United Stales
        Environmental Protection
        Agency
Office of Solid Waste
and Emergency Response
(OS-120)
September 1992
OSWER-92-006.1
Series 6, No. 9
4IEPA  Successful Practices in
        Title III Implementation
        Chemical Emergency
        Preparedness and Prevention
        Technical Assistance Bulletin
        Natrona County, Colorado
        Erie County3 New York
        State of Arizona
        Mohave County, Arizona
        Subject Index
                                    Recycled/Recyclable
                                    Printed on paperthat contains
                                    at lasst SO% roeydaeHIhar

-------

-------
                         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 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, hazards analysis, and outreach.
The 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 nine Successful Practices
bulletins has been included in this bulletin.  The index is designed to allow the reader to identify
successful Title III implementation practices by topic area, and then locate the Successful Practices
bulletin in which the practice was profiled.  Details on all nine bulletins, and how to order them, are
provided on page 18.

If you know of Tide III 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 19), or the Emergency Planning and
Community Right-to-Know Information Hotline at (800) 535-0202.

-------

-------
Successful Practices
Natrona County, Wyoming
Page 1
                                                                Natrona County,
                                                                     Wyoming
       The Natrona County LEPC, in
       coordination with EPA Region 8, has
       embarked upon a Title III outreach and
       compliance campaign throughout the
county. The LEPC has made a concerted effort
to educate both industry and the public about
Tide in. The committee holds at least two
meetings per year, and has five distinct
subcommittees which address plan modification
and update, evacuation, community awareness,
training and exercises, and response and
preparedness. The LEPC has a relatively large
staff and a good working relationship with area
businesses. The  chair of the LEPC is the
coordinator of the county Emergency
Management Agency (EMA) and a law
enforcement officer in the county sheriff's office
in Casper — the  county's largest city with a
population of nearly 47,000.  This situation has
resulted in the EMA taking a leading role in Title
in implementation for Natrona County.
            Compliance

                   Before an outreach and compliance
                   program could begin, the Natrona County
                   LEPC needed to identify facilities within
            the county that must report under Title HI. With
            assistance from the U.S. EPA Region 8 office in
            Denver, the LEPC began to target facilities using
            several methods.  First, the LEPC identified a
            number of facilities simply by using the business
            section of the local telephone book and by
            visiting facilities listed under subjects related to
            gasoline and chlorine use. In addition, the LEPC
            identified possible reporters using computerized
            data bases provided by the EPA regional office.
            These data bases included the names of facilities
            on the  Resource Conservation and Recovery Act
            (RCRA) Notifiers List, the List of Registered
            Underground Storage Tanks (USTs), and the
            section 313 Toxic Release Inventory (TRI)
            reporting list. By crossing out the names of
 Membership:  39 members, including representatives from law enforcement, fire and rescue
               services, health department, education, industry, county and municipal government,
               emergency management, county agricultural extension office, news media,
               hospitals, American Red Cross, and private citizens.

 Population:   61,000

 Facilities:     20 facilities have reported under section 302, and 161 have reported under sections
               311/312 of Title HI, including petroleum production and refining facilities, chemical
               manufacturers, and utilities.

 Topics:       Compliance
               Outreach
               Exercises

-------
Page 2
Natrona County, Wyoming
Successful Practices
facilities listed in these data bases that were out
of business, the Natrona County LEPC was able
to compile a target list of potential Title III
reporting facilities that had reported under the
requirements of other statutes.

Because fire fighters are often familiar with the
types of chemicals in use at a facility, and may
also have an established relationship with facility
management, fire departments can be another
valuable source of information about potential
Title in reporters.  The Natrona County LEPC
has supplied local fire departments with Title ffl
information packets to deliver to companies
during scheduled fire safety inspections.  The
packets include a list of Title HI reporting
requirements, a list of Title III contacts and
telephone numbers, and a cover letter asking
companies to supply a list of their chemicals to
the LEPC to determine if the facility is required
to report. Through close coordination with local
fire departments, the Natrona County LEPC was
able to reach a larger audience with its Title in
message than might otherwise have been
possible.

Following these initial efforts, the Natrona
County LEPC compiled  a list of facilities
identified through the use of the data bases,
telephone books, fire department inspections,
and other sources.  The LEPC then carefully
reviewed the list, eliminating all duplicates and
business closures, and concluded with a list of
260 potentially covered facilities that had not
reported under Title III.  To each facility on the
list, the Natrona County LEPC sent a letter that
included a Title IH fact sheet, a response
postcard, and phone numbers for questions. The
response postcards presented the facility
representative with four response options: (1)
reported under Tide HI; (2) aware of Title III,
but do not need to report; (3) uncertain if need to
report; and (4) have questions on Tide in and
would like to attend an informational meeting to
discuss reporting requirements. Along with
these materials, the initial package included a list
of Federal Register notices concerning Title III;
FEMA and EPA publications on Title HI; and
information on Natrona County's hazardous
materials planning efforts.

Prior to these compliance efforts by the Natrona
County LEPC, 89 facilities had reported under
            various sections of Title III. Within 90 days of
            sending the initial letters and response postcards
            to the facilities, the Natrona County LEPC
            received 20 new submissions of Title III reports,
            and identified an additional 64 facilities who
            appeared to be required to report. Follow-up
            letters were sent to those facilities that did not
            respond to the initial information package. As of
            March 1992, compliance efforts resulted in 72
            additional facilities reporting under Title III (for
            a total of 161 facilities), an increase of more than
            80 percent.

            Outreach

                   Because some facilities either
                   misunderstood the Title HI reporting
                   requirements or ignored them, 'the
            Natrona County LEPC developed and conducted
            a workshop for industry to explain requirements
            and issues associated with Tide III reporting in
            more detail.  The workshop covered a variety of
            topics, including business confidentiality, release
            notification procedures, compliance with Title
            III sections 311 and 312, facility emergency
            planning, and civil and criminal penalties. To
            publicize the workshop, the LEPC issued several
            press releases for publication in the local
            newspaper and promoted the workshop at
            several emergency exercises in which industry
            participated. Facilities for the workshop were
            obtained from the local Agricultural Extension
            Office free of charge.

            The Natrona County LEPC provided numerous
            informational materials at the workshop. The
            LEPC customized copies of the Tide in
            requirements to include names and phone
            numbers of representatives of the Natrona
            County LEPC and the Wyoming state
            emergency response commission (SERC). In
            addition, the LEPC compiled and made available
            a schedule of hazardous materials training
            courses offered by fire and police departments,
            hospitals, large local companies, and other
            organizations.  Other documents handed out at
            the workshop include OSHA guidelines on
            hazard communications standards; related
            worker right-to-know materials; EPA's List of
            Lists, detailing reporting levels for specific
            chemicals under various statutes; and other
            pamphlets and EPA publications obtained for
            free from the EPA regional office.

-------
Successful Practices
Natrona County, Wyoming
PageS
At the request of industry representatives
attending the workshop, the Natrona County
LEPC has made its members available for one-
on-one meetings to provide a more company-
specific, personalized approach than is possible
at a workshop. To date, the LEPC has conducted
about 20 one-on-one meetings with
representatives of potential reporting facilities
and has found the meetings to be often more
fruitful than the full-scale workshops.

Several success stories have resulted from these
meetings. Following one such meeting, a bulk
fuel distributor located in Casper provided the
LEPC with a list of its hazardous chemicals, a
site-safety plan, and a facility map detailing
specific areas where each hazardous chemical is
stored on site. This information was
accompanied by an invitation to LEPC members
to tour the plant for more information. Another
successful one-on-one meeting involved the
Parks and Recreation Department of the  City of
Casper.  After meeting with the Natrona County
LEPC, the Parks Department identified a number
of facilities and locations operated by the city
where fuels, fertilizers,  herbicides, chlorine, and
other drinking and waste water treatment
chemicals were stored.  The LEPC has remained
in close contact with the Parks Department after
the meeting, and has assisted department
officials in filing thorough Tier II reports with
the LEPC.

Exercises

       Exercises conducted with the cooperation
       of industry, local responders, and the
       Natrona County LEPC have tested
emergency response procedures while furthering
the cause of informing industry and the public
about Title HI. Consider the following scenario.
On the afternoon of September 17,1990, just
outside the gates of the  Nalco Chemical
Company on Old Glenrock Highway in Casper,
the driver of a commercial transit bus suffered a
heart attack, lost control of the vehicle, and sent
the bus crashing into the side of a tanker truck
containing thousands of gallons of flammable
and corrosive liquids. Fortunately, this
description is not from an actual occurrence, but
from an exercise developed by the Natrona
County LEPC in coordination with Nalco
Chemical and various emergency.responders.
                         Information Management

              Several agencies in Natrona County and the City of
              Casper are in the processof improving the911 emergency
              center by installing a computer-aided dispatch system.
              This system would send Title HI information by modem
              from EMA's Emergency Information System (EIS)
              software package,  which  stores chemical, facility,
              transportation, and other planning  and response
              information, to the 911 system. When installation of the
              improved dispatch system is complete, first responders
              will have information on buildings and stored chemicals
              before they enter the premises. For field operations, the
              Natrona County EMA and LEPC used emergency
              management funds to purchase a laptop computer that
              can access information from the EIS software in the main
              office. Use of this new computer will provide facility-
              specific information to the EMA in the field for both
              emergency and non-emergency situations.

              To improve its software capabilities, the Natrona County
              LEPC has  installed dBase IV in addition to the  EIS
              software on their office system. When the annual Title
              III reports come in, the LEPC adds the contents of each
              form to the office system. Currently, the Natrona County
              LEPC is planning to expand this information system to
              increase the amount of data, and make it more accessible
              to other agencies. To supplement this information, the
              LEPC also remains in close contact with the Casper Fire
              Department, which uses the Computer-Aided
              Management of Emergency Operations (CAMEO)
              software to aid in emergency planning and response to
              hazardous material accidents.
             Preparation for this exercise included working
             with the news media to videotape the event,
             consultation with participating emergency
             responders, and solicitation of an old tanker
             truck from Nalco Chemical. Personnel from the
             Nalco response team, three fire departments, two
             ambulance services, and four law enforcement
             agencies responded to the "incident," and were
             directed at the scene by  the EMA.  Roadblocks
             were set along the highway with vehicles from
             the highway patrol and sheriff's department, and
             medical personnel treated about 20 "casualties"
             from the bus at the scene.

-------
Page 4
Natrona County, Wyoming
Successful Practices
Several lessons learned by participants in this
and other exercises have shed light on the
strengths and weaknesses of the local emergency
response plan. Communication among
responders was constant during the Nalco
Chemical exercise, keeping response efforts
organized. Law enforcement personnel were
able to prevent public access to the area
surrounding the facility quickly and efficiently.
Media coverage of the dramatic exercise has
increased community and industry awareness of
the Title in message; for instance, Nalco
Chemical has since modified its tape of the
exercise into a chemical safety awareness video
for use in training new employees at all of the
company's facilities.

Lessons were also learned through response
shortcomings.  During the Nalco exercise,
responders did not dedicate a specific area near
the scene for on-site medical treatment or for
transport of accident victims to local hospitals.
Although public and emergency notification of
the "accident" was timely, Nalco Chemical did
not alert all of its workers to the exercise
unfolding outside their building.  Since the
exercise, medical procedures for emergency
medical personnel and hospitals have been
modified and are now incorporated in the
community emergency plan. In addition, Nalco
Chemical has improved its procedures for
alerting all employees to an emergency.
            LESSONS LEARNED

            Industry and Emergency Responders Must Be
            Informed and Involved. Outreach has been the
            foundation for all the work of the Natrona
            County LEPC. Its central goal is to deliver the
            message to facilities and to the emergency
            response community that Title III is everyone's
            responsibility. The more that an LEPC strives to
            deliver this message and the more members of
            the emergency response community become
            informed and involved, the better each responder
            will perform in an actual emergency.

            The Natrona County LEPC Doesn't Like
            Surprises. Through exercises performed in
            conjunction with local industry and response
            personnel, the Natrona County LEPC has
            discovered some areas of vulnerability in its
            response plan and procedures that it has
            subsequently worked to resolve. By solving
            unexpected response problems during
            simulations and full-scale exercises, the Natrona
            County LEPC has helped to prevent unwanted
            surprises from hampering responders during
            actual emergencies.
            Contact:

            Lt. Stewart Anderson
            Natrona County LEPC
            Office of the Sheriff
            201 North David Street
            Casper, WY 82601
            (307) 235-9282

-------
Successful Practices
Erie County, New York
PageS
                                                                   Erie County,
                                                                     New York
       Erie County is located in western New
       York, south of Niagara County and
       sharing a border with the Regional
       Municipality of Niagara, Province of
Ontario, Canada, along the Niagara River. The
largest community is Buffalo, with a population
of 334,000; there are also 25 towns, 16 villages,
and two other cities in the county.

Erie County has a full-time LEPC coordinator,
the first appointed in the state, although
administrative support is provided by the Erie
County Department of Emergency Services'
(DES) Office of Disaster Preparedness and the
Erie County Department of Environment and
Planning.
          International Coordination

                The region consisting of Erie County,
                Niagara County, and the Municipality of
                Niagara has considerable transportation
          and use of hazardous materials, which translates
          into an ever-present threat around and across the
          international border. For example, on November
          11,1979, a train with alternating rail cars of
          propane and chlorine derailed and caught fire
          near the city of Mississaugua, in the Province of
          Ontario, Canada, requiring the evacuation of
          240,000 residents over several days, one of the
          largest evacuations in North American history.
          Recently, in December 1989, a ship went
          aground in the Buffalo Harbor carrying over
  Membership:  30 members, including representatives from local and county emergency services,
               fire safety, emergency medical services, environment and planning, civil defense
               and disaster preparedness, and police, sheriff, fire, and health departments; state
               senate; media; Niagara Frontier Transportation Authority; hospitals; Citizen's
               Action Organization; private citizens, including medical and legal professionals;
               and industry (chair: industry representative).

  Population:   969,000

  Facilities:     834 reporting under section 312, and 175 under section 302, including
               communication centers, sewage and waste water treatment facilities, ice rinks, and
               manufacturing, warehousing, and cold storage facilities.


  Topics:       International Coordination
               Exercises
               Training
               Emergency Response

-------
Pages
Erie County, New York
Successful Practices
600,000 gallons of toluene, a carcinogen. Lastly,
in May 1990 the plume of a chemical release
from Rich Products in Buffalo was detected
across the border in Canada.

Recognizing the potential for a disaster in the
border region, the United States and Canada
signed an Agreement on Cooperation between
the United States and Canada on Civil
Emergency Planning in August of 1986.
Meanwhile, also prior to the passage of SARA
Title III, attempts were being made to establish a
joint disaster planning effort between Erie
County, the City of Buffalo, Niagara County,
and the Province of Ontario.  During the next
two years, after reviewing hazardous substance
inventories obtained under Title HI, local
officials recognized that the existing planning
effort had to be intensified. Because a variety of
issues relating to immigration, customs, and
border bridge authorities needed to be examined
to determine how to coordinate cross-border
response activities, an International Joint
Committee on Emergency Planning was formed,
consisting of representatives from LEPC
member agencies in Erie and Niagara counties,
and similar agencies in Ontario.

The first product of the international committee
emerged on March 15,1989, when the Regional
Municipality of Niagara, Ontario, and the
Counties of Erie and Niagara signed an
agreement addressing emergency planning and
response for major incidents or disasters that
would impact any of the border communities.
The signing of this agreement, however, was just
the first stage in the international coordination
process. A variety of planning sessions, training
programs, and meetings have been held with the
local law enforcement community, fire service
personnel, emergency medical and health
officials, social services agencies, customs and
immigration people, bridge authority
commissioners, the military, and various other
response groups.

The coordination process continued in 1991 with
the signing of a Memorandum of Understanding
that defines the guidelines and parameters for the
unimpeded and mutual use of manpower,
equipment, and other resources during
emergencies that would affect any portion of the
border area between Canada and Erie and
Niagara counties.  The agreement is designed to
improve public safety for citizens on both sides
                of the border by providing an effective,
                immediate response to any major emergency or
                disaster. It also ensures that the current federal
                and state (and provincial in Canada) benefits
                provided to police officials, firefighters, and
                other emergency responders (e.g., death benefits,
                worker's compensation, etc.) are continued when
                they are engaged in emergency response
                operations on either side of the border, and
                delineates financial responsibilities for damage
                to equipment and use of manpower. Standard
                operating procedures for the implementation of
                the Memorandum of Understanding are
                incorporated in a cross-border contingency plan
                that serves as an annex to the existing
                contingency plans in the three participating
                areas.

                The signing of the international agreement
                kicked off the planning for a major exercise,
                Operation Big 3 (Disaster Exercise), held on
                September 14, 1991. This massive exercise at
                the Greater Niagara Falls International Airport
                was designed to test the effectiveness of the
                Memorandum of Understanding and all the
                unique planning efforts that went into the
                international agreement. The exercise was a
                simulated air disaster involving approximately
                450 casualties, 50 hospitals, and well over 3,000
                participants, including the Erie County Health
                Department and the Department of Emergency
                Services, and a variety of American and
                Canadian response agencies — law enforcement,
                emergency health and medical responders, fire
                service, and airport response teams — as well as
                many other support groups. This  exercise also
                activated the United States' National Disaster
                Medical System, which supplements and assists
                local governments' medical resources when they
                are overwhelmed  by the magnitude of any
                incident or disaster.

                Exercises

                      In addition  to international coordination,
                      over the past few years the Erie County
                      DES and the Crash/Fire/Rescue Division
                at the Greater Buffalo  International Airport have
                been working together in an attempt to enhance
                response capabilities in the event of an air
                disaster. Because over 90 percent of air disasters
                occur off airport property, planning exercises,
                meetings, and seminars have brought together a
                great number of organizations that must interact
                in the response to  an air disaster or any other

-------
Successful Practices
Erie County, New York
Page?
type of mass casualty incident. A series of
exercises, both full scale and table-top, have
been conducted through the joint efforts of
airport authority and Erie County DES.  One of
the largest of these exercises was "Orbit Sage
'89," a mass casualty simulation that was
conducted simultaneously in Erie County and at
other locations in New York, Pennsylvania,
Connecticut, and Canada. The achievements of
the air disaster planning process were formalized
with the signing of the first mutual aid
agreement between the airport authority and the
local volunteer fire departments.

On October 11, 1990, DES and Crash/Fire/
Rescue Division conducted a second mass
casualty exercise with the National Disaster
Medical System, involving a number of federal,
state, and local agencies. The scenario simulated
the reception of victims in Erie County from a
massive earthquake, occurring along the Madrid
Fault, in Arkansas, where seismographic data
predict that an earthquake will occur in the
future. In this table-top exercise, earthquake
victims received triage at the airport and were
then sent to a variety of area hospitals, including
Canadian facilities. The existing provisions of
the international agreement were activated and
proved to be a tremendous asset to the county,
triggering the involvement of local Canadian
emergency planners, hospitals, communications,
law enforcement agencies, and other resources.

Training

       To further expand the emergency exercise
       program, the LEPC recently began
       implementation of the Public Safety
Critical Incident Management system, a table-
top, emergency simulation methodology. First
developed in Monroe County, New York, the
system involves the use of simulator boards
(HO-scale models of communities originally
designed for training police personnel and thus
easily adaptable to general emergency response
scenarios).  The simulator,board system is used
to examine operational concerns and       , .  ..
responsibilities of participating response    :
organizations  under a unified emergency
operations command structure. A 16-hour
training course, consisting of lectures and
exercises, is offered through the New York State
Emergency Management Office to fire,
emergency medical services, police, and
business and industry representatives. The
         LEPC has already conducted a train-the-trainer
         workshop for 32 local fire, emergency medical,
         and police officials, and hopes to disseminate the
         system to personnel from local response
         agencies through community colleges.

         Emergency Response

                To support the efforts of response agencies
                in communities both with and without
                their own hazmat team, the Erie County
         Hazardous Materials Organization was formed.
         This all-volunteer hazmat response team
         operates under the direction of DES, and
         provides technical, command, security, and  ,
         decontamination assistance. The team has full
         Level A response capability and is available for
         response to any area without a hazmat team or to
         assist an existing hazmat team. The organization
         does  not take control of incidents to which it is
         called; command control remains with the local
         incident commander. The team is available via a
         24-hour hotline and does not bill municipalities
         or fire departments for the costs incurred at an
                     Settlement of Citizen Suits

           The settlement of several citizen suits filed under section
           326 of Title III has provided funding for various local
           emergency planning and response efforts in Erie County,
           including the county response team, outreach activities,
           and contingency planning.  On December  11,  1990,
           agreements were reached in the first two cases settled
           nationally under the citizen suit provisions of Title III.
           After a review of the TRI database and the sections 311-
           312 submissions from ARO Corporation of Buffalo and
           Murray Sandblast and Paint Company of West Seneca,
           the Atlantic States Legal Foundation filed citizen suits
           alleging that these companies  had failed to meet  the
           annual release reporting requirements of section 313 for
           1987 and 1988. Under the settlements, ARO Corporation
           agreed to pay $34,000, and Murray Sandblast agreed to
           pay $10,000 and institute a pollution prevention and
           toxics use reduction/program.      •           :

           A third citizen suit, filed against.Allied Signal, Inc.,'of
           Buffalo:also alleging section 313 violations was settled on
           January 3,1991; Allied Signal agreed to pay a penalty of
           $17,000 (of which $13,500; will be given, to the Erie
           County .LEPC) .and .also to  comply with section 313
           requiremen,ts for the 1990 reporting year and beyond.
           Altogelher,_theLEPChasreceiyedapproximately$50,000
           in these and other citizen suit settlements to finance the
           Erie County Hazardous Materials Organization.

-------
Pages
Erie County, New York
Successful Practices
incident. Instead, the team bills the responsible
party — the transporter, the facility owner, or the
product manufacturer. In addition, the county
has funded the purchase of a Mobile Command
Post, equipped with a CAMEO system loaded
with 750 facility reports, and several local
companies have donated response equipment
(e.g., a decontamination tent and emergency
breathing apparatus) and provided equipment
maintenance services to support the team's
efforts.

Following a chemical fire in 1987, in which
several firefighters were injured, the LEPC
began formally addressing the decontamination
of chemical accident victims.  First, the LEPC's
Hospital Subcommittee conducted a survey of all
Erie County hospitals to determine their current
ability to manage the decontamination process in
emergency rooms. All 15 local hospitals were
evaluated, and the LEPC established a set of
formal decontamination protocols, which have
since been distributed to the hospitals through
the Western New York Hospital Association. In
addition, emergency room personnel from
several area hospitals have received training in
conjunction with the county's mobile
decontamination  unit described below. Erie
County has also funded the purchase of a 35-foot
trailer equipped with a portable decontamination
unit. This vehicle allows firefighters to be
decontaminated on location before being sent by
ambulance to a hospital, thus eliminating the
potential of contaminating ambulances or
emergency rooms. During its first year, the Erie
County Hazardous Materials Organization used
the trailer to assist in decontaminating
firefighters and other personnel at four separate
incidents.
LESSONS LEARNED

International Coordination Follows Path of
LEPC.  Many of the issues related to developing
and implementing the international agreement
follow the trail blazed by the Erie County LEPC.
The initial success of the international agreement
along the border between New York and Ontario
can be traced to the same cooperative spirit that
supports the Erie County LEPC, carried out on a
greater scale with literally scores of participating
entities.  In addition, the creation of a cross-
                border forum has been critical in the planning for
                the 1993 World University Games, to be held at
                locations in Erie and Niagara counties as well as
                in the Province of Ontario. The existing
                coordination structure has simplified the
                development of contingency plans for these
                events, which will feature athletes from 120
                countries and an estimated 500,000 visitors.

                Exercise Pays Off. As a direct result of the on-
                going planning between the LEPC and the
                Crash/Rescue/Fire Division at the Greater
                Buffalo International Airport, the airport was
                able to assist the county during a major gasoline
                leak on November 10, 1990. Responders feared
                that activities to locate and fix the underground
                leak might ignite the gasoline, so the airport
                provided foam trucks to lay a field of foam over
                the gasoline-affected areas in West Seneca. This
                protective action  minimized the danger of an
                explosion that could have injured neighbors,
                motorists,  and emergency responders, and also
                speeded activities to protect the environment
                from further gasoline contamination.

                Facilities are Partners, not Targets.  Beyond
                their direct support for the Erie County
                Hazardous Materials Organization, industry in
                Erie County has become increasingly involved in
                the preparedness  activities of the LEPC, going
                well beyond the submission of emergency
                planning information. This willingness is further
                demonstrated by  the selection of an industry
                representative, rather than the usual emergency
                management or other public official, to serve as
                the chairman of the LEPC. In addition, an
                industry hazardous materials advisory council
                has expressed interest in sending facility
                personnel to participate in the Public Safety
                Critical Incident Management System.
                Contact:

                Art Domino, Erie County LEPC
                Erie County Department of Emergency Services
                95 Franklin Street
                Buffalo, NY 14202
                (716)858-6578

-------
Successful Practices
State of Arizona
Paged
       The Arizona Division of Emergency
       Management (ADEM) is designated by
       state law as the lead agency for
       implementing Title III. The hazardous
materials staff of ADEM is the support arm of
the SERC for implementing and performing
commission duties and activities, and for
integrating EPCRA with the state hazardous
materials emergency management program.
This is accomplished through the SERC
Executive Director who is also the Assistant
Director for Hazardous Materials within ADEM.
The SERC normally meets three times a year.

The Arizona SERC organized the LEPCs by the
15 county jurisdictions. Emergency
management directors/coordinators are an
                                                  State of
                                                  Arizona
         integral part of LEPC operations and chair the
         committees in 10 of the 15 jurisdictions.

         The SERC/ADEM conducts outreach to build
         positive relationships among LEPCs, industry,
         Indian nations, and other groups in the state.
         Through extensive seminars and workshops, the
         SERC/ADEM keeps industry and the LEPCs up
         to date on Title HI requirements and changes in
         the law. The SERC/ADEM stays "on the road,"
         assisting industry during section 313 compliance
         inspections and chemical safety audits conducted
         by the U.S. Environmental Protection Agency
         (EPA), and offering its assistance to Indian
         nations and to cities along the Arizona/Mexico
         border as they develop emergency management
         strategies. The SERC/ADEM has found that the
  Membership: Director of the Arizona Division of Emergency Management and directors or
              designees of the Arizona Departments of Environmental Quality, Health Services,
              Public Safety, and Transportation.

              An advisory committee to the Commission consists of the State Fire Marshal, the
              director, chief administrator or designee of the Department of Agriculture,
              Corporation Commission, Industrial Commission, Arizona Radiation Regulatory
              Agency, State Mine Inspector, two representatives nominated by the Arizona Fire
              Chiefs Association, and four private sector representatives.

  Organization: 15 LEPCs representing the 15 Arizona counties

  Topics:      Outreach
              Training
              Compliance
              Indian Tribes
              International Coordination

-------
Page 10
State of Arizona
Successful Practices
best way to meet its Title ffl responsibilities is
through regular communication and outreach to
LEPCs and all groups in the state involved in
hazardous materials emergency management.

Outreach

   T  n 1991, the Arizona SERC/ADEM
   •*•  sponsored approximately 20 Title HI
       seminars, lectures, and workshops.
Several of these were developed in conjunction
with the Center for Environmental Studies at
Arizona State University (ASU).  The topics of
the seminars range from compliance issues to
emergency  planning.  Industry personnel,
government personnel, and other professionals
involved in emergency management depend on
these programs for accurate and up-to-date
information on environmental regulations.

One series of Title HI seminars held in
conjunction with ASU that began as a half-hour
presentation at a Resource Conservation and
Recovery Act (RCRA) seminar in 1989, has
since become a full-day presentation given twice
a year. In November 1991, for example, the
SERC/ADEM and the Center for Environmental
Studies sponsored a one-day Right-To-Know
"refresher course." The seminar was open to
government staff, facility representatives,
emergency services personnel, professionals
from the safety, health, and environment sectors,
and the public. Lectures and discussion sessions
covered all aspects of Title III.

One of the SERC/ADEM's innovative
techniques  is incorporating the Emergency
Planning and Community Right-to-Know
Information Hotline into the seminars, giving
seminar attendees the opportunity to experience
the hotline  first-hand. At a specified time during
the seminar, a hotline information specialist calls
the seminar and briefly explains the purpose of
the hotline. The audience then has the
opportunity to ask questions of the specialist
regarding use of the hotline. This informal
introduction exposes seminar participants to the
hotline and increases the likelihood that they will
use the hotline in the future.

For three years, the SERC/ADEM has sponsored
half-day Title in section 313 workshops
following the jointly sponsored ASU seminars.
The workshops, conducted with representatives
from EPA, give industry representatives and the
         public an opportunity to discuss section 313
         requirements with both federal and state
         officials. Topics covered during these
         workshops include changes to Form R reporting
         requirements and the new Pollution Prevention
         Act requirements.

         Other Tide III seminars and workshops are
         sponsored jointly by the Arizona SERC/ADEM
         and the EPA Region 9 office.  In 1990, for
         example, the SERC/ADEM, EPA Headquarters,
         and EPA Region 9 conducted two hazards
         analysis workshops in Arizona for over 100
         LEPC representatives, industry personnel, and
         fire fighters. The workshops stressed the
         importance of each facility conducting its own
         hazards analysis with the public sector also
         conducting a community-based analysis.  The
         philosophy behind this approach is that, although
         facilities may know more about chemicals they
         store or use, the public sector has greater overall
         knowledge of the makeup (e.g., sensitive
         populations, ecosystems) of the community.

         Participants at the workshop learned to use the
         Technical Guidance/or Hazards Analysis, also
         known as the "Green Book" as a tool for
         conducting community-based hazards analysis.
         The participants completed worksheets about
         chemicals in their communities before coming to
         the workshop and then were able to work out
         "real life" problems with the help of the SERC/
         ADEM and EPA representatives. The workshop
         not only provided an introduction to community-
         based hazards analyses, but also prepared
         participants to conduct full-scale hazards
         analyses on their own. In addition, the
         workshops also provided a basis for participants
         to use hazards analysis data incorporated in the
         Computer-Aided Management of Emergency
         Operations (CAMEO) DOS program.

         Additional SERC/ADEM-sponsored workshops
         for the Arizona LEPCs cover topics such as risk
         communication, liability, emergency
         management, CAMEO, and the Aerial Locations
         of Hazardous Atmospheres system (ALOHA) -
         an air dispersion model that allows the user to
         estimate the movement and dispersion of an air
         release. In an effort to keep the LEPCs up-to-
         date, the SERC/ADEM offers financial
         assistance to the LEPCs for transportation to the
         workshops and always encourages them to
         attend.

-------
Successful Practices
State of Arizona
Page 11
                            Information Management Using CAMEO DOS

  Following the initial development of CAMEO DOS—'• a computer system that provides a wide variety of databases,
  including information on facilities and the chemicals they store, transportatron,-and local street maps to assist emergency
  responders '±- the Arizona SERC/ADEM was selected .by EPA to be a "beta test" site for theCAMEO DOS software.
  Upon successful completion of the beta test, the SERC/ADEM elected to implement CAMEO at the state and LEPC
  levels. The CAMEO DOS software as well as additional computer hardware were purchased to provide each LEPC the
  equipment necessary to work with their respective county map file and planning data. The SERC/ADEM has created
  maps for each of the LEPCs jurisdictions using theMARPLOT conversion program arid the U.S. Census Bureau's CD-
  ROM TIGER/line files. The maps can be used to present a street-by-street identification of sensitive populations and
  the locations of hazardous chemicals.

  To expedite establishing a statewide CAMEO system, EPA assisted in developing an import program to convert
  Arizona's existing database into CAMEO. This program converted all the Title III data received prior to 1990, which
  covered some  3,500  facilities and over 5,000 chemicals.  An additional 1,700 facilities filed in  1991 and were
  incorporated into the database. The LEPCs and all state emergency response organizations receive their jurisdictional
  information via diskette. Fire departments can obtain this information by contacting the SERC/ADEM or the LEPC in
  their area.                              •

  In October 1991, the SERC/ADEM conducted a CAMEO DOS train-the-trainer course. Two members of the SERC/
  ADEM and seven emergency responders from fire departments from around the state attended. These individuals are
  now available to provide training throughout the state. Following the train-the-trainer course, four two-day "Introduction
  to CAMEO DOS" courses were conducted in 1991. Students in the introduction course's included personnel from the
  LEPCs, state emergency response organizations, and various fire departments that also:have CAMEO. In all, over 45
  personnel were trained in the five courses.

  This year, the SERC/ADEM will conduct two CAMEO DOS introduction courses. There will also be three CAMEO
  DOS advanced workshops that will  include training on the Aerial Locations of Hazardous Atmospheres (ALOHA)
  system.  "                                                            ^   ' -   - • '• •  • ~l '   "- :
Training

       Training is another key element to
       supporting LEPC and local emergency
       response personnel.  As of June 30, 1992,
the Arizona SERC/ADEM conducted and/or
sponsored 172 hazardous materials emergency
response training activities reaching 3,286
students statewide.  A two-person training staff
and a cadre of part-time state certified instructors
are responsible for preparing Arizona's
responders for hazardous materials incidents.

Arizona's courses are consistent with the
training requirements of 29 CFR  1910.120 (q)
and with the National Fire Protection
Association's Professional Standard 472. First
Responder Awareness, First Responder
Operational and Technician courses are the most
requested training activities.  In addition, the
SERC/ADEM sponsors emergency response
courses offered locally by EPA.
           Arizona recognizes the importance of supporting
           the needs of emergency responders by providing
           training, by making them part of the planning
           process, and by providing them with facility
           data. The SERC/ADEM coordinates all .these
           elements to ensure that emergency response.'
           personnel  are prepared to protect the public, the
           environment, and themselves.

           Compliance

                  The majority of the SERC/ADEM's
                  outreach efforts are geared towards
                  helping industry in Arizona meet the
           requirements of Title III. A primary objective of
           the SERC/ADEM is to "soften the blow" of Title
           III reporting requirements by offering assistance
           and education to facilities covered by the law.
           For example, the ADEM Title HI coordinator is
           present at  facilities during section 313
           compliance inspections conducted by EPA. The
           Title III coordinator assists facilities by

-------
Page 12
State of Arizona
Successful Practices
answering questions, interpreting the law, and
helping assemble the documents needed by the
inspector. This methodology gives the SERC/
ADEM an opportunity to talk with facility
managers and be sure the managers know what
is expected of them under all parts of Title III,
not only section 313.

Another way the SERC/ADEM has helped ease
the burden of Title IE reporting for industry is by
modifying the federal Tier II reporting form to
better fit the needs of industry in Arizona. The
SERC/ADEM rewrote the instructions for the
form and removed any reference to the Tier I
form, since the Tier II is mandated in Arizona.
The new instructions include local phone
numbers that facilities can call with questions
about Tier II.

The SERC/ADEM also developed a Tier Report
Error Notification Data Sheet (TRENDS) that
identifies any error(s) on the Tier n submissions.
The Tier II report  and TRENDS package is
returned to the submitter who is directed to the
appropriate portion of the instructions to correct
the error(s) or asked to contact the SERC/ADEM
staff for guidance. The facility then resubmits its
corrected Tier II to all reporting agencies and is
better prepared for submitting accurate reports in
the future. "Helping people not make errors" is
the SERC/ADEM's objective,  says Dan Roe, the
Title ffl coordinator.

The SERC/ADEM also participates with facility
visits conducted under EPA's Chemical Safety
Audit (CSA) program. The CSA program is
designed to heighten awareness of the need for
chemical safety among chemical producers,
distributors,  and users.  Chemical safety audits
consist of interviews with facility personnel and
on-site reviews of various aspects of facility
operations related to the prevention of accidental
chemical releases. A representative from the
Arizona SERC/ADEM has accompanied the
EPA audit teams on every chemical safety audit
conducted in Arizona in order to assist facilities
and EPA during the audits.

The SERC/ADEM representative visits facilities
before an audit is conducted to go over the audit
process and to encourage the facility to prepare a
briefing for the audit team.  Briefings generally
provide an overview of the facility, its chemical
         processes, and other operations such as shipping
         and receiving practices and storage methods. All
         Arizona facilities that have been audited have
         prepared a briefing that has assisted the facility,
         the audit team, the LEPC, and the SERC/ADEM
         by providing background information about the
         facility's management of chemical process
         safety.

         Indian Tribes

                Arizona outreach efforts also extend to
                Indian nations. The state is home to 20
                Indian nations with a wide variety of
         privately-owned industries located on their land.
         While some Indian nations or tribes have the
         capability to handle emergency response
         independently, the state hazardous materials
         emergency response team from the Departments
         of Public Safety and Environmental Quality will
         respond to emergencies at an Indian nation's or
         tribe's request.

         The SERC/ADEM is very interested in
         maintaining a partnership with the Indian nations
         as they develop strategies for implementing Title
         in. At one tribe's request, the SERC/ADEM
         met with tribal leaders to discuss Title III and
         hazardous materials emergency preparedness so
         that, as one SERC/ADEM representative said,
         "the tribes don't have to reinvent the wheel."
         These meetings also provide an opportunity for
         the tribes and the SERC/ADEM to exchange
         information on chemicals stored at facilities
         within the reservations and on the periphery of
         their boundaries. Such an exchange benefits
         both the tribes and the SERC/ADEM as they
         develop or modify existing emergency response
         plans.

         Emergency response exercises are conducted
         occasionally by the SERC on Indian reservations
         at the tribes' request.  The SERC/ADEM
         recently assisted in conducting such an exercise
         at Peach Springs, on the Havasupai Reservation.
         This was a table-top exercise based on a
         transportation accident involving hazardous
         materials. Tribal leaders, the chair of the
         Mohave County LEPC (also the director of the
         nearby Mohave County Emergency Services
         Division), public safety officials, and others in
         attendance worked through the problems of
         handling the spill and coordinating the response

-------
Successful Practices
State of Arizona
Page 13
 among different agencies (e.g., hospitals, fire
 departments, police). Exercises such as the one
 in Peach Springs increase the county's and
 tribes' awareness of the need for emergency
 preparedness and provide the opportunity to
 smooth out problems in response plans before
 real emergencies occur.

 All in all, the SERC/ADEM's efforts to assist
 Indian tribes have been very well received. The
 SERC/ADEM has worked directly with at least
 four tribes on emergency management issues.
 Two of the tribes have set up TERCs of their
 own and the SERC/ADEM is working to help
 other tribes do the same.

 International Coordination

       In addition to its involvement with
       sovereign Indian nations, the Arizona
       SERC/ADEM, in coordination with EPA
 Region 9, participates in outreach to
 communities along the U.S./Mexico border. The
 SERC/ADEM began working with EPA and the
 United States/Mexico Inland Join Response
 Team (JRT) over a year ago and the executive
 director of the SERC is a member of the JRT.
 The JRT coordinates preparedness and response
 activities for hazardous substance emergency
 incidents along the joint U.S./Mexico inland
 border.  The JRT is activated in the event of a
 significant hazardous substance incident in the
 border area. Additionally, the JRT serves as a
 conduit for information about each country's
 hazardous substance emergency preparedness
 and response activities.

 Emergency response planning for small spills
 along the border is handled by EPA, the states,
 and the 14 pairs of Sister Cities designated along
 the U.S./Mexico border.  The Sister Cities work
 in pairs to plan emergency notification
 procedures and joint hazardous materials
 responses in the event of an accidental chemical
 release on either side of the border. The
 Directors of EPA's Chemical Emergency
 Preparedness and Prevention office (CEPPO)
 and the Secretaria de Desarrollo Social
 (SEDESOL) serve as Co-chairs of the JRT.
         Other members of the JRT include regional
         EPA, federal and SEDESOL officials, as well as
         SERCs and LEPCs located in the border area.

         The SERC/ADEM provides technical assistance
         to the four border towns in Arizona that are
         working on Sister City plans with their Mexican
         counterparts.  The SERC/ADEM recently held a
         Public Officials Conference for the Sister City
         pair of Douglas, AZ, and Agua Prieta, Sonora, to
         provide an orientation on hazardous materials
         emergency management programs and planning
         activities of the United States and Arizona. City
         managers, public works employees, and mayors
         attended the conference and learned about issues
         such as environmental laws, liability, Sister
         Cities hazardous materials plans, and EPA and
         SEDESOL's roles in the JRT.

         The SERC/ADEM recently participated in a
         three-day hazardous materials first responder
         training course conducted by  the University of
         California (Davis) for first responders in the
         border area. Topics covered included safety
         during hazmat incidents, instruction in the use of
         the DOT Emergency Response Guidebook,
         identification of hazardous materials, field
         decontamination, agency coordination, and
         contingency planning.  A similar emergency
         response training course was held for the Sister
         City pairs of Nogales, Sonora/Nogales, AZ and
         San Luis, Rio Colorado/Yuma, AZ. All of the
         training courses for emergency responders on
         both sides of the border are conducted in both
         English and Spanish.
          LESSONS LEARNED

          Constantly Going to the Basics.  Recognizing
          that environmental laws such as Title III can be
          overwhelming for industry when looked at all
          together, the SERC acts as a funnel, receiving
          information from the federal level on new
          requirements for industry and then consolidating
          this information into more digestible forms.  The
          information is conveyed to industry throughout
          the state through seminars, workshops, and the
          Arizona LEPCs.

-------
Page 14
State of Arizona
Successful Practices
Keeping Linked with Other Programs. In
order to be most helpful to industry, the SERC/
ADEM goes beyond its primary role of
implementing Title III by staying current on
other, related programs, such as RCRA and the
Clean Air Act. Members of the SERC/ADEM
believe they "can't work within a box" where
they understand only Title El.  The SERC/
ADEM wants to understand how the many
programs that relate to emergency management
overlap so that they can clarify confusing issues
for industry in the state.

Developing a Partnership with Indian
Nations. The SERC/ADEM views its
relationship with Indian nations as a partnership,
where the sovereignty of the tribes is fully
recognized. The SERC/ADEM explains the
lessons they learned so that the tribes can avoid
some of the pitfalls they may encounter. The
interaction between the SERC/ADEM and the
tribes is beneficial to the SERC/ADEM as well,
because the tribes can assist the SERC/ADEM
by sharing information about facilities handling
hazardous chemicals on their land.
         Contact:

         Ms. Ethel DeMarr, Executive Director
         Arizona Emergency Response Commission
         5636 East McDowell Road
         Phoenix, AZ 85008          ..'-.--
         (602)231-6326

-------
Successful Practices
Mohave County, Arizona
Page 15
                                                               Mohave County,
                                                                     Arizona
       Mohave County is home to some of the
       largest natural and man-made points-of-
       interest in the United States, including
       the Grand Canyon, the Hoover Dam, and
 portions of the Colorado River. Set in the
 northern and western portions of Arizona,
 Mohave County has the fifth largest area of any
 county in the U.S.  There are three primary
 population centers  in the county:  Kingman,
 Lake Havasu City, and Bullhead City, each with
 a population of approximately 20,000, and each
 separated from the others by 40 miles or more.
 An industrial park, including light industry such
 as a cable company, a boatmaker, and a
 housewares warehouse, is located in Kingman.
 The industrial park also contains a Union
 Carbide facility. There are two major
 transportation routes: Highway 93, which runs
             north to south, and 1-40, which run east to west
             through the county. There is also one major
             railroad through the county — the Atchison/
             Topeka/SantaFe (ATSF).

             LEPC Organization

                    The structure of the LEPC allows for
                    maximum county-wide participation.
                    Three subcommittees have been
             established to handle emergency planning for the
             facilities in each of the three main cities —-
             Kingman, Lake Havasu City, and Bullhead City.
             The LEPC meets every two months on a rotating
             schedule among the three major cities. Because
             the county is extremely large, this schedule was
             established to increase the opportunity for
             interested parties to participate in meetings
  Membership:  28 members including, representatives from the Mohave County Board of
               Supervisors; Mohave County Emergency Services; industrial facilities; medical
               services; city police and fire departments; Mohave County Sheriff's Office; media;
               Kingman Area Chamber of Commerce; Citizens Against Toxic Substances-
               (C.A.T.S.); Bureau of Land Management-Kingman Resource Area; and,private
               citizens (chair: Mohave County Emergency Services Director).        ! ..

  Population:    93,500                                            .      ^      :.:,.:,:  • .;

  Facilities:     40, including a Union Carbide plant; approximately 4-5 facilities report under •  . •'-''-
               section302, 60 (including 20 service stations) under section 312.   /     ,  ,. '

  Topics:       LEPC Organization                                          ,     ;
               Inter-jurisdictional Coordination                         •               '/  :
               Exercises          .                                      •          ,
               Emergency Planning                                             •

-------
 Page 16
Mohave County, Arizona
Successful Practices
without having to travel extensively.  A core of
about half of the members attend all meetings.

In general, media representatives, although
members of the LEPC, do not attend meetings
regularly due to travel requirements (except for
the Bullhead City representative). However,
because the media has participated on the LEPC
in the past, a strong relationship has developed
between the media and the LEPC, and the media
has been very cooperative in helping the LEPC
disseminate information to the public. To date,
press releases have been the LEPC's primary
outreach mechanism to the community, although
they are interested in improving their outreach
programs.

Although relatively few facilities that handle
hazardous chemicals are in Mohave County,
there is a cluster of significant industrial activity
at the Kingman Industrial Park, near the
Kingman Airport. A Union Carbide facility
produces arsine and phosphine gases, and
another large facility in the industrial park
manufactures ethylene oxide.

In 1998, concerned community members formed
Citizens Against Toxic Substances (C.A.T.S.) as
a result of the proposed opening of the Union
Carbide facility. Over 8,000 signatures opposing
the plant opening were collected by the  C.A.T.S.
organization. The public outcry over the use of
hazardous substances such as ethylene oxide so
close to a population center caused Union
Carbide to relocate a portion of the facility —
the most hazardous operations were moved to a
location 14 miles outside of Kingman. As a
result, Union Carbide has also beome actively
involved in the LEPC — the Union Carbide
plant manager is a member of the LEPC and is
head of the LEPC's Kingman district
subcommittee.

Inter-Jurisdictional Coordination

       Mohave County recognizes the need to
       coordinate with nearby communities to
       mitigate potential hazards and promote
information and idea sharing. As part of this
process, Mohave County conducted a peer
exchange workshop with Clark County, Nevada
in October 1991. The peer exchange program is
a relatively new grant program run through the
International City Managers Association
(ICMA). The process is simple: LEPCs apply
                to ICMA, and ICMA matches up LEPCs that
                will benefit from an exchange with those that
                feel they have valuable information or programs
                to share. At the Mohave-Clark workshop, the
                participants decided that they would take part
                over the next year in mutually beneficial
                activities such as sharing hazardous materials
                planning information, identifying facilities along
                the Clark County-Mohave County boundary that
                pose concerns for people in both counties,
                conducting a cooperative emergency response
                exercise, and completing mutual aid plans for
                emergency response. Clark County is directly to
                the west of Mohave County and is home to Las
                Vegas and Henderson, the site of the 1988
                explosion at an ammonium perchlorate rocket
                fuel plant.  The fire departments in the two
                counties will be holding a joint exercise in
                October 1992; a peer exchange between Clark
                County and Mohave County is scheduled to
                follow the drill.

                Exercises

                      The exercise being planned for the fall of
                      1992 is only one portion of Mohave
                      County's exercise program. In fact, the
                Mohave County LEPC has been very active in
                holding exercises.  In the past year there have
                been two field exercises, one involving a
                transportation incident and one a fixed facility.
                The fixed facility field exercise involved a
                simulated leak from a one ton chlorine cylinder
                from the City of Kingman swimming pool,
                planned by Kingman Fire Department and
                Kingman hospital.  Both a school and a hospital
                are within the vulnerable zone of the chlorine
                facility. The vulnerability displayed by the
                exercise really "hit home" with the community
                and has led to tangible prevention measures. As
                a result of the exercise, the city plans to replace
                chlorine gas with dry chlorine for public
                swimming pools by the summer of 1992. This
                type of prevention is a cornerstone of the
                Mohave County LEPC philosophy.

                Emergency Planning

                      While the LEPC will review and revise its
                      emergency plans as a follow-up to its
                      exercises and accidents, it also conducts
                an annual plan review. The three subcommittees
                each have plans specifically addressing reporting
                facilities. Subcommittee plans are revised when
                new reporting facilities enter the district.

-------
Successful Practices
Mohave County, Arizona
Page 17
Because the community is small, the
subcommittees are able to find out about the
opening of new plants that would be subject to
section 302 reporting through word of mouth and
local news coverage.

Mohave County is also the home to three Native
American Reservations: the Kaibab
Reservation, the Fort Mohave Reservation, and
the Hualapai Reservation. The County
Department of Emergency Services is working
with Hualapai Native Americans to assist in
developing a tribal emergency operations plan
containing an emergency response plan for
hazardous materials.

A tabletop exercise based on a transportation
accident, the first to involve the tribe, was
conducted on May 4,1992, in Peach Springs.
Tribal leaders, the LEPC Chair, public safety
officials, and others addressed the problems
associated with handling the spill and
coordinating the response among different local
agencies.  In addition to holding their exercise,
the tribe is considering establishing its own
Tribal Emergency Response Commission (the
equivalent of the SERC). Exercises and
programs such as these will increase the tribe's
awareness of emergency preparedness and,
hopefully, will inspire the other tribes to do the
same.
 LESSONS LEARNED

 A Well-Rounded LEPC Equals Compromise
 and Good Community Relations. Many
 different organizations and groups within the
 county have representatives on the 28-member
 Mohave County LEPC. This blend of
 individuals not only assures widespread
 community representation, but also provides a
 useful forum for the exchange of differing
 viewpoints.  Because everyone from industry to
 environmental groups has a voice on the LEPC,
 the group works to achieve a balanced program.

 Since October 1989, a representative from
 Citizens Against Toxic  Substances (C.A.T.S.),
 the first local grassroots environmental
 organization in Mohave County, has been a
 participant on the LEPC. The C.A.T.S.
 representative joined the LEPC during the
 conflict over the Union Carbide plant siting, and
 although initially intimidated and uncomfortable
              "Most fundamentally, the two sides learned
              how to talk to one another in Kingman, and that
              is no small doing."

                          Chemical & Engineering News,
                                        January 7,1991
             working with facility representatives, the
             C.A.T.S. representative believes that the LEPC
             provides a useful forum for the exchange of
             ideas. The Mohave County LEPC has learned
             that there is a "human factor" involved in
             emergency planning and wants the community to
             know that the LEPC is more than just
             technicians and government employees.  It is
             important that everyone has an equal voice and
             that the LEPC is a good way for different facets
             of the community to express their concerns.  The
             diversity of the planning committee forces
             individuals with disparate viewpoints to
             overcome their differences and address safety
             problems that pose risks to the community.

             Another important focus of the Mohave County
             LEPC is learning from past experiences and
             developing future programs to best suit the needs
             of the community. The group believes in
             "immediate corrective action" and when they see
             problems, they attempt to address them quickly
             and determine a safer and more effective course
             of action. For example, when a safety device on
             a nitrogen storage vessel malfunctioned, the
             sheriffs office immediately came in to help.
             Because only the fire department  has SCBA
             (self-contained breathing apparatus) equipment,
             it was important for the sheriff's office to be
             aware that although they wanted to assist in the
             response, their services were more useful in
             securing the area and providing crowd control.
             This problem was addressed though the LEPC,
             and when an alarm sounded a short time later,
             the response process worked smoothly.
             Contact:

             Jerry D. Hill, Chairman
             Mohave County LEPC
             Mohave County Emergency Services
             P.O. Box 7000
             3675 E. Andy Devine Avenue
             Kingman, Arizona 86402-7000
             (602) 757-0910

-------
Page 18
                     Successful Practices
                                More Successful Practices

       Additional Successful Practices in Title in 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
                                                 Successful Practices #9        ,  -
                                                 Doc. # OSWER-92-006.1, September 1992. _

                                                 T      _Natrpria County,1 Wyorning , ,. _.  ''
                                                 .-: :,n>;Erie County, New York   ".,.,-•;".- '.;'•• ':<
                                                       State of Arizona
                                                       Mohave County, Arizona

-------
Successful Practices
                                                      Page 19
                                 Regional Chemical Emergency
                         Preparedness and Prevention Coordinators
               Ray DiNardo
               EPA - Region 1
               New England Regional Lab
               60 Westview Street
               Lexington, MA 02173
               (617) 860^301

               John Ulshoefer
               EPA-Region 2
               2890 Woodbridge Avenue
               Edison, NJ 08837-3679
               (908) 321-6620

               David Wright
               EPA - Region 3
               Oil and Title HI Section
               841 Chestnut Street
               Philadelphia, PA 19107
               (215) 597-5998
    Henry Hudson
    EPA-Region 4
    345 Courtland Street, NE
    Atlanta, GA 30365
    (404) 347-1033

    Mark Horwitz
    EPA - Region 5
    77 West Jackson
    HSC-9J
    Chicago, IL 60604-3590
    (312)353-1964

    Jim Staves
    EPA - Region 6
    Allied Bank Tower
    1445 Ross Avenue
    Dallas, TX 75202-2733
    (214) 655-2270

    Ed Vest
    EPA-Region 7
    726 Minnesota Avenue
    Kansas City, KS 66101
    (913)551-7308


States By Region
Cheryl Chrisler
EPA - Region 8
One Denver Place
999 18th Street, Suite 500
Denver, CO 80202-2466
(303) 293-1723

Kathleen Shimmin
EPA - Region 9
75 Hawthorne Street (H-l-2)
San Francisco, CA 94105
(415) 744-2100

Walt Jaspers
EPA - Region 10
1200 6th Avenue (HW-114)
Seattle, WA 98101
(206) 553-4349
                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

-------
Page 20	•    	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); Natrona County, Wyoming
      (SP9:l-2)

      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); Harford County, Maryland (SP7:14-15); Arapahoe County,
      Colorado (SP8:23); Erie County, New York (SP9:5-8)

      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.

-------
Successful Practices
Subject Index
Page 21
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); Mohave County, Arizona (SP9:16); Natrona County, Wyoming (SP9:3)

       Table-top programs:
       Hartford County, Maryland (SP7:15); Dallas County, Texas (SP7:20); Hamilton County, Ohio
       (SP6:9-10); Cumberland County, Maine (SP5:11); Erie County, New York (SP9:7); Arizona
       (SP9:12-13); Mohave County, Arizona (SP9:17)
Funding;
       Citizen Suits:
       Erie County, New York (SP9:7)

       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 (SPlrlO); 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:
       CuyahogaCounty, 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)

-------
Page 22
Subject Index
Successful Practices
JHTasards Analysis (continued);

      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)

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); Arizona (SP9:10);
      Natrona County, Wyoming (SP9:3)

      Conversion software:
      Greene County, Missouri (SP8:13)

      dBase:
      El Paso County, Colorado (SP4:7); Bucks County, Pennsylvania (SP7:9); Natrona County,
      Wyoming (SP9:1-2)

      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)

      "Packet" 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); Natrona County,
      Wyoming (SP9:3)

      Worksheet forms:
      Washtenaw County, Michigan (SP1:5)

-------
Successful Practices
Subject Index
Page 23
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); Mohave County, Arizona (SP9:16)

      International coordination:
      Maine (SP4:18); Cameron County, Texas (SP7:l-3); Arizona (SP9:13); Erie County, New York
      (SP9:5-8)


LEPC Organization:

      Pre-SARA/Title III 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 (SP8:1 l-13);Pampa, Texas (SP2:4); Jefferson
      County, Kentucky (SP1:10); Mohave County, Arizona (SP9:15-16)


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)

      Indian Tribes:
      Arizona (SP9:12-13)

-------
Pag© 24
Subject Index
Successful Practices
Outreach Programs (continued);

      Industry:
      Virginia (SP3:4-5); Arizona (SP9:9-11)

      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); Arizona (SP9:10-13); Natrona
      County, Wyoming (SP9:2-3)

      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)

      Media Use (TV, radio, newspaper):
      Kansas (SP1:3); Buder 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); Natrona County, Wyoming (SP9:2,4); Mohave
      County, Arizona (SP9:16)

      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)                               '.'.-•


jReporting Modifications;
      Ohio (SP6:2); Oauchita Parish, Louisiana (SP6:20); Hawaii (SP8:19)
Right-tQ-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)

-------
Successful Practices	Subject index	Page 25

Section 313 Data:

       Accessibility and analysis:
       Connecticut (SP5:8); El Paso County, Colorado (SP4:9); Ohio (SP6:3-5); Dallas 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)

       Hospital Preparedness:
       Erie County, New York (SP9:6-8)

       Indian Tribes:
       Mohave County, Arizona (SP9:12-13)

       Nursing homes:
       Cherry Hill, New Jersey (SP8:4)

       Schools:
       Wallingford, Connecticut (SP6:13); Harford County, Maryland (SP7:14)

       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 (SP7:11); 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, Oklahoma (SP5:3); Connecticut (SP5:7); Cumberland County, Maine (SP5:11); Wallingford,
       Connecticut (SP6:15); Harford County, Maryland (SP7:15); Cherry Hill, New Jersey (SP8:3-4);
       Cameron County, Texas (SP7:3); Arizona (SP9:13)

       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)

-------
Page 26
Subject Index
Successful Practices
Training Programs (continued);

      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); Erie County, New York
      (SP9:7)
Vulnerability Analysis;
      Cuyahoga County, Ohio (SP2:9); Hamilton County, Ohio (SP6:8); Wallingford, Connecticut
      (SP6:14-15); Greene County, Missouri (SP8:13-14)

      HBRT:
      Bucks County, Pennsylvania (SP7:11)

-------