v>EPA
United States
Environmental Protection
Agency
Office of Soild Waste
and Emergency Reponse
(OS-120)
August 1989
OSWER-89-006.2
Series 6, No. 2
Successful Practices in
Title III Implementation
Chemical Emergency
Preparedness and Prevention
Technical Assistance Bulletin
Calhoun County, Alabama
Pampa, Texas
State of Wisconsin
Cuyahoga County, Ohio
Racine County, Wisconsin
State of Idaho
Printed on Recycled Paper
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ABOUT THIS BULLETIN
This is another in a series of bulletins 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 bulle- '
tins is to share information on successful practices with Local Emergency
SSS??? Committees &EPCs), State Emergency Response Commissions
u us)' departments, and other Tide 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, hazard analysis, and out-
reach. The particular topics covered in each LEPC or SERC profile are
reference "^ "^ h™d COmer °f the ^ P&ge °f the pr°flle for easy
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.
If you know of Title HI implementation efforts that you feel would
be of interest to others, please contact your EPA Regional Chemical
Emergency Preparedness and Prevention coordinator (see list on the last
page) or the Emergency Planning and Community Right-to-Know Infor-
mation Hotline at 1-800-535-0202, or, in WashingtonTDC 4792449
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Compliance
Funding
LEPC Organization
LEPC:
CALHOUN COUNTY, ALABAMA
125 members (elected officials and representatives of all
county law enforcement agencies, fire departments, medi-
cal, and emergency response units, military installations,
facilities, and media; ex-officio chairman: county commis-
sion chairperson; working chairman: county emergency
management agency director) '
Population: 123,800
Facilities:
41, primarily textiles and apparel and primary and fabri-
cated metals
A Hazmat Task Force was in existence in Alabama prior to the
passage of SARA Title HI, although no state right-to-know legislation
existed. The Task Force was expanded by the Governor to form the
Alabama SERC and each of the sixty-seven counties was declared an
LEPC. The Calhoun County Emergency Management Agency (CC
EMA) in Anniston serves as the operations center for the Calhoun County
LEPC, which has requested Tier E information from facilities.
LEPC ACTIVITIES
^ ™ A?H?pl!^de* To imPr°ve compliance with Title HI requirements,
UC bMA, the Alabama Department of Environmental Management and
the Alabama Emergency Management Agency conducted a pilot project
with the assistance of US EPA Region IV during the winter of 1988-89 in
Anniston, the seat of Calhoun County, Alabama. The county was selected
as a result of its economic diversity, which provided a wide variety of
facilities, and the extensive experience of the CC EMA director.
The first phase of the project began in September, and the princi-
pal objectives were to identify and notify those facilities likely to be
subject to sections 302, 311, and 312 of Title m which had not reported
Regular meetings with the news media were arranged to intensify the
outreach program through county newspapers, radio, and television A
comprehensive database was developed, combining the information
provided in the Dun and Bradstreet listings; the current CC EMA list of
Title IE reporting facilities; EPA Region IV's list of water and RCRA
permit-holders, and filers of the Toxic Release Inventory; county industry
and business listings; the Anniston telephone directory; and local contacts
and interviews.
Initially, the database contained approximately 250 entries, but it
was reduced to 100 candidates for compliance following a series of
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interviews. Arranged and coordinated by CC EMA, these conversations
with civic officials and representatives of select industries sought to
identify which county entities would be covered by Title III as a result of
their use or storage of hazardous chemicals. These interviews produced
mixed results — the fire departments, despite limited training in chemical
hazards response activity, proved to be a major source of information, but
some industry representatives indicated they had little information to
contribute about their competitors.
After review, 47 of these 100 entities were determined to be likely
compliance candidates for the LEPC. These facilities were mailed a
comprehensive package of Title HI materials, including an explanatory
cover letter, an EPA Title m Fact Sheet, a list of extremely hazardous
substances, a flow chart on reporting hazardous material spills, and a list
of Title m filing addresses. The limited CC EMA budget prevented a
certified mailing to insure the receipt of these materials, however, and
only seventeen responses to this inquiry were received. One month later,
non-respondents were sent a follow-up letter, asking them to review the
Tide IE materials and indicate in writing whether they were subject to
reporting requirements. Although a few more responses were received in
the following weeks, all of these were negative.
Phase two of the project was implemented in mid-February of
1989 with the assistance of EPA Region IV. Teams of government
officials visited unresponsive facilities suspected of being covered by
Title in. These visits initiated a "get tough" program which produced the
most significant results of the project — twelve entities with extremely
hazardous substances and seventeen subject to sections 311-312 of Title
in were identified and informed of their reporting obligations. Within
several weeks, almost all of these had filed the appropriate reports. The
LEPC is currently working to determine which identified facilities have
failed to respond.
Funding. Funding for the Calhoun County LEPC and for the pilot
outreach project is drawn from the budget of CC EMA. During the
formation of the LEPC, CC EMA received donations from the Monsanto
Corporation and the City of Anniston to purchase an IBM computer
system; Monsanto also donated the time of an employee to provide word
processing assistance. Aware of the financial burden of current regula-
tions on county industry, the LEPC has not requested the establishment of
a fee structure to provide for its funding. At the present time, however,
the LEPC has only two employees, and the workload has prompted
consideration of a fee system by the state legislature.
LEPC Organization. The Calhoun County LEPC is composed of
approximately 125 individuals. An executive group of the chief elected
officials, a business and industry subcommittee composed of all facility
representatives, and seven task groups were established to perform LEPC
functions. More effective and manageable than the entire LEPC, the
smaller task groups are assigned responsibility for specific activities
directly related to the knowledge and expertise of their members. Pre-
sided over by the acting LEPC chairperson, they have developed guidance
documents, directed outreach efforts, and evaluated existing response
resources for the LEPC.
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LESSONS LEARNED
More Outreach Needed for Smaller Facilities. Prior to the An-
niston project, a number of Calhoun County firms had filed submissions
under sections 302, 311, and 312 with the LEPC. As expected, these
facilities were the largest in the county; the smaller firms appeared to lack
comparable awareness and capacity to respond to Title HI, and thus
require special attention in any compliance effort. Because of the dramatic
increase in the number of reporting facilities described above, especially
among smaller entities, the pilot project has been judged a success. For
example, an ice manufacturer who used 2300 Ibs of ammonia in refrigera-
tion had no knowledge of his obligations under Title IE, but promptly
filed under section 302 when informed by members of the project.
Developing a Facility Database is Important. Central to the
success of this pilot project was the development of the database of or-
ganizations and firms likely to be subject to the provisions of Title in.
Although holders of municipal and county licenses (a potentially more
comprehensive listing) were not organized by SIC code in Alabama, the
databases acquired proved to be a sufficient source of information. It
should be noted that this project benefitted from the small, closely-knit
nature of Calhoun County, where local officials and industry representa-
tives know each other; the need for a comprehensive database is likely to .
be even greater in a larger, more industrialized area.
Coordinated Efforts at the Start. The success of the Calhoun
.County project illustrates the effectiveness of a combined effort by state
and local Title III agencies. While Region IV staff did provide significant
assistance in this project, these were exceptional circumstances because
the project was designed to serve as a pilot for Alabama and potentially,
for other states. It is likely, however, that the success of this project can
be duplicated in other LEPCs, with SERCs or regional government
agencies providing the database listings not available to local agencies
and the enforcement clout necessary to reach recalcitrant facilities. At the
present time, LEPCs across Alabama are taking part in a similar compli-
ance program modeled on the Anniston outreach project. The Alabama
SERC is providing local officials with guidance materials and lists of
candidate facilities arranged by SIC code for their outreach efforts.
Contact: Constance Sims, Deputy Director
Calhoun County Emergency Management Agency
Attention: LEPC
East Basement County Courthouse
25 West llth Street
Anniston, Alabama 36201-4584
(205)237-7023
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LEPC:
Compliance
Training
Information Management
PAMPA, TEXAS
Over 15 members including the city manager, police chief,
health officer, Gray County Judge and Sheriff, and repre-
sentatives from the city fire department, Texas Highway
Patrol, Texas National Guard, American Red Cross, Santa
Fe Railroad, industry, media, and citizens.
Population: 21,000
Facilities:
125 reporting facilities, including petrochemical refineries,
and a carbon black production plant
Pampa, Texas, first realized the need for planning for hazardous
materials incidents and complying with other aspects of Title III as a
result of participation in the Community Awareness and Emergency
Response (CAER) program, which was organized by local industry. The
CAER program served as a foundation for the development of the Title III
program, coordinated jointly by the Pampa/Gray County Office of Emer-
gency Management and the City of Pampa Fire Department. The city is
relatively small in area, and the fire department cooperates with adjacent
Gray and Roberts counties.
The LEPC meets with members of industry reporting under Title
IE on a quarterly basis; these meetings are open to the public and the
media; 40 to 50 people have attended on average. The LEPC has ap-
pointed an oversight committee which meets on a monthly basis to dis-
cuss current issues. This oversight committee designs the agenda for the
quarterly LEPC meeting. The inclusion of the media in the process has
resulted in a close working relationship between the media and the LEPC.
LEPC ACTIVITIES
Compliance. The Pampa Fire Department inspects all businesses
within the city limits for fire hazards at least once per year. A hazardous
materials specialist now accompanies the fire inspection officer on these
inspections to assist with implementing Title in. During the course of an
inspection, the specialist will survey the business to determine if any
hazardous materials are on-site. If hazardous materials are found, the
specialist will inform the owner or manager of the requirements of the
Title DDE program. The manager is then offered assistance with meeting
these requirements, including help with procedures, forms, and other
paper work required of the facility; in addition, the representative will
attempt to answer any questions that arise and may act as liaison between
the facility and the Texas Department of Health. Other assistance may
include identifying where to obtain needed MSDSs and advice on storage
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and transportation of hazardous materials.
The surveys have resulted in increased awareness by the fire de-
partment and businesses of all hazardous materials that may be involved
during fire fighting operations, including materials that are not listed
under Title III. The cooperative nature of the program has enhanced
relations between industry and the fire department.
Training. Pampa doesn't have enough manpower to maintain a
full-time hazardous materials response team, so the city relies on hazard-
ous materials specialists who are matched to incidents as the need arises.
In an emergency, the hazardous materials specialist works to identify the
chemical, contain the spill, and notify the public. The fire department
relies on the facility or state to handle the incident itself. A local facility
has a hazmat team that responds to incidents throughout the Texas pan-
handle. To prepare for such an emergency, Pampa, Gray County and
local industry, through the LEPC training subcommittee, conduct annual
full-scale emergency exercises.
The LEPC training subcommittee agrees on a location for the
exercise, as well as a scenario for an emergency or disaster. The subcom-
mittee develops that scenario, coordinating with the appropriate agencies
and industries. Then, a table-top exercise is conducted and evaluated;
Following the table-top exercise, a full-scale exercise is held. This allows
industry and local responders to work together, not only through the •
planning process, but through the response process as well.
To train the hazardous materials specialists, the city took advan-
tage of free training, including courses hosted by EPA, DOE, and the
State of Texas. In addition, Pampa sought out other training opportuni-
ties. Knowing that Houston has an experienced hazmat team that some-
times responds to as many as three incidents per day, Pampa called the
Houston Fire Department and asked if they could send someone to Hous-
ton on detail. Houston agreed, and, as, a result, the Pampa hazmat special-
ists gained valuable hands-on experience for little cost. Pampa has also
worked with the Santa Fe railroad, which brought in tank cars and person-
nel to talk about what to do and what not to do during railroad incidents.
Information Management. Pampa has a acquired several com-
puter software packages, which it has combined to create a menu-driven
system to assist with management of information obtained under Title III
Most of the software was free.
The city obtained a copy of the Computer-Aided Manage-
ment of Emergency Operations (CAMEO) system from the
National Oceanic and Atmospheric Administration
(NO A A) to aid with meeting the requirements of Tide in.
CAMEO contains a database of chemical information and
may be used in response situations. CAMEO is also used
by the LEPC to research chemicals for planning purposes.
Pampa acquired a copy of Management Information of
Title IE (MITT), a system developed by EPA Region VI,
to help individual facilities manage Title HI information;
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the system has been adapted for use by the LEPC,
The city uses Pyre Eyte, a software program that maintains
records of fireman training and special skills; it assists with
matching specialists to situations.
The LEPC uses a desktop publishing package to maintain
sketches of each facility including locations of all hazard-
ous materials.
The city is attempting to acquire a portable computer and modem
for use in the field, but, in the meantime, information is communicated via
two-way radio.
LESSONS LEARNED
Assisting Industry Pays Off. Lasting and trusting friendships
between the fire department and industry have developed. This relation-
ship led to quick joint response during the Hoechst/Celanese explosion of
November 1987, and resulted in substantial savings of lives, property, and
time.
Contact: Steve Vaughn
Coordinator Pampa/Gray County Emergency Management
P.O. Box 2499
Pampa, TX 79066-2499
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Funding
Compliance
Outreach
WISCONSIN
State Characteristics: 72 counties are LEPDs
SERC:
14 members, representing state agencies, fire fighters, law
enforcement, county and municipal governments, labor,
environmentalists, and industry; chair: Administrator, State
Division of Emergency Government
The State of Wisconsin has taken an active role in helping its
LEPCs to implement Title HI by providing funding and outreach pro-
grams as well as compliance procedures.
SERC ACTIVITIES
Funding. In the first year of its Title III implementation, Wiscon-
sin appropriated $96,000 from general revenues to initiate its program.
After estimating that the costs for LEPCs would be ten times that amount
the state legislature adopted a fee system to support both the SERC and
LEPCs. Wisconsin has adopted the following schedule of fees to pay for
Title in programs:
• A one-time fee of $800 for filing the notification required under
SARA section 302 and state law.
Annual fees based on the number of chemicals a facility reports on
the section 312 hazardous chemical inventory form:
$100 for 1 to 100 chemicals;
$150 for 101 to 500 chemicals: and
$300 for more than 500 chemicals.
.Funds are used to administer the state program and are made
available to LEPCs for emergency planning grants. The State law re-
quires that plan preparation be the first priority for use of grant funds. The
grants, however, may pay for up to 50 percent of the cost of computers or
response equipment, up to a maximum $6,000 for each. State law prohib-
its local governments from adopting fees of their own to fund the pro-
gram. The State awarded grants totalling almost $380,000 to LEPCs for
1988. Initial payments on these grants totalling over $284,000 were made
just before Christmas in 1988.
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Compliance. The SERC is in the process of adopting formal
compliance and enforcement procedures. If an LEPC or an individual
citizen notifies the SERC that a facility is not complying, a form letter
will be sent to the facility notifying it of the complaint and the Title HI
requirements. The LEPC will receive a copy of the letter and will be
asked to contact the facility. If the facility fails to respond within a
specific time, the case will be referred to the state for prosecution.
Outreach. The SERC sends regular Information and Guidance
Memos to all LEPCs to keep them up-to-date on Title III issues. The
SERC has established procedures for LEPCs to apply for the planning
grants. To help the LEPCs with their planning and outreach, the SERC
obtained a printout from the Wisconsin Industry, Labor, and Human
Relations Agency that provides the name of every business in the state,
organized by county and SIC codes.
LESSONS LEARNED
Draft Your Laws Carefully. The SERC advises other states and
local governments to be careful how they draft their Title Hi-related
statutes. The Wisconsin law requires every facility with ten or more full-
time equivalent employees to pay the fees. Although the intent was to
exempt small facility businesses, the law has allowed some unexpected
exemptions. Many large companies keep their extremely hazardous
substances in facilities where they have very few employees. As a conse-'
quence, because the law says "facilities" not "employers," 30 to 50
percent of the facilities that were expected to be covered by the fee system
are now claiming to be exempt.
Contact: Deborah Epps
SARA Program Manager
Department of Administration
Box 7865
Madison, Wisconsin 53707-7865,
(608) 266-1509
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LEPC:
Hazards Analysis
Planning
Outreach
CUYAHOGA COUNTY, OHIO
22 members (covers 59 political subdivisions;
subcommittees open to all interested parties)
Population: Approximately 1,500,000 (includes Cleveland)
Facilities: Approximately 650 total, 250 subject to section 302
i A-- County LEPC covers 59 political subdivisions in-
cluding the City of Cleveland. The LEPC decided that if it was to obtatn
consistent, high quality information from all facilities subject to section
302 in its planning district, it needed to take an active approach.
LEPC ACTIVITIES
Pn«,rir, Htf f?S An.aly?isy The LEPG deci^d that the best method of
bv SARA Sc\ r?09 ade(luate/nformation from the facilities covered
by SARA section 302 was to conduct a survey of firms expected to be
subjec to the requirements of Title HI. The LEPC developed an initial list
Sona±?S lh su™yf™™&™ who had submitted a secSon-302^K-
^b^^°^fntlfled^Clhty emergency coordinators, and those who
submitted Tier II forms. The survey was mailed in April 1988 At the
same tone, they sent each fire chief in the county the questionnaire The
fire chiefs were asked to visit each facility and go through the question-
naire with facility staff to gather the needed information q
-The questionnaire covered the transportation of extremely hazard-
ous substances (e.g., how they are transported, shipment sS type of
earner, and unloading system), alert systems, training, emergency equip-
ment and prevention equipment. Each facility's emfrgency^ooSZ
was also asked to determine zones of vulnerability for each section30 2
o? Ae^TeST^-/116 ff <&***** was Prided with a sun^ary
SI f* -rf ' Quince for Hazards Analysis" and was asked to assist
£?itvc±v s emergency coordinator with the determination of the vulnera-
thivywtfH ^c11"168^6 encouraged to use their own methodology if
they wished. Finally, the largest zone found from among all chemicals at
each facility was drawn ^on a U.S. Geographical Service Lp to iEate
the area that might be affected in a worst case release of a section 302
suostance.
™ , interview process benefited both the facility and fire depart-
ment Ihe fire department gained more emergency preparedness informa-
tion than it previously had and established coltacts ™
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The facilities benefited because they became acquainted with the people
who would have to respond to an emergency. Overall, the LEPC sees tms
cooperation and information exchange as a major benefit of the process.
Planning. The LEPC has used the information gathered from the
survey to develop its plan and will continue this interview process as it
identifies additional facilities subject to section 302 requirements. It plans
to conduct a small number of detailed follow-up interviews with facilities
surveyed in 1988 as a first step in developing a more thorough analysis ot
each facility.
The questionnaire also served as a way to gather information for
die county's emergency response resources inventory. Each facility
provided information regarding equipment and expertise it would be
willing to share with the community in the event of an emergency inci-
dent. Fire department equipment and supplies information was also
gathered as part of the process. This information has been added to the
Cuyahoga Emergency Resources System (CERS) Reference Manual,
which includes reference material for all types of emergencies.
Outreach. The LEPC distributed a set of guidelines on how to
report an emergency release of an extremely hazardous substance or
CERCLA hazardous substance in Cuyahoga County. The guidelines,
published as a brochure, divide releases into three groups: releases discov-
ered by a transporter, releases discovered by a third party; and releases
discovered by a facility. For each, the brochure provides a flow diagram
to show who gets contacted by whom and when. The guidelines, which
include a list of reportable quantities of SARA section 304 substances,
were distributed to each facility's emergency coordinator, to mayors, and
* ui:~ oofi»nr ™-rtf,»cc;rni;ii
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Outreach
Compliance
Training
Planning
Information Management
RACINE COUNTY, WISCONSIN
LEPC: 15 Members (emergency management, industry, environ-
ment, deputy city attorney, health department, EMS, Red
Cross, elected official, police, sheriff, fire, business groups,
media, civic organizations)
Population: 173,000 (including City of Racine)
Facilities: 74 facilities subject to section 302; 526 facilities reporting
under sections 311 and 312 (expected agricultural
facilities: 100+)
Racine County in southeastern Wisconsin is just south of Milwau-
kee and borders on Lake Michigan. The county followed the develop-
ment of Title El as the Superfund Amendments and Reauthorization Act
(SARA) was being debated in Congress. The county met with industry
during the development of the legislation so that both would be prepared
to start working together if the legislation was enacted. As a conse-
quence, the county was familiar with the provisions of Title III and ready
to start planning as soon as the legislation was signed.
LEPC ACTIVITIES
Outreach. When the LEPC first received a list of potentially
covered facilities from the SERC, the LEPC realized that the list included
many facilities that were unlikely to be covered under SARA section 302
requirements. The problem arose because a number of facilities had
notified the SERC that they were covered based on a misunderstanding of
Title in requirements. In addition, a number of facilities known to have
extremely hazardous substances above the TPQ were missing from the
SERC list. Only a few agricultural sites had reported yet the indications
were that a hundred or so farms would be covered under the reporting
requirements of section 302. To begin to handle these problems, the
industry members on the LEPC ran a series of programs for businesses to
explain Title HI and to identify which facilities are covered.
For the agricultural community, the LEPC felt it needed to do
more. The section 302 list of chemicals is not readily translated into the
kind of information farmers can use .because the chemicals are listed by
generic names used by chemists, not by the names recognized by farmers
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on product labels. A group of LEPC members looked up every section
302 chemical. They identified 66 chemicals that are used in agricultural
products and cross-referenced them to over 1,000 trade name products.
This cross reference list was then taken to the agricultural dealers in the
county who identified those products used locally by the farm community.
From this second list, calculations were made with information supplied
by the agricultural distributors on how much of each product a farmer
would need on site to fall within the reporting requirements. Posters with
this information were printed up and distributed throughout the county as
was a "compliance station," which included cards and mailing labels that
could be used by the farm community to report to the SERC and name a
facility coordinator to the LEPC.
Compliance. As part of the City of Racine, Wisconsin, program
for ascertaining compliance with Title HI, a variety of small businesses
were inspected. Besides identifying facilities not in compliance with Title
III, the results of these inspections were unexpected. Major safety viola-
tions were identified in the inspections and, in fact, one facility had to be
immediately evacuated because of the imminent potential for a serious
chemical accident. All of these facilities' inadequate safety practices
escaped detection despite obtaining building permits, insurance and bank
loans, and meeting fire codes. The managers of these small businesses all
claimed to be running safe operations. A good number of these facilities
have fallen outside of the loop, claiming never to have heard of Title III
and OSHA's Hazard Communication Standard. Their facilities have been
inspected by the fire department and issued building permits with no
mention of their safety practices or lack thereof.
Training. The medical subcommittee raised the question of what
would happen if members of the hazmat team were hurt or contaminated
during an incident. To explore the question, the county held an exercise,
the results of which indicated that they were not prepared to deal with this
problem. Further, the medical community was not prepared to handle the
problems of contamination control with the ambulance fleet and the
hospital emergency department.
In cooperation with St. Mary's Medical Center of Racine, the
emergency medical services section of the Wisconsin Division of Health,
the coordinator of the Emergency Government Office, and others used
funds obtained under the section 305 grants to develop two eight-hour
courses, one for emergency medical technicians and one for hospital
emergency room staff, to teach them how to deal with contaminated
victims of a hazmat incident. These programs have been conducted
throughout the State with more than 20 offerings scheduled for 1989.
Planning. The LEPC has focused on the community conse-
quences of an incident. Areas being investigated include establishing
emergency day care centers to care for the children of emergency work-
ers. Many families were found to have both spouses employed in emer-
gency response or care elements within the community. These people
could not fully respond to deal with an emergency because of family
commitments. The LEPC has also considered the provision of emergency
medical care in shelters to the chronically ill who may have left vital
medications at home. The LEPC is looking into preservation and retrieval
12"
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of critical records needed in an emergency such as nursing home charts,
pharmacy prescription records, and medical charts from areas impacted
by a chemical incident.
Information Management. The LEPC is using CAMEO to
manage all the data for the county and to take the burden off local fire
departments. The CAMEO information has been loaded into a Macintosh
II computer set up as a file server and is linked to several fire departments
using 9600 baud modems and Timbuckto Remote software, which allows
multiple users to view the information being called from the system. The
LEPC is exploring1 the transmission of data over high speed radio systems
to provide greater flexibility for field use. The LEPC has used CAMEO
to prepare response plans for 58 facilities; the plans have been submitted
to the SERC for its approval.
LESSONS LEARNED
Everyone Has To Work. One key to the LEPC's success has
been that everyone on the LEPC has a defined function and everyone has
worked hard at their assigned tasks. When routine jobs such as stuffing
envelopes have to be done, several LEPC members groups can rally civic
groups to get the job done in a timely manner. Business and industry
members assisted with mailings and handled follow-up information and
requests. Civic groups and the media helped with public presentation and
gave their time and talents at regular LEPC meetings and functions. This
involvement makes everyone feel that they have a role to play and pro-
vides a sense of purpose to the process.
Involve Non-LEPC Experts. The LEPC's subcommittees have
not restricted their membership to LEPC appointees. Instead, they have
opened the subcommittees to interested people and have actively sought
out people with relevant expertise. For example, they have drafted a
retired chemist to work with them on issues such as the chemical list for
farmers and used high school students to design posters. By adding non-
LEPC members to the subcommittees, the LEPC has been able to expand
their knowledge base significantly.
Get to Know the Big Picture. Critical to the success of the
program has been the importance the LEPC has placed on understanding
the differing views of SARA held by the players. By working together
industries and business have learned the concerns of emergency respond-
ers and vice versa. Differences in views and opinions were found to be
minimal once discussion and communication lines were opened up to
participants on all levels of the program.
Contact: Peter R. Jensen, Coordinator
Racine County Office of Emergency Government
730 Center St.
Racine, Wisconsin 53403
(414)636-3515
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Planning
Outreach
Compliance
Training
Information Management
IDAHO
State characteristics: 6 Local Emergency Planning Districts
SERC: 10 members (6 State agency directors, 2 local representa-
tives, 1 state-based facility representative, and an Idaho
Mining Association representative; chair: Mining
Association representative)
One of the first questions Idaho had to face was how to divide the
State into planning districts. One option, to set up one LEPC for each of
the 44 counties, was eventually rejected because some counties are very
sparsely populated — one has only about 600 residents and one paid
public official, the sheriff. The State chose instead to piggyback on the
districts that the law enforcement and transportation departments use.
SERC ACTIVITIES
Planning. The division of the State into six planning districts led
to some identity crises over what exactly was the county versus the LEPC
role. The SERC has solved some of those problems by having each
county do a plan as an annex to existing emergency plans and using the
LEPCs as coordinating bodies. The LEPCs have become forums for
training local officials and responders and for information sharing and
mutual aid. Counties that were reluctant have been educated about the
State's emergency management system and are learning how planning for
a hazmat incident enhances their multi-hazard emergency plan.
Outreach. The SERC has been going out, county by county when
asked, to provide as much face-to-face help (e.g., training) as possible. A
temporary research/planning position has been created to provide direct
assistance to counties on hazard/vulnerability analysis. EPA and FEMA
regional offices have also participated in some of these meetings with the
LEPCs and counties. The SERC has prepared a brochure of general
information on Title in for the public and did a large scale mailing.
Compliance. The SERC mailed an 8-page brochure with State-
specific compliance information to pesticide dealers and applicators, ex-
tension agencies, all local Chambers of Commerce, all hazardous waste
generators, air permit holders, National Pollution Discharge Elimination
System (NPDES) permit holders, local governments, OSHA inspectors,
the association of industrial hygienists, and all waste water treatment
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plants. SERC staff have conducted several compliance workshops for
trade associations. A series of 12 workshops were held in the summer of
1989. These were open to any business, industry, or individual interested.
These outreach efforts reflect the policy of the SERC that the most effi-
cient, effective, and economical compliance strategy is educating the
regulated community.
Training. The SERC sent three people to FEMA's Emergency
Management Institute for the "train the trainer" course in Hazardous Ma-
terials Contingency Planning (a joint EPA/FEMA/DOT course). That
course was delivered to each LEPC with the help of EPA, FEMA, and an
experienced fire chief. A cadre of 60 new trainers have now been certi-
fied and have trained over 700 people on recognition and identification of
hazards and on hazardous material incident analysis. Another 35 instruc-
tors have been trained in "Hazardous Materials: The Pesticide Challenge."
These "train the trainer" courses have been extremely successful. The
SERC has focused its training efforts on npn-fire department personnel —
for example, industry and police — because the fire departments already
have access to training.
Information Management. The SERC has decided to handle all
the data submitted. The information from the section 312 Tier II forms is
being entered into the Idaho Department of Transportation's mainframe
computer because it has terminals at a minimum of two points in each
county so the data can be retrieved locally.
LESSONS LEARNED
Title IH Is Positive. The SERC believes that the Tide m process
has done a tremendous amount of good. The industry people who initially
participated in LEPCs strictly out of self-interest have dropped out of the
LEPCs or expanded their views and those who remained have developed
a new rapport with the government officials. The SERC sees a new level
of openness and mutual understanding between government and industry
that is allowing them to work together to prevent accidents.
Non-government Chair Can fltelp. The SERC chair is the repre-
sentative of the Idaho Mining Association, the state-level mining trade as-
sociation. Because the person is outside the State government, he has
been able to guide the SERC without being involved in interdepartmental
conflicts.
Contact: Jennie Records
Idaho Emergency Response Commission
State House
Boise, Idaho 83720
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REGIONAL CHEMICAL EMERGENCY
PREPAREDNESS AND PREVENTION
COORDINATORS
RayDiNardo
EPA-Region 1
New England Regional Lab
60 Westview Street
Lexington, MA 02173
(617) 860-4300
Bruce Sprague
EPA-Region 2
Woodbridge Avenue
Edison, NJ 08837
(201)321-6656
Karen Brown
EPA-Region 3
841 Chestnut Street
Philadelphia, PA 19107
(215)597-1399
Henry Hudson
EPA-Region4
345 Courtland Street, NE
Atlanta, GA 30365
(404)347-3931
Mark Horowitz
EPA-Region 5
230 South Dearborn
Chicago, IL 60604
(312)886-1964
Charles Gazda
EPA - Region 6
Allied Bank Tower
1445 Ross Avenue
Dallas, TX 75202-2733
(214)655-2270
RonRitter
EPA-Region7
726 Minnesota Avenue
Kansas City, KS 66101
(913)236-2806
Cheryl Chrisler
EPA - Region 8
One Denver Place
999 18th Street, Suite 1300
Denver, CO 80202-2413
(303)293-1723
Kathleen Shimmin
EPA-Region 9
215 Fremont Street
San Francisco, CA 94105
(415)974-7477
Gordon Goff
EPA - Region 10
1200 6th Avenue
Seattle, WA 98101
(206)442-1263
STATES BY REGION
4 - Alabama 1 - Maine
10 - Alaska • 3 - Maryland
9 - Arizona 1 - Massachusetts
6 - Arkansas 5 - Michigan
9 - California 5 - Minnesota
8 - Colorado 4 - Mississippi
1 - Connecticut 7-Missouri .
3 - Delaware 8 - Montana
3 - D.C. 7 - Nebraska
4 - Florida 9 - Nevada
4 - Georgia 1 - New Hampshire
9 - Hawaii 2 - New Jersey
10-Idaho 6-New Mexico
5-Illinois 2-New York
5 - Indiana 4 - North Carolina
7 - Iowa 4 - North Dakota
7 - Kansas 5 - Ohio
4-Kentucky 6-Oklahoma
6-Louisiana
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
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