v>EPA
United States
Environmental Protection
Agency
Office of Solid Waste
and Emergency Response
(OS-120)
February 1991
OSWER-91-006.1
Series 6, No. 7
Successful Practices in
Title III Implementation
Chemical Emergency
Preparedness and Prevention
Technical Assistance Bulletin
Cameron County, Texas
Bucks County, Pennsylvania
Harford County, Maryland
Dallas County, Texas
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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 El 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 HI implementation efforts that you feel would be
of interest to others, please contact your EPA Regional Chemical Emergency
Preparedness and Prevention coordinator (see list on the last page) or the
Emergency Planning and Community Right-to-Know Information Hotline at
(800) 535-0202.
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International Coordination
Training
Outreach
Compliance
Funding
CAMERON COUNTY, TEXAS
LEPC:
Population:
Facilities:
19 members, including elected officials and health,
police, emergency management, fire, emergency
medical service, local hospital, industry, railroad,
media, and chamber of commerce representatives.
125,000
59 reporting facilities, including distribution and
warehousing facilities, fertilizer manufacturers,
pesticide distributors, water treatment plants, gas
stations, paint mixing suppliers, and transporters.
Cameron County, Texas, is a primarily agricultural area with a large
amount of tourism located at the southern tip of the state. Brownsville is the
county's largest city and lies across the Rio Grande from the neighboring city
of Matamoros, Tamaulipas, Mexico. Because of its proximity to the Gulf of
Mexico, the Cameron County Local Emergency Planning Committee (LEPC)
must prepare for off-shore response actions as well as land-based response
actions. And because the county is on the Mexican border, the LEPC must
be prepared for international coordination and communication in the event of
an emergency on either side of the border.
Cameron County has few chemical production facilities, but is home
for a large import and export trade. For this reason, the LEPC is primarily
concerned with the hazardous materials stored in warehouses in the area and
transported through the county by rail or by truck on Highways 77 and 83.
LEPC ACTIVITIES
International Coordination. International emergency planning
agreements between the United States and Mexico call for bilateral action to
protect the border environment. These agreements emphasized the need for
the Inland Joint Response Team (JRT) to support and assist sister cities
located on the U.S./Mexico border in coordinating emergency preparedness
and response. The Cameron County LEPC has responded to these
agreements by establishing close ties and coordinating emergency response
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plans with its Sister City of Matamoros. In particular, the LEPC has worked
with a Committee Locale de Ayuda Mutua (CLAM) in Matamoros, the
Mexican equivalent of an LEPC.
Representatives from the Quimica Fluor plant in neighboring
Matamoros and the Cameron County LEPC chair agreed that a full-scale
international exercise to test chemical emergency response capabilities along
the border might be extremely beneficial to all persons involved. The first
step in making the exercise a reality was in clearing the operation with
federal, state, and local authorities from the U.S., as well as representative
organizations on the Mexican side. After five months of extensive planning
done exclusively by volunteers, the exercise "Operation Amigo" began.
Operation Amigo involved a staged chemical spill of sufficient
toxicity to require the aid of the emergency response team at the Quimica
Fluor plant in Matamoros. The exercise tested both international
communication capabilities and the expediency of customs and immigration
procedures for moving response personnel and equipment across the U.S./
Mexico border.
The timely arrival of the Matamoros response team at the accident
scene in Brownsville made the exercise a success. But Operation Amigo also
exposed easily overlooked deficiencies in existing emergency plans, allowing
participants to learn from their mistakes during a harmless exercise. For
example:
One of three hospitals in the area (thirty miles north of
Brownsville) has remedied its lack of contamination suits by
acquiring a number of contamination suits and a portable
decontamination unit.
EPA Headquarters found during the exercise that its
computerized communication link could not access
international numbers to contact Mexican authorities; the
Agency has since rewritten the communication program to
allow access to foreign countries in emergency situations.
The Cameron County LEPC learned that they should have
immediately contacted a representative from the Brownsville
Irrigation District after a chemical accident occurs. The
Brownsville Irrigation District pumps water from the nearby
Rio Grande river via "resecas," or old river beds, to the water
treatment facility. For this reason, drainage into the resecas
during a chemical spill would seriously endanger the purity of
the water supply if the pumping were to continue.
With the discovery of these shortcomings during the Operation Amigo
exercise, improvements in the emergency plans could be made before an
actual chemical accident occurs.
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Due to the success of Operation Amigo, the LEPC took part in two
conferences of note. On June 6 and 7, 1990, the U.S./Mexico Inland JRT
Conference was held in Brownsville and was attended by officials from the
fourteen sister cities, as well as federal and state representatives from theU.S.
and Mexico. The conference highlighted both the problems of language,
customs, and governmental structure for emergency response along the
border, and the need to overcome such obstacles. Cooperation between the
cities of Brownsville and Matamoros, particularly concerning Operation
Amigo, was cited as a promising sign of effective joint inland response
across international borders.
On July 24,1990, members of both the Cameron County LEPC and
the CLAM organizations were invited to attend the Latin America and
Caribbean Training Seminar on the Awareness and Preparedness for
Emergencies at Local Levels (APELL) in Metepec, Toluca, Mexico. The
APELL program was developed in mid-1987 by the United Nations
Environment Programme to foster coordinated emergency planning for
chemical accidents throughout the world. Representatives from the LEPC
and CLAM described Operation Amigo and their corresponding
contributions to the Sister City program. The conference stressed the need for
such cities to work together for chemical safety, and presented some of the
more global issues in the chemical safety and emergency planning arenas.
The chair of the Cameron County LEPC summed up the message of the
conference by saying, "In emergency response we must see borders as
joining two countries, not separating them."
Training. The Cameron County LEPC has succeeded in sparking
public interest through offering free hazardous materials training. One of the
first services performed by the LEPC was to ask the physician from the
Matamoros Quimica Fluor facility to give a two-hour chemical accident
awareness course to staff members from Cameron County hospitals. In June
of 1989, EPA Region VI gave a two-day "First Responders" course, drawing
150 people from Brownsville/Matamoros and about 65 people from nearby
Weslaco. The course described different chemical hazards and equipment,
explained the uses of the CAMEO software system, outlined hazards
analyses methods, and set up several table-top exercises for its participants.
Upon the request of the Cameron County LEPC, local industry joined
in the move to offer hazardous materials training. Approximately 80 persons
from local fire and police departments, emergency medical services,
government agencies, and various industries attended a two-hour hazardous
materials awareness course offered on two successive days by the Chemical
Leaman company. Groendyke Trucking, a local shipping company,
sponsored a two-hour preparation session for Operation Amigo between
members of the Quimica Fluor Hazmat team and local police. In October
1990, Union Pacific also offered training for local police and emergency
response units in emergency planning for mitigating rail accidents involving
the transfer of chemicals; more than 50 people attended.
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Outreach. The Cameron County LEPC hopes to improve their
ability to communicate the Title m message to both local citizens and
members of industry. The monthly LEPC meeting is open to the general
public, including citizens of neighboring towns in Mexico. The LEPC sends
out monthly announcements summarizing current information on LEPC
issues to 200 local government, emergency medical service, industry, and
Texas SERC representatives.
At the present time, the Cameron County LEPC meets on occasion
with various clubs and community organizations for lunchtime presentations.
Local print and television media provide coverage for some LEPC events,
and the LEPC hopes to obtain free space to promote their activities in local
phone books. The LEPC ultimately wants to get people involved on a more
local level by haying industry representatives meet with neighborhood
associations to discuss their facilities' emergency plans. In this way, the
LEPC believes residents will become more aware of emergency preparedness
and the chemical hazards that exist in their own community.
The Cameron County LEPC is working to enlist the aid of the Texas
Agricultural Extension Service to spread the emergency preparedness and
response message to residents of the State of Texas. The extension service is
based at Texas A&M and is funded through grants and contracts, as well as
through the county, state, and federal government budgets. The LEPC has
proposed that some members of the extension service be trained in
emergency response procedures to better educate the public on what to do in
case of a chemical emergency.
Compliance. Facilities are required under the Texas Hazard
Communication Act to report Tier n information as outlined in section 312
of Title III. Compliance under the requirements of Title IE and the Texas
Hazard Communication Act has proven to be difficult to ascertain for the
Cameron County LEPC. Many companies that transport chemicals through
and within the county do not report on the hazardous chemicals they store
within the county, claiming that chemicals stored in their vehicles and
warehouses are under active shipping papers and exempt under sections 302-
303, and 311-313. However, at any given time, these chemicals may be
either stored for days_ in warehouses or remain unmoved in tanker trucks.
The LEPC is contacting these companies to explain the Title HI requirements
and the spirit of the law. Letters have been sent to almost 200 warehouses
and transportation companies in an attempt to identify the hazardous
chemicals present on-site.
Funding. In the past, the Cameron County LEPC has received
donations from local banks, hospitals, and industry for receptions during
various training sessions and during the Operation Amigo exercise. In
addition, the LEPC has asked local businesses to help defray the cost of
several other items such as a VCR for recording hazmat training cable
broadcasts. Additional sources of funding consist of postage donated
monthly by local industry and a small grant from a local foundation. The
grant has allowed the LEPC to do more of the things they had wanted to do
(e.g., Operation Amigo).
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LESSONS LEARNED
Consistent Meetings Mean Continuous Outreach. Contact with
the community is needed if emergency preparedness is to be on people's
minds. Monthly meetings are very important; if the community gets into the
habit of participating every month, emergency preparedness and response
will remain a fresh subject for all those who participate.
Emergency Response Exercises Should be a Team Effort.
Because members of the community respond to chemical accidents together,
they should train together as well. On the day after Operation Amigo, for
example, an evaluation of the exercise occurred in which each person who
participated explained what he/she had learned to the entire group. In this
way, people became aware of the different responsibilities and problems of
different responders. All those involved learned that training and exercising
together is the key to organized emergency response. The Cameron County
LEPC views this post-exercise evaluation as essential for people to know
what others are doing in case of an emergency, so the community can work
as a team.
Practice Makes Perfect The best way to realize the needs of an
emergency plan is to stage exercises, as the Cameron County LEPC did with
Operation Amigo. The LEPC found that problems, like international
communication and notification of the local water treatment facility, became
apparent only as they responded to a simulated emergency. These issues can
be addressed now before a real accident happens.
Always Think Postively. Emergency planning and education should
be conducted in a positive, non-threatening manner, and it should prove
helpful to industry as well as the community in identifying hazards. Prior to
Operation Amigo, the Cameron County LEPC realized that the county lacked
fully encapsulated suits for use during the mitigation of a chemical accident.
As of September 1989, the nearest such suit on the United States side of the
border was in Corpus Christi, approximately 250 miles away. Local
industry, exemplifying its positive working relationship with the LEPC,
donated four fully-encapsulated suits to the Brownsville Fire Department and
decontamination unit.
Contact: Jackie Lockett, Chair
Cameron County LEPC
143 E. Price Road
Brownsville, TX 78521
(512)546-1161
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LEPC Organization
Information Management
Funding
Planning
Compliance
Training
BUCKS COUNTY, PENNSYLVANIA
LEPC:
Population:
Facilities:
15 members, including representatives from law
enforcement, fire service, emergency management,
emergency medical service, civil defense, local and
state government, industry, transportation, county
health department, local community college, and the
media.
500,000
290 facilities have submitted Tier II reports and 99
facilities are subject to sections 302-303. Reporting
facilities include chemical manufacturers, metal
processors, federal facilities, coating manufacturers,
water and sewer authorities, gas stations, specialty gas
processors, distributors, swim clubs, and farms. 44
facilities reported under section 313.
Bucks County is situated in southeastern Pennsylvania just over the
Delaware River from New Jersey. Part of the five-county greater
Philadelphia metropolitan area, Bucks County is located northwest of the
New Jersey Turnpike between Philadelphia and Trenton, New Jersey.
Industrial facilities and distributors are predominantly present both in the
county's southern portion and in the lower half of its western edge. The
central portion of the county is largely residential with scattered farmlands,
while upper Bucks County is essentially a rolling rural area dotted with small
municipalities.
LEPC ACTIVITIES
LEPC Organization. Prior to the enactment of the Emergency
Planning and Community Right to Know Act of 1986 (EPCRA or commonly
known as Title IH), industry in the lower portion of the county had begun to
address chemical emergency preparedness under the Chemical Manufacturers
Association's Community Awareness and Emergency Response (CAER)
program, in conjunction with Burlington County, located across the
Delaware River in New Jersey. With the enactment of Title HI, the CAER
program essentially melded into the Bucks County Local Emergency
Planning Committee (LEPC) program.
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The assistance of a professional management consultant, provided to
the Bucks County LEPC under a grant from Rohm and Haas, a large
Philadelphia-based chemical company, proved to be critical in the LEPC's
first four months. The consultant led the group in initial "team building"
exercises to mold the committee into a cohesive group with a defined
direction and objective. Team building highlighted the philosophies of each
of the LEPC members through the use of group interaction, role-playing
scenarios, addressing problems in small groups, and various other ways. As
the members discussed their ideas about the purpose behind the Title in
emergency preparedness message, the goals of the LEPC began to develop
and take shape. As the members became more comfortable working with one
another, they began to work more as a team than just a group of individuals.
The initial leadership provided by the management consultant helped
the Bucks County LEPC members coalesce rapidly as a team. After the team
concept was developed, the LEPC was able to organize themselves into
appropriate subcommittees and to develop their own administrative
procedures. The LEPC was divided into six subcommittees to direct the
tasks of administrative duties, public information, training, emergency
services liaison, data and information management, and emergency planning.
To ensure active participation in the LEPC, administrative rules require
LEPC members to be on at least two subcommittees, and to review continued
membership of anyone who misses two LEPC meetings in any year. The
Bucks County LEPC credits its ongoing success as a well-organized and
active LEPC to the indispensable aid of the management consultant during
those first four months.
Information Management. The Bucks County LEPC data
management subcommittee originally decided to load the Emergency
Information System/Chemical (EIS-C) software package on available IBM-
compatible computers at the county emergency management office. The
EIS/C package records chemical, facility, transportation, and other planning
and response information and graphically displays such information on color
maps. After several months of use, however, members of the LEPC
concluded that the EIS-C program did not fit the needs and budget of the
LEPC, and that a substitute program would be more beneficial.
In place of the EIS-C program, the Bucks County LEPC established a
simpler, dual system consisting of an IBM-compatible database using dBase
IV software for hazardous materials data, and the Macintosh version of the
CAMEO computer software system, developed by EPA and the National
Oceanographic and Atmospheric Administration, for emergency response
planning. The LEPC found the new dual system of dBase IV and CAMEO
to be comprehensive and easy to use for the LEPC, while remaining within
its limited budget constraints. The LEPC plans to implement the CAMEO-
DOS version to consolidate their entire information network on the available
IBM-compatible computers.
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All personal computers in the offices of the Bucks County Emergency
Management Agency have been linked together as a network. The dBase IV
hazardous materials database was added to the network to provide ready
access to information on facilities, budgeting, and other administrative
functions. The Bucks County Communications Center, the central fire,
rescue and police dispatch center for the county, can access this database for
communicating hazardous materials information to emergency responders.
The Data Management subcommittee helped the Communications
Center to develop a revised computer-aided dispatch system, which will have
greater capabilities to handle information related to hazardous materials
incidents. Before such a system was in place, dispatchers handled chemical
emergency calls in the same manner as other emergency calls. During a
chemical emergency call, however, the revised dispatch system prompts
dispatchers with a series of questions to ask facilities about the nature of the
accident to determine the most appropriate way to respond.
Funding. The Bucks County LEPC incorporated as a non-profit
corporation and received tax-exempt status from the Internal Revenue
Service in 1989. This step improved the LEPC's ability to solicit monies
from facilities and from the county directly, avoiding the deay of applying for
funding through county government channels.
In order to meet the budget requirements for 1988 and 1989, the
LEPC proposed to the County Commissioners a dollar-matching concept
between facilities and the county government. To provide an indication of
what each facility's "fair share" of the industry contribution should be, the
LEPC has analyzed data supplied on Tier I and Tier II reports and prepared a
graduated scale of suggested contribution amounts. These voluntary
contributions are solicited by a letter sent to each facility and municipality
annually.
In each of the last three years, the Bucks County LEPC has received
$27,500, $36,750, and $35,250 respectively from the volunteer contributions
for a total to date of $99,500. This figure does not include a number of "in-
kind" donations of equipment and services given to the LEPC in the last
several years. The LEPC credits much of its success in the past to its ability
to financially undertake major endeavors, including establishment of a
Hazardous Incident Response Team (HIRT), a data management system, and
hazardous materials training and education programs.
A permanent revenue-raising program that will replace the voluntary
contribution approach recently passed in the Pennsylvania state legislature.
This program, outlined in Pennsylvania's Hazardous Material Emergency
Planning and Response Act, allows the state and its numerous counties to
levy chemical reporting fees on facilities which report under section 312 at or
above the EPA-established threshold of 10,000 pounds for hazardous
chemicals, and 500 pounds or the threshold planning quantity (TPQ),
whichever is lower, for extremely hazardous substances (EHSs). The fees
are intended to provide incentive for facilities to self-police Title in
reporting, and thus to foster a safer business and community while reducing
the chemical registration paperwork load for the LEPCs, local fire
departments, and the Pennsylvania Emergency Response Commission
(PERC).
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Planning. The Bucks County LEPC succeeded in finding a number
of creative ways in which to foster effective emergency planning within the
county. The LEPC developed a county emergency plan that taps into
existing emergency management resources, and helped in the development of
compatible municipal and facility plans. The LEPC also identified areas of
the county vulnerable to chemical incidents.
As required by Title m, the Bucks County LEPC created a chemical
emergency response plan for the county. In order to ensure simplicity and
compatibility with existing plans for other types of emergencies, the LEPC
has developed the county plan within the framework of the Bucks County
Disaster Operations Plan' mandated by the Pennsylvania Emergency
Management Act. Because many of the mechanisms already in place to
handle other types of public emergencies are also used to mitigate hazardous
materials incidents, the LEPC felt that expanding on the existing emergency
plan would be most efficient. The county plan includes a general operation
philosophy in addition to a standard operating procedure (SOP) for hazardous
materials incidents, an SOP for an incident command system, and an SOP for
the County Communications Center for use in hazardous materials
emergencies. The LEPC reviews and updates the county emergency
response plan annually during the first quarter of each year.
The county plan is supplemented both by municipal preparedness
plans and by site-specific chemical emergency plans. Using the authority of
Title III section 303(d)(3), the LEPC has asked facilities to submit such site-
specific plans to the LEPC. In 1988, the Bucks County LEPC prepared both
a Planning Guide for Site-Specific Plans and a sample site-specific plan to
assist facilities in developing adequate response plans. Each facility is
encouraged to work jointly with the municipality in which it is located and
with the emergency responders who will be first on the scene in the event of
an emergency. In order to ensure universal agreement on emergency
response procedures, the LEPC emphasizes that each plan should contain a
statement of joint development signed by both the facility's emergency
coordinator and the municipal emergency management coordinator before
the plan will be accepted for review by the LEPC.
The Bucks County LEPC also completed a county-wide vulnerability
analysis, which is an estimation of the geographical area that may be affected
as a result of a spill or release from a specific location. This analysis, based
on information submitted to the LEPC in the site-specific plans, included
identification of transportation routes and a review of emergency
preparedness at the municipal level throughout the county. In the upcoming
year, the LEPC plans to analyze the risk from facilities in the counties which
adjoin Bucks County. The LEPC also plans to develop a "Field Manual" for
incident commanders of hazardous materials emergencies. The manual will
outline appropriate decision-making steps to mitigate chemical emergencies
for a given on-scene situation.
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As a cost-effective way to further assist local emergency responders
in the mitigation of chemical emergencies anywhere within the county, the
LEPC decided to develop a Hazardous Incident Response Team (HIRT).
The HIRT, composed of fire and emergency medical service personnel, is a
volunteer organization with no specific legal authority to respond to a
chemical emergency; the HIRT responds at the request of the local first
responders. Members of the HIRT elect a county coordinator, who is
approved by the Bucks County LEPC, to head the team. Under the county
coordinator, three regional coordinators supervise the activities of the HIRT
in particular areas of the county.
Compliance. The Planning subcommittee of the Bucks County
LEPC conducted an outreach program to identify and educate users of
gaseous chlorine. By examining the records of the county health department,
the LEPC determined that a large number of chlorine sources exist at sites
throughout the county, including water wells and swimming pools. An effort
to contact these sources has resulted in both comprehensive planning for
chlorine releases and, more significantly, a change from chlorine to less
hazardous materials at numerous facilities. An effort has also been made by
the LEPC to contact the many small farmsteads in the county's rural areas
which may use and store hazardous chemicals during certain times of the
year. Letters have been sent to the farms to introduce the LEPC and
summarize the reporting requirements under Title HI.
Training. About 75 people attended a one-day industrial workshop
sponsored by the training subcommittee to train plant managers and facility
emergency coordinators on developing site-specific plans. The
subcommittee also sponsored a half-day workshop for municipal emergency
coordinators and elected municipal officials; representatives of 27 of the
county's 54 municipalities attended. The subject matter included an
overview of the county Title III plans and the municipal requirements under
the Pennsylvania Emergency Management Act. Information from the
workshop was sent to those local officials that did not attend.
The Bucks County LEPC has put together a comprehensive training
program for the county HIRT Team, as well as a program for groups of new
recruits. Another major accomplishment of the Training subcommittee was
the development of specialized training units for fire, police, and emergency
personnel covering the Incident Command System and hazardous materials
training. The LEPC expects that such specialized training of all emergency
responders will require from two to three years to complete.
LESSONS LEARNED
The Spirit of Volunteerism is Alive and Well. An effective LEPC
is one whose members give a lot of themselves. LEPC members should be
willing to communicate their ideas and concerns to each other. They should
strive to introduce the LEPC and the Title HI message to facilities,
communities, and emergency responders. Members need the conviction to
participate in more than one committee, and must be able to attend meetings
regularly. No one can be an LEPC member in name only; it takes a group of
people who are willing to volunteer a lot of time and effort.
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Be Resourceful with Resources. The ability to undertake major
endeavors, from the establishment of a Hazardous Incident Response Team
(HIRT) to the development of a data management system, requires a
fundraiser to be imaginative. An LEPC needs to use its resources, whether
ample or scarce, to its best advantage through creative ideas that stretch each
dollar. Development of a reliable source of funding such as a fund-matching
system is but one example of a creative way of raising funds, incorporation
as a non-profit corporation is another.
Contact: Arlyn Poppen, Chair
Bucks County LEPC
c/o 3 M Tape Manufacturing Division
Green Lane
P.O. Box 119
Bristol, PA 19007-0119
(215) 945-2800, Ext. 3127
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Planning
Exercises
Outreach
Training
Funding
HARFORD COUNTY, MARYLAND
LEPC:
Population:
Facilities:
40 members, including representatives from police,
fire, U.S. Senate Office, Maryland Emergency
Management Agency, county departments of health
and emergency operations, industry, media,
Aberdeen Proving Grounds, public schools, and
private citizens (chair: appointee of Harford County
Executive).
185,000
31 facilities under section 302, primarily chemical
manufacturers and water treatment plants; 96
facilities under sections 311-312.
Harford County is located in northeastern Maryland at the north end
of the Chesapeake Bay. The Susquehanna River forms the eastern border of
the county and flows into the Bay. The major transportation routes include
Interstate Highway 95, US Route 1, and US Route 40; railroads include
Amtrak, the B&O, and US government tracks. The coastal shoreline of
Harford County is primarily wetlands, and has been designated as the
Susquehanna National Wildlife Refuge. The county also contains the
Aberdeen Proving Grounds Edgewood Facility, a Department of Defense
chemical weapons stockpile installation.
The Harford County Council passed Bill No. 90-83, which became
effective on October 16, 1990, revising existing county legislation on
hazardous wastes. The bill allows for the recovery of all costs (i.e.,
operational, administrative, personnel, payroll, and legal) incurred during a
response action from the individual or organization responsible, immediate
reporting of all fixed facility and transportation incidents involving
hazardous substances and submission of a written follow-up report within
two weeks, right of entry for monitoring and inspection by a representative of
the Harford County Department of Emergency Operations (DEO), and civil
action authorized in the event of any violation. The LEPC recently received
the Chemical Manufacturers Association's Community Awareness and
Emergency Response (CAER) achievement award for its coordination of
emergency planning between government and industry in Harford County.
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LEPC ACTIVITIES
Planning. In order to prepare the comprehensive local response plan,
the LEPC in 1988 sent a letter to all facilities which had reported under
section 302. The letter requested that a facility response plan, including a
map of the site and the surrounding area, be developed, and provided
guidelines for the completion of the plan. In 1989, DEO began to conduct
facility visits to review facility response plans; prior to the visit, each facility
was issued the inspection checklist that would be used to evaluate the
facility's plan. At the present time, facility site visits by a member of the
sheriffs office are being conducted to serve as the basis for a hazards
analysis to be developed in conjunction with the facility and the local fire
department.
As part of its Title HI plan, the LEPC developed Annex N:
Commander's Guide and Check List for Hazmat Incidents, a 24-panel wall
chart that summarizes the responsibilities of the lead officials involved in a
hazardous materials response. Annex N indicates the individual mission and
key activities for each phase (before arrival, on arrival, operational, and close
out) of the response for the Incident Commander; Hot, Warm, and Cold Zone
Commanders; Police Commander; and Public Information Officer.
The two key chemical emergency planning concerns currently facing
the Harford LEPC are the Aberdeen Proving Grounds (APG) and local
schools. APG is participating in the Army's Chemical Stockpile Disposal
Program (CSDP), under which the Army has been tasked with destroying its
unitary chemical weapons, all of which contain extremely hazardous
substances. If an incident were to occur at the facility, it could pose a serious
threat to the public health and the environment. Although APG is a federal
facility and thus is not obligated to comply with Title III, it is closely
involved with LEPC activities. Personnel from the installation serve on many
of the LEPC's subcommittees, and APG notifies the community in the event
of any incidents at the facility. In coordination with the LEPC, APG has
developed a chemical emergency contingency plan. The LEPC and APG
also conduct joint response exercises and training in the treatment of persons
exposed to chemical agents.
Site-specific planning for hazardous materials incidents involving
schools, either for releases originating from schools or from nearby facilities
potentially affecting schools, became an important issue in 1990. An incident
at a local school in which improper storage procedures resulted in the mixing
of muriatic acid and chlorine stored for the swimming pool served as an
impetus for this program. A cloud of chlorine was produced, and school
officials simply ventilated the area without an evacuation or notification of
authorities. A debriefing at the LEPC meeting led to procedural changes and
served as a spur to the school planning initiative.
The LEPC developed a sample plan outline and provided this
guidance as part of a briefing delivered to all public and private elementary
and high school principals to assist in the preparation of school contingency
plans. The guidance addresses emergency notification of schools and the
public and describes the overall communication policy. A school newsletter
bulletin for parents, a school notification memo, a sample announcement for
the radio Emergency Broadcast System, and a straightforward plan
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assessment checklist were included. Individual schools develop plans to
address their particular situation; some schools are just yards away from
chemical facilities or railroad yards, while others are quite distant from any
outside risk. These plans will be reviewed by local response officials, and
comments and suggestions will be provided to the schools.
Exercises. Harford County participates in regular exercises in
conjunction with the Aberdeen Proving Grounds facility. In the summer of
1990, APG and Harford County conducted a hazardous materials field
exercise. The 1988 Combined Response Force Exercise (CRFX 88) was a
field exercise simulating a release of mustard agent from unearthed
munitions at APG. The 1988 Command Post Exercise (CPX 88) was a table-
top exercise simulating a release of phosgene from a derailed railroad tank
car. Both of these exercises used hypothetical toxic plumes modelled using
the Computer-Aided Management of Emergency Operations (CAMEO)
system developed by the National Oceanic and Atmospheric Administration
and EPA. CAMEO also provided Response Information Data Sheets
(RIDS), chemical-specific guidance similar to MSDSs oriented for response
purposes.
Outreach. The LEPC, in conjunction with a local cable TV
company, has developed a video, "Hazardous Materials in Harford County,"
which discusses public safety issues. The video was advertised in the local
media and in bulletins which were mailed to community associations. It has
been shown on the local cable television station, presented to community
groups with a speech by an LEPC member, and is available at all public
libraries. The video is designed to familiarize people with the hazards around
them, and suggests that families conduct "chemical" drills in their homes in
similar fashion to fire drills.
The LEPC has also developed a brochure "Stay Cool, Stay Alive,"
which explains what people should do in the event of a possible hazardous
chemical incident if they are at home or on the road. The brochure has been
distributed through the school system and to community groups. "Play It
Safe: Handle Hazardous Materials with Care," a 20-page hazardous materials
safety manual, has also been distributed to community groups at LEPC
presentations. The LEPC has also distributed copies of the Department of
Transportation's Emergency Response Guidebook to all fire, police, and
public works department employees to improve response time and provide
initial safety assistance to residents.
Training. The Department of Emergency Operations maintains a 14-
member hazmat team composed of regular DEO employees and employees
of local industry. The team has converted two school buses into response
vehicles; one serves as a spill unit and the other as a command post and
storage for Level A and B response equipment. The team conducts weekly
training in Level A response operations and all members have been trained to
Hazmat Technician level per Occupational Safety and Health Administration
standards under 29 CFR 1910.120. DEO is now providing training and
equipment to all twelve local fire departments, including training on spill
containment and decontamination procedures. The hazmat team conducts an
annual emergency exercise of either table-top or field varieties. DEO also
invites outside organizations to conduct seminars in specific areas of
expertise; the Centers for Disease Control has provided training on the
chemical agents present at APG.
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Funding. Harford County provides funding for a hazardous materials
team and staff for the LEPC operations. EEMA, through the Army's
Chemical Stockpile Emergency Preparedness Program (CSEPP) designed to
support chemical emergency preparedness activities at the eight CSDP sites,
also provides one emergency planner who participates in LEPC meetings and
activities. In August of 1988, the LEPC organized a presentation to the
Maryland Association of Counties' Annual Convention, aimed at building
support for legislation that would help local jurisdictions recoup the cost of
implementing Title HI. This caucus formally resolved that the Governor and
General Assembly establish a fee system or redirect general revenues to
support the costs of data management and training at the local level.
LESSONS LEARNED
Hazardous Materials Transportation Issues Cannot be Ignored.
Initially, the Harford County hazardous materials preparedness activities had
focused on incidents occurring at fixed facilities, such as chemical companies
and water treatment facilities. The experience of the last several years,
however, has shown that the 1-95 corridor presents a much more significant
risk in terms of hazardous materials events. Transportation incidents
introduce a greater amount of uncertainty into a response operation; there is
no facility representative or site plan, or even a file of MSDSs to identify the
problem immediately. As a result, the hazmat team has had to focus on
developing a library of research materials to identify the substances involved
and proper response techniques for transportation incidents.
LEPC Meetings Can Serve an Expanded Role. The Harford
County LEPC holds a debriefing session at the monthly LEPC meeting in
which recent hazardous materials incidents in the county are discussed.
Representatives from involved facilities are invited to attend and meet with
members of the response community to discuss potential problems, as well as
how the facility and community conducted the response and suggestions for
improvements are considered. The recommendations are primarily incident-
specific; for example, one facility has since paved its grounds and installed a
berm and holding pond. These sessions have also helped to increase
awareness of hazardous materials issues at facilities and provide chemical-
specific information to local responders. Experience with handling less
common chemicals such as methyl ethyl ketone and toluene diisocyanate has
been provided to local responders by facility representatives at these sessions.
Contact: Barbara Risacher, Chair
Harford County Council
20 West Courtiand Street
Bel Air, MD 21014
(301) 879-2000
Jim Terrell, Chief
Department of Emergency Operations
Hazardous Materials Team
2220 Ady Road
Forest Hill, MD 21050
(301) 838-5800
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Use of Section 313 Data
Planning
Hazards Analysis
Exercises
Outreach
Funding
DALLAS COUNTY, TEXAS
LEPC: 33 members, including facility representatives, a state
representative, city councilman, hazmat team director,
and representatives from the Sierra Club; League of
Women Voters; local police, emergency management,
transportation, environmental, and fire agencies;
Dallas-Fort Worth Hospital Council; local television
and radio news stations; Chamber of Commerce; and
the North Central Texas Council of Governments.
Population: 1,800,000
Facilities: 150 facilities reported under section 302, including
chemical distributors and users, such as computer chip
manufacturers, food processors, water treatment
facilities, and engraving and plating operations; 1,500
facilities have reported under sections 311-312.
Dallas County is a primarily urban county located in north central
Texas and encompasses 27 jurisdictions, including the city of Dallas and the
Dallas/Fort Worth airport. The county includes five major railroads,
numerous interstate highways, and major pipeline systems which carry a
variety of hazardous materials.
The Fire Marshall's Office serves as the information coordinator for
the LEPC. The Dallas County LEPC has formed five subcommittees to
address the requirements of Title HI: the Hazardous Material Facility Liaison
Committee, the Emergency Response and Resources Committee, the Public
Education and Information Committee, the Transportation Committee, and
the Right-to-Know Committee. Each LEPC member serves on the
subcommittee of their choice, many choosing the committee that best utilizes
their expertise; for example, a media representative serves on the Public
Education and Information Committee. The LEPC meets monthly and the
Chair, Vice-Chair, and Secretary each serve a two-year term.
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LEPC ACTIVITIES
Use of Section 313 Data. The Dallas County LEPC was the recipient
of a fee waiver for the use of the Toxic Release Inventory (TRI) database.
The TRI database contains the data submitted under Title III section 313 on
chemical releases from manufacturing facilities. The fee waiver program,
implemented through EPA's Office of Toxic Substances, provides LEPCs a
waiver from the costs associated with accessing the TRI database for
conducting research and data searches. The LEPC used the TRI data to
examine the chemicals being emitted in their county and to compare those
emissions to emissions in other counties in Texas. The LEPC has also used
the TRI database to answer questions from the community regarding
facilities in their areas. To alert the public that the LEPC has access to the
TRI data, the LEPC broadcast radio announcements.
The Dallas County LEPC hopes to participate in any future fee
waiver programs, and is already planning projects for using the data. With
the LEPC's increased efforts in public education, interest in the TRI data has
already increased. The LEPC is developing presentations about the TRI data
to supplement the notices and radio announcements to guarantee increased
community participation. In addition, the LEPC is looking forward to using
the new TRI data to continue their study of the chemicals and emissions in
their district as they compare to other districts.
Planning. There are three emergency planning programs in effect in
Texas: the Federal Emergency Management Agency (FEMA) requirements
for an all-hazards plan, the state's Texas Disaster Act of 1975 requirements,
and the Title HI emergency planning requirements. The FEMA planning
requirements include planning elements for events such as tornadoes, floods,
earthquakes, and other natural and man-made hazards. The Texas Disaster
Act of 1975 places the responsibility for emergency planning on the mayor of
the city or the county judge, in an unincorporated area. Title m places the
responsibility for emergency planning on the LEPC and sets forth required
elements for these plans.
The Texas SERC designated local emergency planning districts along
county lines. The Dallas County LEPC has conducted its emergency
planning efforts under Tide m within the existing planning structure
established under the Texas Disaster Act to prevent the development of
duplicative planning bodies and plans. As a result, much of the city and area
plans that were previously developed were incorporated into the Dallas
County LEPC emergency plan.
The Dallas County LEPC encourages facilities that have reported
under section 302 to develop and submit emergency plans to the LEPC on a
voluntary basis, and to use the LEPC as a source of guidance and assistance
for emergency planning. These facility plans, once developed, are kept by the
LEPC and a copy is given to the fire department with jurisdiction over the
facility.
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The LEPC is coordinating its emergency response plan with
neighboring LEPCs to insure that inter-jurisdictional issues are addressed.
Each city is asked to coordinate their emergency response plan with
neighboring cities to ensure that conflicts and duplication of efforts in multi-
jurisdictional emergencies can be minimized. In order to test and coordinate
their emergency plan with neighboring counties and to assist cities in testing
and coordinating their plans with other cities, the LEPC is developing a
table-top exercise, which is discussed in the exercises section of this profile.
The "Dallas County Hazardous Substance Emergency Response
Plan" was completed and submitted to the SERC prior to the October 17,
1988, deadline. The plan is reviewed and revised annually. Dallas County
encompasses 27 different jurisdictions. Prior to the enactment of Title HI,
only three jurisdictions had state-approved FEMA plans, five had no plans
for chemical incidents, and the remainder had only outdated standard
operating procedures. The LEPC estimates that most, if not all, cities will
have emergency response plans that meet the Tide HI planning requirements
by early 1991. The efforts of the Dallas County LEPC, in combination with
the increased awareness of chemical hazards, has resulted in the steady and
significant improvement of chemical emergency preparedness within the
county.
Hazards Analysis. US EPA Region 6 and a consultant with
Southern Methodist University assisted the Dallas County LEPC in
developing fixed facility risk assessments. As part of this project, they
developed a computer program to calculate simultaneously the vulnerability
zones for a single chemical under varying atmospheric conditions.
In order to collect the facility-specific data necessary to conduct the
risk assessment, the Dallas County LEPC developed a questionnaire which
was sent to each facility that initially reported under section 302 as having
extremely hazardous substances (EHSs) present on-site. The questionnaire
requested more detailed chemical information than could be provided on a
Tier I or Tier II report. The information requested included product name,
EHS name, the chemical abstract service (CAS) registry number, molecular
weight, density, melting point, boiling point, flash point, specific gravity,
vapor pressure, type of storage container, maximum amount on hand and
average daily amount (as an amount rather than a range), temperature of the
stored chemical, form of the stored chemical, and the location of any diked
storage.
Of the 250 facilities sent questionnaires, 80 percent responded. Of
the 80 percent, 150 facilities had EHSs present above the threshold planning
quantity (TPQ) amount, and the remainder did not but had notified anyway.
The LEPC is developing the vulnerability zones for these facilities and each
facility will receive a copy of the analysis for data verification. Once
reviewed, the LEPC will both incorporate the analysis into their county-wide
emergency plan and work with the North Central Texas Council of
Governments to use the Geographic Information System, a computerized
mapping system, to plot the vulnerability zones to identify vulnerability zone
overlap and corridors of concern for future planning efforts.
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Exercises. Members of the LEPC have served as responders and
response officials in the capacity of their professions (e.g., fire fighters),
however, not in their capacity as LEPC members. In order to create a more
active role for the LEPC in incident response, the Dallas County LEPC is
developing a generic table-top exercise. The purpose of this exercise is to
test and evaluate multi-jurisdictional response and resource coordination. As
a result, the generic exercise can be customized to involve any two cities or
municipalities, any facility within the area, and any type of incident.
The first use of this exercise is scheduled for March 1991. The
exercise will involve the cities of Dallas and neighboring Mesquite. The
release will be a chlorine release from a truck accident on a major interstate,
which borders both cities. Dallas County LEPC is working to develop the
next table-top exercise, which will involve a release from a facility and
require coordination between two counties and the facility response
personnel.
Outreach. The Dallas County LEPC began their outreach efforts by
targeting industry likely to be subject to Title HI reporting to inform them of
the requirements. Initially, the LEPC conducted two seminars with the
Chamber of Commerce. As awareness of Title HI grew, the LEPC was
increasingly requested to make presentations and conduct training seminars.
The requests came mostly from industry and trade associations; however,
environmental and community groups also expressed interest. These
presentations and seminars have been held twice a month, every month, over
the last three years.
For the upcoming year, one of the major goals of the Dallas County
LEPC is to shift outreach away from industry to public education. The LEPC
is working on the development of a speakers roster to be distributed with a
one-page fact sheet describing the LEPC, its purpose, and its activities to
various community groups, such as the Rotary and Lions Clubs. Presentation
materials, including a general video and slide presentation, are being
developed. The LEPC is using its media representatives and other members
of the Public Education and Information Committee to develop both a thirty
second public service announcement to be broadcast on the local news radio
station and a video to be shown on cable television.
Funding. Dallas County government allocates approximately $6,000
per year to the LEPC. This money is primarily used for printing and postage
and public outreach. No fee structure exists in Dallas County because the
county does not have the authority to establish and collect reporting fees. In
addition, the Texas Department of Health has announced plans to make small
grants available to LEPCs for specific projects. The Dallas County LEPC
hopes to utilize this avenue of funding to support a transportation risk
assessment.
The majority of the administrative support for the LEPC is provided
by the Fire Marshall's Office. Two county employees are on the staff of the
LEPC one from the Fire Marshall's Office and one from the Dallas
County Institute of Forensic Sciences. These two county employees greatly
assist the LEPC by developing materials such as fliers and presentation
materials.
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LESSON LEARNED
Improved Cooperation, Improved Emergency Plans. Many city
and county planners became aware of the Title HI planning requirements
through seminars, publications, and word-of-mouth. As a result, many city
and county planners voluntarily upgraded their existing city plans or county
plans developed under either their own standards or those of the Texas
Disaster Act to conform to the Title El standards. In addition, jurisdictions
are more aware of the importance of multi-jurisdictional planning,
particularly for chemical releases. Tide HI, through the establishment of the
LEPC, has formed a nucleus for communication and planning among
jurisdictions within Dallas County.
Improved Outreach, Improved Awareness, Improved
Information. The Dallas County LEPC's extensive outreach efforts to
facilities hi the county regarding Title HI has greatly improved the quality
and quantity of specific facility chemical information. Subsequently, this
improved and enlarged amount of information is now more readily available
to emergency responders and to the general public. The 500 pound
threshold, established by the State of Texas for all OSHA hazardous
substances reinforces the growing awareness that even small amounts of
chemicals can be hazardous when handled improperly. Title III has
improved the chemical awareness among not only facilities, but also
emergency planners, emergency responders, and the general public.
Contact: Dr. Elizabeth Todd, PhD, Chair
Dallas County Local Emergency Planning Committee
Dallas County Institute of Forensic Sciences
5230 Medical Center Drive
Dallas, TX 75235
(214) 920-5990
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More Successful Practices
Additional Successful Practices in Title HI Implementation technical assistance bulletins
are available from your Regional Chemical Emergency Preparedness and Prevention Coordinator
(see the listing on the following page), or call the Emergency Planning and Community Right-to-
Know Information Hotline at (800) 535-0202. The following bulletins are currently available:
Successful Practices #1
Doc. # OSWER-89-006.1, January 1989.
State of Kansas
Washtenaw County, Michigan
Butler County, Kansas
Jefferson County, Kentucky
Successful Practices #2
Doc. # OSWER-89-006.2, August 1989
Calhoun County, Alabama
Pampa, Texas
State of Wisconsin
Cuyahoga County, Ohio
Racine County, Wisconsin
State of Idaho
Successful Practices #3
Doc. # OSWER-89-006.3, December 1989.
Woodbury County, Iowa
State of Virginia
Fairfax County, Virginia
Pierce County, Washington
Successful Practices #5
Doc. # OSWER-90-006.2, June 1990.
Tinker Air Force Base, Oklahoma
State of Connecticut
Cumberland County, Maine
Wyandotte County, Kansas
Successful Practices #6
Doc. # OSWER-90-006.3, September 1990.
State of Ohio
Hamilton County, Ohio
Wallingford, Connecticut
Ouachita Parish, Louisiana
Successful Practices #7
Doc. # OSWER-91-006.1, February 1991.
Cameron County, Texas
Bucks County, Pennsylvania
Harford County, Maryland
Dallas County, Texas
Successful Practices #4
Doc. # OSWER-90-006.1, March 1990.
New York, New York
El Paso County, Colorado
Alexandria, Virginia
State of Maine
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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-Region2
Woodbridge Avenue
Edison, NJ 08837
(908) 321-6620
Karen Wolper
EPA-Region 3
841 Chestnut Street
Philadelphia, PA 19107
(215)597-8751
Henry Hudson
EPA-Region 4
345 Courtland Street, NE
Atlanta, GA 30365
(404)347-1033
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)744-2100
Walt Jaspers
EPA - Region 10
1200 6th Avenue
Seattle, WA 98101
(206)553-4349
States by Region
4 - Alabama
10 - Alaska
9 - Arizona
6 - Arkansas
9 - California
8 - Colorado
1 - Connecticut
3 - Delaware
3 - D.C.
4 - Florida
4 - Georgia
9 - Hawaii
10 -Idaho
5 - Illinois
5 - Indiana
7 - Iowa
7 -Kansas
4 - Kentucky
6 - Louisiana
^^^^^^M^H^^^^^^^^^^^^^^^^^MH
IT U. S. Government Printing Office: 1991
1 -Maine
3 - Maryland
1 - Massachusetts
5 - Michigan
5 - Minnesota
4 - Mississippi
7 - Missouri
8 - Montana
7 - Nebraska
9 - Nevada
1 - New Hampshire
2 - New Jersey
6 - New Mexico
2 -New York
4 - North Carolina
4 - North Dakota
5 -Ohio
6 - Oklahoma
IWMwMMMiH^^^^^^^^^^^^^^B^^Wttld
- 281-724 (43562)
10 - Oregon
3 - Pennsylvania . 1
1- Rhode Island
4 - South Carolina
8 -South Dakota
4 - Tennessee I
6 - Texas
8 - Utah
1 - Vermont 1
3 - Virginia
10 - Washington
3 - West Virginia
5 - Wisconsin
8 - Wyoming
9 - American Samoa I
9 - Guam
2 - Puerto Rico
2 - Virgin Islands
*~ J
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