4>EPA
United States
Environmental Protection
Agency
Office of Solid Waste
and Emergency Response
(OS-120)
October 1991
OSWER-91-006.2
Series 6, No. 8
Successful Practices in
Title III Implementation
Chemical Emergency
Preparedness and Prevention
Technical Assistance Bulletin
Cherry Hill, New Jersey
Manitowoc County, Wisconsin
Greene County, Missouri
State of Hawaii
Arapahoe County, Colorado
Subject Index
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ABOUT THIS BULLETIN
This is another in a series of bulletins that EPA is issuing to provide examples of implementation
programs and strategies of the Emergency Planning and Community Right-to-Know Act of 1986,
known as Title HI, that are innovative or have proven effective. The purpose of these bulletins is to
share information on successful practices with Local Emergency Planning Committees (LEPCs),
State Emergency Response Commissions (SERCs), fire departments, and other Title m
implementing agencies throughput 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, ine
particular topics covered in each LEPC or SERC profile are listed in the box at the bottom of the
first page of the profile for easy reference, along with descriptions of the planning district or state
and LEPC or SERC membership.
The descriptions of the innovative and effective implementation programs and strategies are not
exhaustive. They are meant to provide readers with enough information to determine if a particular
approach is applicable to their own situation. Each profile includes a contact person who can
provide more detailed information.
For your convenience, a subject index covering the contents of the eight Successful Practices
bulletins has been included in this bulletin. The index is designed to allow the reader to identify^
successful Tide m implementation practices by topic area, and then locate the Successful Practices
bulletin in which the practice was profiled. Details on all eight bulletins, and how to order them, are
provided on the page preceding the index.
If you know of Title lH implementation efforts you feel would be of interest to others and that we
should identify in Successful Practices, please contact your EPA Regional Chemical Emergency
Preparedness and Prevention coordinator (see the list on page 22), or the Emergency Planning and
Community Right-to-Know Information Hotline at (800) 535-0202.
Printed on Recycled Paper
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Successful Practices
Cherry Hill, New Jersey
Paget
The Township of Cherry Hill is located in
Camden County, four miles east of
Philadelphia. While there are several
major industries and industrial parks
within the township, the Cherry Hill LEPC is
also concerned with hazardous materials
transportation throughout the township. Two
major interstate highways, the New Jersey
Turnpike and 1-295, run through the heart of the
township and several trucking terminals are
located within Cherry Hill.
Cherry Hill,
New Jersey
within the township. This group, the Cherry Hill
Emergency Management Council, was created
by the mandate of the New Jersey Civil Defense
Act of 1942 (Title 58, App. A:9 et al). The Act
required New Jersey municipalities to develop
emergency operations plans for natural and man-
made disasters. Following the passage of Title
in, Cherry Hill and many other municipalities in
New Jersey incorporated the roles and
responsibilities of the LEPC into the structure of
these established councils.
LEPC Organization
Prior to the passage of the Emergency
Planning and Community Right-to-Know
Act of 1986 (commonly known as Title
IE), Cherry Hill already had an emergency
planning group composed of representatives of
different public- and private-sector organizations
Planning
Using the existing emergency operations
plan developed under the direction of the
council, the LEPC updated the hazardous
materials annex as well as the overall plan to
conform with the comprehensive planning
process encouraged by the Hazardous Materials
Membership: 15 members, including elected officials and representatives of the Office of
Emergency Management, police and fire departments, public works, the American
Red Cross, New Jersey Department of Environmental Protection, emergency
medical services, the general public, and industry.
Population: 79,000
Facilities: 21, including a major pharmaceutical manufacturer
Topics: LEPC Organization
Planning
Information Managment
Training
Outreach
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Cherry Hill, New Jersey
Successful Practices
Emergency Planning Guide developed by the
National Response Team, as required under Title
HI. This document provides guidance on
identifying and assessing chemical hazards
throughout the community and developing an
emergency plan that is coordinated and
integrated with all organizations, from fire
departments to the American Red Cross, that
have a role in emergency situations.
To identify chemical hazards within the
township, the Cherry Hill LEPC reviewed
follow-up notification reports on hazardous
material accidents that have occurred within the
township, as well as the right-to-know inventory
forms (New Jersey's version of the Tier n form
required under section 312 of Tide DT) submitted
by reporting facilities. This information
highlighted the need to address transportation
corridors in the planning process. Because of the
size and complexity of the hazardous materials
transportation hazards, the Cherry Hill LEPC
recognized the need for immediate access to
chemical hazard information in a reliable and
integrated format.
Information Management
Initially, the information collected by the
Cherry Hill LEPC under Tide m, which
included the right-to-know inventory
forms, MSDSs, and facility emergency plans,
were alphabetized by facility name and placed in
a file cabinet in the Police Communications
Center. A copy of the facility's emergency plan
and right-to-know inventory form was also
provided to the appropriate fire district (there are
seven fire districts in Cherry Hill) by each
facility. These materials were stored in a file
drawer on the fire chiefs response vehicle.
While tire information is available for planning
activities, access to hazard and inventory
information critical to response operations was
limited at best
The Cherry Hill LEPC decided that a
computerized information management system
was needed to support their emergency
operations. The system would link all response
entities (e.g., fire department, the hazardous
materials response unit, and emergency
management) to an integrated, centralized
database. However, the response community
lacked sufficient computer hardware or software
for such a system, the LEPC had no funds
available, and the township had a cap on
expenditures that limited their ability to fund
such a major endeavor.
Because of the commitment of its members, the
LEPC did not give up in the face of such
significant obstacles. Instead, they identified a
way to access funds necessary to develop their
system. While each municipality in New Jersey
operates with a cap on expenditures, the state
provides a reserve of funds for major capital
improvements such as resurfacing roads or
upgrading the computer system for the police
department. Recognizing this as an avenue for
obtaining the necessary funding, the LEPC made
a presentation to a committee of the Township
Capital Improvement Committee that manages
the reserve for Cherry Hill. Following the
presentation, which stressed the need for
immediate access to emergency information, the
committee, composed of the township's business
manager, and the directors of several of the
township's departments, approved a capital
improvement grant of $11,000 in May 1991.
The Cherry Hill LEPC has decided to use the
CAMEO-DOS software to help them manage
their Title IH information. CAMEO (Computer-
Aided Management of Emergency Operations) is
designed to manage chemical- and facility-
specific information about hazards in or near a
community and to help emergency response
personnel plan for the safe handling of chemical
accidents. Developed by the U.S. Environmental
Protection Agency (EPA) and the National
Oceanic and Atmospheric Administration
(NOAA), CAMEO is available at cost to state
and local governments through the National
Safety Council. Because of its low cost, the
LEPC was able to purchase the software prior to
obtaining the grant money. Currently, CAMEO
is run on the personal IBM-compatible computer
of the deputy coordinator for the LEPC.
However, the LEPC is reviewing bids for
purchasing computers for the Office of
Emergency Management and the mobile
command response unit.
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Successful Practices
Cherry Hill, New Jersey
Page 3
Training
The Cherry Hill LEPC is currently
developing a training program for all
potential CAMEO users in the township.
The training program will explain how to use
CAMEO to develop emergency plans; retrieve
facility Title in reports, emergency plans, and
information on response resources; and use
CAMEO's mapping capabilities to search and
display transportation routes, facilities, and
sensitive populations and create overlays specific
to their planning or response needs. A full-time
firefighter with extensive computer experience
has been tapped to provide CAMEO training to
all personnel in the fire districts as well as other
response personnel in the township. The training
course is being developed using materials the
LEPC's deputy coordinator obtained at the
national CAMEO conference held in
Washington, DC, in January 1991.
The Cherry Hill fire and police departments have
also sponsored several Title Hi-related training
programs, including hazard awareness training
for all first responders and incident command
courses for all police and fire supervisors. These
training courses have helped to develop closer
relationships among all emergency services
within the community.
In addition, the Emergency Management Office
recommended that municipal department
directors select certain employees to attend a
series of train-the-trainer courses on hazardous
materials awareness and employee right-to-
know; this training was completed in the first
half of 1991. These new trainers, hi turn, will
ensure that all municipal employees receive
hazardous materials awareness and employee
right-to-know training on a regular basis.
Outreach
Working to increase awareness of chemical
hazards and the Title HI requirements is
an ongoing process for the Cherry Hill
LEPC. A video, Hazardous Materials: An
Introduction for Public Officials, was provided
to all municipal department directors. The
video, which describes the requirements and
responsibilities of local government in
Faster Communication -- Packet Radio
The LEPC also has used some funds to purchase radio
modems needed to establish a "packet" radio system.
Packetradio allows acomputer to be connected to a high
frequency radio (e.g., police radio) via a radio modem
that relays data to a receiving computer that also has a
radio modem. The information is transmitted in small
"packets" of data (250 characters per packet) to a
receiving computer, which must return a message that
the information was received correctly before the next
packet is sent. Because there is down-time between
each packet, one frequency can be used by five or six
computer stations at one time. This is important in
emergency situations when there is a high demand on
communication systems and limited frequencies are
available.
The LEPC believes this communications system is an
invaluable tool in response actions, especially at remote
sites (e.g., transportation-related incidents). Packetradio
allows the emergency operations center to transmit
Title HI information or other emergency information
contained in the CAMEO system to response sites
where conventional communication systems are non-
existent, malfunctioning, or destroyed. In addition, the
costs of establishing such a system are very small when
compared with other, more elaborate communication
systems. Packetradio reliesmostly on existinghardware
police and fire radios, cellular telephone, personal
computers, and existing short wave radios, run by a
network of 29 HAM radio operators in the township
more than willing to volunteer in any emergency
situation.
implementing Title III, was also shown to the
LEPC and to facility representatives. The Office
of Emergency Management also makes available
the Federal Emergency Management Agency's
(FEMA) home study course, Hazardous
Materials: A Citizen's Orientation. The LEPC
has found that such presentations and courses
provide a good catalyst to get more people aware
of chemical hazards in the community and,
hopefully, more involved in reducing those
hazards.
One result of the LEPC's drive to increase public
awareness of chemical hazards has been with the
township's seven nursing homes. The LEPC has
been helping the nursing homes develop
emergency plans required under state law. As a
result of the LEPC's cooperation, the nursing
homes became more aware of chemical hazards
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Cherry Hill, New Jersey
Successful Practices
in their immediate vicinity and the potential
impact to their establishments. One outcome of
this cooperation with the nursing homes is that
the nursing homes are working on developing
mutual aid agreements. The agreements will
established emergency procedures so that if one
nursing home has to be evacuated, procedures
will be available to distribute the evacuees
among the other homes in a timely and safe
manner.
LESSONS LEARNED
'It's All in the Presentation," says Craig
Martin, deputy coordinator for the Cherry Hill
LEPC, referring to the presentation that got the
LEPC a $11,000 capital improvement grant to
purchase a computerized planning and
information management system. With the
LEPC stressing the usefulness of the Title HI
information for responding to hazardous
materials accidents and the cost effectiveness of
the EPA and NOAA-developed CAMEO
software, the committee could not say no to the
LEPC.
"The pitch was easy," Craig Martin emphasizes,
"community right-to-know identifies the
potential dangers and, through the software, we
can find out how close these dangers are to
sensitive populations, like nursing homes or day-
care centers."
The Commitment Is There, It's the Time
That's Needed. The Cherry Hill LEPC has no
full-time staff. While the LEPC is composed of
people dedicated to fulfilling the Title m
mission, they do have full-time jobs and
families, and finding the time to accomplish the
goals they have set for themselves is difficult.
Many training courses have to be offered on
weekends, and meetings are held at night. To
help lighten the load of the volunteers, the LEPC
is working on having the full-time personnel
from the fire department take on the role of
managing the CAMEO system.
In addition, the LEPC is also considering
accessing persons who have been ordered to
perform community services as the result of
driving while intoxicated or other such
violations. These persons, depending on their
skills or expertise, can help enter data into the
CAMEO system or help write or review
emergency plans.
LEPCs also should look anywhere or anyway to
find help. Craig Martin is a good example he
is a police officer and an adjunct instructor for
FEMA's Emergency Management Institute. His
"part-time" role as deputy coordinator for the
LEPC and the Emergency Management Office is
funded by FEMA's emergency management
assistance grant program.
Contact:
Craig Martin, Deputy Coordinator
Cherry Hill Office of Emergency Management
820 Mercer Street
P.O. Box 5002
Cherry Hill, NJ 08034
(609) 488-7822, extension 7690
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Successful Practices
Manitowoc County, Wisconsin
Pages
Manitowoc County,
Wisconsin
Manitowoc County, Wisconsin, located
near Lake Michigan approximately 90
miles north of Milwaukee and 45 miles
south of Green Bay, includes the cities of
Manitowoc and Two Rivers. Several railroads
and Interstate 43 (1-43) pass through Manitowoc
County. Most industry and population in the
county are concentrated in the cities of
Manitowoc and Two Rivers. The Manitowoc
County Local Emergency Planning Committee
(LEPC) has established five separate
subcommittees to address the following issues:
education, funding, planning, exercises, and
LEPC membership.
Outreach
Upon establishing the education
subcommittee, the LEPC recognized that
facilities throughout Manitowoc County
must understand the Title in requirements and
their reporting responsibilities. Members of the
education subcommittee invited local industry
representatives, the county Tavern League,
agricultural cooperative (co-op) representatives,
and a representative from a local advertising
agency to attend their meetings.
At an initial, priority-setting meeting in October
1989, the subcommittee decided that the
agricultural community should be the first
audience for focused outreach activities, as most
local farmers were unfamiliar with Title HI
reporting requirements. The Manitowoc County
LEPC sent a letter to all area farmers introducing
Title HI and providing contacts and telephone
numbers for more information. A list of
commonly-used agricultural chemicals covered
under Title ffi was included with the letter.
The LEPC also worked with the local
Agricultural Stabilization and Conservation
Service (ASCS) office to send this same letter in
Membership: 25 members and 12 alternates, including representatives from county emergency
government, hazmat response team, county board of supervisors, fire service, law
enforcement, hospitals, the Amercian Red Cross, industry, transportation, citizens,
news media, the Towns Association, and local health and public works departments,
Population: 82,477
Facilities: 216, including several food processing and storage companies
Topics: Outreach
Exercises
Training
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Manitowoc County, Wisconsin Successful Practices
conjunction with ASCS's mailing to area
fanners in January 1990. The ASCS is an
agency within the Department of Agriculture
with approximately 2,800 county offices
nationwide that administers federal agricultural
programs to local farmers. Coordinating with the
ASCS allowed the Manitowoc County LEPC to
reach a large audience at little expense. The
letter designated area co-op agents as contact
persons because local farmers are familiar with
these agents. About 1,450 farmers from the total
mailing of 1,500 called for more information.
As a result of the agricultural outreach
campaign, the number of farmers that submitted
Tier H forms under section 312 of Title m
increased from one to twenty-seven.
Subsequently, the education subcommittee has
aimed its outreach campaign at both local
industry and the general public. As part of the
industry outreach campaign, the subcommittee
consulted with representatives from the local
industrial council, various members of the press
and radio, and a local advertising agency. All
parties agreed that the campaign should be short,
simple, and to the point and that the goal of the
industry outreach campaign was to make
businesses aware of Tide HI in a visual and
compelling way.
The LEPC asked representatives from local
newspapers and radio stations to attend an
education subcommittee meeting to plan the
outreach campaign. Pictures with brief Tide IE-
related articles appeared in various local
newspapers. An advertising agency donated a
billboard as a public service, providing a highly
visible Title El message on the well-traveled
highway between Manitowoc and Two Rivers.
The billboard warned of steep fines for industries
that fail to report the presence of hazardous
materials on their premises using the message,
"By playing this lottery, you could lose
$25,000!" The board depicts a dollar bill in the
left hand corner with tiny pieces of it breaking
apart, and a phone number for more information.
The total cost to the county for the billboard was
about $70 for production and posting fees.
Ads echoing the billboard's warning appeared in
various local newspapers throughout Manitowoc
County during the first two weeks in October
1990. The costs for printing the ads varied
the Manitowoc County LEPC secured free space
in some papers, and received public service- or
small business-reduced rates in others. The ads
ran in at least one area paper on each day of the
two-week period. Since the industry outreach
campaign started, the number of facilities that
submitted Tier E forms under section 312 of
Title HI increased from 113 to 216.
The goal of the public outreach campaign, which
was developed concurrently with the industry
campaign, was to introduce Title El and its
community right-to-know message to a largely
unaware public. A separate advertisement was
developed and appeared every day for the last
two weeks in October 1990, in one of the area
papers and at least one day per week in all the
others. The theme of the advertisement was "It's
Your Right to Know," emphasizing the role of
the LEPC in planning and preparedness, and
providing a phone number for more information.
The Emergency Government Director, the LEPC
chair, and the chair of the education
subcommittee followed the press ads with
appearances on local radio talk shows.
The education subcommittee also has formed an
LEPC Speakers Bureau whose members are
available to speak before area groups on Title
El-related topics. A list of speakers is posted at
the public library, area colleges, the county
clerk's office, and other strategic Manitowoc
County locations. Speakers do not charge fees,
but groups may make a donation to support
LEPC activities.
As a result of its outreach efforts, the LEPC
received a "Certificate for Excellence in
Hazardous Materials Outreach Programs" from
the Region 5 Regional Response Team, a group
consisting of regional representatives from the
fourteen federal agencies with hazardous
materials response and planning expertise, as
well as the a representative from each state in the
Region. These certificates award LEPCs within
the Region that have exceptional outreach,
planning, exercise, training, or hazards analysis
programs.
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Successful Practices
Manitowoc County, Wisconsin
Page?
Exercises
The LEPC's public awareness campaign
was also supported by two field exercises
Manitowoc County has held in
cooperation with the local hazmat team. These
exercises (held on June 13,1989, and October 6,
1990) helped to increase awareness of Title ni
preparedness and response issues. Manitowoc
County officials have held various full-scale
exercises in the past with two nearby nuclear
plants, but only recently have city officials been
involved in an exercise in which they have to
interact with their county counterparts.
Training
Because the Manitowoc County LEPC is
made up of people with diverse
backgrounds, the LEPC decided to first
understand the emergency preparedness and
response duties or interests of each LEPC
member. As of May 1991, representatives from
the local hazmat team, the Red Cross, local law
enforcement, emergency management, and the
County Public Works Department, as well as an
emergency planner from the Kewaunee nuclear
power plant all have made presentations to the
Manitowoc County LEPC. These presentations
have included a demonstration of hazmat
emergency response equipment and tours of the
police department and its dispatch center, as well
as overviews of Red Cross emergency services,
the mobile command center and emergency
operations center, progress on a household
chemicals outreach campaign, and emergency
planning techniques at the local nuclear power
plants.
LESSONS LEARNED
Title in Outreach Is a Continuous Process.
The Manitowoc County LEPC believes that
outreach is an ongoing process even though they
have conducted several effective outreach
campaigns. The LEPC recognizes that there
may be many other facilities which are unaware
or uninterested in the requirements of Title HI.
In fact, the LEPC still receives a large number of
calls each month about reporting requirements,
Accident Tests LEPC Plan
Theemergencyresponseplansofthe Manitowoc County
LEPC were tested recently when a tanker truck leaked
ferric chloride solution along a stretch of roadway in
May 1991. The tanker truck had gotten lost because the
driver had no maps and the truck routes may not have
been clearly identified. To make matters worse, the
truck wasnotinspected after the initial clean-up, creating
new leaks to be addressed by responders. High
temperatures and extreme humidity hampered the
responding hazmat team, forcing team members to
work in short, 15-minute shifts.
The coordinated efforts of a range of organizations,
including fire, police, public works, Red Cross,
emergency government, news media, and the LEPC,
helped to alleviate a potentially dangerous situation.
Direct radio links with local radio stations allowed
emergency government personnel to make protective
action announcements to the public. Mobile phones and
fax machines, as well as other communications
equipment, were made available to response personnel.
With thecompletion of the responders' work some eight
hours after the release began, the efforts to coordinate
Manitowoc County emergency planning process had
proven extremely effective.
fee payments, and other regulations under Title
IE. Because turnover at facilities and, more
important, within the LEPC and emergency
response community is continuous, the LEPC
believes providing these groups with continuous
information on Title in and the LEPC's role in
planning for potential chemical emergencies is
essential.
An Emergency Response Plan Is a Living
Document. In responding to the recent ferric
chloride leak from a tanker truck in May 1991,
the Manitowoc County LEPC realized that
emergency planning is a dynamic, ongoing
process. As a result of that accident, the LEPC
recognized that hazardous materials
transportation routes should be clearly identified
throughout the county and that highway
patrolmen should be called earlier to carefully
inspect any vehicle involved in a hazardous
materials incident before letting the vehicle leave
the scene. These issues are to be addressed in
future LEPC meetings.
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Manitowoc County, Wisconsin Successful Practices
Climate can also be a significant factor in
response actions; to avoid exhaustion, hazmat
personnel had to receive tremendous amounts of
fluids while working in high temperatures.
Fatigue on the part of responders can contribute
to loss of concentration, especially during a long
response incident such as this recent one. To
resolve these issues in their emergency plan, the
Manitowoc County LEPC plans to establish
mutual aid agreements with hazmat teams from
neighboring communities to provide back-up
support in future incidents of long duration.
Contact:
Doug Day
Manitowoc County LEPC Chairman
c/o Wisconsin Public Service
P.O. Box 19002
Green Bay, WI54307-9002
(414) 433-5528
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Successful Practices
Greene County, Missouri
Page 9
Greene County,
Missouri
Greene County is located in southwestern
Missouri; the county seat, Springfield,
has a population of over 140,000.
Primary transportation routes in the
county include the Burlington Northern and
Missouri Pacific Railroads, Interstate 44, and
U.S. Highways 60,65,66,160, and 266.
Prior to the enactment of Title ffl, a voluntary
Chemical Emergency Task Force, composed of
representatives from both the public sector and
private industry, began developing an emergency
plan for the city of Springfield. The plan
developed by the task force was submitted to the
City Council in October 1987. The Springfield
plan was subsequently converted to a county-
wide plan in keeping with the designation of
Greene County as a local emergency planning
district under Title HI.
LEPC Organization
In the late spring of 1989, the LEPC
stopped meeting when the LEPC Chair,
the Director of the Springfield-Greene
County Emergency Management Office,
resigned. To avoid the potential for another
stoppage or slowdown in its activities, the LEPC
began to develop a more formal organizational
structure after its re-establishment in November
1989. In June 1991, the LEPC published a
document formalizing the structure and
procedures which have allowed it to maintain a
high level of activity over the last year and a
half, as described below.
Membership: 111 members, including representatives from the local health, public works, and
highway departments, fire services, Greene County Commission, local and state
police, hospitals, Amercian Red Cross, utitlities, emergency services, the Burlington
Northern Railroad, news media, University of Missouri, industry, Watershed
Committee, Household Hazardous Waste project, individual citizens, and citizen
groups. The chair is the director of the Springfield-Greene County Emergency
Managment Office.
Population: 200,000
Facilities: 245
Topics: LEPC Organization
Information Management
Hazards Analysis
Exercises
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Greene County, Missouri
Successful Practices
LEPC Active in Other Community Projects
The varied membership of the Greene County LEPC
includes representatives from local environmental
projects such as the Watershed Committee and the
Household Hazardous Waste Project The LEPC,
through various subcommittees, is working with the
Watershed Committee to address potential
con taminationof the watershed from transportation and
fixed facility incidents involving hazardous chemicals.
For instance, information on sinkholes located along
area highways will be entered into the CAMEO system
to identify the sinkholes as possible avenues for
watershed contamination in the event of a nearby spill.
The LEPC is also coordinating with the Watershed
Committee in developinglegislationtorequiresecondary
containment at fixed facilities where chemicals, if
released, could contaminate the watershed. For the
Household Hazardous Waste Project, the LEPC assists
in coordinating collection and publicity activities.
LEPC membership is open to any individual who
resides or works in Greene County. All
members are expected, to serve on at least one of
the following eight subcommittees:
Education and Media: develops outreach
materials explaining the purpose and
goals of the LEPC;
Data Collection: identifies facilities in
compliance and provides assistance to
facilities in meeting the requirements of
Title HI;
Data Management and Public Inquiry:
verifies and reconciles facility
submissions and responds to citizen
requests for right-to-know information;
Assessment: evaluates the hazards posed
by the storage, production, and use of
chemicals at specific locations;
Resources: identifies all available public
and private resources for emergency
response purposes;
Medical and Health: addresses
decontamination and emergency medical
services issues, including training;
Evacuation and Sheltering: identifies
shelters and develops evacuation and
in-place protection procedures; and
Exercise and Evaluation: organizes
exercises to test the emergency plan and
evaluates exercise results.
The LEPC also has an Executive Committee,
consisting of the heads of the eight
subcommittees and the three elected LEPC
officers (LEPC members elect a chairperson,
vice-chairperson, and secretary every February).
The Executive Committee's responsibilities
include the approving amendments to the
emergency plan; identifying gaps in the plan;
reviewing information requests from citizens;
and overseeing LEPC elections.
The full LEPC meets bi-monthly at the
American Red Cross Center, with the Executive
Committee meeting in the alternate months at the
county Emergency Operations Center, where all
LEPC records and information are maintained.
Subcommittees meet as often as necessary to
achieve their objectives. To better schedule and
track LEPC projects, minutes are published for
all meetings minutes for the Executive
Committee and full LEPC meetings are mailed
to all members; subcommittee minutes are
distributed to all subcommittee chairs and LEPC
elected officers.
Information Management
In conjunction with the Missouri
Department of Natural Resources (DNR),
the LEPC developed a conversion
program that allows them to download all the
Tide HI submissions from Greene County
facilities from the DNR mainframe. This
process avoids a redundant data entry and helps
the LEPC's Data Management Subcommittee to
identify companies that are reporting to the
SERC and not to the LEPC or the local fire
department, or that are reporting under some, but
not all, of the required sections of Title in. In
the fall of 1990, the LEPC sent out a letter to
over 100 facilities requesting the submission of
information to the LEPC or the SERC to
complete this reconciliation process. Almost
every one of these facilities have since come into
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Successful Practices
Greene County, Missouri
Page 11
compliance, and the publicity surrounding the,
effort alerted several additional facilities that had
previously not provided any information under
Title HI to its reporting requirements.
Continuing to optimize its data management
system, in February 1991, the LEPC installed the
IBM-compatible CAMEO-DOS system to
manage their Title m information and planning
efforts: CAMEO is the Computer-Aided
Management of Emergency Operations system
developed by EPA and the National
Oceanographic and Atmospheric Administration.
Both the LEPC and the Springfield Fire
Department are uploading information and the
LEPC hopes to use CAMEO as a resource
database and as a means of more accurately
identifying vulnerable populations once this
process is completed.
Hazards Analysis
To begin the process of identifying these
vulnerable populations, the assessment
subcommittee has examined over 50
facilities using a simple format developed by the
LEPC to assess risk. The initial assessment
collects information on the types, amounts, and
locations of hazardous chemicals on-site, and
potential exposure pathways and vulnerable
populations. In the next step, the fire department
will review and validate these assessments based
on the information collected during their annual
fire inspections. The finalized assessments will
be provided to the facility to serve as a means of
initiating a dialogue with the LEPC on
mitigating the potential for a dangerous chemical
release. Because the preliminary analysis by the
assessment subcommittee indicates that chlorine
is one of the primary hazards in the county, the
next LEPC simulation exercise will address a
chlorine incident.
Exercises
Meanwhile, the LEPC has participated in
an evacuation and sheltering exercise in
April 1990 with the American Red Cross,
the Southwest Missouri State University, the
Emergency Management Office, the Springfield
Fire Department, amateur radio operators, and
other agencies. The exercise simulated
coordinating of the evacuation and sheltering
process. The participants university students
and other members of the general public
remained overnight at a local Red Cross shelter.
During the course of the evening, workshops
were held on emergency preparedness issues for
both the public and first responders. An exercise
critique held the next morning' identified the
need to develop clear procedures for the
decontamination of potential exposure victims
two of the simulated victims had been
transported to the local hospital without
decontamination of their bodies and clothing.
The LEPC held a joint field exercise in April
1991, with the SYNTEX Agribusiness, Inc.,
facility involving the facility hazmat team and
the newly organized Springfield Fire Department
Hazmat Team. The week before, a table-top
simulation was held to familiarize the
participants with the scenario. The incident
involved a leak of phosphorus trichloride
reacting with water to create phosphoric and
chloride acids as liquids and vapors.
The exercise was designed to test both
established emergency response procedures and
the coordination among the various responding
agencies. Two critical issues were identified:
Limited equipment and insufficient
procedures for decontaminating exposure
victims by emergency medical personnel;
and
A lack of experience and understanding
in making evacuation and in-place
protection decisions.
These problems are being addressed by the
appropriate subcommittees of the LEPC. In
addition, the two hazmat teams have established
a cross-training relationship to resolve any
procedural differences; the LEPC has also sent
out letters to other private facility hazmat teams
in hopes of developing similar arrangements.
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Page 12
MBI
LESSONS LEARNED
Greene County, Missouri
Successful Practices
Lead Agency Can Provide Partial Funding
for LEPC Activities. The Springfield-Greene
County Emergency Management Office (EMO)
recognized that the Title in mandate was
consistent with its responsibilities under
Missouri law to prepare the community for
emergencies. Thanks to the support of the
Greene County Commission, EMO has become
the lead agency for the LEPC, with its director
serving as the LEPC chair. Funding for LEPC
mailings and other support is supplemented
through the annual EMO operations budget.
The EMO director suggests that other planning
districts experiencing difficulty in funding their
activities should consider coordinating their
activities more closely with a local agency(ies).
Many of the tasks associated with implementing
Title HI are already performed, and funded, by
local fire, police, health, and civil defense
agencies.
LEPCs Require Structure and Definition to
Function. To effectively implement the Title HI
mandate, each LEPC must organize and establish
specific operating procedures. LEPCs should
design a workable system as soon as possible to
serve as a functional basis for operations, and
then let experience guide further developing the
LEPC's structure and guidelines. During its first
years, the Greene County LEPC relied on the
leadership of the EMO Director, and when he
resigned, a period of inactivity followed.
Recognizing this structural flaw, during the
November 1989 reorganization, one of the key
steps taken by the members of the LEPC was to
develop written procedures to prevent a
recurrence of this type of situation.
Expanded LEPC Mission Increases
Awareness. The Greene County LEPC realizes
that by becoming involved in other community
projects relating to chemical usage and
environmental protection, it will be better able to
fulfill its Tide m mandate. The LEPC's work
with the Watershed Committee, the Household
Hazardous Waste Project, and local
environmental groups has increased Title III
awareness among the public and industry. In
recognition of its achievements, the LEPC
received the Missouri Department of Natural
Resources' 1990 Resource Steward Award. This
award commends the LEPC for its outstanding
efforts to promote safe chemical management in
an effort to protect the citizens and natural
resources of Greene County. The LEPC is now
working with the Springfield Area Chamber of
Commerce to gain funding for an informational
brochure to be distributed to area businesses.
Compliance Efforts Should Rely First on
Outreach, Not Enforcement. The Greene
County LEPC has had notable success with a
compliance policy which stresses assistance to
local facilities in being aware of and complying
with the requirements of Title El. LEPC
members believe that industry wants to be in
compliance, and that by adopting an initial,
enforcement-oriented approach, the LEPC will
place facilities on the defensive and make them
less cooperative with the LEPC.
Contact:
Mr. Joye G. McElwee, Chair
Greene County LEPC
Springfield-Greene County Emergency
Management Office
833 BoonviUe
Springfield, MO 65802
(417) 869-6040
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Successful Practices
State of Hawaii
Page 13
State of Hawaii
To improve Hawaii's chemical emergency
planning and response capability and to
streamline the collection of Title IH data,
the state has been a pioneer in the use of
CAMEO (Computer-Aided Management of
Emergency Operations) software developed by
EPA and the National Oceanic and Atmospheric
Administration (NOAA) to help local districts
manage and use information about chemical
hazards in their communities. Hawaii's use of
CAMEO includes an innovative new effort to
take Title m awareness "to the streets" through a
public information pilot program under an EPA
grant. In addition to its use of CAMEO, the
Hawaii SERC has conducted emergency
response exercises and enhanced its hazardous
material training.
The lead agency responsible for implementing
Title m in Hawaii is the state Department of
Health. The department's Office of Hazard
Evaluation and Emergency Response (HEER)
serves as the technical advisor for chemical
incidents. HEER also dispatches response
personnel to the scene of a chemical incident and
has developed through a committee
established by the SERC an oil and hazardous
substance emergency response plan. Civil
defense agencies and fire departments manage
Title m programs at the LEPC level.
Information Management
Hawaii is one of the first states to have a
fully integrated Title HI data
management system using CAMEO
software and Macintosh computers. The
CAMEO system a powerful tool that presents
the user with a wide array of databases,
including information on chemicals, facilities,
transportation, and even street maps to assist
response personnel is offered to state and
local governments at cost through the National
Membership: 15 members, including representatives from the Departments of Health, Defense,
Labor and Industrial Relations, Business and Economic Development, and
Trasnportation; Boards of Agriculture and Land and Natural Resources; University
of Hawaii; American Red Cross; Office of Environmental Control; and the four
Hawaii LEPCs.
Organization: 4 LEPCs representing the four Hawaiian counties
Topics: Information Management
Outreach
LEPC Organization
Training
Exercises
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Page 14
State of Hawaii
Successful Practices
Follow-up Improves Compliance
The Hawaii SERC has found that getting facilities to fill
out Title M forms completely and accurately is a vital
first step in compiling a good database on chemicals in
thecommunity. In 1989, about 30 percent of the state's
facilities submitted correct and complete Title m
information for the CAMEO database. In contrast, the
Title HI submissions for 1990 have shown a great
improvement, with 85 percent submitting correct and
complete information.
This achievement is in large part attributable to the
thoroughfollow-upconductedfor the 1989 submissions.
Each of these reports was reviewed, and a letter was
written to eachfacilitythathadsubmitted an incomplete
report. A follow-up phone call was made to those
facilities that did not respond to the letter, and a final
follow-up letter was sent to each facility that did not
respond to the phone call. The HEER office then sent
a mailout reminder to all previous Title HI submitters in
February 1991 for the 1990 submission. The reminder
letterincludedsimpleexamplesofaproperlycompleted
Tier n form, a list of common TPQs and RQs, a list of
SERC and LEPC addresses, and an information hotline
number.
Safety Council. (A DOS version also is
available for users with IBM-compatible
machines.)
In Hawaii's Title HI community, data is easily
shared. Rather than having right-to-know
information scattered around in different
formats, all of the agencies with a stake in Title
HI have agreed to use CAMEO. To get the most
out of their CAMEO system, Hawaii has
emphasized training programs for LEPC and
SERC members who use the software, and has
worked with chemical facilities to help them
submit Title HI data in a more consistent form.
As part of this training, the SERC instituted
annual one-week CAMEO training courses, and
sent one representative from each LEPC to a
national CAMEO workshop. EPA's Region 9,
with the assistance of NOAA, also conducted
two CAMEO courses in Honolulu, which were
attended by representatives from all four LEPCs
and the state Department of Health.
To provide general Macintosh training and more
specialized instruction in the CAMEO program,
a Hawaii data management workshop also was
held. Attendees were given a procedural
manual, instructions on how to use it, and
guidance on Tide HI topics such as enforcement
and facility inspections. The workshop also
trained attendees in the use of FEMA's
Hazardous Materials Information Exchange
(HMK), a computer bulletin board that include
various categories of information on hazardous
materials planning and response.
During the workshop, the participants discussed
data flow within Hawaii's Title III community
and identified potential problems. As a result, a
task force was established to address such issues
as formatting Title HI information so that all
users enter data into the system in the same way.
A $50,000 Tide HI training grant from FEMA
and funding from the state Department of Health
cover training and travel expenses for the task
force.
In addition, the SERC has conducted workshops
in each county to help LEPC members and
facilities learn more about hazards analysis, and
to provide guidance in filling out Tier n forms
and the "Hawaii Facility Profile." This four-
page profile addresses the storage of hazardous
substances at each facility, as well as
transportation routes, nearby facilities that
contribute to potential risk, geographic features,
climate, critical time variables (e.g. rush hours),
and the facility's own response capability.
These data all feed into the CAMEO system and
can be used either for emergency planning and
completing a hazards analysis or by response
personnel at the time of an actual incident. This
information can also be used by each LEPC for
cross-referencing against existing files.
Outreach
To enhance the usefulness of its Title HI
information, the Hawaii SERC recently
received a $73,540 grant from EPA to
develop a computer-based public information
program. This will allow Hawaii's LEPCs to
disseminate Title HI data to the general public.
The project includes public demonstrations of
the Hawaii CAMEO system, installation at
permanent public sites, training programs, a
publicity campaign to inform the public about
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Successful Practices
State of Hawaii
Page 15
the program and Title pi in general, and a survey
to determine the effectiveness of this outreach.
Under the grant, Hawaii also will produce a draft
manual describing how the CAMEO system can
be used by other states.
The project is now in the preliminary design
phase. A contractor has been hired to develop a
system that would allow any user to locate the
chemical facility nearest them perhaps using
touch-screen computer displays and to learn
more about the chemicals at that facility.
LEPC Organization
Another central issue for the Hawaii SERC
has been incorporating Title HI
administrative responsibilities into the
emergency response structure that had been in
place prior to the passage of Tide in. A
memorandum of understanding facilitated the
transition from the pre-existing arrangement to a
new, dual structure, whereby the civil defense
agency handles natural disasters and the
Department of Health handles oil and hazardous
materials incidents. A 24-hour civil defense
emergency notification hotline supports
reporting of both types of events.
Each of the four Hawaiian counties Hawaii,
Maui, Oahu, and Kauai has formed its own
LEPC, but each has its own distinct character
based on the emergency planning structure that
had been in place before Title HI. In all four
counties, the director of the civil defense office
is the active chair of the LEPC. Fire departments
provide assistance to varying degrees. For
example, in Kauai, a small county with only fifty
facilities, the local fire department's eight-
member hazmat team handles initial response,
while civil defense officials are responsible for
emergency planning and data management But
hi Maui (a county composed of several islands),
the fire department assumes both roles.
Training
For several years, the Oceania Regional
Response Team the federal
coordinating body for chemical
emergency preparedness for Hawaii, Guam, and
the Pacific Islands has been supporting the
Honolulu Fire Department's efforts to develop a
Level A first-responder hazardous materials
response capability, the first such capability hi
Hawaii. The Coast Guard and other federal
agencies have helped in this effort by providing
training, equipment, and technical assistance.
The goal is to have all four counties equipped
with first-responder capability.
A $60,000 state grant and additional funds from
FEMA are supporting hazardous materials
training hi Hawaii. Using this funding, a
technical committee established by the SERC
has developed training guidelines that meet or
exceed the OSHA minimum standards. The
document discusses four categories of hazmat
training, ranging from short familiarization
sessions to intensive courses:
Hazardous Materials First Responder: An
8-hour "awareness" course for
emergency medical personnel, police,
and highway personnel who might be
confronted with a hazmat incident.
Hazardous Materials Incident Response:
A 40-hour course on personal protection
for first responders.
Hazardous Materials Supervisor: An 8-
hour class for supervisors of response
teams, taken in addition to the 40-hour
incident response course.
Hazardous Materials Specialist: A pah* of
FEMA courses for personnel entering a
"hot zone." Two weeks are spent on
hazardous materials chemistry and two
weeks on tactical considerations.
Response exercises have been designed for
personnel in all categories, and courses are
offered once or twice a year with state funding.
Exercises.
The Hawaii SERC, along with EPA,
FEMA, and the state and county civil
defense agencies, have co-sponsored a
series of exercises that have proven valuable in
highlighting potential emergency response
problems. A full-field exercise was conducted in
Honolulu, on the island of Oahu, and tabletop
exercises have been conducted in Maui, Hawaii,
and Kauai counties.
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Page 16
State of Hawaii
Successful Practices
The main lesson learned from these exercises to
date has been that response resources are
inadequate outside of Oahu. At present, the
Oahu emergency response team is the only one
with full Level A response capability (including
personal protective gear). When a chemical
accident occurs on another island, the Oahu team
can provide technical advice to initial responders
until the Oahu responders arrive with Level A
personal protection equipment. As a result of the
exercises, each county now recognizes the need
for an independent response capability to
manage serious incidents until the Oahu team
arrives, and Department of Health officials have
become convinced of the need for additional
personnel and equipment.
The exercises also identified communications
issues relating to response coordination among
agencies and between field and Emergency
Operations Center personnel. One proposed
solution is to equip all Department of Health
district offices with cellular phones to ensure that
there are no breaks in communication.
Cooperation Is the Key. In agreeing to set up a
common data management system, Hawaii's
LEPCs and SERC also have learned that
working together has helped to identify common
problems among the Title El community and
foster an atmosphere conducive to developing
solutions to these problems. For example,
emergency response exercises conducted on
islands (other than Oahu) have shown the need
for each island's independent response
capability, and the state, through the SERC, is
supporting the development of these capabilities.
Contact:
J. Mark Ingoglia, Manager
Office of Hazard Evaluation and
Emergency Response
Hawaii Department of Health
5 Waterfront Plaza, Suite 250
500 Ala Moana Boulevard
Honolulu, Hawaii 96813
(808) 543-8249
LESSONS LEARNED
Getting the Most From Title TTT Data.
Hawaii's pioneering use of CAMEO to create a
Title in information database, while still in the
early stages, has already produced results, says
Mark Ingoglia of the state Department of Health.
"It's gotten everybody to pay attention to [the
data], to clean it up and make it a tool, instead of
just a box full of paper."
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Successful Practices
Arapahoe County, Colorado
Page 17
Arapahoe County,
Colorado
Arapahoe County, in the suburbs of
Denver, encompasses 14 different fire
districts and five law enforcement
jurisdictions. Arapahoe County includes
several heavily used interstate highways, Lowry
Air Force Base, and several major railroad
systems. The largest municipality in the county,
Aurora, was designated as its own planning
district and has formed its own LEPC.
The Arapahoe County LEPC, operating through
the Sheriff's Office, has formed two
subcommittees to handle LEPC operations, the
Emergency Response Subcommittee and the
SARA Title El Compliance Subcommittee. The
Emergency Response Subcommittee handles
emergency planning, hazards analysis, and inter-
jurisdictional issues, such as establishing mutual
aid agreements. The SARA Title El Compliance
Subcommittee is responsible for facility
compliance, public education, outreach, and
information management. The two
subcommittees meet in alternating months and
the LEPC as a whole meets at least annually.
Planning
The Arapahoe County LEPC emergency
plan covers the jurisdictions of 14
different fire departments, many of
whom have their own emergency procedures.
To avoid duplicative or contradictory plans, the
Emergency Response Subcommittee developed
an umbrella plan for the entire county, focusing
on interdepartmental coordination, chain-of-
Membership: 18 members, including representatives from county government, law enforcement,
local fire departments, county health department, emergfency management, industry,
local television and newspapers, and private citizens.
Population: 400,000
Facilities: 578 reported under sections 302, 311, and 312, including chemical processors,
laboratories, chemical distributors, explosives manufactures, food processors, water
treatment plants, metal plating operations, and aircraft parts manufacturers.
Topics: Planning
Information Management
Hazards Analysis
Exercises
Outreach
Compliance
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Page 18
Arapahoe County, Colorado
Successful Practices
Ihter-LEPC Coordination
An example of the successful coordination among
neighboring LEPCs is the efforts of the Arapahoe
County and City of Aurora LEPCs. Lowry Air Force
Base is located in both the Arapahoe County and the
Aurora emergency planning districts. By coordinating
closely with each other and with Lowry, the two LEPCs
were able to determine the resources needed from each
district to supplement the Lowry resources for
responding to a chemical incident at the base. As a
resultof this cooperative atmosphere.Lowry has offered
the use of their resources, such as personnel, heavy fire
fighting equipment, and evacuation equipment, to
support emergency response actions undertaken by
both LEPCs, including those not at Lowry Air Force
Base.
command structure, mutual aid agreements, and
emergency communication procedures.
This umbrella plan also includes provisions for
coordination and cooperation with neighboring
LEPCs. The city of Aurora and the neighboring
counties of Douglas, Jefferson, Adams, and
Denver are all covered by the inter-jurisdictional
provisions of the Arapahoe County plan. In
addition, mutual aid agreements are in place
between the Arapahoe County LEPC and these
neighboring LEPCs. As a result of this inter-
jurisdictional coordination, the Arapahoe County
LEPC has access to almost 100 fully certified
hazmat responders.
The Emergency Response Subcommittee's
planning efforts are also supported by the State
of Colorado's Uniform Fire Code, which
mandates counties to adopt a fire code requiring
the submission of a facility emergency response
plan to the LEPC and the local fire department
by all facilities required to report under sections
311-312 of Title m. To help incorporate the
facility response plans into the LEPC plan,
Arapahoe County has developed the Facility
Profile and Internal Contingency Plan form.
Each facility is asked to provide information on
the facility location, emergency coordinator and
alternate(s), quantity of chemicals present, list of
available material safety data sheets (MSDSs),
evacuation distances for worst case accident
scenarios, notification procedures, response
capabilities, and vulnerable or sensitive
populations near the facility. Each completed
Facility Profile and Internal Contingency Plan is
then incorporated into the LEPC's umbrella plan.
The completed Facility Profile and Internal
Contingency. Plans are also used by the local fire
departments in their code enforcement and
emergency planning activities. In most cases,
the local fire department and the covered facility
work together to develop specific emergency
procedures.
Hazards Analysis
When the LEPC receives the Facility
Profile and Internal Contingency Plan, a
facility identification number is assigned.
With chemical information received from the
facility or a computerized database, the LEPC
uses National Fire Protection Association
(NFPA) section 704 labelling standards, which
rate, on a scale of zero to four, health, fire,
reactivity, and chemical hazards of chemicals, to
calculate overall facility hazard codes. The codes
are then entered into the dispatch computer as
part of the facility's identification information.
When a call is placed to the Sheriff's Office, the
dispatch officer is immediately able to provide
first responders with general hazard information
about the incident site.
The Facility Profile and Internal Contingency
Plan forms are also examined by the LEPC to
identify the facilities that present the highest
likelihood of a chemical incident. The
Emergency Response Subcommittee then
identifies potential accident scenarios that could
be simulated at these facilities in either a table-
top or field simulation exercise.
Exercises
The Arapahoe County LEPC conducts
exercises to test emergency response
procedures, to encourage facility
compliance with Title HI, and to make facilities
more aware of the hazards present at their sites.
As a result of the hazards analysis process
mentioned above, a large manufacturing facility
was identified as a location for a potential field
simulation because of the large quantities of
chemicals stored on site. The facility agreed to
participate in the exercise and helped stage the
incident using facility staff and equipment.
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Successful Practices
Arapahoe County, Colorado
Page 19
The simulated incident involved a truck that,
during unloading, rolled into a nearby tank farm
and ruptured two storage tanks, releasing plumes
of chlorine and ammonia into the atmosphere.
The company's emergency responders
coordinated with the local first responders in the
simulated response. The mutual aid, emergency
communications, and transportation elements of
the LEPC plan were tested by this exercise.
As a result, the facility recognized that the staged
truck incident represented a realistic scenario
and, subsequently, better isolated the loading
dock area from the tank farm. The LEPC
determined that the communication procedures
established in the plan were inadequate.
Although the plan included effective procedures
for coordinating vehicles and equipment during a
response, the number and type of vehicles were
inadequate for evacuating large numbers of
people, especially at nursing homes. Since the
exercise, the emergency plan has been revised to
improved communication procedures and, with
the help of Lowry Air Force Base, to increase
the numbers and types of vehicles available for
evacuations.
The list of high-risk facilities is again being
reviewed for a possible exercise in late summer
1991. One possibility being considered for the
next exercise is a transportation incident along
the Interstate 70 corridor. Interstate 70 is a
heavily travelled commercial route with a history
of chemical incidents. This exercise will utilize
the LEPC's new computerized information
management system.
Information Management
To improve access to Title HI information,
the Arapahoe County LEPC is
implementing a computerized
information management system to be used in
the field by first responders. The computerized
system consists of two parts, a computer-aided
design (CAD) dispatch system and Macintosh
personal computers equipped with the
Computer-Aided Management of Emergency
Operations (CAMEO) software package. The
CAD dispatch system is used by the Sheriffs
Office to track locations and activities of patrol
cars and consists of a computerized city map and
tracking system. The CAMEO software system
was developed by EPA and the National
Oceanographic and Atmospheric Administration
to assist emergency planners and first responders
with then* Title HI information management,
response, and planning activities.
When the first responders reach the incident site,
they can use a Macintosh computer, a cellular
phone, and a fax modem to access the CAMEO
database maintained by the LEPC in the
Sheriff's Office. In addition, first responders can
phone or radio the dispatch officer to request that
MSDSs or facility maps be sent via the fax
modem to the responder's computer screen.
Although this information management system
has been tested by the LEPC, it has not yet been
used in an actual response situation the
proposed exercise represents its first real
challenge.
Outreach
To inform first responders, facilities, and
the general public about the requirements
of Title HI, the Arapahoe County LEPC
developed a series of fact sheets designed for
different groups. Each fact sheet explains the
purpose of Title in and the general reporting
requirements. The fact sheet for the general
public includes additional information about how
the Tide HI data are made available to the public
and how to use the data to identify chemical
hazards in the community. The fact sheet for
first responders includes additional information
about the usefulness of Title HI information to
planning and response activities. The fact sheets
for private-sector and state and local government
facilities include more specific information about
the reporting requirements and applicable
reporting exemptions. All potentially covered
facilities are provided the appropriate facility
fact sheet as part of an information packet, which
also includes the Facility Profile and Internal
Contingency Plan form and the Arapahoe
County LEPC-developed version of the Tier n
form and instructions.
The Arapahoe County LEPC routinely places
articles in newsletters and LEPC members attend
meetings of homeowner, community, and special
interest groups to foster awareness of Title HI,
the role of the LEPC, and chemical hazards in
the community. One such special interest group
is the "Interstate 70 Corridor Group." This
group consists of first responders from
businesses, law enforcement, and local fire
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Page 20
Arapahoe County, Colorado
Successful Practices
departments which meets monthly to discuss
issues such as chemical incidents and traffic
control. On several occasions, members of the
Arapahoe County LEPC have responded to
incidents along 1-70 and, as a result, the 1-70
Group is being approached to participate in a
possible transportation-related exercise in late
summer 1991.
Compliance
Rather than use limited LEPC resources to
conduct mass mailings, the Arapahoe
County LEPC chose to use an existing
fire inspection program to disseminate Title TTI
information, identify subject facilities, and
encourage compliance with the provisions of
Title m. Under Colorado's Uniform Fire Code,
local fire departments in Arapahoe County
regularly identify and inspect both new and
existing facilities in their jurisdictions for
potential fire hazards.
Many provisions of the Uniform Fire Code
parallel the requirements of Title EL For
example, the fire code requires that MSDSs be
submitted to the local emergency planning
authority, which in Arapahoe County is the
LEPC. Because the Uniform Fire Code is
enforced at the local level, the Arapahoe County
LEPC encourages compliance with the
provisions of Title m by working with the local
fire department to enforce the parallel provisions
of the Uniform Fire Code.
During a fire code inspection, if a facility is
identified as being potentially subject to Title m
and has not reported to the LEPC, the fire
inspector gives the facility owner/operator a
copy of the facility information packet and
records the receipt of the information and
documents the violation in the inspection report.
The identified facilities are reported to the LEPC
Emergency Response Subcommittee monthly.
Each facility not in compliance is contacted by
the LEPC, which offers assistance in complying
with the Tide IE provisions. The facility is then
given two weeks (the time allowed to respond to
a Uniform Fire Code violation) to comply with
the provisions of Title El.
If nothing is submitted by the facility, the facility
is contacted again by the LEPC with another
offer of assistance and is given another two
weeks to comply (per the Uniform Fire Code).
If no reports are then forthcoming, the Sheriffs
Office informs the facility of the penalties for
noncompliance (called a Hazard Notice). The
facility is then given seven days and if no reports
are submitted by the facility, a summons is
issued for the facility owner/operator to appear
before a judge to explain this lack of compliance
and face possible fines and/or a jail sentence.
Violations of the Uniform Fire Code are
misdemeanors with penalties up to $1,000 and/or
a jail sentence of up to 12 months per violation.
In addition, every day a facility is out of
compliance with the Uniform Fire Code (the
time between when the Hazard Notice is
received and the summons is issued) can be
considered a separate violation under the
Uniform Fire Code. Therefore, a facility that
does not respond to the Hazard Notice and
receives a summons could be assessed penalties
for a minimum of seven violations (one for each
day between the issuance of the Hazard Notice
and the issuance of the summons).
To date, the Arapahoe County LEPC has issued
only two summonses for non-compliance with
Title IE. Both of these cases were settled out of
court and the facilities are now in compliance.
Most of the facilities that do not immediately
comply are unfamiliar with the requirements and
need assistance to determine their reporting
responsibilities.
LESSONS LEARNED
Piggyback on Existing Programs. Like many
LEPCs, the Arapahoe County LEPC was faced
with implementing and enforcing Title III on a
smaU budget. Because of the LEPC's
commitment to assist first responders by
providing Title IE information, the LEPC
considers identifying all subject facilities very
important. Because many provisions of the
Uniform Fire Code parallel Title El
requirements, the LEPC is able to improve
compliance with Title IE by enforcing the
Uniform Fire Code. The local fire departments,
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Successful Practices
Arapahoe County, Colorado
Page 21
with their extensive knowledge of facilities in
their jurisdictions and their existing inspection
program, provide the LEPC with an excellent
resource for identifying facilities subject to Title
HI. Through the innovative use of the Uniform
Fire Code, the Arapahoe County LEPC is able to
effectively bring facilities into compliance with
Title HI despite limited resources.
Provide the Tools, Improve the Results. When
the Arapahoe County LEPC first approached the
various local fire departments with their proposal
to have firefighters identify facilities and
distribute information about Title HI, the
proposal was met with much resistance. The
local fire departments already had plenty to do
with their own jobs. The LEPC provided
training to the firefighters on Title m and, more
important, the LEPC illustrated the usefulness of
the information collected under the Title in to
improving the fire department's emergency
response capabilities. As a result, the local fire
departments have become a very active and
knowledgeable component of the LEPC's efforts
to improve compliance with Title TEL.
Similarly, many facilities are wary of reporting
requirements due to a lack of knowledge of the
regulatory program. By providing the facility
information packets and continuous offers of
assistance, the LEPC has not only increased the
number of facilities in compliance, but also
improved the quality of the information
submitted.
Build on Existing Plans and Procedures. Prior
to Title HI, many organizations had developed
their own emergency response procedures. In
Arapahoe County, the local fire departments had
their own emergency procedures, the Lowry Air
Force Base had a site contingency plan, and
many facilities had standard operating and
emergency procedures. Rather than starting
from scratch, the Arapahoe County LEPC
decided to develop an umbrella plan to
coordinate existing plans and procedures. As a
result, the Arapahoe County LEPC has
conserved valuable resources and integrated
facility-specific information into an LEPC plan
that can be easily updated. Because the LEPC
umbrella plan coordinates existing plans and
sponsors regular exercises, fire department and
facility first responders are familiar with each
other's procedures and then- roles within the
LEPC's umbrella plan.
Coordination Encourages Cooperation. A
single local emergency planning district often
does not have available all the resources
necessary to respond to a large-scale incident.
The Arapahoe County LEPC recognized that,
during an emergency, the county response
resources may need to be supplemented. The
LEPC then began an active coordination effort
with neighboring LEPCs, stressing not only what
Arapahoe needed but also what Arapahoe could
offer to assist them. The Arapahoe County
LEPC used the same approach when contacting
subject facilities. By taking the lead in
coordinating neighboring LEPCs and facilities
into their emergency plan, the Arapahoe County
LEPC has successfully created an atmosphere of
cooperation not only with neighboring LEPCs
but also with facilities within the district.
Industry Must be Aware of Accidents Waiting
to Happen. The Arapahoe County LEPC
believes that field simulation exercises are
important not only to test the provisions of the
LEPC plan, but also to make facilities aware of
chemical hazards at their sites and identifying
ways to mitigate those hazards. The key is
effective facility emergency planning to identify,
prepare for, and prevent all possible hazards.
Contact:
Rick Young
Arapahoe County LEPC
5686 S. Court Place
Littleton, CO 80120
(303) 797-4410
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Page 22
Successful Practices
Regional Chemical Emergency
Preparedness and Prevention
Coordinators
RayDiNardo
EPA-Region 1
New England Regional Lab
60 Westview Street
Lexington, MA 02173
(617) 860-4300
John Ulshoefer
EPA-Region 2
Woodbridge Avenue
Edison, NT 08837
(908)321-6620
Karen Wolper
EPA-Region 3
841 Chestnut Street
Philadelphia, PA 19107
(215)597-8751
Henry Hudson
EPA-Region 4
345 Courfland Street, NE
Atlanta, GA 30365
(404)347-1033
Mark Horwitz
EPA-Region 5
230 South Dearborn
Chicago, IL 60604
(312) 886-1964
Jim Staves
EPA-Region 6
Allied Bank Tower
1445 Ross Avenue
Dallas, TX 75202-2733
(214) 655-2270
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
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
10 - Oregon
3 - Pennsylvania
1 - Rhode Island
4 - South Carolina
8-South Dakota
4 - Tennessee
6-Texas
8-Utah
1 - Vermont
3 - Virginia
10 - Washington
3-West Virginia
5 - Wisconsin
8 - Wyoming
9 - American Samoa
9-Guam
2 - Puerto Rico
2-Virgin Islands
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Successful Practices
Page 23
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 preceding 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
Successful Practices #8
Doc. # OSWER-91-006.2, October 1991.
Cherry Hill, New Jersey
Manitowoc County, Wisconsin
Greene County, Missouri
State of Hawaii
Arapahoe County, Colorado
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Page 24
Successful Practices
Successful Practices in Title III Implementation:
Subject Index*
Compliance (Enforcement);
Kansas (SP1:4); Idaho (SP2:14-15); Arapahoe County, Colorado (SP8:26-27)
Identifying/contacting facilities:
Calhoun County, Alabama (SP2:l-2); Fairfax County, Virginia (SP3:9); Alexandria, Virginia
(SP4:13); Wyandotte County, Kansas (SP5:15-16); Tinker Air Force Base, Oklahoma (SP5:2);
Hamilton County, Ohio (SP6:11); Bucks County, Pennsylvania (SP7:11); Wisconsin (SP2:8);
New York, New York (SP4:3-4); Cameron County, Texas (SP7:4)
Inspections:
Racine County, Wisconsin (SP2:12); Pampa, Texas (SP2:4-5)
Emergency Plans;
Jefferson County, Kentucky (SP1:9-10); Idaho (SP2:14); Pierce County, Washington (SP3:13);
Tinker Air Force Base, Oklahoma (SP5:2); Bucks County, Pennsylvania (SP7:10-11)
Community Consequences:
Racine County, Wisconsin (SP2:12-13); Wallingford, Connecticut (SP6:13)
Coordination with other LEPCs and communities:
Dallas County, Texas (SP7:19); Harfbrd County, Maryland (SP7:14-15); Arapahoe County,
Colorado (SP8:23)
Existing plans:
Cumberland County, Maine (SP5:10-11); Cherry Hill, New Jersey (SP8:1)
Facility input:
New York, New York (SP4:3); Hamilton County, Ohio (SP6:9); Wyandotte County, Kansas
(SP5:14-15); El Paso County, Colorado (SP4:6-7); Cuyahoga County, Ohio (SP2:10)
Facility plans:
Fairfax County, Virginia (SP3:9)
Hazard analysis:
Alexandria, Virginia (SP4:11-12); Butler County, Kansas (SP1:7)
Planning guidance:
Connecticut (SP5:5-6); New York, New York (SP4:2), Kansas (SP1:3)
Public alert and notification system:
Wyandotte County, Kansas (SP5:17)
Structure:
Ohio (SP6:l-2)
*The citation provided for each profile refers to the issue number (SP3 refers to the third issue of
Successful Practices) and the page number within that issue.
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Successful Practices
Subject Index
Page 25
Exercises:
Decontamination:
Greene County, Missouri (SP8:14)
Evacuation and sheltering:
Arapahoe County, Colorado (SP8:24); Greene County, Missouri (SP8:14)
Field programs:
Woodbury County, Iowa (SP3:2); Cumberland County, Maine (SP5:11); Hamilton County,
Ohio (SP6:9-10); Wallingford, Connecticut (SP6:13-14); Oauchita Parish, Louisiana (SP6:21-
22); Hawaii (SP8:21); Manitowoc County, Wisconsin (SP8:8); Arapahoe County, Colorado
(SP8:24)
Table-top programs:
Hartford County, Maryland (SP7:15); Dallas County, Texas (SP7:20); Hamilton County, Ohio
(SP6:9-10); Cumberland County, Maine (SP5:11)
Funding:
Donations:
Jefferson County, Kentucky (SP1:10); Calhoun County, Alabama (SP2:2); Pierce County,
Washington (SP3:14); Cameron County, Texas (SP7:4); Bucks County, Pennsylvania (SP7:9)
Fee systems:
Kansas (SP1:4); Washtenaw County, Michigan (SP1:5); Calhoun County, Alabama (SP2:2);
Wisconsin (SP2:7); Fairfax County, Virginia (SP3:10); Maine (SP4:16-18); Ohio (SP6:3)
Grants:
Connecticut (SP5:6)
State and local agency budgets:
Jefferson County, Kentucky (SP1:10); Wisconsin (SP2:7); Connecticut (SP5:6); Ohio (SP6:3);
Bucks County, Pennsylvania (SP7:9); Hartford County, Maryland (SP7:16); Dallas County,
Texas (SP7:20)
Hazards Analysis:
Hazard identification:
Cuyahoga County, Ohio (SP2:9-10); Wyandotte County, Kansas (SP5:13-14); Hamilton County,
Ohio (SP6:7-9); Arapahoe County, Colorado (SP8:23-24); Alexandria, Virginia (SP4:11-12)
Hazards Incidents Complexity Analysis:
Kansas (SP1:3); Wyandotte County, Kansas (SP5:13-14)
Risk analysis:
Hamilton County, Ohio (SP6:8-9); Dallas County, Texas (SP7:19)
Transportation:
Kansas (SP1:3); Butler County, Kansas (SP1:7); Alexandria, Virginia (SP4:11-12)
Vulnerability zones:
Cuyahoga County, Ohio (SP2:9); Hamilton County, Ohio (SP6:7-9); Wallingford, Connecticut
(SP6:14-15); Greene County, Missouri (SP8:13-14)
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Page 26
Subject Index
Successful Practices
Information Management (Computer Systems);
CAMEO:
Jefferson County, Kentucky (SPlrlO); Racine County, Wisconsin (SP2:13); Pampa, Texas
(SP2:5); El Paso County, Colorado (SP4:7); New York, New York (SP4:2); Wallingford,
Connecticut (SP6:14); Hamilton County, Ohio (SP6:10); Bucks County, Pennsylvania (SP7:8);
Arapahoe County, Colorado (SP8:25); Hawaii (SP8:17-19); Greene County, Missouri (SP8:13);
Cherry Hill, New Jersey (SP8:2-3); Wyandotte County, Kansas (SP5:16)
Conversion software:
Greene County, Missouri (SP8:13)
dBase:
El Paso County, Colorado (SP4:7); Bucks County, Pennsylvania (SP7:9)
Dispatch system:
Bucks County, Pennsylvania (SP7:9)
Modified reporting format:
Ohio (SP6:2), Oauchita Parish, Louisiana (SP6:20), Hawaii (SP8:19)
Networks:
Idaho (SP2:15)
'Tacket" radio:
El Paso County, Colorado (SP4:7); Cherry Hill, New Jersey (SP8:3)
Software programs:
Kansas (SPl:3-4); Pampa, Texas (SP2:5-6); Virginia (SP3:5-6); Fairfax County, Virginia
(SP3:9-10); New York, New York (SP4:l-2); Tinker Air Force Base, Oklahoma (SP5:2-3);
Connecticut (SP5:6-7); Hamilton County, Ohio (SP6:10); Oauchita Parish, Louisiana (SP6:21);
Bucks County, Pennsylvania (SP7:8); Arapahoe County, Colorado (SP8:25)
Worksheet forms:
Washtenaw County, Michigan (SP1:5)
LEPC Coordination:
Coordination with SERC:
Hamilton County, Ohio (SP6:10); Kansas (SP1:2)
Federal facilities:
Tinker Air Force Base, Oklahoma (SP5:1)
Inter-LEPC coordination:
Virginia (SP3:4-5); Alexandria, Virginia (SP4:12-13); Wyandotte County, Kansas (SP5:17);
Woodbury County, Iowa (SP3:3)
International coordination:
Maine (SP4:18); Cameron County, Texas (SP7:l-3)
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Successful Practices
Subject Index
Page 27
LEPC Organization;
Pre-SARA/Title m organizations:
Bucks County, Pennsylvania (SP7:7-8); Cherry Hill, New Jersey (SP8:1); Hawaii (SP8:19-20);
Racine County, Wisconsin (SP2:11); Woodbury County, Iowa (SP3:l-2)
Subcommittees:
Calhoun County, Alabama (SP2:2); Oauchita Parish, Louisiana (SP6:17-18); Bucks County,
Pennsylvania (SP7:7-8); Greene County, Missouri (SP8:11-13); Pampa, Texas (SP2:4); Jefferson
County, Kentucky (SP1:10)
Liability;
Virginia (SP3:5); Pierce County, Washington (SP3:15); Maine (SP4:16)
Outreach Programs;
Wisconsin (SP2:8); Hawaii (SP8:19)
Agriculture:
Racine County, Wisconsin (SP2:11-12); Manitowoc County, Wisconsin (SP8:6-7)
Audio/Visual Aids:
Virginia (SP3:4-5); Ohio (SP6:2-3); Harford County, Maryland (SP7:15); Cherry Hill, New
Jersey (SP8:4)
Brochures, factsheets, and booklets:
Kansas (SP1:2); Cuyahoga County, Ohio (SP2:10); Idaho (SP2:14); New York, New York
(SP4:4); Hamilton County, Ohio (SP6:10); Wallingford, Connecticut (SP6:15); Harford County,
Maryland (SP7:15); Arapahoe County, Colorado (SP8:25)
Guidelines:
Cuyahoga County, Ohio (SP2:10); Virginia (SP3:4-5)
Industry:
Virginia (SP3:4-5)
Lectures & workshops:
Butler County, Kansas (SP1:7); Idaho (SP2:14); Pierce County, Washington (SP3:14); New
York, New York (SP4:4); Connecticut (SP5:7); Dallas County, Texas (SP7:20); Cameron
County, Texas (SP7:4); Manitowoc County, Wisconsin (SP8:6-8)
Library displays:
Pierce County, Washington (SP3:14); El Paso County, Colorado (SP4:8);
Local government:
Cherry Hill, New Jersey (SP8:4)
Mailing lists:
New York, New York (SP4:4)
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Page 28
Subject Index
Successful Practices
Outreach Programs (continued^:
Media Use (TV, radio, newspaper):
Kansas (SP1:3); Butler County, Kansas (SP1:7); Woodbury County, Iowa (SP3:2); Fairfax
County, Virginia (SP3:10); Pierce County, Washington (SP3:14); El Paso County, Colorado
(SP4:8); Tinker Air Force Base, Oklahoma (SP5:3); Oauchita Parish, Louisiana (SP6:18-20);
Cameron County, Texas (SP7:4); Dallas County, Texas (SP7:20); Manitowoc County, Wisconsin
(SP8:6-8); Harford County, Maryland (SP7:15)
Public schools:
El Paso County, Colorado (SP4:8)
Prevention;
Washtenaw County, Michigan (SP1:5); Hamilton County, Ohio (SP6:11)
Public Alert System;
Wyandotte County, Kansas (SP5:17)
Reporting Modifications;
Ohio (SP6:2); Oauchita Parish, Louisiana (SP6:20); Hawaii (SP8:19)
P?ght-to-Know Laws;
Washtenaw County, Michigan (SP1:5); Wisconsin (SP2:8); Maine (SP4:15-16); Wyandotte
County, Kansas (SP5:16-17); New York, New York (SP4:4)
Section 313 Data;
Accessibility and analysis:
Connecticut (SP5:8); El Paso County, Colorado (SP4:9); Ohio (SP6:3-5); DaUas County, Texas
(SP7:18); Virginia (SP3:6)
Compliance:
Fairfax County, Virginia (SP3:8); Ohio (SP6:4)
Special Planning Features;
Chemical Stockpile Disposal Program facilities:
Harford County, Maryland (SP7:16)
Federal facilities:
Tinker Air Force Base, Oklahoma (SP5:2); Harford County, Maryland (SP7:14)
Nursing homes:
Cherry Hill, New Jersey (SP8:4)
Schools:
Wallingford, Connecticut (SP6:13); Harford County, Maryland (SP7:14)
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Successful Practices
Subject Index
Page 29
Special Planning Features (continued);
Transportation:
Alexandria, Virginia (SP4:11-12); Oauchita Parish, Louisiana (SP6:21-22)
Training Programs;
Coordination with government organizations:
Virginia (SP3:4); El Paso County, Colorado (SP4:8); Tinker Air Force Base, Oklahoma (SP5:3);
Connecticut (SP5:7); Bucks County, Pennsylvania (SP?2ll); Hawaii (SP8:20)
Facility management personnel:
Tinker Air Force Base, Oklahoma (SP5:3); Bucks County, Pennsylvania (SP7:11)
First-responders:
Pierce County, Washington (SP3:13-14); El Paso County, Colorado (SP4:8); Tinker Air Force
Base,OMahorm(SP5:3);Comecticut(SP5:7);QimberlandCbunty,Maine(SP5:ll);Walhngford,
Connecticut (SP6:15); Harford County, Maryland (SP7:15); Cherry Hill, New Jersey (SP8:3-4);
Cameron County, Texas (SP7:3)
Hazmat team personnel:
Jefferson County, Kentucky (SP1:9); Pampa, Texas (SP2:5); Virginia (SP3:4); Connecticut
(SP5:7); Harford County, Maryland (SP7:15); Hawaii (SP8:20)
LEPC:
Kansas (SP1:3); Virginia (SP3:4); Alexandria, Virginia (SP4:13-14); Connecticut (SP5:7)
Medical personnel:
Racine County, Wisconsin (SP2:12)
Potential CAMEO users:
Cherry Hill, New Jersey (SP8:3-4)
Public:
Bucks County, Pennsylvania (SP7:11)
Train-the-Trainer:
Idaho (SP2:15); Maine (SP4:18); Cherry Hill, New Jersey (SP8:4)
Vulnerability Analysis;
Cuyahoga County, Ohio (SP2:9); Hamilton County, Ohio (SP6:8); Wallingford, Connecticut
(SP6:14-15); Greene County, Missouri (SP8:13-14)
HIRT:
Bucks County, Pennsylvania (SP7:11)
it U.S.GOVEHNMENTPFINTINQOFFICE;19G1-ei7-003/47CM8
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