vvEPA
United States
Environmental Protection
Agency
Office of Solid Waste
and Emergency Response
(OS-120)
September "1990
OSWER-90-006.3
Series 6, No. 6
Successful Practices in
Title III Implementation
Chemical Emergency
Preparedness and Prevention
Technical Assistance Bulletin
State of Ohio
Hamilton County, Ohio
Wallingford, Connecticut
Oauchita Parish, Louisiana
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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 IE,
that are innovative or have proven effective. The purpose of these
bulletins is to share information on successful practices with Local
Emergency Planning Committees (LEPCs), State Emergency Response
Commissions (SERCs), fire departments, and other Title HI implementing
agencies throughout the country in the hope that such information will prove
useful to other SERCs and LEPCs as their programs develop and evolve.
Elements from the programs featured here may be transferable to
other programs in similar communities or with similar situations. The
bulletins provide information on a variety of practices — for example,
planning, compliance, information management, 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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Planning
Data Management
Outreach
Funding
Section 313 Implementation
STATE OF OHIO
SERC Membership: 19 members, including representatives from the
Departments of Health and Industrial Relations;
Attorney General's and State Fire Marshall's
Offices; Emergency Management Agency;
Environmental Protection Agency; Industrial,
Public Utilities, and State and Local Government
Commissions; the State House and Senate;
industry and trade associations; environmental
groups; county commissioner's association;
three fire service associations; and an elected
municipal official; chaired by the Ohio EPA
State Characteristics: 87 LEPCs, 86 are single-county districts
and one is a two-county district
Executive Order 87-16 established the Ohio SERC on April 15,1987,
and the SERC has established five subcommittees: executive, planning and
exercises, procedural rules, training, and LEPC membership. Ohio Substitute
Senate Bill 367, which became effective December 14, 1988, establishes
chemical emergency preparedness and prevention activities to support
implementation of the Emergency Planning and Community Right-to-Know
Act (Title III of the Superfund Amendments and Reauthorization Act of
1986). There are also local right-to-know laws, subject to grandfather
clauses in the state law, in the communities of Akron, Cleveland, Cincinnati,
Canton, Lancaster, Kent, Morwood, Oregon, Toledo, and Columbus.
SERC ACTIVITIES
Planning. The Ohio Emergency Management Agency (EMA) is
responsible for the review of local emergency response plans. Plans are
submitted to Ohio EMA, which formally reports its evaluation and comments
to the SERC. Ohio Code requires that a plan must be designated as deficient
if any of the thirteen state planning requirements are not addressed. These
requirements were adopted and expanded by the state of Ohio from the
National Response Team's Hazardous Materials Emergency Planning Guide
(NRT-1) and elements of Title III. Ohio EMA prepared a Guidance for
Submitting Plans and Updates to assist LEPCs by identifying what needs to
be submitted for initial plans, updates, and the correction of deficient plans,
as well as who must receive a copy of these materials. Ohio EMA presented
nine training sessions in August and September of 1990 on hazards analysis
based on the EPA/FEMA/DOT Technical Guidance for Hazards Analysis.
the Computer-Aided Management of Emergency Operations (CAMEO)
software system, and the IBM-compatible Automated Resource for Chemical
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Hazard Incident Evaluation (ARCHIE) software system to assist local
emergency planners in the preparation of plans.
Ohio EMA conducts its review of local plans using NRT-1 and a
Hazardous Materials Plan Cross Reference, which Ohio EMA developed
directly from NRT-1. The Cross Reference is an outline which the LEPC is
requested to submit along with its plan. It identifies the location of the
planning elements and considerations listed in NRT-1, which were adopted
as guidelines by the SERC, within the plan itself. The Cross Reference thus
serves as an indexed checklist for the reviewers of the essential plan
components, and assists the LEPC in developing their Title IE plan. Ohio
EMA also uses this detailed Cross Reference to comment on planning
elements during plan review.
State planning and exercise rules require each Ohio LEPC to carry out
three exercises within each three year period, including at least one full-scale
and two table-top, functional, or full-scale exercises. LEPCs must submit a
notification to the SERC and Ohio EMA thirty days prior to any hazardous
materials exercise. A form has been developed to simplify this procedure for
the LEPCs and to assist the SERC in evaluating the exercise. The SERC,
through Ohio EMA, has designated five planners to assist the state's 87
LEPCs. Ohio EMA has provided exercise facilitator training for the state
agencies who will evaluate LEPC exercises for the SERC.
The Ohio Revised Code also required the Ohio SERC to prepare a
separate hazardous materials emergency plan for the state; the plan as
compiled by Ohio EMA identifies responsibilities for 26 Ohio agencies in the
event of a hazardous materials event. Ohio EMA developed and then
conducted a functional exercise to evaluate the state plan on August 1,1990.
The state exercise was a joint exercise with all state agencies located at the
Ohio EMA offices, as well as the Montgomery/Greene County/Miami Valley
LEPC and the Monsanto Agricultural Company at the Monsanto plant in
Dayton, Ohio.
Data Management. Ohio EPA is responsible for Title El data
management under state law. Ohio EPA's Division of Emergency and
Remedial Response is responsible for collecting and maintaining sections
302,304, and 311-312 information. The state recommends the submission of
chemical lists instead of MSDSs if more than ten chemicals are being
reported. The state also requires Tier II information under section 312. The
SERC developed and adopted a more comprehensive industry reporting form
for sections 311 and 312 submissions. A facility identification form requests
data on the facility's latitude and longitude, state permit numbers, number of
employees, and phone number of the local fire department. The revised Ohio
sections 311-312 form requests specific storage locations (i.e., floor and
sector of the building) of the on-site hazardous chemicals. Ohio also requires
a facility map which correlates to the information submitted on the state
sections 311-312 form.
Outreach. In order to maintain the critical ties between state and
local Tide El entities, the SERC is planning to develop a technical assistance
and guidance program for LEPCs. The program would develop a series of
guidance manuals and cassette tapes on selected Title El topics — What is
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Title III, Starting an LEPC, Role of Elected Officials in Title III, Role of
LEPC Members — to support a more consistent and coordinated Title III
effort state-wide. The materials would be distributed to the LEPCs and
would enable new LEPC members to get up to speed more quickly and
clarify questions for existing LEPC members. Finally, the SERC has
developed a training and outreach program for LEPC members on achieving
Title in compliance that is to be presented at five locations in Ohio during
September of 1990.
Funding. Ohio's enabling legislation provides a flat fee of $50 for
facilities which have no EHSs, no more than ten hazardous chemicals, and
less than 500,000 pounds or 74,000 gallons of hazardous chemicals. A fee of
$75 plus $5 for every hazardous chemical beyond ten up to a maximum of
$2,500 is charged to all other facilities. Oil and gas extracting companies are
charged $10 dollars per tank battery storage location over thirty-five, with a
cap of $700. In addition, there is a 15 percent late fee for filing past the
section 312 deadline. These fees are submitted to Ohio EPA and deposited in
a state Right-to-Know grant fund — $328,000 during 1989 and $692,000
during 1990. State law requires that 15 to 25 percent be provided to state
agencies on the SERC, 60 to 75 percent be handed out as grants for LEPC
activities, and 5 to 15 percent be provided as grants for first responder
training — these training funds are to be coordinated between the fire
department and their county-designated LEPC. The state legislature
appropriated approximately $580,000 from July 1, 1987, to June 31, 1990,
from general revenues for Ohio EPA to fund the operations of the SERC.
TOXIC RELEASE INVENTORY PROGRAM
Section 313 Implementation. S.B. 367 authorized the
establishment of the Ohio Section 313 Toxic Release Inventory (TRI)
program. The law gave Ohio EPA the authority to pass rules necessary to
enforce section 313 consistent with federal regulations, to collect filing fees
which will support the administration of the program, and to collect civil and
criminal penalties from facilities and individuals failing to report or falsifying
data. Thirteen rules were developed by Ohio EPA's Division of Air Pollution
Control (DAPC), and were effective as of June 22, 1989. TRI data for
reporting years 1987 and 1988 are already in the state database; reporting
year 1989 data are currently being entered and should be complete by the fall
of 1990. Ohio EPA received over 5,900 forms from over 1,500 companies in
1990.
A formal policy has been created to fulfill public requests for this
information. Written requests are filled within 10 working days, except in
the case of large requests, which may require more time. The standard
copying fee of $0.20/page will be charged, although computer-generated
reports are provided free of charge. The TRI data files are also available for
public inspection, under supervision, during normal business hours —
appointments can also be made upon request.
A section 313 network has been established comprised of
representatives from each Ohio EPA division and the Ohio Department of
Health to provide a forum for addressing TRI right-to-know issues. The
network reviews the concerns of citizens and identifies which forms are
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being requested by the public. During the announcement of the initial
availability of the TRI database, the network met primarily to discuss public
information requests from citizens and public interest groups; at the present
time, the emphasis is shifting to maximizing effective use of TRI data by
state agencies, such as for prioritizing air toxics and ground water quality
activities and in preparing grant applications.
The primary concern of the DAPC at this time is enforcing
compliance with section 313. Ohio DAPC and Resource Conservation and
Recovery Act (RCRA) permit-holders have been sent information on section
313 and a section 313 survey, which upon completion becomes part of the
facility's file. Ohio EPA has co-sponsored three seminars with the US EPA
Regional Office for industry on the section 313 reporting requirements. At
the request of trade and professional organizations, Ohio EPA has also
participated in section 313 workshops to provide information to the regulated
community.
The Form R report serves as the starting point for the compliance and
enforcement initiatives. First, every section 313 submission is reviewed for
completeness. This administrative review focuses on clerical reporting errors,
and notices are sent to those facilities submitting incomplete reports. The
second phase is a review of the accuracy of the forms — current air permit
records and RCRA generator lists are cross-referenced with section 313
reports to evaluate the accuracy of the release estimates. Once again,
facilities will be contacted if questions arise concerning their estimations.
The third element in the program is a series of section 313 audits of reporting
facilities. Select facilities are audited to review how Form Rs were
completed and how release estimates were calculated.
The enforcement initiative also includes an inspection program for
non-reporting facilities. Facilities have been identified primarily from RCRA
and air permitting records, although DAPC is coordinating with other Ohio
EPA divisions to identify further non-reporting facilities. The facilities first
receive a written notice of inspection, approximately two weeks before an
inspection. Inspections (30 have been conducted) and subsequent legal
enforcement action (seven have been initiated) will be carried out if
necessary. DAPC personnel have also visited paint manufacturers to insure
that MSDS information is being prepared and provided to their customers as
required under the section 313 supplier notification requirements.
Under the Ohio Code, the owner or operator of a facility is liable for
civil penalties of up to $25,000 per day for non-compliance with section 313.
In order to insure consistent enforcement, Ohio EPA has developed a formal
policy detailing various options for dealing with these facilities, including
issuance of a compliance order or requesting action from city, county, or
state prosecutors. In addition, Ohio EPA has developed distinct enforcement
alternatives for each type of violation: late reporting (following a one-month
grace period), administrative (clerical) errors, technical (release estimation)
errors, filing false information, and supplier notification (identifying the
presence of a toxic chemical in a mixture, its concentration, and the
relationship to section 313 reporting obligations).
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DAPC section 313 activities became self-sufficient with the
implementation of filing fees in fiscal year 1990. The program is now fully
funded by a fee system which provides a staff of two engineers, one clerical
position, and one intern for data entry. Each facility reporting under section
313 is required to submit $50 plus $15 per Form R submitted, not to exceed
$500 per facility. There is also a 15 percent late fee for facilities which
submit after expiration of a 30-day grace period. In 1988, Ohio EPA had
$65,000 to implement the program. For fiscal year 1989, the program was
budgeted $65,000 and over $160;000 in filing fees was collected for 1989
reporting. It is estimated that $150,000 will be generated through the filing
fees in fiscal year 1990.
LESSONS LEARNED
It's Not Over. The SERC is developing a number of projects for the
near future to re-establish important connections and dialogue between itself
and Ohio LEPCs. In the first days after Title in was passed, there was
considerable enthusiasm in the state for the new program, but this has since
diminished due to funding difficulties. The SERC hopes to develop an LEPC
recognition program to support and encourage increased Title HI activities
and to serve as a method to publicize LEPC efforts within the state.
Effective Outreach Creates a Positive Atmosphere. The Division
of Air Pollution Control at Ohio EPA has made a concerted effort to maintain
a high level of outreach to facilities subject to reporting under section 313.
By contacting facilities that received Ohio air and RCRA permits, the DAPC
was able to identify a number of smaller facilities previously unaware of the
requirements of section 313, and survey them to identify which of these
facilities were pbligated to submit Form Rs. In addition, the DAPC annually
contacts facilities who have filed under section 313 during the previous years
to remind them of the reporting requirements. This effort has produced a
positive environment in which the Ohio EPA is viewed as helping facilities
comply with Tide in, rather than simply enforcing penalties.
Contact:
JeffBeattie
RTK Program Supervisor
Ohio EPA
1800 Watermark Drive
P.O. Box 1049
Columbus, OH 43215
(614) 644-2269
Cindy DeWulf
TRI Program Coordinator
Ohio EPA - DAPC
1800 Watermark Drive
P.O. Box 1049
Columbus, OH 43215
(614)644-2266
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Hazards Analysis
Planning
Exercises
Data Management
Outreach
LEPC Organization
Prevention
Compliance
HAMILTON COUNTY, OHIO
LEPC: 35 full-time appointed members and 70 volunteers,
including representatives from local government, law
enforcement, emergency management, local fire
departments, first responders, health organizations,
hospitals, local enviromental and community groups,
transportation, Red Cross, and covered facilities.who
provide expertise for the various LEPC subcommittees
Population: 850,000
Facilities: 130 facilities reported for section 302 including large
chemical manufacturers and small gas stations
Hamilton County is located in southwestern Ohio and borders the
states of Kentucky and Indiana. The county is composed of 49 separate
political jurisdictions, including the city of Cincinnati, and contains many
major transportation routes including several interstate highways, major
railroad systems, and the Ohio River.
The LEPC has formed eight subcommittees to handle the following
subject areas: plan oversight, hazard analysis, training, hazardous materials
exercises, technical interpretation, data management, public and media
relations, and membership nominations. Each subcommittee fulfills its
responsibilities utilizing experts drawn from the community applicable to the
subject area; for example, a representative from the local television station
serves on the public and media relations subcommittee.
LEPC ACTIVITIES
Hazards Analysis. The LEPC decided a detailed hazard assessment
of the chemicals, particularly extremely hazardous substances (EHSs), was
necessary to provide a focus for emergency planning in the community. A
technically-oriented LEPC subcommittee was assigned the task of identifying
facilities and substances that posed the most serious threat to the community.
This assessment will serve as the primary means for the LEPC to revise its
emergency plan annually.
Section 302 reports indicated that 130 facilities in the county use
EHSs, and the LEPC sent these facilities a comprehensive survey which
requested information on facility location, emergency notification and
communications systems, emergency equipment and personnel resources,
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chemical-specific storage and transport, spill prevention and control,
hazardous waste management, and contingency planning. As this
information was being collected, the subcommittee decided to focus the
hazard assessment on a small list of chemicals rather than on the entire EHS
list so that emergency planning could address the hazards most immediately
dangerous to the community.
The list was narrowed based on each substance's physical state, acute
toxicity, reactivity, and explosive potential. For example, compressed gases
and volatile liquids were considered more hazardous to the community than
inert solids. In addition, hazardous chemicals subject to sections 311-312
reporting were also evaluated to determine if some were as hazardous and
also needed to be included. Principle factors in this decision were a National
Institute of Occupational Safety and Health (NIOSH) Immediately
Dangerous to Life and Health (IDLH) level at or below 100 ppm and spill
records from EPA's Acute Hazardous Events Database. This screening of
EHSs and other hazardous chemicals produced a list of 85 substances, and
after cross-checking with facility section 302 submissions, the subcommittee
identified 74 facilities where 20 of these substances were present.
The subcommittee then further reviewed these facilities' sections
311-312 submissions to identify the maximum and average range of the
substances present on-site and to conduct preliminary dispersion modelling.
This was done to identify 10 facilities of primary concern. These facilities
serve as the initial phase of the program, which will be completed later this
year. Upon completion, the subcommittee will begin to analyze the hazards
posed by other facilities with significant quantities of EHS and other
hazardous chemicals. In addition, the LEPC plans to begin work on hazards
analysis for transport of hazardous chemicals in the near future.
As a pilot program, the subcommittee decided to request ten selected
facilities to assist the LEPC in performing a detailed hazards analysis for
these substances. A letter was sent to each facility along with a copy of the
Technical Guidance for Hazards Analysis, requesting that the facility conduct
the analysis pursuant to the authority of section 303(d)(3). The facilities
were also provided with a simple worksheet for conducting a vulnerability
zone and risk analysis for specified release scenario(s). The results of the
risk analysis section of the submitted worksheets indicated that some facili-
ties had underestimated both the probability and severity of the potential
release. (Even though the vulnerability zone analyses indicated that several
facilities could potentially affect a ten-mile radius in populated areas, this
was not reflected in the risk analyses.)
To correct this situation, the subcommittee developed a two-page risk
analysis evaluation form to serve as the basis for a more quantitative
estimate. The evaluation form asked a series of questions specifically
designed to evaluate first the likelihood of an incident and secondly, the
severity of the consequences. Each question was to be answered with one of
three provided responses (i.e., choose A, B, or C). A certain number of
points were assigned to each response. When totalled, the number of points
corresponds to a scale which translates the number into a measure of the
likelihood and severity of an incident. For example a score of 16-24 points
in the "Likelihood of Incident" portion of the form corresponds to a
"Medium Likelihood" that the event will occur.
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The questions pertaining to the likelihood of the event included
areas such as contingency planning, storage facilities, monitoring and
inspection procedures, history of leaks and spills, location of storage tanks,
and employee hazardous materials awareness. The questions pertaining to
the severity of the consequences covered areas such as the population within
the vulnerable zone estimated by the facility, the capabilities of on-site and
local response personnel, the anticipated property damage, and the expected
environmental effects.
Planning. The Hamilton County Office of Emergency Management
and Civil Defense is primarily responsible for coordinating the LEPC's
planning efforts. This office had in place an approved Emergency Operations
Plan (EOF), required by the Federal Emergency Management Agency, at the
time of the enactment of the Emergency Planning and Community Right-to-
Know Act (also known as Tide III) and used it as the basis for the LEPC
plan. The EOP was closely examined with respect to the Title III emergency
plan requirements using the Hazardous Materials Emergency Planning Guide
(also known as NRT-1), which was adopted as the LEPC's official planning
guide.
The planning efforts of the LEPC have also been assisted by
Hamilton County's Disaster Planning and Coordinating Council. The
Disaster Council, formed in 1962 under the auspices of Civil Defense, has
provided first response and planning organizations a forum for the exchange
of ideas, expertise, knowledge of resources, plans, and limitations of each
organization prior to a disaster.
The LEPC sent every facility that reported under section 302 and
every local fire department with jurisdiction over a covered facility an
extensive questionnaire requesting facility specific emergency planning
information, such as emergency contacts, the jurisdictional police
department, characteristics of the surrounding community, emergency
response capabilities, and the names and quantities of the chemicals stored
on-site. The questionnaire instructs the facility emergency coordinator to
meet with the local fire department to jointly fill-out the information. The
questionnaire has proved successful in prompting initial and continued face-
to-face contact between the facility, the local fire department, and the LEPC.
Exercises. The Hamilton County LEPC uses table-top, functional,
and full-scale field exercises to test their emergency plan. A table-top
exercise was conducted in January 1990 and consisted of examining a
chemical release within the city limits of Cincinnati. Although the release
was limited to the city boundaries, personnel from bordering counties also
participated. The focus of this exercise was to test the basic provisions of the
emergency plan: first responder coordination, communication procedures,
and the roles of the different authorities involved. The table-top exercise
identified weaknesses in the existing plan that have since been corrected.
Lines of emergency communication have been better defined for more
effective information dissemination both during and following an incident.
The precise roles of the different authorities involved in a response have also
been better defined as a result of the exercise.
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Currently, a full-scale field exercise is being coordinated for May,
1991. The Monsanto Ports Plastics facility, in Addyston, Ohio, has volun-
teered to serve as the incident site. The exercise will involve a chemical
release from a tank car into the Ohio River. Such an incident will require
multi-jurisdictional coordination between various local emergency planning
districts and will include the US Coast Guard. The exercise was formulated
to test the mutual aid provisions of the emergency plan, the role of the LEPC
in an emergency, and the coordination of emergency response personnel, and
will involve local fire and police departments, local hospitals, and the media.
Data Management. The Hamilton County LEPC is examining
various software packages for information management as well as creating
their own programs to integrate and supplement the existing programs.
Currently, the LEPC is using.dBASE III plus on an IBM PS 2 to store
information such as facility locations, facility emergency coordinators, and
local fire departments, and CAMEO on a Macintosh II to store chemical
information, such as sections 311-312 information.
In order to evaluate their own progress and solicit suggestions for
improved management of Title El data from other LEPCs, the Hamilton
County LEPC sent a questionnaire to every LEPC in Ohio. The responses
from the LEPCs indicated a majority wanted more computer software and
support. As a result, Hamilton County petitioned the SERC to increase its
development of software and support for data management to LEPCs and to
help fund seminars for state-wide training programs.
Outreach. The LEPC has distributed information to the public and
community groups about the LEPC and Title in. Specifically, they have
developed a three-page fact sheet describing the role of the LEPC, the
information available under Title III, and the local emergency response plan.
This fact sheet, US EPA documents, and a letter offering additional
information and speakers was mailed to all community groups identified
within Hamilton County. A series of newspaper articles was also published
describing the LEPC and its activities.
As a result of these efforts, the LEPC has received several requests
for chemical information from the public. Some community groups also
have identified facilities that may not be in compliance with Title III. For the
future, the LEPC is creating presentation packages and a speakers roster to be
distributed to community and industry groups to improve awareness of Title
LEPC Organization. LEPC members are first officially
recommended by the County Commissioner's Office and reviewed by the
SERC for approval. The LEPC reviews and evaluates the performance of
each LEPC member every two years. The purpose of the evaluation is to
review the member's level of activity and commitment to the LEPC. At the
end of this process, members are either recommended to be offered a
continued membership or asked if they wish to resign their membership.
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Prevention. Included in the planning questionnaire sent to facilities
discussed in the planning section, is a very detailed self-evaluative
prevention test for the facility. It includes areas such as alarm systems, chain
of command information, equipment maintenance schedules, and other
questions of similar nature. The check-list is intended to stimulate facilities'
awareness of the need for chemical accident prevention. In the future, as
resources and time permit, the LEPC wants to pursue more actively
additional prevention initiatives.
Compliance. The LEPC has experienced a 90 percent compliance
rate on the questionnaires that were mailed to the facilities. The universe of
facilities that should be reporting has not yet been estimated. In order to
identify facilities for both compliance and outreach efforts, each local fire
department was sent a list of the facilities for which a questionnaire had been
submitted to the LEPC. The local fire department was then asked to identify
facilities in their jurisdictions that had not submitted a report. In addition, the
state of Ohio has provided each LEPC with a list of all the permit-holding
facilities, such as state and federal air and water discharge permits, in their
emergency planning districts. Both the information from the local fire
departments and the state of Ohio will be used to increase awareness of and
compliance with Title HI.
LESSON LEARNED
Broad Participation, Broad LEPC Capabilities. Prior to the
enactment of Title III, there was no specified or required membership on an
emergency planning team. As a result, many valuable representatives with
valuable knowledge were left out of the planning process. The LEPC's
hazard analysis subcommittee conducts a much more effective and efficient
hazards analysis because its membership is very broad. The membership
includes a toxicologist, facility representatives, a mechanical engineer, and
first responders, as well as local planning officials. Toxicologists and health
professionals can provide a clearer picture of the hazards posed by chemicals,
and simplify prioritizing release scenarios. Response personnel can provide
insight into previous incidents and the effort necessary to conduct a full-
fledged response. Engineers and facility representatives can better assess the
hazards associated with specific industrial processes and the value of
prevention and mitigation systems. In addition, the inclusion of industry
members will improve facility cooperativeness with the process.
In addition, many residents concerned about hazardous chemicals in
their community have become active in the LEPC. Through working
together on the LEPC, industry and residents have developed a cooperative,
non-adversarial relationship. As a result, the emergency response plan
resolves facility hazards and community concerns in a more responsive
manner.
Contact: Don Maccarone
Hamilton County LEPC
Office of Emergency Management and Civil Defense
84 Shadybrook Drive
Cincinnati, Ohio 45216
(513) 821-1092
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Planning
Exercises
Data Management
Hazards Analysis
Training
Outreach
WALLINGFORD, CONNECTICUT
LEPC:
Population:
Facilities:
30 members, including elected officials; representatives
from local fire, police, civil defense, utilities, and public
works, as well as facilities reporting under sections 302
and 311-312; and the Red Cross and other community
groups (chair: mayor; vice-chair: American Cyanamid
plant manager)
41,000
Large and small chemical companies and specialty metal
manufacturers
Wallingford is located in New Haven County between New Haven
and Hartford, Connecticut. Heavily-traveled commercial Interstate Highway
91, a freight rail line, and the Quinnipiac River run through the area. The
Wallingford LEPC has established several subcommittees, such as Public
Education and Educational Institutions, to address specific Title III issues.
LEPC ACTIVITIES
Planning. The Wallingford LEPC is in the process of completing its
annual emergency response plan review. A current issue of concern is
educational institutions — what is the need for emergency planning for
chemical incidents at these locations (e.g., lab or maintenance incidents) or
from incidents in the surrounding neighborhoods which could affect a school.
Local educational institutions have been participating in a special LEPC
subcommittee on schools, which has addressed the integration of school
contingency planning with the LEPC plan, particularly in reference to
evacuation and in-place protection decisions. As a result of an incident in
nearby New York State in the Spring of 1990, where a school wall collapsed
during a violent storm, the LEPC has been exercising an extra degree of
caution before making firm decisions on appropriate locations for sheltering
schoolchildren.
Exercises. In conjunction with the local American Cyanamid
facility, the LEPC held a full-scale exercise in 1989 which was attended by
state and local officials as well as representatives from US EPA Region I.
Because the facility and the local fire department had a long history of
cooperation and coordination of preparedness activities, the exercise was
designed to test the other branches of the community's response system —
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primarily the police department and emergency medical services (EMS). The
scenario featured a ruptured tank of aqueous ammonia, which produced a
toxic cloud which was to pass over a primarily commercial and industrial
area.
The police department was responsible for establishing roadblocks
and conducting notification of potentially affected businesses of the need for
in-place protection and/or evacuation. Police cruisers were dispatched to the
areas in the path of the cloud, and were provided with index cards for a
building representative to sign and indicate the time, so that the length of the
operation could be estimated. In return, each building representative was
provided with a statement that described evacuation and/or in-place
protection options.
Meanwhile, emergency medical personnel treated and transported the
"contaminated" victims to local hospitals via ambulances. During the in-
depth critique of the exercise, the primary concern raised was with the proper
decontamination of not only the victims, but also ambulances and hospital
treatment areas. These issues have been addressed by revised EMS
protocols, and the two local hospitals and the ambulance service have been in
the forefront of the planning for an exercise later this year. This exercise,
scheduled for October, 1990 at the Ametek facility, will also involve an
ammonia release.
Data Management. The Wallingford Fire Department uses the
Computer-Aided Management of Emergency Operations (CAMEO) software
system, designed by US EPA and the National Oceanic and Atmospheric
Administration (NOAA), to assist local emergency planners and responders
with Tide ni activities. At this time, CAMEO provides Material Safety Data
Sheet and storage location information on hazardous chemicals to the fire
department and dispatcher. Tier I and Tier II information is accepted from
facilities for emergency planning purposes and is available at the fire
department, city hall, and the local library. For emergency response, the
LEPC has developed Chemical Information Inventories, which identify each
hazardous substance by DOT class, Tier I form hazard class, Occupational
Safety and Health Administration hazard categories, National Fire Protection
Association section 704 labeling standards, and Paint Industry standards, in
order to provide a comprehensive rating system for the hazards associated
with each substance, and to identify the personal protective equipment
needed during a response action.
Hazards Analysis. The LEPC has developed vulnerable zones using
four separate methodologies — the National Response Team's Hazardous
Materials Emergency Planning Guide (NRT-1), the Department of
Transportation's Emergency Response Guidebook, CAMEO, and the
ToxChem software system used by local chemical companies. The LEPC
determined that the most dangerous release scenarios involved ten-mile
radius zones of vulnerability, i.e., they could conceivably have impacts
beyond the municipality of Wallingford. The hazards analysis has prompted
prevention projects at local facilities, including moving storage tank
locations, switching to less hazardous chemicals, and introducing engineering
controls (such as improving the protection of tanks to prevent vehicles from
backing into them and installing diking to contain a release or spill). The
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LEPC has also been concerned with transportation incidents that could result
in a release at a fixed facility. In 1981, for example, a train derailment
almost resulted in a serious incident when a derailed car narrowly missed a
collision with a steel annealing furnace building which uses hydrogen and
ammonia.
Training. Firefighter training on hazardous materials response is a
priority in Wallingford. The entire Wallingford Fire Department, consisting
of 60 paid and 150 volunteer firefighters, have been trained to "operational
level," as regulated under SARA section 126, which requires local
emergency responders to be provided with training in understanding
chemical hazards and proper safety procedures. Sixteen firefighters have
received additional training to qualify as hazmat technicians; four of these
have been certified by the state after undergoing a 132-hour training program
sponsored by the Connecticut Commission on Fire Prevention and Control,
and receiving specific training with the hazardous substances in Wallingford.
The local American Cyanamid facility has a 7-member hazmat team which
responds to incident involving Cyanamid products in much of southern New
England. Recently, during a gasoline tanker truck roll-over incident, the
American Cyanamid in-plant fire brigade was called in to assist local
firefighters in applying foam.
Outreach. The LEPC developed a citizen's brochure on Tide HI for
distribution to all households in the community as part of an aggressive
approach to educating the public on chemical emergency issues. The
brochure provides specific information on how citizens can prepare for and
respond to notification of an evacuation or in-place protection for a chemical
emergency, including a map of the town showing major facilities,
transportation routes, and schools for evacuation purposes. It also describes
how citizens can get access to facility information under the right-to-know
provisions of Title III and the Wallingford emergency response plan.
In 1989, the LEPC sent an information packet on Title in reporting
requirements to 500 area businesses identified from various sources as likely
to be subject to Title IH The LEPC believed that many smaller businesses
might be unfamiliar with, or unaware of, the requirements of Title III. The
mailing identified several new facilities subject to section 302, which have
subsequently not only reported their extremely hazardous substances, but
also joined the LEPC. This effort has also instigated a reevaluation of
hazardous chemical policies at other facilities, and after this analysis, several
facilities altered existing process and inventory procedures (e.g., by reducing
on-site inventories), thereby reducing the risk to the community. The Public
Education subcommittee is developing an audio-visual program to assist
LEPC members in making presentations to industry and other organizations
on Title HI and the role of the LEPC.
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LESSONS LEARNED
LEPC Membership Should be Inclusive, Not Exclusive.
Wallingford LEPC industry participation is not limited to those facilities that
are involved in emergency planning under SARA section 302, but also
includes several facilities that only report under sections 311 and 312, but
nevertheless want to be involved in LEPC activities. The LEPC has
established a number of ad-hoc subcommittees to serve as workgroups in
addressing specific Title HE issues, such as school contingency planning
described above, and has invited organizations outside the LEPC to
participate, such as the public school system.
Industry Can be an Equal Partner in Title HI Activities. The
LEPC believes that many emergency preparedness and prevention initiatives
fail to recognize the important role that industry can play in fulfilling their
objectives. Any past adversarial relationships between local government and
industry must be replaced with communication to rebuild trust and thereby
work to ensure the success of Title III efforts in the community. In
Wallingford, industry plays a major role by participating in the planning
process and exercise development, by maintaining a fully-trained hazmat
team and response equipment, and by distributing Title in-related
literature. For example, the BYK-Chemie USA and Bristol Myers LEPC
representatives drafted the materials for the 1989 outreach project to small
businesses.
Furthermore, the Connecticut Emergency Resource Manual, pub-
lished by the Connecticut Business and Industry Association in connection
with the State Emergency Response Commission, serves as a means of
quickly identifying response resources available at nearby facilities in the
event of a hazardous materials incident. B YK-Chemie USA, Allegheny
Ludlum Corporation, Ulbrich Stainless Steels, and American Cyanamid are
represented on the Wallingford LEPC and have agreed to provide specific
technical expertise and response equipment in this effort. Each has provided
a list of available equipment and expertise, as well as a business and 24-hour
phone number and an emergency contact for the manual, which has been
distributed by the SERC to all Connecticut LEPCs and fire departments.
Contact: Mr. Donald Roe
Wallingford Town Hall
45 South Main Street
Wallingford, CT 06492
(203) 294-2060
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LEPC Organization
Public Outreach
Data Management
Inter-j urisdictional Coordination
OUACHITA PARISH, LOUISIANA
LEPC: 18 members, including fire, law enforcement,
lexicological, health, emergency management, and
general services officials, Red Cross and media
representatives, the Mayor of the parish seat, a State
Senator and a representative, industry officials,
attorneys, officials from State and Federal agencies,
including the US Coast Guard, and representatives from
the Lions Club and the Chamber of Commerce. The
Chair is theDirector of the Parish Civil Defense Agency.
Population: 142,000
Facilities: Approximately 215, ranging from chemical
manufacturing companies to small businesses such as
service stations, and to a number of farms and
agricultural operations •
^ -
Located in the northeast part of Louisiana, Ouachita Parish is
predominately agricultural, though about a third of its population lives in
Monroe, the parish seat. Significant contingency planning considerations
include an interstate highway, a railroad line, and the navigable Ouachita
River. A fish preserve and two wildlife areas lie within the parish bounds, as
does one of the nation's largest manufacturers of anhydrous ammonia, and
two major anhydrous ammonia distributors. Also, a major paper factory is
located there.
Given the amount of production and use of ammonia within the
parish, the LEPC and the emergency response community have paid
considerable attention to the possibility of an accidental release.
Transportation-related spills of ammonia have occurred several times in
recent years, and, indeed, two separate incidents involving barges on the
Ouachita River have led to significant LEPC action and to the improvements
of hazardous materials response operations throughout the parish.
LEPC ACTIVITIES
LEPC Organization. From its origin in September, 1987, the
Ouachita Parish LEPC has been characterized by steady leadership, clear
guidelines for LEPC members' involvement, and candor in its work. Starting
with an existing, well-developed all-hazards contingency plan, and relying on
intensive orientation and training of all its members, the LEPC was able to
move quickly towards accomplishing its assigned mandates. At the
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committee's second meeting, objectives were discussed and agreed on, and
operating procedures were adopted. Additionally, four standing
subcommittees were formed:
• Information Management;
• Hazards Analysis;
• Capabilities Analysis; and
• Plan Review.
Continuing guidance has been given to subcommittee members in the
form of brochures, articles, and specialized training sessions. With such a
strong emphasis on organizational principles, the LEPC plan began to grow.
One major factor stands out in the success to date of the LEPC's working
together, the members seem to realize that Title in depends on a slow,
building process, requiring patience and persistence.
From the beginning, every LEPC member was given assignments,
and was expected to join actively in the LEPC's continuing work. The
committee was able to finish and submit its draft contingency plan in
September, 1988; the plan was incorporated as an annex to the Parish All-
Hazard Plan.
The LEPC has functioned mostly on a volunteer basis. With the
exception of computers purchased by the Police Jury (which is the Louisiana
equivalent of a county commission) for the parish fire department, and state-
level training for response personnel, no additional funds have been sought or
spent to support the committee's work.
Public Outreach. Initially, in Ouachita Parish, there was little
interest in chemical safety and the new era of Title III; natural disasters such
as tornados formed the center of public concern. Realizing that its ultimate
success would depend in part on changing this attitude, the LEPC began
public information work early in its existence. For example, media
representatives were recruited and retained as committee members (indeed, at
present, there are three).
First, arrangements were made with the local radio and television
stations for public service announcements to be broadcast. These brief
messages outlined the new federal law, commented on the nature and
presence of hazardous chemicals, and explained the existence of the new
LEPC. Later on, interviews of the committee chair were set up, both on radio
and television. Two separate half-hour television programs were aired,
explaining Tide HI and the local parish activities in detail.
In another approach, the Ouachita Parish LEPC prepared and sent
informational letters to all the schools and civic organizations in the Parish,
again, explaining the law and the importance of hazardous chemicals
contingency planning. Following up on the school letters, officers of the
three parish fire departments developed and presented chemical safety
programs to teachers and students. Also, members of the LEPC presented
similar offerings at civic club meetings. All this effort eventually led to the
establishment of a separate public information subcommittee to plan a long-
range educational effort.
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To date, the high-point of this effort has been the LEPC's sponsorship
of a Chemical Awareness Week, held parish-wide during the week of
October 2-6,1989. The Chemical Awareness Campaign planning work
began that summer, and the subcommittee drafted a brochure for distribution
to households throughout the parish. The campaign was based on the
premise that since "society today is dependent on chemicals, it is important
for people to be aware of precautions to take when accidents occur."
LEPC members prepared a "chemical releases" fact sheet for general
distribution, summarizing all accidental chemical releases for the past five
years. While most of these incidents were minor, the sheet was meant to
remind Parish residents that even in a relatively tranquil part of Louisiana,
hazardous materials were not only present, but sometimes leaked, burned, or
exploded, and threatened lives and the environment.
Also, members worked on a series of nine special public service
announcements to be broadcast during the Chemical Safety Week. Ranging
in length from fifteen to sixty seconds, these announcements concentrated on
practical advice on what steps to take immediately following an accidental
release. They covered informal respiratory protection, in-place protection,
and orderly evacuation. At the end of each announcement, the following
sentence was read: "[T]his message from your Local Emergency Planning
Committee."
Additionally, a three-page news release was prepared, explaining the
intent of Title HI, and detailing the history, purpose, and work of the LEPC.
Of special focus in the text was the announcement of the mailing of the
brochure, What to Do in Case of a Chemical Emergency.
Official support for the campaign was given by the parish and its two
incorporated municipalities. Proclamations announcing the Chemical
Awareness week were issued by the Mayors of Monroe and West Monroe,
and by the Ouachita Parish Police Jury . Each proclamation stressed the
presence of hazardous chemicals, the need for the public to inform itself, and
the work of the LEPC.
The Louisiana Power and Light Company underwrote the publication
and mailing of the chemical emergency brochure. Accompanied by a letter
from the LEPC, the brochure was mailed separately to all 68,000 customers
of LP&L in the parish - no cost was incurred by any governmental agency.
The letter urged residents to take a few minutes to read the material in order
to increase their awareness of what to do in case of a chemical release. What
to Do in Case of a Chemical Emergency was printed in two colors on glossy
paper. The text echoed the main points of the public service announcements:
• What if you are told to protect your self from
breathing hazardous chemicals?
• What if you are told to remain indoors for in-place
protection?
• What if you are told to evacuate?
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• What should you do if you know there is a release and
it's coining toward you?
At a press conference held at the start of Chemical Awareness Week,
LEPC members and local officials were joined by representatives of the US
EPA and the State of Louisiana. It was noted that this campaign was the first
of its kind to be organized in Region VI. Shortly afterwards, the New
Orleans LEPC used it as a model for its own campaign.
Currently, following up on the October, 1989 events, the LEPC is
preparing a 1991 calendar containing chemical safety information for free
distribution in the parish. Also, members are preparing written material for
distribution to all school children with the intention that the children will take
the material home to their parents. Further, the LEPC is producing a
videotape for showings at public meetings.
Data Management. To better manage all the information gathered
under Title III, the LEPC turned its attention to establishing a local repository
agency, and to the acquisition of appropriate computers and software.
Accordingly, a special subcommittee was formed to draft specific procedures
for the repository's operation. Rules and reporting forms were drafted and
presented to the LEPC for adoption. The LEPC decided to mail copies of the
adopted rules and forms to all facilities that had submitted Tier II forms
previously in order to foster better understanding of the LEPC's expectations.
Reporting a release with the parish forms is voluntary, but the LEPC views
the procedures as vital to its operation.
With help from the Louisiana State Police, the subcommittee
completed its work, and the LEPC adopted its report without opposition.
Subsequently, the Ouachita Parish Fire Department was selected as the
repository agency, witii the concurrence of the two municipal fire
departments. The Parish Police Jury purchased IBM-compatible computers
for use in managing the data, and the three departments began a coordinated
effort to develop common information capabilities. The LEPC continues to
monitor the repository's operations, providing guidance whenever requested.
In July, 1988, in order to ensure that the chemical reporting practices
would be uniform throughout the parish, the LEPC sent an explanatory letter
to facilities potentially subject to Title JJJ requirements. Enclosed with the
letter were copies of the repository's operating rules regarding public access
to facility submissions adopted by the LEPC. Also, the three LEPC reporting
forms were enclosed:
1) Initial Release Report: to be filled out by fire
personnel when an incident is called in. Facilities
were instructed to notify the repository agency and
the SERC, as well as the local fire department
following an accidental release;
2) Chemical Information Request: to be completed by
anyone asking for material under the community
right-to-know provisions. A courtesy copy of this
form is mailed to the facility in question; and
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3) Repository Agency Query Letter: to be sent to facilities
notifying them that information has been requested that is not
on file, and that it must be supplied within 30 days.
The LEPC, concerned that it might be imprudent to allow the widespread
dissemination of confidential chemical location information, agreed that such
information would be kept sequestered unless facilities agreed to its release.
Also, concerned about the accuracy of the data collected under the
various reporting requirements of Title HI, the Ouachita LEPC began a
process of annual cross-checks of data with the Louisiana State Police Right-
to-Know Unit. Repository agency personnel check current reports with those
from prior years, and send notices to delinquent facilities and to those whose
reports are questionable.
By April, 1990, the LEPC had decided to make a further
improvement in its information management services. Having
reviewed the East Baton Rouge/Exxon automated reporting system, the
committee chose to adopt it for use throughout Ouachita Parish. Free
diskettes for Tier II filing requirements would be supplied to any owner or
operator who requested them. A memorandum was sent to facilities
throughout the parish advising them of this time-saving offer, and
announcing a series of training workshops for facility personnel; the floppy
diskettes (requiring IBM-compatible PC's and software) are to be mailed
annually to the repository agency. The workshops last about one hour and
were scheduled by appointment, starting with the parish's larger industries.
This automated system is expected to ease the workload of the parish fire
department considerably when fully implemented.
Inter-jurisdictional Coordination. In analyzing chemical incident
responses, the committee noted the ever-present traffic of hazardous
materials on the parish's interstate highway, the railway, and the Ouachita
River. In March, 1988, the LEPC organized an exercise simulating the leak
of a chemical product from a truck in a parking lot in Monroe. The written
critique was generally favorable, but noted minor communications,
coordination, and command problems: after all, several independent
jurisdictions suddenly were forced to act together.
Just a little over a year later in April, 1989, the real thing happened,
this time on the river as two barges carrying anhydrous ammonia ran into two
separate bridges, resulting in a minor leak. Initial inter-jurisdictional
confusion hampered the response efforts.
Then, on August 10, 1989, another barge crashed into a river bridge
releasing anhydrous ammonia gas into the air. This time, an evacuation was
ordered, and the local newspaper featured a special story tided, "Anhydrous
Ammonia a Suffocating Killer," explaining the nature and hazards of the
chemical. The LEPC met to review this incident as the real test of its
contingency plan and its training and exercising program. A written report,
prepared as the result of the meeting, concluded with ten recommendations to
improve future response actions, as well as the contingency plan itself. The
final recommendation read as follows:
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"Consideration should be given to establishing a multi-agency
HAZMAT Team, combining the equipment and trained personnel
that already exists within the Parish..."
The OuachitaLEPC agreed to serve as the forum for the study and
consideration of a unified response approach. Initially, the committee
organized a Hazardous Materials Task Force, composed of parish and
municipal police and fire agencies, the State Police, and the Parish Civil
Defense office. The task force first met in August, 1989, and has been
working together since then to develop guidelines, procedures, and criteria
for response force membership and training (following the new OSHA
regulations). Several prospective members are qualified hazardous materials
response instructors. LEPC members are confident that their Task Force will
soon grow into an effective operational team — a positive expression of
continuing contingency planning and analysis.
LESSONS LEARNED
Money Alone Does Not Make Title in Work. Speaking for her
LEPC, the chair has noted two keys to successful Title HI implementation.
The first, in her words is "that money does not, will not, should not fix
SARA Title IE. If anything, money introduced into this program, except for
training, will destroy what it is intended to do. Everyone who is by law
involved in SARA Title IE should do his part. No one should be able to pay
someone to take his responsibility." As police, fire, and hospital personnel
are learning, the objectives and activities of Title HI are "part of what we are
supposed to have been doing all along...."
Success Involves Commitment, Patience, and Persistence. The
second key lies in the understanding that chemical safety and contingency
planning are long-range activities: there are few overnight successes; LEPC
membership involves commitment, patience, and persistent effort in the
"slow building process" towards full local knowledge and capability.
Contact: Jackie Little, Chair
Ouachita Parish Local Emergency Planning Committee
413 Natchitoches Street
West Monroe, LA 71291
(318) 322-2641
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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. The following
bulletins are currently available:
Successful Practices #1
Doc. # OSWER-89-006.1, January 1989.
State of Kansas
Washtenaw County, Michigan
Butler County, Kansas
Jefferson County, Kentucky
Successful Practices #4
Doc. # OSWER-90-006.1, March 1990.
New York, New York
El Paso County, Colorado
Alexandria, Virginia
State of Maine
Successful Practices #2
Doc. # OSWER-89^006.2, August 1989
Calhoun County, Alabama
Pampa, Texas
State of Wisconsin
Cuyahoga County, Ohio
Racine County, Wisconsin
State of Idaho
Successful Practices #5
Doc. # OSWER-90-006.2, June 1990.
Tinker Air Force Base, Oklahoma
State of Connecticut
Cumberland County, Maine
Wyandotte County, Kansas
Successful Practices #3
Doc. # OSWER-89-006.3, December 1989.
Woodbury County, Iowa
State of Virginia
Fairfax County, Virginia
Pierce County, Washington
Successful Practices #6
Doc. # OSWER-90-006.3, September 1990.
State of Ohio
Hamilton County, Ohio
Wallingford, Connecticut
Ouachita Parish, Louisiana
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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
JohnUlshoefer
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-Region4
345 Courtland Street, NE
Atlanta, GA 30365
(404)347-3931
MarkHorwitz
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
RonRitter
EPA-Region 7
726 Minnesota Avenue
Kansas City, KS 66101
(913)551-7005
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
75 Hawthorne Street
San Francisco, CA 94105
(415)744-1450
Walt Jaspers
EPA - Region 10
1200 6th Avenue
Seattle, WA 98101
(206)442-4349
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