United States
Environmental Protection
Agency
Solid Waste
and .Emergency
Response (OS-120)
September 1992
OSWER-92 -009.1
Series 9, No. 2
&EPA Making It Work
Hazards Analysis
Are your community
planners trying to
answer the following
. questions:
What are the major
chemical hazards in
our community?
How can we
determine the area
or population likely
to be affected by a
release?
What emergency
response resources
(personnel and
equipment) does our
community need? "
What kind of
. training do local
responders -need?
How can we help
prevent chemical
accidents?
The hazards analysis
process described in this
bulletin can assist local
planners in answering
these and pther important
planning questions.
Hazards analysis is a way
of identifying the threats
that hazardous substances
such as ammonia,
WHY CONDUCT A
HAZARDS ANALYSIS?
chlorine, and other
chemicals pose in the
community. Under the
Emergency Planning and
Community Right-to-
Know Act (commonly
known as EPCRA or
Title III), communities
conduct hazards analyses
to develop and revise
emergency plans.. These
plans are based on
facilities where
extremely hazardous
substances (EHSs) are
present in amounts
exceeding the threshold
planning quantity (TPQ),
and for other facilities or
transportation routes that
the Local Emergency
Planning Committee
The Making It Work bulletins are intended to provide
technical assistance to those responsible for implementing
the Emergency Planning and Community Right-to-Know
Act of 1986, commonly known as EPCRA or Title III.
Hazards Analysis, the second in the series, is intended for
members of Local Emergency Planning Committees
(LEPCs), State Emergency Response Commissions
(SERCs),fire departments, andotheragenciesresponsible
for emergency planning and hazards analysis. The first
bulletin addressed Tide III compliance and future bulletins
will cover such subjects as SERC operations and funding.
Inside you' 11 find practical information on hazards analysis,
with examples drawn from successful or unique state and
local programs. You'll also find information on resources
available to help you establish your own hazards analysis
program. If you know of Qther innovative hazards analysis
programs, we'd like to hear about them. Contact your
EPA Regional Title III office (see page 15) or the
Emergency Planning and Community Right-to-Know
Information Hotline at 1-800-535-0202.
(LEPC) identifies as a
focus of planning efforts.
The following three steps
to a community-level
hazards analysis are
described in the
Technical Guidance for
Hazards Analysis, or
"Green Book."
Hazards identification
identifies the location,
quantity, storage
conditions, and the
specific hazards posed
by the hazardous
chemicals transported,
manufactured, stored,
processed, and used in
the community.
Vulnerability analysis
locates geographical
areas and the people, .
property, services, and
. natural areas that may
be affected by a
release.
Risk analysis provides
a ranking of specific
release scenarios (e.g.,
X pounds of chemical
Y released from facility
Z under certain
conditions) based on
the likelihood and
severity of the release.
(continued on page 2)
-------
Why Conduct a Hazards
Analysis?
(continued from page 1)
The Handbook of
Chemical Hazard
Analysis Procedures, or
"Brown Book,"
describes four steps
within the hazards
analysis process. The
extra step, consequence
analysis, is simply an
elaboration of the risk
analysis step discussed
above.
To be'successful, hazards
"analysis must be an
ongoing process the
three steps should be
repeated to address
changes in the hazards
arid other circumstances
in the community that
affect emergency
planning and response.
Coordination between
facilities and local
emergency planners and
responders during the
process will ensure a
thorough evaluation of
the community's hazards
and allow planners to
focus their efforts on the
greatest potential threats
to the community.
Local emergency
planners should consider
conducting the hazards
analysis process in
phases. This "phased"
approach will allow
planners to reduce the
initial expenditure of
valuable resources on
analyzing less significant
hazards and instead
focus their efforts on the
most important hazards
in the community. There
are three phases, as
follows:
Screening phase.
Using readily available
information and worst-
case assumptions,
determine which
facilities and hazards in
the community should
be the subject of a more
detailed analysis.
LEPCs can use
Technical Guidance for
Hazards Analysis to
complete this phase
rather quickly.
1 Planning phase.
Refine the initial
(worst-case)
assumptions and get
up-to-date information
from the priority
facilities identified in
the screening phase and
begin to develop the
local emergency plan.
Scenario phase. For
priority facilities and
transportation routes,
develop a range of
specific release
scenarios that could
pose the highest risk to
the community. These
more detailed scenarios
can be used to develop
site-specific emergency
response plans.
The Hazards Analysis
Training Systems
(HATS) illustrated below
and elsewhere in this
publication, is a computer
program developed by
EPA to introduce local
planners to the hazards
analysis process, the
planning process,
vulnerable zone
calculations, and scenario
development. Various
screens from the program
appear throughout this
document. Contact your
Regional Title III office
or the Title III Hotline for
more information about
obtaining HATS.
Hazards Analysis Training System
THREE STEPS OF HAZARDS ANALYSIS
D Hazard Identification
D Vulnerability Analysis
D RiskAnatysis
-------
As illustrated by
another screen
from HATS, identifying
the hazardous chemicals:
that pose a serious threat
to the community is the
first stage of hazards
analysis (see below).
Communities of all sizes
can develop simple
programs, which meet
their needs and match
their resources; to locate
these chemicals and to
identify specific
information on
hazardous situations and
the risks they pose.
Using information
submitted to LEPCs,
planners should first
identify the facilities that
use, produce, process, or
store hazardous
chemicals. Under Title
III, facilities that have
EHSs in amounts
exceeding a TPQ are
KNOW THE HAZARDS:
HAZARDS
IDENTIFICATION
required to notify the
LEPC and designate a
facility emergency
coordinator to serve as
.the contact between the
facility and die LEPC.
Planners may also
consider identifying
other hazardous
chemicals that may pose
significant hazards to the
community. These
include flammable,
reactive, and explosive
substances; pesticides in
rural areas; other
chemicals present in
substantial quantities;
and even EHSs present
in smaller quantities.
Contacting Facilities
The first step is to
determine which
facilities have hazardous.
chemicals. Conducting a
survey of facilities in the
community that handle
hazardous chemicals can
be a time-consuming
process. Developing a
comprehensive list of
facilities to contact can
be difficult if there is no
unified source of
information about
companies in the
community. Local, state,
Hazards Analysis Training System
Hazard Identification - Purpose
Provide the planning committee with information on:
- Chemical Identity
-Quantity
- Physical and Chemical Properties
- Storage Conditions
- Transportation Routes
- Potential Hazards (e.g., taxirity, flammability, reactivity)
and federal
environmental records;
Dun and Bradstreet and
Chamber of Commerce
listings; telephone
directories; tax rolls;
police and fire
department records; and
industry itself can be
sources for compiling
this list.
Once a list has been
compiled, cpmmunities
with a Small number of
facilities may find it
more effective to take a
more personal approach:
contacting facilities by
telephone, or visiting in
person.
For most communities,
success will depend upon
the involvement of the
fire service. Fire
departments conduct fire
prevention inspections,
develop pre-incident
plans, approve
occupancy permits, serve
on the LEPC, and are
usually the first
responders during an
incident. As seen in the
examples cited below,
fire departments can play
a critical role in
gathering information for
Tide III plans.
If facility cooperation is
a problem, fire
departments have the
authority under Title III
section 312(f) to conduct
bn-site inspections and
(continued on page 4)
-------
Know the Hazards
(continued from page 3)
obtain specific location
information on
hazardous chemicals.
.For instance, in Prince
George's County,
Maryland, fire stations
conduct inspections and
hazards analyses and
prepare response plans at
facilities covered under
section 302.
An Alexandria,
Virginia, ordinance
requires businesses that
store, use, or handle
hazardous chemicals to
obtain a hazardous -
substances use permit
from the fire department
As part of the review and
approval process, the fire
department conducts a
facility inspection to
verify the types and
quantities of the
hazardous chemicals
present at the facility;
this process provides an
accurate record for
hazards identification
purposes.
Communities with a
more extensive list of
facilities could create
outreach materials to
maximize the response
from industry and the
usefulness of the
information that is
provided. .Mailing out a
comprehensive survey
may be necessary. For
example, the Wyandotte
County, Kansas, LEPC
developed a chemical
hazards survey to
identify the facilities in
the county that handled
EHSs. Facilities were
issued a questionnaire
that addressed EHSs and
26 other potentially
hazardous chemicals. If
any of these chemicals
were present, the facility
was asked to supply
information on quantity;
conditions of handling
and use; special safety
precautions and control
devices; transportation;
and facility
preparedness, such as
contingency planning,
employee safety training,
and response equipment.
The success of the Title
III planning process
depends upon the active
involvement of both
public and private
individuals; local
. planners should support
facility involvement in
emergency planning, not
simply as an attempt to
force facilities to provide
the required information
although Title III
section 303(d)(3)
authority can be
referenced if necessary
but to tap into
industry's resources in
prevention and response
efforts. Local planners
may want to designate a .
contact person for
facilities that may be
unfamiliar with the
requirements of Title III.
Some facilities have
developed community
outreach programs as a
part of the Chemical
Manufacturers
Association's
Responsible Care
program. Responsible
Care facilities are
committed to effective
public dialogue and
addressing public
concerns by improving
facility performance.
Local planners should
strive to coordinate
efforts with these
companies and
encourage other facilities
to become involved.
Rlght-to-Know
For each facility,
planners should identify
the quantity of each
hazardous chemical
present at any storage or
processing location, the
physical and chemical
properties of each
substance of interest, and
the conditions of storage.
This information may be
drawn from Title III
reports under sections
31 lor 312, as well as
inspection and permitting
..records of state and local
agencies; additional data
may be requested from
the facility itself.- As part
of Title Ill's "Right-to-
Know" concept, section
303(d)(3) requires
facilities reporting under
section 302 to provide
the LEPC, upon request,
with any information
necessary for developing
the local emergency
plan, and can serve as
compliance leverage for
uncooperative facilities
throughout the planning
process.
Transportation
Emergency planners also
need to identify the
various routes through a
community over which
EHSs are transported.
Identifying the dangers
associated with the
transportation of
hazardous chemicals will
be more difficult than for
fixed facilities because
transporters are not
required to report under
the planning provisions
of Title III.
Nevertheless,
transportation-related
hazardous chemical
incidents are a
significant hazard, and
such spills and releases
pose an immediate threat
to the public since they
usually occur along
normal traffic routes.
Representatives of
trucking, railroad, air
freight, and shipping
industries, as well as
representatives of the
(continued on page 5) .
-------
Know the Hazards
(continued from page 4)
facilities that receive or
produce transported
products may be able to
provide the following .
information:
the hazardous chemical
involved;
the frequency of
shipments (daily,
weekly, or irregular
schedule);
the form of shipment
(tank truck, tank car,
drums, boxes, carboys
in trucks or vans,
pipelines, barges); and
the quantity of each
shipment (tons or
gallons), and/or the
number of drums,
tanks, vats, or carboys.
Planners in Butler
County, Kansas, a
relatively rural area,
initially assumed that
few hazardous chemicals
were used or stored in
their community. The
county, however, has
five major highways, two
railroad lines, and 800
miles of pipelines, so the
LEPC conducted a
survey to identify the
hazardous chemicals
transported into, out of,
or through the county.
The LEPC developed a
form for traffic watchers
asking for the type of
vehicle carrying a
hazardous chemical and
its placard number.
Eight major entrance
points to the county, as
well as seven points
within the county, were
surveyed over 12 hours
to determine peak
transportation times.
When the survey was
completed, the
information was plotted
on a large map to give
the LEPC a picture of
where the hazardous
chemicals are and which
are the major routes of
concern for planning
purposes.
Planners may also want
to coordinate with
adjoining communities to
share transportation
information and reduce
their collective
workload. For example,
although Alexandria;
Virginia, does not have
any heavy industry, it is
part of the major
transportation corridor
through and around
Washington, D.C. An
Alexandria LEPC
representative serves on
a multi-jurisdictional
task force on hazardous
chemicals transportation
which is exploring ways
to reduce the likelihood
of hazardous chemical
accidents and developing
incident response
procedures for multi-
jurisdictional events. In
addition, the Alexandria
LEPC requests
transportation route
information from
facilities as part of its
hazards identification
program under the
authority of Title III
section 303(d)(3).
The Hazardous Materials
Transportation Uniform
Safety Act of 1990
(HMTUSA) provides
funding for determining
flow patterns of
hazardous materials.
Contact your SERC and/
or the state HMTUSA
contact for more
information.
-------
After identifying the
chemical hazards
in the community, but
before making an :
assessment of the overall
risk they pose, local
planners should conduct
a vulnerability analysis
to estimate who is at risk
from a potential
hazardous .chemical
incident (see below).
Using specific
assumptions,
vulnerability analysis
estimates the
geographical area that
may be affected as a
result of a spill or
release. Specific-ally, the
vulnerability analysis
identifies people
(numbers, density, and
types facility
employees, local
residents, and special
populations) within the
vulnerable zone; private
KNOW THE POTENTIAL
EFFECTS:
VULNERABILITY ANALYSIS
and public property and
essential support systems
(water, food, power, and
communications sources,
as well as facilities such
as hospitals, police, and
fire stations) that could
be damaged; and
sensitive natural areas
and endangered species
that could be affected.
In Pierce County,
Washington, the LEPC
also incorporates natural
hazards, such as fault
lines and floodplains,
into the mapping system
that identifies vulnerable
zones.
During an actual
incident, the area
potentially affected by a
release is simply the area
downwind. But because
the wind direction at the
time of the release
cannot be predicted,
planners must consider
all possible wind
directions and
subsequent toxic plume
paths. Consequently,
vulnerable zones are
. circles with the release
abiUty Analysis
of our community that maybe affected by
The geographic
ca
airborne release erf a hazardous chem
The populations within the zone that may be subject to harm
hospitals) that are. at risk
Critical faH1iH«*t in the zone (e.g.
site located at the center.
Estimating vulnerable
zones for toxic hazard?
may be done by hand, or
with the assistance of a
computer modelling
program. If the task is to
be completed by hand,
the Technical Guidance
for Hazards Analysis
provides complete step-
by-step instructions,
including the
mathematical formulas
and tables for calculating
the radius of the zone.
Planners will also need to
gather maps of the
planning district and
surroundings, and
information sources (e.g.,
Material Safety Data
Sheets and section 312
Tier n reports) on the
hazardous chemicals
involved.
Always keep in mind that
the vulnerability analysis
results are only as good
as the assumptions that
were made throughout
the process. The results
are estimates, best used
for planning and training,
and not to be relied on
during an actual
response.
If sufficient resources are
available, a computer
modelling system will
reduce the time spent
calculating vulnerability
zones. Plume modelling
(continued on page 8)
-------
The federal government provides guidance, technical assistance, and training related to hazards analysis. The Technical
Guidance for Hazards Analysis (EPA, FEMA, DOT) (OSWER-88-001,1987) describes a methodology and provides
equations and tables for screening possible airborne releases of extremely hazardous substances. This guidance is a tool
for emergency preparedness and is not designed for direct use in a response situation.
EPA's Successful Practices in Title III Implementation series describes innovative projects undertaken by SERCs and
LEPCs across the country, and is designed to disseminate information on successful practices with LEPCs, SERCs, fire
departments, and other Title III agencies. Issue #8 from October 1991 (OSWER 91-006.2) includes a subject index that
outlines all of the hazards analysis and other Title Ill-related efforts described in this series. In addition, each LEPC or
SERC profile contains the names of individuals who may be contacted for more information.
Contact theEPCRA Hotline at (800) 535-0202 to obtain free copies of these Successful Practicesbulletins and the Technical
Guidance for Hazards Analysis, or write:
Emergency Planning and
Community Right-to-Know Information Service
Mail Stop OS-120
401 M Street, SW
Washington, DC 20460
CAMEO (Computer-Aided Management of Emergency Operations), designed by the National Oceanic and Atmospheric
Administration (NOAA) and EPA, is available in two formats for Macintosh and IBM-compatible computers. The
CAMEO system includes databases for chemical name and synonyms; Response Information Data Sheets for more than
4,000 chemicals; the capability to manage data about response resources, emergency contacts, facilities, transportation
routes, special populations, and Title in reports; the capability to calculate screening zones as well as to develop incident
scenarios; mapping software which allows plotting of the data base information; and an air dispersion model. CAMEO
is available for approximately $345 for government and non-profit organizations (county maps with 1990 US Census
data are available at an additional charge) from: . .
National Safety Council
Attn: Ms. Sabrina Radford
444 North Michigan Avenue
Chicago,-IL 60611-3991 .
(800)621-7615
The Handbookof Chemical HazardAnalysis Procedures (FEMA/DOT/EPA, 1988) addresses hazards analysis on a site-
specific basis and introduces the Automated Resource for Chemical Hazard Incident Evaluation (ARCHIE) computer
software package. ARCHIE can help emergency planners understand the magnitude of potential toxic, explosive,
reactive, and flammable hazards (e.g., the size of fireballs, the distance at which explosion effects will be felt, and the
size of toxic plumes and their dispersion rates), the sequence of events likely to produce an incident, and the response
actions necessary to mitigate the release at a specific site. ARCHIE and the Handbook of Chemical Hazards Analysis
Procedures are available upon written request free of charge from:
Federal Emergency Management Agency
Publications Department
500 C Street, SW
Washington, DC 20472
-------
Protective Actions: Evacuation and In-Place Protection
Although decisions on personal protection must be made at the time of an actual event, effective hazards analysis will
assist in training and planning for protective actions. Short-term releases, fast-moving plumes, or unstable weather
conditions can make evacuation difficult; often the danger is over before an evacuation can be completed. In these cases,
in-place protection may be the most appropriate action during the release of a chemical. On the other hand, if the release
occurs over an extended period of time, or if a fire cannot be quickly controlled, an evacuation may be the appropriate
option. Decisions should be based on several important factors:
Physical and chemical properties of the hazardous substance;
Short-term exposure effects;
Dispersion patterns;
Weather conditions;
Anticipated size, duration, and rate of the release; and
Concentration of the release in the surrounding air, water, or land.
The emergency planning process can help build a sense of trust between citizens and emergency responders to improve
public understanding of the need and methods for conducting effective protective actions. For example, parents must
be confident that local school officials will take appropriate protective measures during an incident, so that their first
action is not to rush outside to pick up the children at school, but to protect themselves. In St. Charles Parish,
Louisiana, the LEPC annually issues a brochure to all citizens on protective action procedures, and takes a pro-active
approach to communicating this message to the public. Full community emergency siren drills are held annually, and
three full-scale chemical release exercises are held at local facilities during the course of the year. The Har ford County,
Maryland, LEPC, in conjunction with a local cable television company, produced a video to identify the proper steps
to take in response to a potential hazardous materials incident The video also suggests that families should conduct
hazardous material release drills just like a family fire drill.
Know the Potential
Effects
(continued from page 6)
software packages are
often included as part of
a more complete
emergency planning
system designed to .
address many elements
of the emergency
planning process.
ARCHIE and CAMEO
are two computer
systems that the federal
government has designed
and made available to
assist local emergency
planners in preparing for
and responding to an
airborne release of a
hazardous chemical.
CAMEO also provides
the tools necessary to
manage and. use
.information collected
under Tide III. The
system was developed by
the National Oceanic and
Atmospheric
Administration (NOAA)
and EPA to assist
LEPCs, emergency
responders, emergency
planners, and others
involved in activities
concerned with the safe
handling of chemicals
(seepage?). CAMEO is
being used by local
governments, fire
departments, and
. industry throughout the
United States, including
the cities of Miami
(Florida) and Portland
(Oregon).
Several other systems are
also available and have
been documented in
EPA's CEPP Technical
Assistance Bulletin:
Identifying
Environmental Computer
Systems for Planning
Purposes (OSWER-89-
005). Contact your
Regional Title III office
fora copy (see page 15).i
8
-------
Once the chemical
hazards in the
community and the
potential areas of impact
for their release have
been identified, the third
stage in a hazards
analysis, risk analysis,
can be conducted. Risk
analysis is a judgment .
made by the LEPC based
on an estimate of:
(1) Likelihood of an
accidental release, based
on various factors such
as the history of releases
at fixed facilities and in
transport, current
conditions and controls
at facilities, unusual
environmental
conditions, and the
possibility of
simultaneous emergency
incidents (such as
flooding or fire) resulting
in the release of
hazardous chemicals;
and
(2) Severity of
consequences the
people, places, and
things located within the
vulnerable zone. Risk
analysis does not require
extensive mathematical
analysis (although
probabilistic risk analysis
can provide valuable
information to
community planners),
but instead relies on the
knowledge, experience,
and common sense of
local emergency planners
and responders using
information gained from
KNOW THE ODDS:
RISK ANALYSIS
hazards identification
and vulnerability
analyses.
In Wyandotte County,
Kansas, for example, the
LEPC ranked facilities
based on the ratio .
between the total amount
of the hazardous
chemical on site and the
quantity of concern (a
measure of a substance's
acute toxicity). The
ranking was thus a
measure of the relative
health threat that a
release might pose to the
surrounding community.
Facilities that had at least
1,000 times the quantity
of concern for a chemical
were given first priority
in .the planning process; a
second tier of facilities
with a smaller multiple
of the quantity of
concern were addressed
in a second phase of the
process.
TIPS FOR SUCCESS
Across the country, there
are several thousand - .-
LEPCs and tens of
thousands of facilities
that have made the
required notification
under section 302 of
Title III. Inevitably,
there will be differences
between the hazards
analysis process in one
community and that of
another, but any
successful program will
be driven by three
features:
Focus on the most
severe threats to the
community;
Responsiveness to the
community's chemical
emergency
preparedness and
prevention concerns
and interests and the
community's right-to-
know; arid
Effective coordination
and involvement
among planners,
responders (e.g., the
fire service), and
industry.
Address Priority
Hazards
Because planners are
usually not able to
evaluate and address the
risks posed by every
facility at the same time
or to the same extent,
priorities must be set
among the potential
hazards in the
community. The
Technical Guidance for
Hazards Analysis
suggests that planners
perform an initial
screening of hazards
using readily available
information (e.g., Tier II
reports) and certain
credible worst-case
assumptions.
Once this initial three-
step hazards analysis
(i.e., hazard
identification,
vulnerability analysis,
and risk analysis) has
been completed,
planning officials should
consider redoing the
analysis based on the
priority ranking obtained
from the initial round of
risk analysis. These
revised analyses will be
. based on more realistic
assumptions about site-
specific conditions
derived from consulting
with facility!
representatives and other
local officials.
To perform such
analysis, local planners
may want to request
additional information to
evaluate specific release
scenarios for each
priority facility,
including the adverse
health effects of each
(continued on page 10)
-------
Know the Odds
(continued from page 9)
substance; successful
mitigation approaches
used in the past; lessons
learned from past events;
and facility process
hazard analyses. In
addition, e-xisting
emergency response
plans may also be a
valuable information
source. Planners may
want to review:
Their community's
FEMA local multi-
hazard emergency
operations plans
(required and funded
by FEMA);
Facilities'
transportation-related
hazard plans;
Facilities' emergency
response planning
required by OSHA's
HAZWOPER (SARA
section 126) and
process "safety
management standards;
Facilities' emergency
response program
required as part of the
risk management plan
under section 112(r) of
the Clean Air Act;
The Spill Prevention,-
Control, and
Countermeasures plans
(required under the
Clean Water Act), if
they are available; and
State and local
planning requirements.
HATS (see below) also
provides additional
guidance on the phased
approach to hazards
analysis.
The Hamilton County,
Ohio, LEPC identified
ten priority facilities and
requested that they
conduct the hazards
analysis themselves,
using the Technical
Guidance for Hazards
Analysis and ah LEPC
worksheet for
vulnerability and risk
analyses. After LEPC
review, the initial facility
risk analyses appeared to
underestimate both the
likelihood and the
severity of consequences
of an accidental release,
so the LEPC developed a
second, more
quantitative risk
evaluation form.
Probability is estimated
Hazards Analysis Training System
THE HAZARDS ANALYSIS PROCESS
O Introduction
Screen and Set Priorities
Q Use More Realistic Assumptions for Planning
Develop Scenarios for Site Spedfic Planning
.based on contingency
planning, storage
conditions, monitoring
and inspection
procedures, history of
leaks and spills, and
employee hazardous
chemical awareness.
Severity of potential
.consequences is rated
based on the capacity of
on- and off-site response
personnel and the
anticipated property
damage and
environmental effects.
Points are assigned for
factors that reduce the
probability and severity
of a release the lower
the score, the higher the
probability or severity of
a release.
Adapt Analysis to
Local Circumstances
Even though the federal
government has provided
guidance and-software to
assist SERCs and
LEPCs, Title III is a
local program and
decisions about relative
risk and planning
priorities are local
decisions that will differ
from place to place,
depending upon
circumstances. For
example, the availability
of resources (i.e.,
equipment, expertise,
volunteer time, and
dollars, as well as the
creativity and
resourcefulness of LEPC
(continued on page 11)
10
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Maximizing Your Hazards Analysis Resources
Coordinate to Avoid Duplicative Efforts
Use existing Title IE, inspection, and permitting records to avoid time-consuming data collection efforts.
Share computer resources to avoid expensive purchases.
' Coordinate with adjacent localities to share the burden of evaluating hazards.
Identify and use chemical-specific and hazards analysis expertise of local industry.
feeview existing emergency operations plans to identify hazards.
' Support chemical emergency prevention and other emergency preparedness efforts to maximize value of hazards
analysis task.
Take Advantage of Free or Inexpensive Federal Resources
Technical Guidance for Hazards Analysis ("Green Book")
Computer-Aided Management of Emergency Operations (CAMEO)
Handbook of Chemical Hazards Analysis Procedures
Automated Resource for Chemical Hazard, Incident Eyaluatioa..(ARCHIE).-,^. . ,.-. ,,;i«il , SJ.,^
~"^:'--';:. vfW*^^£^«-x..;n^v -^^ .^^z^?<>y,^..-,^f^^:^^z,i
Training and workshops on hazardiFanalysisi^gp HATS-program)," --_;''~ < r " *~~:.;i~ "' E^;. L
-'"^SV^ - '" J-^:».c~---.-- *'-" . '"- T* - ,- " " -*,* "'" i-" ' ~-rr- -^ ., '- -v -.- - . L"lnj, *
-- - - -'- - --.-" -. - - r - . ~~ .. . , . -- t... .if - ~~~ v- - ~~ _ - >
Emergency Planning and Comm.unity Right-to-Know Information Hotline: 1-800-535-0202.
Apply for Grants under HMTUS A
The Hazardous Materials Transportation Uniform Safety Actof 1990 (HMTUSA) provides for grants to support LEPCs
in conducting hazards analyses. Hazards analysis is identified as one of the activities eligible for funding under the
planning grant program. These grants, and grants for training efforts, will be available through 1996. LEPCs should
contact the state agency designated by the Governor as the primary lead for the HMTUSA program to learn more about
the state's planning grant application.
Know the Odds
(continued from page 10)
members and the
willingness of facilities
to cooperate with
LEPCs) will play a major
role in shaping the scope
of local planning
activities. A number of
ways to stretch local
resources are highlighted
in the box. on the
preceding page.
Rather than ranking
facilities or release
locations, the Pasadena,
Texas, LEPC focused its
hazards analysis on
fifteen priority chemicals
manufactured or stored
in the community that
facilities judged to be of
major concern in the
event of a release. For
each chemical, the LEPC
identified locations and
quantities, modes of
transportation, and the
substance's hazardous
properties. The LEPC
then conducted a
vulnerability analysis for
(continued on page 12)
11
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Know the Odds.
(continued from page 11)
each chemical location
using typical weather
conditions. Next, the
LEPC determined which
people and services a
release could affect and
the specific hazards they
might face.
In addition to the
chemicals classified as
airborne toxics, Pasadena
examined chemicals that
present flammability or
Flammables and Ex
Although none of the current EHSs was designated based
upon its flammableand explosiveproperties, EPA recently
published an Advanced Notice of Proposed Rulemaking
to add commercial explosives and blasting agents, and is
evaluating- options for flammable substances. This
addition, if enacted, would provide fire departments and
LEPCs with information on explosive hazards that is not
currently being provided under sections 311 and 312
because'these substances are dangerous in quantities
below the 10,000 pound reporting threshold. Local
contingency planners could then formally address
substances beyond those currently listed under section
302. For the present, however, communities that wish to
evaluate flammable and explosive hazards should use
existingpermittingorlicensing information or theauthority
of section 303(d)(3) of Title IE.
Because the Technical Guidance for Hazards Analysis
does not address flammable and explosiye.hazards, the4?
evaluation of additional hazards that these substances"
pose can be formally conducted using the Handbook of-
Cliemical Hazards Analysis Procedures and. ARGHIEr
Reviewing these hazards can direct planning efforts to
additional sites, or indicate that a specific site deserves
priority because itposesmultiple hazards to thecommunity.
ARCHIE has modelling programs for fires and explosions
of flammable liquids and gases and detonations of solid
and liquid explosives. In order to model these release
scenarios, planners must identify certain physical and
chemical properties of the substance, the quantity involved,
the type of release, the existing temperature and pressure
conditions prior .to the release, and weather conditions.
Some of these data may be available from sections 311--
312 reports,, fire department records, or from the facility,
if reporting is not required.
explosivity hazards (for
more information on
these hazards, see
below). The.LEPC theri
ranked the fifteen
chemicals so that
planners could identify
the community's
chemical-specific
response needs.
The State of Idaho used
Technical Guidance for
Hazards Analysis as a
starting point and
developed a "blueprint"
for LEPC hazards
analysis efforts. The
step-by-step guidance to
hazards analysis explains
how to incorporate the
use of such programs as
CAMEO and ALOHA,
but focuses on planning
and information
management methods
that do not require a
computer.'
12
-------
Once the LEPC has
finished
evaluating the hazards in
the community, the
hazards analysis
information can be used
to support other local
chemical emergency
preparedness and
chemical accident
prevention efforts.
The realistic release
scenarios for the priority
hazards in the
community, refined from
initial worst-case
assumptions, can be
communicated to the
community to help
improve awareness of
chemical hazards. The
local emergency
response plan can then
be designed to address
specific incidents
.described in these
scenarios.
In the event of an actual
incident, current weather
conditions (e.g., wind
direction and speed,
atmospheric stability)
and accurate release data
(e.g., quantity and rate of
release) can be entered in
the appropriate pre-
existing scenario-to
derive realistic estimates
of possible off-site
impacts of the release.
In addition to planning
and real-time response
applications, scenarios'
can be used to develop
realistic exercises to test
. local emergency
response capabilities.
USING THE RESULTS OF
HAZARDS ANALYSIS
LEPCs, SERCs, and
facilities are also
applying hazards
analysis to help facilities
prevent of chemical
accidents.
Getting the Word Out
The LEPC has a
responsibility under
section 324 of Title III to
inform the public about
its right to know. Many
LEPCs have gone
beyond the modest
mandate to publish the
fact that the various
facility reporting forms
and LEPC plans are
available for public
inspection.
During EPCRA .
Awareness Week
(January 1992), the
District XI LEPC in
Florida, serving
B reward, Dade, and
Monroe, counties, held
public outreach
workshops focusing on
citizen information. The
workshops included
presentations explaining
the hazards
identification,
vulnerability and risk
analysis process, and
graphically showed
citizens sample facilities
and their respective
vulnerability zones.
In addition, the Sun-
Sentinel published a
feature story and a two-
page article that named
and located on a county
map the over 80 facilities
reporting under section
302 and listed the .
extremely hazardous
substances at those
facilities in Broward
County (Ft. Lauderdale
metro area). All of the
LEPCs in Florida
reported a measurable
increase of public
requests for EPCRA
information as "a result of
the Awareness Week
activities.
Planning
Applications
Knowledge of the
hazards present in the
community will enable
planners to identify what
response personnel and
equipment are needed for
the community, as well
as what training will be
necessary.
The identification of the
health threats in the
community will support
the development of
necessary emergency
medical care procedures.
Public notification and
alarm systems in the
community should
reflect the results of
vulnerability analyses.
Public education efforts
may be needed to
describe evacuation and
in-place protection
procedures.
The Alaska SERC is
providing technical and
financial assistance to its
LEPCs as part of a state-
wide hazards analysis
project The project
generally will follow the
airborne toxics approach
outlined in the Technical
Guidance for Hazards
Analysis, but the analysis
has been expanded to
include facilities with
flammables and
explosives, as well as the
potential for chemical
and petroleum spills to
impact the drinking
water supply or sensitive
ecosystems. Once the
information has been
compiled at the local
level, it will be
transferred into a state-
wide CAMEO system,
and eventually
incorporated into a
Geographical
Information Systems
(continued on page 14)
13
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Using the Results
(continued from page 13)
format along with data -
from other state
environmental programs.
'The hazards analysis
data will also be used as
the basis for evaluating
emergency response
capabilities as part of an
effort to establish
volunteer response teams
and equipment depots
across Alaska.
As part of the hazards
analysis process, local
fire departments and
other planning officials
may want to inspect
facilities to collect
specific information and
develop a working
knowledge of the facility
in order to pre-plan for
an emergency response
situation. The
emergency dispatcher
can be made aware of
locations with extra
hazard potential in the
event of an emergency
(e.g., incompatible
materials stored in close
proximity or extremely
flammable or explosive
substances.) A special
notation can be included
to indicate that the local
hazardous materials team
should be dispatched
immediately of placed on
alert.
Under the Clean Air Act
. Amendments of 1990,
many facilities in your
community may be
required to provide
information on the ways
they manage risks posed
by certain substances
listed by EPA and
indicate, by submitting a
risk management plan
(RMP), what they are
dqing to minimize risk to
the community. These
provisions are likely to
generate more detailed
facility-specific
information useful for
LEPC planning purposes-.
One component of the
RMP will require
facilities to prepare
detailed off-site
consequence analyses.
The RMPs, with their
analysis of off-site
impacts, will help LEPCs
update their community
plans. LEPCs will also
be better able to
coordinate community
plans with facility plans.
The Chandler Fire
Department in Arizona
requires facilities with
certain categories of
hazardous chemicals to
file a hazardous materials
management plan
(HMMP) when applying
for a hazardous materials
permit. The HMMP
includes a section
requiring completion of a
vulnerability analysis.
Their guidance for
preparation of a
vulnerability analysis
suggests using the
Technical Guidance For
Hazards Analysis for
information regarding
vulnerable areas. This
HMMP is similar to the
RMP that is required by
the Clean Air Act
Amendments.
Prevention
Implications
Hazards analysis allows
local emergency planners
and industry to work
together to reduce
hazards in the community
and prevent future
accidents. As with the
implications for planning
efforts (see page 13), the
LEPC, or specific
members such as the fire
departments, can identify
prevention strategies
while gathering the
information to conduct
the hazards analysis.
Some important
questions to keep in mind
when looking at a
specific facility are:
What possibilities exist
for substituting less .
dangerous chemicals for
any hazardous
chemicals at the
facility?
What possibilities exist
for reducing the
quantity of the
hazardous substances in
use or stored at the
facility? Can this be
done without increasing
transportation-related
dangers?
1 Have operation or
storage procedures
been modified to
reduce the probability
of a release and
minimize potential
effects?
What is. the overall
layout and spacing of
the storage area,
process areas; and other
positions with respect
to the plant property
line? What is the
spacing'between the
individual equipment
both in storage and
process areas? Are
incompatible chemicals
separated sufficiently?
What areas and
pathways will be
available for the
movement of personnel
'and vehicles in the
event of an emergency?
Are placards describing
the hazard of the
chemical displayed
prominently?
How are the hazardous
substances received/
shipped? How often
and in what quantities?
Are there dedicated
personnel trained, in the
handling of these
materials?
(continued on page 15)
14
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Using the Results
(continued from page 14)
The role of hazards
analysis in a chemical
accident prevention
program can vary from
influencing a single
facility's inventory
decisions to serving as
the basis for a state-wide
initiative. The
Washington, B.C., LEPC
and the State of
California are examples
at each end of the
spectrum. After
receiving a section 302
notification from a local
water treatment plant, the
Washington, D.C.
LEPC encouraged the
facility to reduce its
storage of large
quantities of chlorine.
The company did not
realize the potential
hazards such storage
posed to the surrounding
community, and ....: ~.
' volunteered tolreduee.its.
on-site inventory. .: . ""
^SKsT^"" > - * _,.^- - ,.,,'z
On the other hand, the
State of California has
developed, as part of its
implementation of state
legislation, the Risk
Management and
Prevention Program
(RMPP). The program is
designed to reduce the
number of releases and
the potential for
casualties and
evacuations; to reduce
facility expenses for
equipment breakdown,
materials loss, cleanup
costs, and claims
litigation; and to improve
environmental
protection.
Facilities with the
potential for a significant
off-site impact from an
EHS release are required
to develop an RMPP. A
comprehensive facility
RMPP report includes a
record of EHS accidents;
a description of the
equipment used in
conjunction with EHSs;
facility controls to
minimize the risks of a
release; monitoring,
backup, mitigation, and
transportation and
storage procedures and
systems; and the facility
safety audit, inspection,
and recordkeeping
policy. The final step in
thefaciUty^RMPPJsj -
serves
' as trie basis f0r"'""
developing a facility
prevention program
consisting of release
reduction techniques,
systems, and procedures,
and a schedule for their
implementation.
WHERE DO YOU
GO FROM HERE?
Hazards analysis is an"-
ongoing process.
Unfamiliar hazards and ,
inaccurate records can
seriously undercut the
effectiveness of
contingency planning
and emergency response
procedures. Records
must be regularly
updated to account for
new chemicals and
facilities in the
community, changes in
the quantity of chemicals
at facilities, or even the
movement of chemical
storage and process
locations within .
facilities. As a result of
these changes in the
hazards environment,
local planners may need
to revise individual
scenarios for
vulnerability and- risk.
(continued on page 16)
EPA Regional Title HI Offices
EPA - Region 1
New England Regional Lab
60 Westview Street
Lexington, MA 02173
617-860-4301
(CT, MA, ME, NH, RI,
VT)
EPA - Region 2
2890 Woodbridge Avenue
Edison, NJ 08837-3679
908-321-6620
(NJ. NY, PR, VI)
EPA-Region 3
OE& Title -M Section
841 Chestnuts tree?
Philadelphia, PA 19107
215-597-5998
(DE, DC, MD. PA, VA,
WV)
EPA - Region 4
345 Courtland Street, NE
Atlanta, GA 3.0365
404-347-1033
(AL, FL, GA, KY, MS,
NC,SC,TN)
EPA - Region 5
77 West Jackson HSC-9J
Chicago, IL 60604-3590
312-353-1964
(IL, IN, MI, MN, OH, WI)
EPA-Region 6 '
Allied Bank Tower
1445 Ross Avenue
Dallas, TX 75202-2733
214-655-2270
(AR, LA, NM, OK, TX)
EPA - Region 7
ARTXADPE/TSCS
726 Minnesota Avenue
Kansas City, KS 66101
913-551-7308
(IA, KS, MO, NE)
EPA - Region 8
One Denver Place
999 18th Street, Suite 500
Denver, CO 80202-2466
303-293-1723
(CO, MT, ND, SD, UT,
WY)
EPA - Region 9
75 Hawthorne Street (H-1-2)
San Francisco, CA 94105
415-744-2100
(AS, AZ, CA, HI, NP, NV,
GU)
EPA - Region 10
1200 6th Avenue (HW-114)
Seattle, WA 98101
206-553-4349
(AK, ID, OR, WA)
15
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Using the Results
(continued from page 15)
Thus, the additional
infonnation required for"
these stages in a hazards
analysis (e.g., the
identification of schools,
hospitals, and other
special populations;
community emergency
response capability; and
facility release
prevention and
mitigation procedures)
should also be updated
regularly. .
Although hazards
analysis can seem at first
a highly resource-
intensive and complex
task, it is the
responsibility of the
' LEPC to put the process-
of hazards identification,
vulnerability analysis,
and risk analysis into
practice in the
community so that
vulnerable populations
can be protected. As
described in this bulletin,
each of these steps can
be, and have been,
conducted in a fashion
that matches LEPC
resources and concerns,
and the process itself can
be used to support a
variety of other chemical
emergency preparedness
and prevention
activities.
Read More About It
The examples used in this bulletin are drawn
from EPA's series, Successful Practices in Title
III Implementation, which is available from
your regional Title III office (see list on page
15), or by calling the Emergency Planning and
Community Right-to-Know Information Hotline
at 800-535-0202. Nine bulletins are currently
available in this series, covering a wide variety
of Title HI implementation practices successfully
employed by a large number of SERCs and
LEPCs.
vvEPA
United States -
Environmental Protection
Agency (OS-120)
Washington, DC 20460
FIRST CLASS MAIL
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EPA
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