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 III,
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 III 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
outreach. The particular topics covered in each LEPC or SERC profile are
listed at the upper right hand corner of the first page of the profile for easy
reference.
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 III 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 Information Hotline at
1-800-535-0202, or, in Washington, DC, 479-2449.
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LEPC Organization
Compliance
Planning
Information Management
Outreach
Training
Tinker Air Force Base, Oklahoma
LEPC:
WORK FORCE:
FACILITIES:
32 member Tinker AFB Environmental Protection
Committee (representatives of the various tenant and
major staff organizations; Chairman: Air Logistics
Center Vice Commander)
Over 26,000 military and civilian personnel
24, primarily related to aircraft maintenance
activities
Tinker Air Force Base (AFB) is located within industrialized
Oklahoma County, adjacent to Interstate 40 and Midwest City, which has a
population of 55,000. Tinker AFB is one of five Air Force Logistics Centers
nationwide, and one of the largest military and industrial complexes in the
world. Two hundred and fifty-four acres of floor space are devoted to
industrial facilities where the majority of the work force reconditions,
modifies, and services military aircraft, missiles, jet engines, accessories, and
other military products. Base operations include the largest electroplating
facility in the country, with 150 process vats; a 75-vat chemical cleaning
facility; two painting and paint stripping facilities; and numerous support
operations. Tinker AFB also has an Industrial Wastewater Treatment Plant
(IWTP) that treats approximately one million gallons of wastewater daily.
LEPC ACTIVITIES
LEPC Organization. In December 1989, Tinker AFB decided to
comply voluntarily with the requirements of Title III in recognition of the
value of such efforts to the surrounding community and the importance of
strengthening inter-governmental emergency response communication. This
determination was consistent with and pursuant to Department of Defense
(DOD) policy, which encourages DOD facilities to comply with Title III to
the greatest extent practicable. In keeping with the demands of national
security arising from its classified operations, the base was designated by the
Oklahoma Emergency Response Commission as a separate Local Emergency
Planning District within Oklahoma County in February 1990. The Tinker
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AFB Local Emergency Planning Committee (LEPC) is comprised of the
members of the base Environmental Protection Committee. Upon
completion of the contingency planning process, Tinker AFB may serve as
an example for the other federal facilities, including other Air Force Logistics
Centers, in complying with Title III.
Compliance. The Environmental Management (EM) Directorate
serves as the central point of contact for environmental compliance at Tinker
AFB, and, in that role, ensures Tinker AFB's compliance with the
requirements of Title HI. As part of its Title III program, the EM Directorate
is responsible for identifying the quantities and locations of all hazardous
materials stored and used on the base. For the purposes of reporting under
Title III, each building on the base is considered to be a separate facility.
Once a covered facility has been identified, designated facility managers are
briefed on the Title III program and their compliance responsibilities.
Building 3001, covering 61 acres of floor space, is the largest
industrial facility in the world. To survey this facility, a twelve-person
environmental compliance team divided the building into five sections for
inspection. Extremely hazardous substances (EHSs) present in this facility
above their threshold planning quantities include sodium cyanide, potassium
cyanide, phenol, sulfuric acid, and nitric acid. The survey of Building 3001
and other facilities on the base provided valuable information for the Tinker
AFB Fire Department concerning the storage locations of EHSs, and was
used in the development of the Title III emergency response plan. The base
has provided the Oklahoma SERC with information on all EHSs that have
been identified at the base, and intends to comply with the public access
requirements of section 324.
Planning. Prior to its involvement in Title III efforts, Tinker AFB
had prepared a spill prevention and response plan addressing many of the
hazardous substances contained in its facilities. The base has finalized its
Title III contingency plan, which was developed separately from the pre-
existing spill prevention and response plan. Now that the emergency
response plan has been finalized, the base intends to carry out table-top
exercises to prepare surrounding municipalities for coordination of
responsibilities in the event of a serious hazardous materials incident.
The base maintains a 24-hour emergency spill response team,
composed of safety, health, environmental, fire, and other specialists and
headed by the Tinker AFB Fire Department, whose representative serves as
the on-scene commander for most spills. The Fire Department also maintains
a hazardous materials vehicle, which serves as a Mobile Command Post.
This specialized vehicle is equipped with emergency response and
decontamination equipment and a Wang lap-top computer which will be
linked with the Tinker AFB Title III computer system to retrieve MSDSs and
facility-specific information.
Information Management. Tinker AFB is using a locally
developed dBase III program to help manage the volumes of data collected
by the EM Directorate and present the data in Tier II form for each facility.
In the near future, the base will implement the second phase of its data
management system, the Chemical Tracking System (CTS), developed by the
Tinker AFB Directorate of Communications-Computer Systems. CTS will
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incorporate the information currently stored in the dBase system into a more
comprehensive structure that contains MSDS information and tracks storage
locations of all EHSs. The update system will also contain section 311-312
information for other hazardous chemicals.
Outreach. Information on Title III was provided to Tinker AFB
management personnel during the hazardous material inventory survey of
base facilities. In addition, the Tinker AFB newspaper, the "Tinker Take-
Off," has featured several articles on Title III, the latest describing compact
disc information on the chemicals used and stored on the base. Once the
emergency response plan is approved, outreach information will be provided
to the media in surrounding communities to update citizens on Title III
activities at Tinker AFB.
Training. Ongoing training is provided to the emergency response
team, as well as to the personnel working in shops that use hazardous
chemicals. A number of the response team's first responders have received
training from the state fire academy; the others have been trained in
conjunction with Oklahoma State University. In the future, there are plans to
provide further training for all facility managers, the emergency response
team, and other personnel as mandated by section 126 of SARA, which
requires that local emergency responders be provided with training in
understanding chemical hazards and proper safety procedures. To train these
specialists, Tinker AFB plans to take advantage of EPA training courses and
to develop in-house training packages, and to coordinate training efforts with
nearby LEPCs.
LESSONS LEARNED
Worker Right-to-Know Coordination Supports Title III. The size
and complexity of the task of identifying the hazardous materials for even
one of Tinker AFB's facilities posed a difficult task to the EM Directorate.
As a result, it was essential to seek the cooperation of the base work force
during the course of the hazardous materials survey. At the present time,
worker right-to-know efforts are supported by a program designed to
reinforce the awareness of the locations and hazards posed by hazardous
materials as well as other regulated chemicals, as required under the
Occupational Safety and Health Administration's Hazard Communication
Standard.
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Participation of Federal Facilities is Part of the Title III
Mandate. The determination to voluntarily comply with the reporting
requirements of Title III is consistent with DOD policy, which encourages
DOD facilities to participate in the Title III program. Furthermore, the base
was able to address the national security problems that would otherwise have
limited their Title HI achievements by establishing its own LEPC. This
decision satisfied the SERC because it enabled the emergency planning
concerns arising from Tinker AFB to be directly addressed by the base in
cooperation with the Oklahoma County LEPC, while still allowing the public
around Tinker AFB access to non-national security information. In addition
to the identification of chemical hazards at Tinker AFB, this spirit of coop-
eration between Tinker AFB and the surrounding community will provide
expanded and faster access to emergency response resources. Finally, by
creating a functional Title III emergency planning organization in three
months, the base serves as an example to federal facilities of how
management can follow the Title III mandate within the scope of normal
operations.
Outreach Magnifies the Benefits of Emergency Planning. The
Title III program at Tinker Air Force Base has been instrumental in focusing
emergency planning efforts on EHSs. These planning efforts are addressing
off-site impacts and have led to better cooperation with state and local
authorities on common emergency response and preparedness concerns.
Awareness by neighboring communities and local government officials of
this vital, comprehensive program will enhance the success of the program,
and assure the public that Tinker AFB officials are fully aware of their
responsibilities and are truly concerned about the public's well-being.
Contact: Mr. Robert L. Reed, Chief
Compliance Division
OC-ALC/EMC
Tinker Air Force Base, OK 73145-5990
(405)734-5199
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Planning
Funding
Information Management
Outreach
Training
Use of Section 313 Data
State of Connecticut
State Characteristics:
SERC Membership:
156 Local Emergency Planning
Committees, with over 2200 members,
including 153 single municipality districts
and 3 multi-municipality districts
consisting of sixteen municipalities
16 members, including representatives
from the Departments of Environmental
Protection (Chair), Transportation,
Health, and Public Safety; Connecticut
Conference of Municipalities; Offices
of State Fire Administration, Emergency
Management, and Policy and
Management; State Senate; New Haven
Department of Fire Services; Bureau of
State Fire Marshals; labor, industry, and
the League of Women Voters
In November 1985, the Connecticut Governor appointed a
60-member Task Force on Accidental Toxic Releases, composed of
representatives from state and local government agencies and industry, to
address release prevention and emergency response issues. Prior to the
passage of the Superfund Amendments and Reauthorization Act of 1986, the
Task Force laid the groundwork for Title III in Connecticut and produced
legislation to institute emergency planning and community and worker
right-to-know programs, and to establish an inspection system for hazardous
materials transportation and storage equipment. Title in was implemented
by Public Act 88-246, which designated the Department of Environmental
Protection (DEP) as the lead agency for administrative matters, and the
Office of Emergency Management (OEM) as the lead agency for emergency
planning.
SERC ACTIVITIES
Planning. Connecticut was one of the first states to achieve 100
percent compliance with the initial emergency planning requirements of Title
IE. OEM supported this accomplishment by providing emergency planning
guidance to Connecticut's Local Emergency Planning Committees (LEPCs).
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OEM distributed the Hazardous Materials Emergency Planning Guide
(NRT-1) together with a supplemental OEM bulletin providing clarification
and guidance on each of the nine planning elements required under section
303 of Title HI. OEM staff has also developed a model LEPC emergency
plan and DEP developed Connecticut-specific guidance on hazards analysis.
The hazards analysis guidance indicated that LEPCs should initially either
request a vulnerability analysis from facilities subject to section 302 or
perform the analyses themselves using the Technical Guidance for Hazards
Analysis, a joint publication of EPA, the Federal Emergency Managment
Agency (FEMA), and the Department of Transportation (DOT), and DOT's
Emergency Response Guidebook.
In December 1989, a member of the SERC, the Connecticut
Business and Industry Association, produced the Emergency Resource
Manual, developed from a survey of over 100 businesses across the state.
The 130-page manual has been distributed to all Connecticut LEPCs and fire
departments, and serves as a means of quickly identifying response resources
available at nearby facilities in the event of a hazardous materials incident.
These emergency response resources are separated into 11 categories:
expertise and personnel; instruments and labs; chemical handling equipment;
special construction equipment; fire suppression equipment; special
mechanical equipment; neutralizing chemicals; personal protective
equipment; breathing apparatus; spill control/cleanup materials; and tanker
truck facilities. Each category is broken down alphabetically by the city in
which the facility is located, and includes the company name, phone number,
24-hour phone number, and the specific type of resources available; an index
provides the street address and emergency contact for the facility. The
manual also includes sample provisions for borrowing or use of these
resources in the event of an emergency.
Funding. Connecticut Title III activities have been funded from
several sources, including a state trust fund, Title III training grant funds, and
appropriations from the state general fund. The Connecticut Municipal Lia-
bility Trust Fund was created from a budget surplus at the close of FY '86;
over $1 million was made available to 74 Connecticut cities and towns for
Title in-related hazardous materials planning, training, and surveys. Title III
training grants provided through FEMA totalled $72,000 in 1987, $52,000 in
1988, and $30,000 in 1990 for training of state and local administrative and
response officials; $100,000 was appropriated in both 1989 and 1990 from
the Connecticut General Fund for the administration of the Title III program
by the SERC. The majority of Title III program accomplishments, however,
have been achieved by the staff of agencies represented on the SERC. As a
result, the staff costs have been absorbed by individual agency budgets,
rather than by the SERC.
Information Management. DEP has developed a data management
system using the SAS statistical software package. The system consists of
two modules: administrative and Form R. The administrative module is a
tracking program for the reports received under sections 302, 311-312, and
313, and contains components that create a facility reporting history; log in
public information requests; enter and update LEPC membership; and
generate reports on facilities, LEPCs, and public information requests. The
Form R module allows the entry of all information on completed toxic
chemical release inventory reporting forms (Form R) received from facilities,
as well as the generation of reports from this data.
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A third module of the data management system is being developed
for accidental release information reported under Title III section 304 and
Connecticut law, which is more comprehensive and requires reporting of any
quantity of a petroleum product or hazardous waste which is spilled or
released. In addition, local fire departments have found the information on
chemical quantities and storage locations contained in the section 312 Tier II
form to be valuable; consequently, the SERC currently requires the
submission of Tier II forms rather than Tier I forms.
Outreach. The Connecticut SERC has made education a major
priority in its Title III implementation activities. In the last two years, the
SERC and Waterbury State Technical College have sponsored an 18-hour
program on Title III compliance for representatives of business and industry.
Over 7,000 Title III compliance brochures have been mailed to potentially
covered facilities and organizations. The SERC also sends bi-monthly
mailings on Title III issues to LEPC chairpersons. In conjunction with the
League of Women Voters, the SERC has produced an informative citizen's
guide called "An Ounce of Prevention" identifying the roles of SERCs,
LEPCs, communities, government, and business and industry in the Title III
effort. The guide is distributed at conferences and made available to LEPCs
for distribution. Finally, the SERC encourages its members and staff to
accept speaking engagements with community and business groups.
Training. The SERC has sponsored or supported a number of Title
III training activities. Regional training conferences for over 400 local
officials were conducted from October 1987 to January 1988. In the summer
of 1988, a series of outreach workshops were held with over 800 attendees
from state and local government and the media. A two-day, statewide LEPC
conference, held in May 1989, had almost 200 attendees and a second
conference was held in February 1990. All of these activities were developed
with the assistance of Title III training grants. In August 1989, OEM
conducted a four-day exercise design course for LEPC members. The SERC
also sponsored four hazmat personnel safety courses in 1988 and 1989 for
emergency medical personnel, transportation road crews, and municipal
police.
In addition, the SERC and the Commission on Fire Prevention and
Control (CFPC) have sponsored over 130 training courses for first
responders, police officers, hazmat technicians, hazmat instructors, and
LEPC members which have reached a total attendance of over 1700. Courses
include first responder hazardous material recognition, contingency planning,
the Computer-Assisted Management of Emergency Operations (CAMEO)
system, and emergency response. They were taught as the by-product of a
series of train-the-trainer courses, which achieved substantial savings in
training funds while preparing 220 instructors by the end of 1988. CFPC has
also sponsored Incident Command training for 196 emergency management
officers in 22 separate programs. More than 75 additional first responder
courses were offered in 1989, and a number of additional instructors have
been trained to deliver courses on first responder procedures and the
chemistry of hazardous materials.
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Use of Section 313 Data. The SERC has analyzed the 1987 Toxic
Release Inventory (TRI) data by media, chemical, and facility. The TRI data
on emissions to water were examined in conjunction with discharge permits
issued by the Bureau of Water Management, and the ten companies reporting
the highest level of emissions were all permitted by the state. While most of
the chemicals that were reported in the TRI are in compliance with existing
regulations and standards, in some cases additional controls are necessary
and are being implemented under the state waterprogram. In addition, TRI
data have been presented as evidence in support of chemical-specific and
emission control legislation pending before the Connecticut legislature.
LESSONS LEARNED
Effective Coordination of SERC Activities Enhances
Achievements. Without sufficient funding for its own staff, the SERC has
relied upon the staff of its members to achieve its Title III obligations.
Fortunately, the agencies and groups involved have contributed successfully
to these efforts under the overall leadership of DEP, whose deputy
commissioner serves as the chair of the SERC. The extensive Title III
training program supported by the Commission on Fire Prevention and
Control and the Emergency Resource Manual developed by the Connecticut
Business and Industry Association serve as prime examples of the
contributions of an active, well-coordinated SERC.
Education and Awareness are Critical to Continuing Title III
Efforts. Outreach for the general public, business and industry, local
officials, and emergency responders is an important aspect of a successful,
long-term Title III program. Connecticut has made extensive efforts to
provide preparedness and response training as well as outreach materials for
all members of the community in order to establish a basis for future
activities. As a result of these efforts, the SERC experienced a threefold
increase in section 312 filings from 1987-88 to 1988-89, and has received
over two hundred Title III information requests from the public.
Contact: Ms. Suzanne Vaughn
Title III Coordinator
Connecticut Department of Environmental Protection
State Office Building, Room 161
Hartford, CT 06115
(203) 566-4856
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Planning
Exercises
Training
Cumberland County, Maine
LEPC: An elected official and representatives from police,
emergency management, fire, emergency medical,
and health departments, hospitals, citizens groups,
and facility representatives
POPULATION: 230,000
FACILITIES: 141 facilities reporting under section 311-12
and 22 facilities reporting under section 302
Cumberland County is located along the southern coast of Maine, and
is the most industrialized and densely populated county in the state. It
contains the largest city in Maine, Portland, which has a population 63,000;
the 125 square mile Sebago Lake; and several major transportation routes,
including US Route 1, Interstate Highways 95 and 295, and State Route 302.
On July 15, 1989, Rigby Yard in South Portland reported a leaking
railroad tank car. The initial response unit surveyed the scene and reported
the placard information and tank car number to the fire department;
minutes later a second unit donned encapsulating suits to confirm this
information, identifying the substance as muriatic acid. After a brief
meeting, senior police and fire officers decided an evacuation was necessary,
and designated response units to carry out the evacuation while other units
sealed off the area. The plume modeling system from the Computer-Aided
Management of Emergency Operations (CAMEO) system, a software
package designed to assist emergency planners and first responders with Title
III activities, was employed to assist with the response to this event.
Information on the substance, its rate of release, and the weather conditions
were input into the modeling program, which produced a plume diagram that
was overlain on a local map to assist responders in determining areas for
evacuation.
The responders established a forward command post to carry out the
immediate response operations and a rear command post or staging area for
equipment and the media. Rotating pairs of response personnel spread four
tons of soda ash under and around the tank car during the next several hours;
next, the leak was plugged, and the remaining muriatic acid off-loaded. The
following day, several units returned to monitor the purging of the remaining
product and vapors from the tank car before it was returned to the
manufacturer for inspection. Over 150 responders were involved in response
activities at the site; these personnel and their equipment were provided by
several nearby municipalities and included two dozen response vehicles.
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LEPC ACTIVITIES
Planning. The events surrounding this and another more recent
transportation-related incident that involved muriatic acid validated the
LEPC's emergency planning assumptions and response procedures to the
extent that they had been developed. Principal planning successes
highlighted by these events include the identification of available public and
private response resources, industry contacts for technical and resource
expertise, and sheltering locations. In addition, the development of standard
operating procedures (SOPs) and staffing protocols for an incident command
post and equipment staging area during the planning process allowed for
improved coordination of response activities.
In both recent events, however, the complexity of the response
operations and the necessity of relocation and sheltering produced situations
that went beyond the range of elements contained in prior full-scale
exercises. One revision to the LEPC response plan suggested by these
experiences involved access to the incident site. Private industry response
vehicles, equipment, and personnel could not be readily identified by officers
in charge of maintaining the security of the incident site. On weekends or
off-days, industry responders and clean-up personnel do not normally have
company identification readily available. As a result, the LEPC may develop
a system of identification cards for private citizens who may be needed at an
emergency response operation, and an insignia system (e.g., a colored ribbon
on the radio antenna) for response and clean-up vehicles.
These incidents also highlighted several difficulties in carrying out an
evacuation: (1) giving directions to the nearest shelter proved excessively
time-consuming for the personnel in charge of the evacuation; (2) tourists in
nearby hotels were unwilling to evacuate to shelters and wanted to move to
another hotel or motel; and (3) evacuees in shelters need to have access to the
latest incident information because they are generally cut off from normal
media connections — radio and televison. As a result, the Fire Department is
considering a system of pre-designed cards with directions for evacuees that
can simply be handed out by response personnel. The cards will provide a
list of things to do before evacuating, a list of necessities to bring to the
shelter, and an indication of the nearest safe hotels or motels for tourists.
Existing communication and response procedures have also been updated to
insure that the latest information on the incident will be transmitted regularly
to evacuation shelters.
The Title III planning process in Cumberland County also identified a
major deficiency in response capability -- the lack of sufficient emergency
response vehicles. The Cumberland County Fire Chiefs Association
(CCFCA) has set a goal of three units for the county in keeping with the
provisions of Maine Public Law 464, which implemented and expanded upon
Title III. This law requires facilities reporting under SARA Title III section
302 to have response vehicles and/or equipment on-site, provide or buy this
equipment in conjunction with the local fire department, and/or establish a
mutual aid agreement with the LEPC. The CCFCA initiative, funded from
the county budget, has so far produced one of the three vehicles needed; this
vehicle was provided by a facility. The LEPC hopes that county facilities
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will provide the two additional vehicles, otherwise, school buses may be
converted for response use. In addition, a comprehensive mutual aid
agreement, as well as SOPs for activation of mutual aid pact resources, are
being developed between facilities and county fire departments to implement
this initiative.
Public Law 464 also requires contingency planning by all facilities
that report under SARA Title III section 302. Facilities with extremely
hazardous substances present in quantities above specified thresholds must
submit a facility contingency plan to the local fire department, LEPC, and
SERC. This plan, which must be exercised and reviewed annually, must
address warning systems, transportation routes, employee training, and
response procedures and equipment. Of the 22 facilities in Cumberland
County that reported under section 302, 19 have already submitted
contingency plans. The three other businesses were sent a notice of non-
compliance via registered mail; of these, two are currently in the process of
preparing their plan. The last facility has not yet responded to successive
notices, and the case will be handed over to the State Attorney General's
office, through the Maine SERC, if action is not soon forthcoming.
Exercises. In conjunction with a local wastewater treatment training
program, field demonstrations/exercises were held in 1985 and 1986 that
increased local awareness of preparedness and response issues before the
passage of Title III. Prior to the recent incidents, the LEPC held a table-top
exercise simulating a hazardous materials accident at a fixed facility; the
exercise focused on the establishment and staffing of an incident command
post. Although it posed a different scenario than that of the two
transportation-related accidents, the exercise, by sponsoring direct
communication among all county response organizations, helped to clarify
the roles and responsibilities of command post staff, which proved extremely
beneficial during the actual responses.
Training. The LEPC established a four-hour hazardous
materials identification and recognition course for its members and all
emergency responders. A 24-hour course is under development to meet the
requirements of section 126 of SARA, which requires local emergency
responders to be provided with training in understanding chemical hazards
and proper safety procedures. In addition, a management-level course for
public officials on hazardous materials incident command is being
developed. The LEPC is also identifying a core of response personnel to
receive hazardous materials team training. These responders will man the
new emergency response vehicles as they become available.
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LESSONS LEARNED
Face-to-Face Contact Between the LEPC and Industry Crucial.
The LEPC believes that face-to-face contact between the LEPC and
industry officials is the most important feature of Title III activities. Above
and beyond the completion of an emergency response plan, the planning
process is a most effective means of promoting interaction and awareness
among local government and private industry. In addition, the preparedness
process has been further strengthened by interaction between these
individuals at field exercises and other initiatives (e.g., the response vehicle
project), as well as at actual response incidents. The opportunity for the
exchange of ideas, concerns, and suggestions provided both formally and
informally by the LEPC structure and its activities remains the critical
element in the success of an emergency preparedness and response program.
Community and facility officials are better able to interact and respond to an
emergency situation when the planning process has already established
mutual respect and understanding.
Evacuation Coordination Meetings: Short but Effective.
Following upon its response experiences, the LEPC strongly believes that if
the nature of an incident permits (i.e., time and risk considerations are less
stringent), a conference between fire, police, EMS, and other involved
officials prior to the evacuation can be extremely helpful. In just a few
minutes, these response personnel can make specific determinations on who
will be evacuated and where and how far they will be evacuated, as well as
identifying where traffic control officers should be located or traffic barriers
should be established. Such a procedure will insure that all evacuation
participants are familiar with the evacuation and sheltering plan, and that
response and evacuation activities are coordinated to eliminate potential
conflicts.
Contact: Mr. John True
Cumberland County LEPC
Cumberland County Emergency Management Agency
22 High Street
Windham, ME 04062
(207) 892-6785
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Hazards Analysis
Planning
Compliance
Data Management
Inter-LEPC Coordination
Public Alert Systems
Wyandotte County, Kansas
LEPC: 21 members (elected and other local officials, and
representatives of police, fire, emergency medical, civil
defense, environmental, and public health agencies, as
well as industry, community groups, and the media;
chairman: Kansas City-Wyandotte County Health
Department Director)
Population: 200,000
Facilities: Approximately 55 under section 302 and 100 under
section 311-12, including soap and detergent and
automobile maufacturing plants, and chemical
processing facilities
Wyandotte County is a heavily industrialized and densely populated
county that includes Kansas City, Kansas, the second largest city in Kansas
with a population of 160,000. The county was selected by the Kansas SERC
as the urban counterpart to rural Washington County when it developed
model emergency plans as guidance for LEPCs in Kansas. Numerous
transportation routes, including Interstate Highways 35, 70, 435, and 635 and
several major railroad routes, pass through the county. Wyandotte County
borders on the intersection of the Kansas and Missouri Rivers, and lies across
the state line from Kansas City, Missouri.
LEPC ACTIVITIES
Hazards Analysis. The county air pollution control program
initiated a hazards survey under EPA's voluntary Chemical Emergency
Preparedness Program (CEPP), the predecessor to Title III. This survey was
designed to determine which facilities in the county handled materials on
EPA's list of acutely toxic chemicals, which were later designated as
extremely hazardous substances (EHSs) under Title III. Every facility in the
county was sent a comprehensive survey based on EPA's CEPP: Interim
Guidance. If the facility indicated that one or more of these toxic chemicals
were present, they were asked to supply further information on quantity and
location of storage and use.
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The survey produced a very sizable response from local facilities, and
using the Technical Guidance for Hazards Analysis, a joint publication of
EPA, FEMA, and DOT, the LEPC determined quantities of concern for the
chemicals present in the community. Because its limited resources could not
support a full-scale effort, the LEPC ranked facilities based on the amount of
the toxic chemical on-site and identified 20 facilities that had at least 1,000
times the quantity of concern for one or more chemicals. A second tier of
facilities with a smaller multiple of the quantity of concern were to be
addressed in the second phase of the program. In this fashion, the ranking
reflected not only the raw quantity of acutely toxic chemicals present at a
facility, but also the relative health and safety threat that a release might pose
to the surrounding community.
The LEPC met with the top 20 facilities and provided them with
relevant portions of the Hazardous Materials Emergency Planning Guide
(NRT-1), a document to assist LEPCs in preparing and reviewing emergency
plans produced by the National Response Team, the organization consisting
of the 14 federal agencies with oil and hazardous materials expertise. The
LEPC asked these facilities to prepare a hazards analysis for all of the
identified EHSs that presented a significant threat to people or property
beyond the facility perimeter. The LEPC also distributed copies of:
Technical Guidance for Hazards Analysis along with a
worksheet the LEPC developed to assist in vulnerability
zone calculations;
• EPA chemical profiles on identified EHSs; and
• Response Information Data Sheets, which are similar to
Material Safety Data Sheets (MSDSs), but more heavily
emphasize emergency fire response information for the
various chemicals.
Each facility was asked to complete a facility resources questionnaire as well
as the hazards analysis matrix recommended in NRT-1. The LEPC set up a
team to assist facilities, but placed most of the analytical burden on facilities
for several reasons:
• LEPC resources were extremely limited;
Facilities were more likely to have the technical
expertise; and
• Facility operators would give much more credibility to
the analyses if they did them themselves.
Planning. The Fire Prevention section of the fire department reviews
the survey submissions and other facility information (e.g., information
obtained from previous inspections and hazards analyses) to determine if a
fire permitwill be required under the Uniform Fire Code. In addition,
businesses whose responses indicate an extra hazard potential are identified
in fire department records with an orange or red warning flag, which focuses
emergency planning efforts on these facilities. Information on the warning
flags is forwarded immediately to the Hazmat Unit and all dispatchers to
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promote safer emergency response activity. The fire department will inspect
flagged facilities and all other businesses handling hazardous materials to
confirm the hazard information. In addition, the Hazmat Unit will work
with red- and orange-flagged businesses to pre-plan for an emergency
response situation, develop a working knowledge of the facility, and collect
information to perform hazards analyses.
The LEPC developed an innovative system known as Hazard Incident
Complexity Analysis (HICA) to evaluate and rank geographical quadrants
within the community according to their specific combinations of special
hazard and vulnerability factors. This analysis helps determine whether
emergency response resources within a quadrant are commensurate with its
hazard and vulnerability potential. Although the Hazardous Materials
Emergency Planning Guide provides a methodology for performing such an
analysis, the LEPC did not have sufficient personnel resources to carry out
this more complex procedure. As a result, the LEPC decided to rely on
HICA, a highly qualitative evaluation of the chemical hazards in the
community. The HICA method took advantage of readily available LEPC
resources, enabling useful analysis to be accomplished in a fraction of the
time of more conventional methods.
In April 1988, the HICA workgroup, representing fire, health, police,
public works, railroads, and civil defense, divided Wyandotte County into 2.6
square mile quadrants or portions of quadrants. During a single, day-long
session the workgroup developed a numerical hazard incident complexity
ranking value for every quadrant within the community based on information
from prior Title III activities (e.g., hazards analyses and inspections) and
personal experience. This evaluation considered 13 separate factors such as
transportation corridors; the location of hazardous and toxic chemical users,
manufacturers, and storage facilities; population density; traffic routes;
institutions such as hospitals, nursing homes, day-care centers, senior citizen
complexes, and schools; and geographic features. The analysis produced a
number from zero (the lowest value) to 100 (highest), representing an initial
judgment by local officials concerning the relative likelihood of incident
complexity and the availability of resources that may be needed to manage an
incident for each quadrant.
Compliance. The LEPC believes that many facilities affected by
Title III are not aware of its requirements, and instituted a comprehensive
compliance program to reach these facilities in 1989. The compliance
program was a multi-faceted effort designed: (1) to obtain information
essential to firefighter safety, the community, and businesses with hazardous
materials; (2) to alert businesses to the necessity of obtaining fire department
permits; (3) to inform businesses about the requirements of local, state, and
federal law on hazardous materials reporting; and (4) to serve as the first step
in the development of a system to insure that critical hazards information is
readily available to first responders. The county is also planning to use the
newly adopted Uniform Fire Code, which specifies more than 40 categories
of activities that require permits, as an additional compliance tool.
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The county included a notice on Title III with the 1989 annual
business tax bills to 4200 businesses and individuals with occupational
licenses. The notice simply stated that the business might be subject to Title
III, gave them a phone number to call for more information, and alerted them
to expect a package of materials from the county. This package included a
cover letter, fact sheets on reporting requirements, and a screening survey on
hazardous materials. The survey questions addressed the development of
facility contingency plans and OSHA hazard communication programs, as
well as the use, production, storage, handling and reporting of hazardous
materials, including:
• explosives;
flammable liquids and other combustible products;
poisonous, infectious, radioactive, or corrosive substances;
and
• toxic chemicals.
The LEPC cross-checks the survey information against the data reported
under Title III to insure compliance. Although the screening survey is quite
comprehensive, it includes the option of requesting additional information,
rather than providing a specific answer, to avoid intimidating potential
respondents and support outreach to businesses unfamiliar with Title III.
Data Management. As with many other LEPCs, Wyandotte County
has confronted the problem of incompatible computer systems; fire
departments have or are getting Macintoshes to run CAMEO (Computer-
Aided Management of Emergency Operations), but county and state
governments have IBM-compatible mainframe systems and personal
computers. At the same time, the LEPC is trying to develop a data
management system that will encompass all the Title III information it
receives and simultaneously meet all three facets of Title III: community
right-to-know, contingency planning, and emergency response.
The immediate solution to the data management problem has been
provided by the Chemical Data Management Unit of the Kansas Right-to-
Know (RTK) program. Wyandotte County was the first LEPC to take
advantage of a new data transfer service provided by the Kansas SERC that
allows Tier II information contained in the state RTK database to be
imported into CAMEO. The program became operational in early 1990; the
time required to perform the transfer is primarily a function of the amount of
data being converted, which in the case of industrialized Wyandotte County
was substantial.
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The program first converts the existing database records into dBase
III+ files, then transfers the dBase III+ files into Macintosh files using the
MacLink utility, and finally imports the data into CAMEO. For more
information about the conversion process, contact Mr. Terry Franklin at the
Chemical Data Management Unit of the Kansas Right-to-Know Program at
(913) 296-1690. For the long term, in summer 1990, Wyandotte County will
be testing CAMEO II - DOS, the updated version of CAMEO designed for
IBM-compatible computers that has recently been developed.
Inter-LEPC Coordination. Representatives from all the municipal
and county LEPCs in the area attend regular coordination meetings
sponsored by the Mid-America Regional Council, which serves as a
metropolitan planning agency spanning the Kansas Cities and their environs.
A series of table-top exercises have been conducted involving response
organizations on both sides of the state line. Until recently, Wyandotte
County possessed the only fully equipped (Level A) hazardous materials
response team in the interstate metropolitan area, and thus responded to all
major hazardous materials incidents, whether in Kansas or in Missouri. An
accident during a response in Kansas City, Missouri, in November of 1988
led to a voter referendum which raised sales taxes to fund a separate hazmat
team for the city.
Public Alert Systems. Largely because of difficulties in rapidly and
effectively alerting and informing the public during two actual hazmat
incidents, the LEPC is involved in two public alert initiatives. The LEPC has
supported the introduction of chemical hazard incidents into the tone-
activated radio weather alert system sponsored by the National Weather
Service (NWS). When an emergency is reported to the fire department, the
dispatcher calls the NWS, which confirms the event and then activates the
radio alert system, consisting of tone-activated radios, which broadcast the
NWS emergency message to locations in every major media (i.e., radio and
television) office.
In concert with local media, the LEPC developed a Chemical Watch
and Chemical Warning declaration system. In the past two years, three
incidents have produced Chemical Watch conditions, involving regular radio
and television updates on events that might have produced a serious threat to
public health, such as an overturned tanker truck. Because the terminology
and triggering circumstances are very similar to those for tornado hazards,
the LEPC has been able to piggyback onto extensive tornado public
education efforts.
In addition, actual experience has shown that there is often no time to
evacuate people during a hazardous materials event. Unless a long-term
release is anticipated, in-place protection can prevent individuals from
coming into direct contact with hazardous materials during their evacuation,
which may not precede the arrival of a toxic cloud by a sufficient time span.
As a result, the LEPC has participated in several conferences to learn more
about in-place protection as an alternative to evacuation. This knowledge
will be used in concert with the Chemical Watch and Chemical Warning
system to provide timely information to individuals within the area of a
hazardous materials incident on how to remain safely in their homes and
businesses.
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LESSONS LEARNED
More Detailed Reporting Information Supports Emergency
Planning. During the development of hazards analyses in conjunction with
facilities, the LEPC recognized that it needed the chemical-specific data
contained on Tier II forms instead of the general hazard category data
required by Tier I. In addition, the LEPC determined that the ranges for
chemical quantities provided inadequate data for planning and response, and
recommends that LEPCs require facilities to provide actual quantities. As a
result, Wyandotte County now strongly requests Tier II information and
more exact quantity information (the actual value for the maximum quantity
of a chemical on-site) from facilities.
Hazards Analyses Support More than Just Emergency
Planning. The hazards analysis task served as a means of introduction and
reinforcement of the chemical emergency preparedness and prevention
message, educating facility personnel on the specific hazards posed by the
EHSs at their facility. In addition, the process introduced facility owners and
operators to a new factor in determining the quantity of material stored at the
facility, one which did not rely solely on the lowest per-unit cost for purchase
and storage, but instead took into account the health threat (and potential
liability) posed by larger quantities of hazardous materials. Some facilities
have already started to identify ways to reduce the quantities of hazardous
chemicals stored on-site; others have decided that they should eliminate their
on-site storage of certain hazardous chemicals. After working with the
facilities, the LEPC modified the hazards analysis matrix to include a
comments column to give facilities the opportunity to explain why they must
store larger quantities, indicate their past safety record with the material, or
provide any additional information that the facility considers relevant.
Rapid Communication of Hazard Information to Responders is
Essential. The November 29, 1988, accident in Kansas City, Missouri, led
the Wyandotte County LEPC to expand responder safety efforts. In the
accident, six fire-fighters were killed when they responded to a fire at a
highway construction site where almost 50,000 pounds of explosives were
stored in an unmarked trailer. In Wyandotte County, red or orange flags
from the compliance survey now help to direct appropriate response
personnel to an emergency incident. When a chemical-related emergency is
reported at a red-flagged facility, the county hazmat team is automatically
dispatched; if the facility is orange-flagged, the responding units are
immediately notified, and the hazmat team is placed on alert.
A second approach adopted in Kansas City and just now being
implemented is a uniform law requiring placarding of fixed facilities similar
to the placarding required on trucks carrying hazardous materials. Such
placarding can serve as a safety net if the other systems prove insufficient,
alerting responders "at the gate" to which materials are present on-site and
thus reducing the likelihood of unknown hazards threatening the lives of
responders. In doing so, the community adopted the National Fire Protection
Association Standard 704 placarding system, in addition to the requirement
that the United Nations number, a unique international identification number
for each hazardous substance, also be displayed.
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Public Alert Systems Critical in an Emergency. With the
experience of two hazardous materials incidents, it has become apparent that
public alert systems play an important role in a successful emergency
response. The Wyandotte County LEPC has taken advantage of existing
notification systems to develop a two-fold chemical emergency alert system,
which is readily comprehensible to people very familiar with the dangers
posed by weather emergencies such as tornadoes. In addition, sheltering and
evacuation planning must take into account that there is often very little time
to perform an evacuation, and that individuals may not leave homes and
businesses until the threat is upon them, or even after the emergency has
passed. With this in mind, the LEPC regards in-place protection and
requisite public education efforts as an integral part of future Title III
activities.
Data Management Must Address Compatibility Issues. The
incompatibility of DOS and Macintosh data management systems has been a
continuing concern of state and local Title III officials nationally. In
Wyandotte County, this problem has been addressed in the short run by the
development of a system for data transference by the Kansas SERC. In the
long run, the LEPC anticipates that CAMEO H-DOS will finally solve most
of the computer compatibility problems that have plagued fire departments
and LEPCs, but until its development is complete, LEPCs and fire
deparments should consider the advantages of the data transferral option.
Contact: Mr. Richard Michael
Director, Air Pollution Control
Kansas City-Wyandotte County Health Department
619 Ann Avenue
Kansas City, Kansas 66101
(913) 321-4803
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More Successful Practices
Additional Successful Practices in Title III 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, or (202) 479-2449 in Washington, DC, and Alaska.
The followingbulletins are currently available:
Successful Practices in OSWER-89-006.1, January 1989.
Title III Implementation
State of Kansas
Washtenaw County, Michigan
Butler County, Kansas
Jefferson County, Kentucky
OSWER-89-006.2, August 1989.
Calhoun County, Alabama
Pampa, Texas
State of Wisconsin
Cuyahoga County, Ohio
Racine County, Wisconsin
State of Idaho
OSWER-89-006.3, December 1989.
Woodbury County, Iowa
State of Virginia
Fairfax County, Virginia
Pierce County, Washington
OSWER-90-006.1, March 1990.
New York, New York
El Paso County, Colorado
Alexandria, Virginia
State of Maine
OSWER-90-006.2, June 1990.
Tinker Air Force Base, Oklahoma
State of Connecticut
Cumberland County, Maine
Wyandotte County, Kansas
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Regional Chemical Emergency
Preparedness and Prevention
Coordinators
Ray DiNardo
EPA - Region 1
New England Regional Lab
60 Westview Street
Lexington, MA 02173
(617)860-4300
John Ulshoefer
EPA - Region 2
Woodbridge Avenue
Edison, NJ 08837
(201)321-6620
Karen Brown
EPA - Region 3
841 Chestnut Street
Philadelphia, PA 19107
(215)597-1399
Henry Hudson
EPA - Region 4
345 Courtland Street, NE
Atlanta, GA 30365
(404)347-3931
Mark Horwitz
EPA - Region 5
230 South Dearborn
Chicago, IL 60604
(312)886-1964
Jim Staves
EPA - Region 6
Allied Bank Tower
1445 Ross Avenue
Dallas, TX 75202-2733
(214)655-2270
Ron Rilter
EPA - Region 7
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
1235 Mission Street
San Francisco, CA 94103
(415)744-1450
Walt Jaspers
EPA - Region 10
1200 6th A venue
Seattle, WA 98101
(206)442-4349
States by Region
4 - Alabama
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4 - Florida
4 - Georgia
9 - Hawaii
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7 - Iowa
7 - Kansas
4 - Kentucky
6 - Louisiana
1 - Maine
3 - Maryland
1 - Massachusetts
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7 - Missouri
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1 - New Hampshire
2 - New Jersey
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1 - Rhode Island
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8-Utah
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9-Guam
2 - Puerto Rico
2 - Virgin Islands
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