Monroe County is the role that education plays
               in implementing a successful program. At first,
               the farmers approached Title III with the attitude
               that this regulation was just another way for the
               government to control farmers and threaten them
               with fines.  But, once the farmers of Monroe
               County were  educated on the importance of Title
               IE, their attitude changed and so did their
               willingness to comply with the regulations.
               When it was explained to them that Title III was
               intended to protect their families, friends, and
               neighbors,  and when the process of compliance
               was made simpler, their attitude towards Title III
               changed. As  of this point, the new system
               developed in  Monroe County has been fully
               tested and the LEPC is continuing the outreach
               program started by the team of representatives
               and are  awaiting the return of some of the
               questionnaires from farmers. So far, the
               program appears to be a success. The farmers
               have been very receptive to the standardized and
               simplified questionnaire.

-------
Page 16
Monroe County, Michigan
Successful Practices
Diversity Works. One premise of the LEPC is
to bring together a diverse group of individuals
— local and state, private and public — so that
issues can be approached from a variety of
different angles. Unfortunately, many times this
creates problems because diversity can lead to
conflicts of interest.  However, despite many
different interests, the team of representatives
was able to develop a plan that made compliance
fast, easy, and effective. As Cyril Keiffer says,
Monroe County and Michigan provides proof for
the benefits of diversity: "If you get the right
people and involve them in the right way, it can
be very successful."

Contacts:

Cyril Keiffer
Monroe County Road Commission
840 So, Telegraph
Monroe, MI 48161
(313) 243-7325 .
              Howard Kelly
              Michigan Farm Bureau
              Public Affairs Division
              7373 West Saginaw Highway
              Lansing, MI 48909-8460
              (517) 323-7000

              Dr. Larry Olsen
              Michigan State University Cooperative
              Extension Service
              Agriculture and Marketing Programs
              11 Agriculture Hall
              East Lansing, MI 48824-1039
              (517)355-0117

              Peggy Torpey
              Monroe County Emergency Management
              Division
              965 South Raisinsville Road
              Monroe, MI 48161
              (313) 241-6400

-------
Successful Practices
State of Alaska
Page 17
       Alaska, America's "last frontier," as the
       state motto proclaims, is best known for
       its natural beauty and its oil industry.
Less well known is the fact that hazardous
substances are used in nearly every community
in the state.  Typical facilities include: crude oil
tank production, pipeline, storage, and tanker
operations; petroleum refineries; bulk fuel
storage; fish processing plants;  and pulp mills.
Common hazardous substances used by these
and other industries and transported through
communities include:  chlorine, used by fish
processors, pulp mills, water and sewage
treatment plants and swimming pool complexes;
methanol, hydrochloric acid, and hydrofluoric
acid, used at oil fields on the North Slope and
Cook Inlet; and of course diesel fuel and other
petroleum products. An atypical facility, and a
significant concern hi the state, is a major
fertilizer manufacturer on the Kenai Peninsula.
                                                          State of Alaska
         Alaska is different from most states in its
         internal political districts. Instead of counties,
         the sub-state political jurisdictions are boroughs.
         There are 16 boroughs that encompass only 30
         percent of the state land area, but encompass 80
         percent of the state population including the
         largest cities, Anchorage (population 220,000),
         Fairbanks (29,000), and the capital, Juneau
         (26,000).  The remainder of the state is in one
         huge unorganized borough.  While 27
         Emergency Planning Districts (EPDs) have been
         created by the state as planning areas, only 14 of
         those areas have LEPCs appointed by the SERC.
         The remaining 13 EPDs are in remote and rural
         areas that often have no road network, with
         populations less than 500 in each EPD, and few
         chemical hazards. In these areas, there is not
         only a lack of the diversity of people to fill the
         required occupational categories to form an
         LEPC, but with so few hazards, there is an
  Membership: includes 16 representatives from the state Departments of Environmental
               Conservation, Community and Regional Affairs, Public Safety, Military and
               Veteran Affairs, Health and Social Services, and Transportation; local
               government; industry; state Fire Chiefs Association; Native Americans; and
               public interest groups.

  Organization: 14 LEPCs established in 27 Local Emergency Planning Districts

  Topics:       SERC Organization
               Hazards Analysis
               Planning

-------
Page 18
State of Alaska
Successful Practices
understandable lack of local motivation to form
an LEPC.  However, the Alaska SERC is
considering alternative mechanisms and forums
to address response issues in these areas. One
potential solution is to use the planning areas of
the Oil Pollution Act of 1990 to address any
hazmat concerns in these rural districts. To date,
all EPDs and the 14 LEPCs generally follow the
jurisdictional boundaries of boroughs.

SERC Organization

       Formed in 1987, the SERC, which meets
       quarterly, is composed of 16 members:
       nine state agency commissioners or their
designees and seven public and private members.
All activities of the SERC are administered by
the Alaska Department of Environmental
Conservation (DEC). In 1990, the state
legislature passed House Bill 566, establishing
the SERC in state law. The legislation provides
funding for Title HI implementation activities.
The funds are appropriated annually by the state
legislature from the Oil and Hazardous
Substance Release Response Fund. The fund is
generated by a surcharge on oil production to
support emergency response and planning. For
FY 92, $900,000 was appropriated with 60
percent ($540,000) being channeled to LEPC
activities. For FY 93, 80 percent, or $ 1.2
million of the state allocation, will be channeled
to LEPC activities.

The commissioner of the DEC serves as SERC
chair and oversees five standing committees.
The Work Plan Committee helps the SERC
identify priority activities and monitors the
state's implementation of Title El.  The LEPC
Liaison Committee coordinates the
establishment and activities of LEPCs. The
Training Committee identifies training needs for
responders. The Emergency Response
Committee facilitates state and LEPC planning
efforts by providing guidance documents and
minimum content standards. The Public
Awareness & Data Utilization Committee works
         to raise awareness in Alaska and is coordinating
         the development of a statewide database for
         community right-to-know uses.

         Hazards Analysis

                One of the first objectives of the SERC has
                been fostering the development of LEPC
                comprehensive response plans.  Hence,
         hazards analysis has been the SERC's most
         recent focus, as a precursor to plan development.
         The SERC is coordinating LEPC-based hazards
         analyses by providing technical assistance to the
         LEPCs in designing the scope of work and
         evaluating contractor proposals which will be
         funded by the legislature's annual appropriation.
         In some cases, groups of adjacent LEPCs will be
         working together; other LEPCs will work
         independently. Many LEPCs have already hired
         contractors, others are in the selection process.
         To date, Petersburg and Ketchikan are the only
         LEPCs that will not be using contractor
         assistance; in Ketchikan a borough employee
         will perform the analyses.

         To complement the activities of the LEPCs, the
         SERC will conduct hazard analyses in all areas
         of the state not included in LEPCs, which is 70
         percent of the state land area and 20 percent of
         the state population.  The state projects that all
         contracts for hazards analyses will be awarded
         by June 1993 and all hazards analyses will be
         completed by the end of 1994.

         The analyses will follow the airborne toxics
         approach outlined in the Technical Guidance for
         Hazards Analysis published by EPA, FEMA,
         and DOT, but, as required in the H.B. 566, the
         analysis has been expanded to include facilities
         with flammables (crude oil and bulk fuel storage
         facilities) and explosives (mining operations) —
         even  though the chemicals are not covered under
         section 302 of Tide EL In addition, the state
         will also be identifying those facilities with the
         potential for chemical and petroleum spills that
         could affect the drinking water supply or

-------
Successful Practices
State of Alaska
Page 19
 sensitive ecosystems.  Cooperative agreements
 are also underway to involve federal military
 facilities in identifying and assessing hazards at
 these facilities.

 Once the hazards analyses have been compiled at
 the local level, they will be transferred into a
 statewide Computer Aided Management of
 Emergency Operations (CAMEO) system, and
 eventually incorporated into a Geographical
 Information Systems (GIS) format along with
 data from other state environmental programs
 such as RCRA and CERCLA. The CAMEO
 system is a computer program .developed by
 EPA and the National  Oceanographic and
 Atmospheric Administration, Department of
 Commerce, that has the capability to manage
 hazardous substance inventories, transportation
 data, estimate vulnerable zones, and calculate
 and store risk analyses. While CAMEO is an
 excellent tool for hazards analysis and
 emergency response, GIS systems typically have
 expanded storage, problem solving, and display
 capabilities.  For example, a GIS can store
 potentially unlimited (limited only by memory
 capacity) amounts of data linked to a specified
 geographic area.

 Applications of GIS for the SERC and the
 Department of Environmental Conservation
 include planning and enforcement. For example,
 if a water (ground or surface) quality sampling
 site is revealing traces  of benzene, the GIS can
 be queried to show facilities that are in the
 vicinity, upstream of the well, that use benzene.
 This application will provide local
 environmental enforcement officers with quick
 and clear information to pursue potentially non-
 compliant facilities. Public health applications
 include developing GIS overlays that reveal
 concentrations of people with respiratory
problems and facilities that use chlorine gas.
This computerized inventory of information will
enable the State Department of Environmental
Conservation to make management decisions
regarding environmental issues based on more
         complete data. The state plans to analyze the
         information not only to plan for emergencies
         involving accidental releases, but also to
         evaluate long-term, chronic pollution problems
         and their effects on public health. In, addition,
         the system will provide the capability to identify
         and map major permitted locations, identify and
         map contaminated sites, identify and map major
         transportation routes for oil and hazardous
         materials, and to monitor and map data from
         water quality programs. The state will also use
         the GIS to identify, based on concentrations of
         chemical hazards, where to encourage the
         development of volunteer response teams and
         where to locate equipment depots.

         Planning

                Because the hazards analyses are not
                completed, as yet no LEPC plans are
                approved. The SERC is currently
         developing emergency response guidelines that
         will include core elements and minimum
         requirements necessary for SERC approval of an
         LEPC plan. The SERC hopes to promote
         development of emergency plans by providing
         specific criteria to assist LEPCs as they develop
         their plans.  The SERC met in October to discuss
         policies for plan review and approval.

         House Bill 566 goes beyond the requirements of
         Title in in its efforts to comprehensively identify
         hazards and plan an integrated response.  To that
         end, the law broadens the definition of hazardous
         substances to include oil for the purposes of
         hazards analyses and response planning.  This is
         a significant distinction from the federal law and
         could double the amount of information
         collected, and analyses performed. Thus, the
         law expands the assessment of the chemical-
         related hazards in a community and identifies the
         potential areas/population to  be impacted should
         a release occur. Further, the law and SERC
         policies together use several mechanisms to
         ensure integrated planning and procedures for
         response.  This is achieved by requiring that the

-------
Paqe 20
State of Alaska
                                                                   Successful Practices
statewide all-hazards plan, addressing natural
disasters and technological disasters, be
coordinated with the statewide hazardous
materials plan.

Also, the state plan will be coordinated with the
EPA Region 10 Regional Contingency Plan
(RCP) and potentially the Region 10 Supplement
to the Federal Response Plan (FRP-Regional
Supplement), Emergency Support Function #10:
Hazardous Materials. Due to the geography of
Region  10, Alaska's RCP and FRP Regional
Supplement are separate from the rest of Region
10. This coordination will support a state/federal
system of response for human-caused hazardous
material/oil pollution incidents or in the event a
natural disaster (earthquake or flood) creates
hazardous material/oil incidents.  The same is
true at the local level, i.e., the LEPC hazardous
materials plans will be coordinated with the
borough or local government all-hazards plans.
When the regional plans for oil spill contingency
are developed as required under the Oil Pollution
Act of 1990, they will be coordinated and
potentially combined with the EPA Region 10
RCP and FRP-Regional Supplement.

Yet another provision under the law creates the
Spill Technology Review Council within the
SERC to identify spill containment,
dispersement, and cleanup products for use in a
release in Alaska's arctic and sub-arctic climate.
In 1991, the Council issued its first annual
report.  The report recommends research
objectives for 1992 that include: utilization of
skimmers and oil/water separators, the
effectiveness of dispersants, in situ burning, oil
recovery from ice, in situ and ex situ
bioremediation of soils contaminated by
hazardous materials, and reuse/recovery of
 hazardous wastes.
         LESSONS LEARNED

         Integrated Planning At All Levels Can
         Overcome Most Obstacles. Several events
         have shaped the emergence of Alaska's drive to
         form a statewide integrated planning process: the
         Exxon-Valdez incident, the creation of LEPCs,
         and the multitude of federal facilities in the state.
         These events focused the state on the need for
         integrated planning and shared capabilities
         among federal, state, regional, and local
         governments; LEPCs; and industry. Camille
         Stephens, staff with the SERC, explains Alaska's
         challenge: "Many industries, federal facilities,
         and a few local governments in Alaska have very
         advanced and capable response teams. Yet, the
         distances and difficulty in access to areas of
         Alaska demand that mutual aid agreements be
         created and jurisdictional borders and issues be
         overcome. Our goal is to instill the concept of
         working together into the various agencies and
         industry to build an integrated response network
         that benefits the entire state."
          Contact:

          Camille Stephens
          410 Willougby Avenue, #105
          Alaska Department of Environmental
          Conservation
          Juneau,AK 99801-1795
          (907) 465-5239

-------
Successful Practices
                                     Page 21
                                More Successful Practices

       Additional Successful Practices in Title IDE Implementation technical assistance bulletins
are available from your Regional Chemical Emergency Preparedness and Prevention Coordinator (see the
listing on the following page), or call the Emergency Planning and Community Right-to-Know Information
Hotline at (800) 535-0202. The following bulletins are currently available:
Successful Practices #1
Doc. # OSWER-89-006.1, January 1989.

       State of Kansas
       Washtenaw County, Michigan
       Butler County, Kansas
       Jefferson County, Kentucky

Successful Practices #2
Doc. # OSWER-89-006.2, August 1989

       Calhoun County, Alabama
       Pampa, Texas
       State of Wisconsin
       Cuyahoga County, Ohio
       Racine County, Wisconsin
       State of Idaho

Successful Practices #3
Doc. # OSWER-89-006.3, December 1989.

       Woodbury County, Iowa
       State of Virginia
       Fairfax County, Virginia
       Pierce County, Washington

Successful Practices #4
Doc. # OSWER-90-006.1, March  1990.

       New York, New York
       El Paso County, Colorado
       Alexandria, Virginia
       State of Maine

Successful Practices #5
Doc. # OSWER-90-006.2, June 1990.

       Tinker Air Force B ase, Oklahoma
       State of Connecticut
       Cumberland County, Maine
       Wyandotte County, Kansas
Successful Practices #6
Doc. # OSWER-90-006.3, September 1990.

       State of Ohio
       Hamilton County, Ohio
       Wallingford, Connecticut
       Ouachita Parish, Louisiana

Successful Practices #7
Doc. # OSWER-91-006.1, February 1991.

       Cameron County, Texas
       Bucks County, Pennsylvania
       Harford County, Maryland
       Dallas County, Texas

Successful Practices #8
Doc. # OSWER-91-006.2, October 1991.

       Cherry Hill, New Jersey
       Manitowoc County, Wisconsin
       Greene County, Missouri
       State of Hawaii
       Arapahoe County, Colorado

Successful Practices #9
Doc. # OSWER-92-006.1, September 1992.

       Natrona County, Wyoming
       Erie County, New York
       State of Arizona
       Mohave County, Arizona

Successful Practices #10
Doc. # OSWER-93-006.1, May 1993.

       State of Florida
       District 5 LEPC, Honda
       Monroe County, Michigan
       State of Alaska

-------
Page 22
                                Successful Practices
                                 Regional Chemical Emergency
                         Preparedness and Prevention Coordinators
               Ray DiNardo
               EPA - Region 1
               New England Regional Lab
               60 Westview Street
               Lexington, MA 02173
               (617) 860-4301

               John Ulshoefer
               EPA - Region 2
               2890 Woodbridge Avenue
               Edison, NJ 08837-3679
               (908)321-6620

               David Wright
               EPA-Region 3
               Oil and Title HI Section
               841 Chestnut Street
               Philadelphia, PA 19107
               (215)597-5998
Henry Hudson
EPA-Region 4
345 Courfland Street, NE
Atlanta, GA 30365
(404) 347-1033

Mark Horwitz
EPA - Region 5
77 West Jackson
HSC-9J
Chicago, TL 60604-3590
(312) 886-1964

Jim Staves
EPA - Region 6
Allied Bank Tower
1445 Ross Avenue
Dallas, TX 75202-2733
(214) 655-2270

Ed Vest
EPA-Region 7
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7287
Cheryl Chrisler
EPA - Region 8
One Denver Place
999 18th Street, Suite 500
Denver, CO 80202-2466
(303) 293-1723

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

Walt Jaspers
EPA - Region 10
1200 6th Avenue (HW-114)
Seattle, WA 98101
(206) 553-4349
                                          States By Region
                4 - Alabama
                10-Alaska
                 9 - Arizona
                 6 - Arkansas
                 9 - California
                 8 - Colorado
                 1 - Connecticut
                 3 - Delaware
                 3 - D.C.
                 4 - Florida
                 4 - Georgia
                 9 - Hawaii
                10-Idaho
                 5-Illinois
                 5 - Indiana
                 7 - Iowa
                 7-Kansas
                 4 - Kentucky
  6 - Louisiana
  1 -Maine
  3 - Maryland
  1 - Massachusetts
  5 - Michigan
  5 - Minnesota
  4 - Mississippi
  7 - Missouri
  8 - Montana
  7 - Nebraska
  9 - Nevada
  1 - New Hampshire
  2 - New Jersey
  6 - New Mexico
  2-New York
  4 - North Carolina
  8 - North Dakota
  5 - Ohio
  6 - Oklahoma
 10 - Oregon
 3 - Pennsylvania
 1 - Rhode Island
 4 - South Carolina
 8 - South Dakota
 4 - Tennessee
 6 - Texas
 8-Utah
 1 - Vermont
 3 - Virginia
 10 - Washington
 3 - West Virginia
 5 - Wisconsin
 8 - Wyoming
 9 - American Samoa
 9 -Guam
 2 - Puerto Rico
 2 - Virgin Islands

-------
Page 23	Successful Practices


               Successful Practices in Title III implementation:

                                   Subject Index*


Compliance (Enforcement);
      Kansas (SP1:4); Idaho (SP2:14-15); Arapahoe County, Colorado (SP8:26-27);Districts LEPC,
      Florida (SP10:6,9); Monroe County, Michigan (SP10:12-15)

      Identifying/contacting facilities:
      Calhoun County, Alabama (SP2:l-2); Wisconsin (SP2:8); Fairfax County, Virginia (SP3:9);
      New  York, New York (SP4:3-4); Alexandria, Virginia (SP4:13); Tinker Air Force Base,
      Oklahoma (SP5:2); Wyandotte County, Kansas (SP5:15-16); Hamilton County, Ohio (SP6:11);
      Cameron County, Texas (SP7:4); Bucks County, Pennsylvania (SP7:11); Natrona County,
      Wyoming (SP9:1-2); Florida (SP10:1-3)

      Inspections:
      Pampa, Texas (SP2:4-5); Racine County, Wisconsin (SP2:12)


Emergency Plans:
      Jefferson County, Kentucky (SP1:9-10); Idaho (SP2:14); Pierce County, Washington (SP3:13);
      Tinker Air Force Base, Oklahoma (SP5:2); Bucks County, Pennsylvania (SP7:10-11); Monroe
      County, Michigan (SP10:12-14)

      Community Consequences:
      Racine County, Wisconsin (SP2:12-13); Wallingford, Connecticut (SP6:13)

      Coordination with other LEPCs and communities:
      Harford County, Maryland (SP7:14-15); Dallas County, Texas (SP7:19); Arapahoe County,
      Colorado (SP8:23); Erie County, New York (SP9:5-8); Alaska (SP10:20)

      Existing plans:
      Cumberland County, Maine (SP5:10-11); Cherry Hill, New Jersey (SP8:1)

      Facility input:
      Cuyahoga County, Ohio (SP2:10); New York, New York (SP4:3); El Paso County, Colorado
      (SP4:6-7); Wyandotte County, Kansas (SP5:14-15); Hamilton County, Ohio (SP6:9); Monroe
      County, Michigan (SP10:12-14)

      Facility plans:
      Fairfax County, Virginia (SP3:9)

      Hazard analysis:
      Butler County, Kansas (SP1:7); Alexandria, Virginia (SP4:11-12); Alaska (SP10:18-19)

      Planning guidance:
      Kansas (SP1:3); New York, New York (SP4:2); Connecticut (SP5:5-6); Alaska (SP10:19)
*The citation provided for each profile refers to the issue number (SP3 refers to the third issue of
Successful Practices) and the page number(s) within that issue.

-------
Successful Practices
Subject Index
Page 24
Emergency Plans ('continued');

      Public alert and notification system:
      Wyandotte County, Kansas (SP5:17); Monroe County, Michigan (SP10:14-15)

      Structure:
      Ohio (SP6-.1-2)


Exercises;

      Decontamination:
      Greene County, Missouri (SP8:11)

      Evacuation and sheltering:
      Greene County, Missouri (SP8:14); Arapahoe County, Colorado (SP8:24)

      Field programs:
      Woodbury County, Iowa (SP3:2); Cumberland County, Maine (SP5:11); Hamilton County,
       Ohio (SP6:9-10); Wallingford, Connecticut (SP6:13-14); Oauchita Parish, Louisiana (SP6:21-
      22); Manitowoc County, Wisconsin (SP8:8); Hawaii (SP8:21); Arapahoe County, Colorado
       (SP8:24); Natrona County, Wyoming (SP9:3); Mohave County, Arizona (SP9:16); District 5
      LEPC, Florida (SP10:8-9)

      Table-top programs:
      Hartford County, Maryland (SP7:15); Dallas County, Texas (SP7:20); Cumberland County,
       Maine (SP5:11); Hamilton County, Ohio (SP6:9-10); Erie County, New York (SP9:7); Arizona
       (SP9:12-13); Mohave County, Arizona (SP9:17)
 Funding;
       Citizen Suits:
       Erie County, New York (SP9:7)

       Donations:
       Jefferson County, Kentucky (SP1:10); Calhoun County, Alabama (SP2:2); Pierce County,
       Washington (SP3:14); Cameron County, Texas (SP7:4); Bucks County, Pennsylvania (SP7:9)

       Fee systems:
       Kansas (SP1:4); Washtenaw County, Michigan (SP1:5); Calhoun County, Alabama (SP2:2);
       Wisconsin (SP2:7); Fairfax County, Virginia (SP3:10);  Maine (SP4:16-18); Ohio (SP6:3);
       Florida (SP10:3); District 5 LEPC, Florida (SP10:7); Alaska (SP10:18)

       Grants:
       Connecticut (SP5:6); District 5 LEPC, Florida (SP10:7); Monroe County, Michigan (SP10:15)

       State and local agency budgets:
       Jefferson County, Kentucky (SPlrlO); Wisconsin (SP2:7); Connecticut (SP5:6); Ohio (SP6:3);
       Bucks County, Pennsylvania (SP7:9); Hartford County, Maryland (SP7:16); Dallas County,
       Texas (SP7:20); Florida (SP10:3-4)

-------
Page 25
Subject Index
Successful Practices
Hazards Analysis:
      Hazard identification:
      Cuyahoga County, Ohio (SP2:9-10); Alexandria,'Virginia (SP4:11-12); Wyandotte County,
      Kansas (SP5:13-14); Hamilton County, Ohio (SP6:7-9); Arapahoe County, Colorado (SP8:23-
      24); Monroe County, Michigan (SP10:12-14); Alaska (SP10:18)

      Hazards Incidents Complexity Analysis:
      Kansas (SP1:3); Wyandotte County, Kansas (SP5:13-14)

      Risk analysis:
      Hamilton County, Ohio (SP6:8-9); Dallas County, Texas (SP7:19)

      Transportation:
      Kansas (SP1:3); Butler County, Kansas (SP1:7); Alexandria, Virginia (SP4:11-12); District 5
      LEPC, Florida (SP10:7-8)

      Vulnerability zones:
      Cuyahoga County, Ohio (SP2:9); Hamilton County, Ohio (SP6:7-9); Wallingford, Connecticut
      (SP6:14-15); Greene County, Missouri (SP8:13-14); Monroe County, Michigan (SP10:14);
      Alaska (SP10:19)
Information Management (Computer Systems):

      CAMEO:
      Jefferson County, Kentucky (SP1:10); Pampa, Texas  (SP2:5);  Racine County, Wisconsin
      (SP2:13); New York, New York (SP4:2); El Paso County, Colorado (SP4:7); Wyandotte County,
      Kansas (SP5:16); Hamilton County, Ohio (SP6:10); Wallingford, Connecticut (SP6:14); Bucks
      County, Pennsylvania (SP7:8); Cherry Hill, New Jersey (SP8:2-3); Greene County, Missouri
      (SP8:13); Hawaii (SP8:17-19); Arapahoe County, Colorado (SP8:25); Natrona County, Wyoming
      (SP9:3); Arizona (SP9:10);  District 5 LEPC, Florida (SP10:6,7); Monroe County, Michigan
      (SP10:14); Alaska (SP10:19)                                             '

      Conversion software:
      Greene County, Missouri (SP8:13)

      dBase:
      El Paso County, Colorado (SP4:7); Bucks County, Pennsylvania (SP7:9); Natrona County,
      Wyoming (SP9:1-2); Florida (SP10:3); Alaska (SP10:18)

      Dispatch system:
      Bucks County, Pennsylvania (SP7:9)

      Modified reporting format:
      Ohio (SP6:2), Oauchita Parish, Louisiana (SP6:20), Hawaii (SP8:19)

      Networks:
      Idaho (SP2:15)

      "Packet" radio:
      El Paso County, Colorado (SP4:7); Cherry Hill, New Jersey (SP8:3)

-------
Successful Practices
Subject Index
Page 26
foformation Management (continued);

      Software programs:
      Kansas (SPl:3-4); Pampa, Texas (SP2:5-6); Virginia (SP3:5-6); Fairfax County, Virginia
      (SP3:9-10); New York, New York (SP4:l-2); Tinker Air Force Base, Oklahoma (SP5:2-3);
      Connecticut (SP5:6-7); Hamilton County, Ohio (SP6:10); OauchitaParish, Louisiana (SP6:21);
      Bucks County, Pennsylvania (SP7:8); Arapahoe County, Colorado (SP8:25); Natrona County,
      Wyoming (SP9:3); District 5 LEPC, Florida (SP10:7); Alaska (SP10:19)

      Worksheet forms:
      Washtenaw County, Michigan (SP1:5)


LEPC Coordination:

      Coordination with SERC:
      Kansas (SP1:2); HamUton County, Ohio (SP6:10); Florida (SP10:3)

      Federal facilities:
      Tinker Air Force Base, Oklahoma (SP5:1)

      Inter-LEPC coordination:
      Woodbury County, Iowa (SP3:3); Virginia (SP3:4-5); Alexandria, Virginia (SP4:12-13);
      Wyandotte County, Kansas (SP5:17); Mohave County, Arizona (SP9:16)

      International coordination:
      Maine (SP4:18); Cameron County, Texas (SP7:l-3); Erie County, New York
      (SP9: 5-8); Arizona (SP9:13)


LEPC Organi/ation;

      Pre-SARA/Title m organizations:
      Racine County,  Wisconsin (SP2:11);  Woodbury County, Iowa (SP3:l-2); Bucks County,
      Pennsylvania (SP7:7-8); Cherry Hill, New Jersey (SP8:1); Hawaii (SP8:19-20); Honda (SP10:1,3);
      District 5 LEPC, Florida (SP10:5)

      Subcommittees:
      Jefferson County, Kentucky (SP1:10); Calhoun County, Alabama (SP2:2); Pampa, Texas
       (SP2:4);  Oauchita Parish, Louisiana (SP6:17-18); Bucks County, Pennsylvania (SP7:7-8);
      Greene County, Missouri (SP8:11-13); Mohave County, Arizona (SP9:15-16); Districts LEPC,
      Florida (SP10:5-6,8)
 jLiability;
       Virginia (SP3:S); Pierce County, Washington (SP3:15); Maine (SP4:16)

-------
Page 27
Subject Index
Successful Practices
Outreach Programs:
      Wisconsin (SP2:8); Hawaii (SP8:19)

      Agriculture:
      Racine County, Wisconsin (SP2:11-12); Manitowoc County, Wisconsin (SP8:6-7); Florida
      (SP10:2-3); Monroe County, Michigan (SP10:11-15)

      Audio/Visual Aids:
      Virginia (SP3:4-5); Ohio (SP6:2-3); Harford County, Maryland (SP7:15); Cherry Hill, New
      Jersey (SP8:4); District 5 LEPC, Florida (SP10:6)

      Brochures, factsheets, and booklets:
      Kansas (SP1:2); Cuyahoga County, Ohio (SP2:10); Idaho (SP2:14); New York, New York
      (SP4:4); Hamilton County, Ohio (SP6:10); Wallingford, Connecticut(SP6:15); Harford County,
      Maryland (SP7:15); Arapahoe County, Colorado (SP8:25); Florida (SP10:2); District 5 LEPC,
      Florida (SP10:6); Monroe  County, Michigan (SP10:13-14)

      Guidelines:
      Cuyahoga County, Ohio (SP2:10); Virginia (SP3:4-5); Florida (SP10:3); Alaska (SP10:19)

      Indian Tribes:
      Arizona (SP9:12-13)

      Industry:
      Virginia (SP3:4-5); Arizona (SP9:9-11); Florida (SP10:2)

      Lectures & workshops:
      Butler County, Kansas (SP1:7); Idaho (SP2:14); Pierce County, Washington (SP3:14); New
      York, New York (SP4:4); Connecticut (SP5:7); Cameron County, Texas (SP7:4); Dallas County,
      Texas (SP7:20); Manitowoc County, Wisconsin (SP8:6-8); Arizona (SP9:10-13); Natrona
      County, Wyoming (SP9:2-3); Florida (SP10:2); District 5 LEPC, Florida (SP10:6)

      Library displays:
      Pierce County, Washington (SP3:14); El Paso County, Colorado (SP4:8)

      Local government:
      Cherry Hill, New Jersey (SP8:4)

      Mailing lists:
      New York, New York (SP4:4)

      Media Use (TV, radio, newspaper):
      Kansas (SP1:3); Butler County, Kansas (SP1:7); Woodbury County, Iowa (SP3:2); Fairfax
      County, Virginia (SP3:10); Pierce County, Washington (SP3:14); El Paso County, Colorado
      (SP4:8); Tinker Air Force Base, Oklahoma (SP5:3); Oauchita Parish, Louisiana (SP6:18-20);
      Cameron County, Texas (SP7:4); Harford County, Maryland (SP7:15); Dallas County, Texas
      (SP7.-20); Manitowoc County, Wisconsin (SP8:6-8); Natrona County, Wyoming (SP9:2,4);
      Mohave County, Arizona (SP9:16); Florida (SP10:3); District 5 LEPC, Florida (SP10:6);
      Monroe County, Michigan (SP10:13)

      Public schools:
      El Paso County, Colorado (SP4:8); District 5 LEPC, Florida (SP10:6)

-------
Successful Practices
Subject Index
Page 28
Prevention;
      Washtenaw County, Michigan (SP1:5); Hamilton County, Ohio (SP6:11); Florida (SP10:4);
      District 5 LEPC, Florida (SP10:6)


Public Alert System;
      Wyandotte County, Kansas (SP5:17)


JReporting Modifications!
      Ohio (SP6:2); Oauchita Parish, Louisiana (SP6:20); Hawaii (SP8:19); Florida (SP10:2)


Right-to-Know Laws;
      Washtenaw County, Michigan (SP1:5); Wisconsin (SP2:8); New York, New York (SP4:4);
      Maine (SP4:15-16); Wyandotte County, Kansas (SP5:16-17); Florida (SP10:1); Monroe County,
      Michigan (SP10:15); Alaska (SP10:18,19)


Section 313 Data;

       Accessibility and analysis:
       Virginia (SP3:6); El Paso County, Colorado (SP4:9); Connecticut (SP5:8); Ohio (SP6:3-5);
       Dallas County, Texas (SP7:18);

       Compliance:
       Fairfax County, Virginia (SP3:8);  Ohio (SP6:4); Florida (SP10:1)
 Special Planning Features;

       Chemical Stockpile Disposal Program facilities:
       Harford County, Maryland (SP7:16)

       Federal facilities:
       Tinker Air Force Base, Oklahoma (SP5:2); Harford County, Maryland (SP7:14)

       Hospital  Preparedness:
       Erie County, New York (SP9:6-8); District 5 LEPC, Florida (SP10:5,8)

       Indian Tribes:
       Mohave County, Arizona (SP9:12-13)

       Nursing homes:
       Cherry Hill, New Jersey (SP8:4)

       Schools:
       Wallingford, Connecticut (SP6:13); Harford County, Maryland (SP7:14)

       Transportation:
       Alexandria, Virginia (SP4:11-12); Oauchita Parish, Louisiana (SP6:21-22); District 5 LEPC,
       Florida (SP10:7-8)

-------
Page 29
Subject Index
Successful Practices
Training Programs:

       Coordination with government organizations:
       Virginia (SP3:4); El Paso County, Colorado (SP4:8); Tinker Air Force Base, Oklahoma (SP5:3);
       Connecticut (SP5:7); Bucks County, Pennsylvania (SP7:11); Hawaii (SP8:20)

       Facility management personnel:
       Tinker Air Force Base, Oklahoma (SP5:3); Bucks County, Pennsylvania (SP7:11)

       First-responders:
       Pierce County, Washington (SP3:13-14); El Paso County, Colorado (SP4:8); Tinker Air Force
       Base, Oklahoma(SP5:3);Connecticut(SP5:7); Cumberland County, Maine (SP5:ll);Wallingford,
       .Connecticut (SP6:15); Cameron County, Texas (SP7:3); Harford County, Maryland (SP7:15);
       Cherry ffill, New Jersey (SP8:3-4); Arizona (SP9:13)

       Hazmat team personnel:
       Jefferson County, Kentucky (SP1:9); Pampa, Texas (SP2:5); Virginia (SP3:4); Connecticut
       (SP5:7); Harford County, Maryland (SP7:15); Hawaii (SP8:20)

       LEPC:
       Kansas (SP1:3); Virginia (SP3:4); Alexandria, Virginia (SP4:13-14); Connecticut (SP5:7)

       Medical personnel:
       Racine County, Wisconsin (SP2:12)

       Potential CAMEO users:
       Cherry Hill, New Jersey (SP8:3-4); Hawaii (SP8:18); District 5 LEPC, Florida (SP10:6)

       Public:
       Bucks County, Pennsylvania (SP7:11)

       Train-the-Trainer:
       Idaho (SP2:15); Maine (SP4:18); Cherry Hill, New Jersey (SP8:4); Erie County, New York
       (SP9:7)


Vulnerability Analysis;
       Cuyahoga County, Ohio (SP2:9); Hamilton County, Ohio (SP6:8); Wallingford, Connecticut
       (SP6:14-15); Greene  County, Missouri (SP8:13-14); Monroe County, Michigan (SP10:14):
       Alaska (SP10:19)

       HIRT:
       Bucks County, Pennsylvania (SP7:11)
                                          •fcu.8. GOVERNMENT PUNTING OFFICE: 1993 - 715-003/870*7

-------

-------

-------
&EPA
United States
Environmental Protection
Agency (OS-120)
Washington, DC 20460
Official Business
Penalty for Private Use
$300
Forwarding and
Address Correction
FIRST CLASS MAIL
Postage and Fees Paid
EPA
G-35

-------