HW-3 1984 c.l A United States Environmental Protection Agency Office of Emergency and Remedial Response Washington DC 20460 EPA's Emergency Response Program 2nd Edition April 198.4. HW-3r ,\ »***, .. ^J*1L » •* |ft -4 "i% ™^- ; ™* *_ OUT "I* 1 ONLY I.) 5. Environmental Protection Agency Pi-gion V, Library 230 South Dearborn Straoi " Illinois 60604 ------- EnvWHTWitol PwiBetlcn ------- EPA's Emergency Response Program Train derailments can re- lease hazardous sub- stances over large areas, possibly requiring evacua- tion of nearby residents. In satisfying the American public's demand for sophisti- cated products, modern technology's response is in- genious and complex Sometimes that technology generates toxic by-products as well—hazardous wastes Effective and safe handling of such wastes has im- proved tremendously under rapidly-advancing disposal technology In 1976, the Re- source Conservation and Recovery Act (RCRA) was enacted, for the first time establishing controls for the generation, transportation, and disposal of hazardous wastes Although it provided the tools to track and regulate the handling of such sub- stances, RCRA did not deal with existing hazardous sites that had become trouble- some as a result of past improper disposal practices. These sites, as well as accidents in handling or transporting hazardous substances, can present emergency situations requir- ing an immediate cleanup or removal Federal authority to respond to releases of oil and hazard- ous substances into the na- tion's navigable waters is found under Section 311 of ------- Emergency Response Program The swollen bottom on this drum indicates a serious threat of leakage. the Clean Water Act This authority, which is assigned to the Environmental Protec- tion Agency and the Coast Guard, has existed for over a decade The Clean Water Act also established a fund to finance these responses. However, it provided only limited authority and limited funds to tackle the variety of problems caused by release of hazardous substances into land, ground water, and air. Superfund To provide a more effective and comprehensive re- sponse to the foregoing problems, Congress enacted the Comprehensive Environ- mental Response, Compen- sation, and Liability Act of 1980 Popularly referred to as "Superfund," CERCLA and Section 311 of the Clean Water Act permit the Federal government to work with State and local govern- ments to provide an immedi- ate and comprehensive re- sponse to accidental release of hazardous substances. Superfund cleanups are financed by a $16 billion ------- Emergency Response Program Barges carrying large car- goes of hazardous materi- als may break loose and strike bridges and other structures. This barge was secured in time, preventing potentially serious damage to the waterway. trust fund The fund can be used to provide both emer- gency and longer-term cleanup of releases of haz- ardous substances and in- active waste sites It is col- lected through taxes paid by manufacturers, producers, and exporters and importers of oil and 42 chemical sub- stances In 1968 the Federal govern- ment established the first National Contingency Plan to respond to emergencies caused by oil spills and releases of hazardous sub- stances in navigable waters CERCLA required EPA to re- vise and republish the Plan to cover all of the actions which can now betaken un- der both Superfund and the Clean Water Act The Plan details the responsibilities of 14 Federal agencies and State and local governments ------- Emergency Response Program When a hazardous sub- stance ignites, it not only presents the immediate dangers of heat and smoke but it can spread hazardous particles and vapors over wide areas. for cleaning up releases of hazardous substances to all media (land, air, surface wa- ter and ground water) and discharges of oil into naviga- ble waters of the U.S In general the Plan • Encourages coordina- tion of Federal, State and local government involvement in re- sponse actions, • Allows State and local governments to be reimbursed by the Fed- eral government for allowable response costs; and • Authorizes the Federal government to under- take cleanup when the responsible party or the State cannot or will not do so Primary responsibility for dealing with accidental releases in or near coastal waters and the Great Lakes is with the Coast Guard The lead responsibility for other emergencies occurring inland or in inland waters belongs to EPA, as specified by an agreement between EPA and the Coast Guard EPA responses are coordi- nated by its Emergency Re- sponse Division with the assistance of the Hazardous Response Support Division. Both are a part of the Of- fice of Solid Waste and Emergency Response ------- Emergency Response Program Emergency Response Program Two types of removal ac- tions are carried out by EPA in its emergency response program: immediate remov- als and planned removals Immediate Removals Immediate removals are triggered by immediate and significant emergencies involving hazardous sub- Chemical foams are often used to prevent evapora- tion of hazardous sub- stances or to extinguish fires resulting from acci- dents. Response personnel wear protective clothing while handling these chemicals. stances Such emergencies might include • Fires or explosions, • Direct human contact with a hazardous sub- stance, • Human, animal, or food-chain exposure to such a substance, or • Contamination of a drinking water supply An immediate removal is a first-aid approach to an emergency It involves cleaning up the hazardous site as necessary to protect life and human health, stopping the hazardous re- lease, and minimizing dam- age or threat of damage to the environment If there has been a spill (from a truck, derailed train or barge, for example) the re- sponse will continue until the spill is cleaned up Inactive hazardous waste sites will be stabilized but the cleanup may continue beyond stabilization if this course appears less expen- sive than stopping and returning later for final cleanup or remedial action Specifically, immediate removal responses may include • Collecting and analyz- ing samples, • Controlling the release, • Removing hazardous substances from the site and storing, treat- ing, or disposing of them, • Providing alternate wa- ter supplies, • Installing security fencing, • Deterring the spread of the pollutants, and • Evacuating threatened individuals Planned Removals A planned removal occurs when the hazard is sub- ------- Emergency Response Program Above: Workers with pro- tective suits and self- contained breathing units extract samples from drums. Samples are sent to a chemical laboratory for analysis. stantial and imminent but constitutes something less than an immediate emer- gency Such a removal assumes that, while the sit- uation is deteriorating, time is available to plan an appropriate response before reaching the site Under Superfund, a planned removal may be initiated if' • The action will mini- mize damages or risks and preclude future emergency response actions, • Removal is consistent with the most effective long-term solution to the problem, • The responsible party is unknown, cannot be found, or cannot or will not take timely and appropriate action, • The State agrees to pay at least 10 percent of the costs of the removal action, and • The State agrees to nominate the site to the National Priority List for remedial ac- tion, if further action at the site is consid- ered appropriate once the removal is com- pleted The planned removal re- sponse will be chosen only after analysis of removal al- ternatives to determine the quickest and least costly approach The selected course of action also must be reliable and effective, and consistent with the probable long-term solution The planned removal ends when the situation is stabi- lized and the imminent dan- ger has been abated The operation may continue, however, if the cleanup can be completed within a short time and at a low cost ------- Emergency Response Program Hazardous Substance Cleanup: An Industry- Government Partnership In practice, many emergency cleanups and removals are handled by the responsible party—usually the generator, transporter, or disposer of the waste The remainder are cleaned up by an industry-government part- nership If government resources are called upon, a variety of local, State, and Emergency situations in- volving hazardous sub- stances require specific techniques, equipment and personal safety protection. Above: Firefighters respond to a night emergency. Federal agencies may be called into action Superfund and Section 311 of the Clean Water Act require that EPA, the Coast Guard, the Federal Emer- gency Management Agency, the Department of Health and Human Services, the Department of the Interior, and nine other Federal agencies cooperate as members of the National and Regional Response Teams to coordinate activi- ties in cases of emergency Additional Federal agencies that may be involved are the Departments of Agricul- ture, Commerce, Defense, Energy, Justice, Labor, State, and Housing and Ur- ban Development; and the Small Business Administra- tion In the event Federal services are called upon- • The Coast Guard or EPA assumes primary responsibility to re- spond, depending upon the location of the emergency, • The Federal Emergency Management Agency is responsible for evacuations; • The Fish and Wildlife Service in the Depart- ment of the Interior and the National Ma- rine Fisheries Service in the Department of Commerce conduct re- search into the effects of the disaster on ma- rine, aquatic and ter- restrial life, • The Public Health Service in the Depart- ment of Health and Human Services inves- tigates incidents of hazardous substance exposure to humans and threats to the public welfare, and • Other agencies play roles related to their re- 7 ------- Emergency Response Program spective authorities if the emergency requires it When To Notify the Government When release of a hazard- ous substance creates an emergency situation, local police and fire departments probably will be the first agencies involved While they are taking initial pro- tective actions, however, local officials may be calling upon State and Federal agencies for assistance The responsible party—such as a generator, transporter or disposer of hazardous waste—must also notify the National Response Center (NRC) as soon as (s)he has knowledge that a hazardous substance was released in a Reportable Quantity (RQ) into the environment Sec- tion 102 of CERCLA desig- nates almost 700 sub- stances as hazardous and assigns RQs that trigger notification requirements To request Federal assist- ance under Superfund, a State or local government should contact its nearest EPA Regional Office When the National Re- sponse Center is notified, the duty officer immediately relays the release informa- tion to an EPA or Coast Guard On-Scene Coordina- tor (OSC), depending upon the location and nature of the emergency The OSC coordinates and monitors all protective and precautionary activities to ensure that everything possible is done to protect public health, welfare, and the en- vironment. The Federal Role The response process be- gins with the OSC's deci- sion to initiate response measures This decision is based on a preliminary assessment of notification information and on follow- up data gathered from the responsible party or officials at the release site The OSC must decide whether the Federal government is the appropriate response agency Alternatively, State agencies may take the lead in cleaning up a release site, or the party responsible for the release may have the capability to provide mitigation actions In both cases, however, the Federal OSC will retain the authority for oversight or monitoring of the cleanup operations to ensure that the threat is mitigated. At times, the ex- pertise of other Federal ------- The grappler's specially- designed pickup arm helps remove hazardous waste drums from an active dis- posal site. agencies and other States can be brought to a re- sponse action through the Regional Response Team (RRT) established by the National Contingency Plan The Federal OSC, either in consultation with other agencies or on the spot, must decide what type of response to make, whether the release should be con- tained to prevent migration, whether the release should be treated in situ, or whether a federally-funded removal to a treatment, storage or disposal (TSD) facility should be un- dertaken. The OSC seeks assistance from the EPA Regional Emergency Reponse Offices and the special Environmen- tal Response Teams based in Cincinnati, Ohio, and Edi- son, New Jersey As part of EPA's policy of keeping the public accur- ately informed, the OSC may also seek assistance from the Agency in coor- dinating information for the media and providing liaison with citizens organizations as necessary According to CERCLA, an official Federal removal ac- tion may be considered in cases where: • The discharger is unknown, • The discharge is caused by an act of God or war; or • The responsible party cannot or will not re- spond adequately Under Superfund, govern- mental emergency response is able to achieve the highest degree of inter- agency and inter-govern- mental teamwork If Federal authorization is provided, State and local govern- ments may conduct the cleanups and reimburse- ment will be made by Superfund The Federal government itself may con- duct the removal if the State or local government requests assistance In either case, the Federal government retains its im- portant advisory and coordi- nation role EPA's scientific resources and its specialized ------- Emergency Response Program monitoring, sampling and safety equipment will sup- port State and local efforts Superfund will be the key source of cleanup money To help keep the fund sol- vent, Superfund also pro- vides that the responsible party may be liable for punitive damages of up to three times the cost of the Federal removal for failure to respond properly to the emergency Prevention The containments around the storage tanks are designed to prevent any leakage of oil products into adja- cent waters. Oil Pollution Prevention For more than a decade, EPA has been concerned about the discharge of oil into the navigable waters of the United States To prevent such oil discharges by non- transportation-related (NTR) onshore and offshore facili- ties, EPA promulgated the oil pollution prevention regula- tion in December 1973 The regulation establishes re- quirements for the develop- ment and implementation of Spill Control and Counter- measure Plans (SPCC Plans) This regulation is ap- plicable to all owner/opera- tors of NTR onshore and offshore facilities engaged in drilling, producing, gather- ing, storing, processing, refining, transferring, dis- tributing, or consuming oil and oil products and who, because of their location, could reasonably be ex- pected to discharge oil into or upon the navigable waters of the United States The EPA Regional Offices implement this regulation by routinely visiting facilities and reviewing their SPCC Plan All transportation-related fa- cilities are regulated by the Department of Transporta- tion in accordance with an agreement with EPA Hazardous Substance Prevention EPA's Hazardous Substance Prevention Program estab- lishes guidelines for industry to prevent hazardous sub- stance releases into the en- vironment The guidelines focus on protection of public health, welfare, and the en- vironment 10 ------- Emergency Response Program Superfund in Action The Emergency Response at Cecil County, Maryland Site workers wearing protective suits placed leaking drums into over- packs. In all, more than 1,300 drums and 5 million pounds of contaminated soil were removed and disposed of at authorized facilities. In the late 1960s, approxi- mately 1,300 drums of haz- ardous wastes were stacked in a clay quarry and covered over in the small Cecil County, Maryland, commu- nity of North East When the new owners of the land be- gan an expansion of a mo- bile home community into the former quarry area, they discovered chemical odors and several surfacing drums After receiving complaints in April 1981, the county and the Maryland Office of En- vironmental Programs tested drinking water wells and sur- face water in the area The property owner also con- ducted geological studies 11 ------- Emergency Response Program The drums were stacked up to 15 layers deep. To speed up the removal action, EPA combined compatible chemicals so they could be either treated at the site or bulk shipped to a disposal facility. The analyses showed safe drinking water, but the sur- face water and soil samples contained organic solvents, including several known and suspected carcinogens The State then requested as- sistance from Superfund From February to April 1982, EPA conducted a site investi- gation, including additional sampling. The on-scene in- vestigators discovered drums of hazardous organic wastes located a few hundred feet from a 300-unit trailer park These wastes were contami- nating soil, two small ponds, and a creek running through the trailer park A joint State and EPA emergency re- sponse team evaluated the site in May EPA approved a removal action under Super- fund in June 1982 EPA began an immediate removal action costing $110,000 on Wednesday, June 16, 1982 This in- cluded erecting a fence around the site to secure the area, installing filter fences on the stream, removing four drums of ignitable materials found on the sur- face, overpacking eight leak- ing drums, conducting mag- netometer and ground- penetrating radar surveys to determine where additional drums were buried, and continuing air, water, and soil sampling Based on these studies, EPA estimated that there were approximately 125 drums at the site Because of the potential danger these posed to the neighboring community, EPA decided to undertake a planned removal action In- stead of the expected 125 drums, however, in November, 1982, on-scene personnel discovered that there were 1,300 drums stacked up to 15 layers deep 12 ------- Emergency Response Program At the completion of the removal action, the site was filled, capped with clay, covered with top soil, and seeded. The discovery changed the scope of the planned re- moval action EPA, State and local agencies, and con- tractors increased personnel to complete the action with- in the statutory limit of six months—a deadline of De- cember 16, 1982 EPA changed the removal strat- egy to combine compatible chemicals together and dis- pose of them as bulked li- quids rather than in drums This and other innovative strategies lowered the per drum cost of cleanup, so that the planned removal ac- tion cost $960,000, only about $300,000 more than anticipated when the num- ber of drums was thought to be a tenth of how many were found In all, EPA removed 50,000 gallons of contaminated li- quids, 5 million pounds of contaminated soil, and treated 100,000 gallons of contaminated water Site workers refilled the hole with clean fill material, installed a clay cap to prevent water seepage into the former drum area and the leaching out of any contaminants possibly left in the deeper ground, and covered the surface with topsoil seeded with grass to prevent ero- sion The State pledged to maintain the air and water monitoring stations To date, all environmental samples have been free of the con- tamination that prompted this Superfund removal action 13 ------- Emergency Response Program Research and Develop- ment Controlling and cleaning up hazardous substances is a relatively new field New equipment and new tech- niques are required to re- spond quickly and effec- tively to emergencies, and to dispose of the materials in a way that is environ- mentally safe Both industry and EPA are working dili- gently to learn more about controlling such substances and to develop new EPA's "Blue Magoo" can be moved quickly to hazardous waste sites to remove hazardous sub- stances from contaminated water. cleanup techniques and equipment Much of the development and testing related to the Emergency Response Pro- gram occurs at EPA's Environmental Emergency Response Unit (EERU) in Edison, New Jersey EERU is a cooperative effort among emergency response research personnel at Edi- son, the Environmental Response Team, other EPA operational personnel, and contractors from private industry. As new equipment is developed and tested satisfactorily, it is utilized by EERU in actual emergen- cies, it is also used in train- ing courses and in develop- ment of emergency response assistance man- uals Additional R&D sup- port is provided at other EPA research installations Chemical Cleanups A number of special clean- up equipment designs are under development at Edi- son One, designed for cleanup of chemical sub- stances, is a fully- operational Physical- Chemical Treatment Trailer nicknamed the "Blue Ma- goo" A combination of treatment units mounted on a flatbed trailer truck, the Blue Magoo is capable of being transported to an emergency site The treatment technology was adapted from equip- ment currently used for conventional water pollution control treatment The physical-chemical treatment 14 ------- Emergency Response Program Oil is released into the EPA OHMSETT tank at Edison, New Jersey, to test spill cleanup methods and equipment. concept for hazardous sub- stances has now been adopted by at least two commercial cleanup equip- ment manufacturers. Still in the testing stage is a mobile hazardous waste in- cineration system This unit will be capable of on-site thermal detoxification of many hazardous materials such as RGBs, kepone, malathion, and TCDD The system is mounted on three over-the-road semi-trailers to facilitate transportation to operating sites. Trial burn- ings of liquid hazardous and toxic substances have been completed successfully This is to be followed by trial burnings on contaminated solids Oil Cleanups EPA also conducts a wide- ranging oil spills research program under Section 311 of the Clean Water Act Major research and de- velopment efforts for oil spills include • Construction and oper- ation of a Spill Clean- up Testing Facility at Leonardo, New Jersey. The testing facility, called the Oil and Haz- ardous Materials Simu- lated Environmental Test Tank (OHMSETT), is a large concrete tank with a mobile bridge. It permits environmentally-safe testing of spill cleanup methods and equip- ment Oil spill contain- ment booms, skimmers and dispersing agents can be tested repeat- edly to insure reliability and efficiency • Evaluation of chemical dispersants developed 15 ------- Emergency Response Program by industry, and tech- niques for applying them from ships and aircraft in rough seas Techniques for cleaning up and protecting shorelines and beaches The Edison facility, for example, is emergencies involving con- tamination of ground water, surface water and drinking water by spills of hazardous substances and oils The unit also has provided emergency responses to uncontrolled waste sites EERU activities during these EPA's mobile hazardous waste incineration system is mounted on three semi- trailers to facilitate trans- portation to hazardous sub- stance sites. investigating use of chemical agents which could be applied be- fore an oil slick arrives These agents form a thin film that prevents the oil from adhering to the beach Emergency Assistance During the past several years, the EERU has responded to a variety of emergencies included. • Evaluation of the severity and extent of contamination, • On-site analytical support, • Recommendation of safe, effective treat- ment and disposal options; and • Supervision of spill cleanup operations 16 ------- Emergency Response Program Training In order to disseminate the latest knowledge on new emergency techniques and equipment, EERU has designed a comprehensive one-week training course for emergency response per- sonnel from Federal, State and local organizations and private industry The course, entitled "Haz- ardous Materials Incident Response Operations," is offered at EERU's Edison facility Its goal is to train response officials in the latest emergency proce- dures, team organization and functioning, and safety The course consists of lec- tures followed by problem- solving sessions in the classroom or outdoor ex- ercises. Subjects include those con- cepts and principles as- sociated with all response activities. • Recognizing the haz- ards associated with specific materials, • Determining the risks to the public and the environment, • Developing methods to reduce or prevent the ef- fects of an incident, and • Insuring protection and safety of response per- sonnel The course is limited to 18 participants per session. During the first part of the instruction, students are divided into small work groups which study and practice problem-solving and decision-making in- volved in the foregoing con- cepts Participants are next instructed in the use of pro- tective clothing and breath- ing equipment, after which they actually use the equip- ment in a smoke-filled en- vironment, on obstacle courses and while operating field instruments Final exercises are designed to test students' ability to utilize the information presented to them in a full- scale environmental episode. They are confronted with two simulated exercises, both based upon actual emergencies, which require practical application of the techniques learned earlier. The course has proven to be one of EERU's most ef- fective means of involving emergency response per- sonnel in the complexities of such a response and ensuring informed, well- coordinated teamwork to resolve the problem. 17 ------- Emergency Response Program EPA sponsors nationwide training for representatives of industry, fire depart- ments, and State and local governments. Right and be- low: Trainees learn how to don and use the self- contained breathing ap- paratus often required for respiratory protection. Several hundred emergency response personnel have completed the course since it was inaugurated in 1981 Graduates include all mem- bers of EPA's Emergency Response Division, other Federal officials with emer- gency responsibilities, and response personnel from State, local and private organizations. 18 ------- Emergency Response Program The course currently is being offered once each month. Further information is available fronr Thomas Sell Training Coordinator, ERT US Environmental Protection Agency 26 West St Clair Street Cincinnati, Ohio 45268 513-684-7537 FTS-684-7537 Inside this EPA mobile laboratory, scientists and technicians test soil and water samples for hazard- ous substances. Manuals In connection with its de- velopmental testing and training functions, EPA pub- lishes an extensive series of manuals to assist emergency response personnel in plan- ning and conducting cleanup operations In an effort to achieve a uniform and cohe- sive national response pro- gram, the Agency develops manuals in emergency response methodology, adaptation of latest cleanup techniques, uniform commu- nications terminology and administrative procedures, guidance on decision- making, and instructional and reference manuals for students in the ERT training courses Recently published manuals deal with pesticide disposal, contingency planning (in cooperation with the Federal Emergency Management Agency), and control of haz- ardous materials spills Cur- rently available manuals on emergency response to spills include: • Manual ol Practice for Protection and Cleanup of Shorelines • Manual for Control of Hazardous Material Spills • Hazardous Materials Incident Response Operations All emergency response manuals are published and made available through the National Technical Informa- tion Service, Springfield, Virginia 22161 Further infor- mation may be obtained 19 ------- Emergency Response Program from NTIS, from EPA's Emergency Response Team or any EPA Regional Office Identification Each hazardous substance has special properties that dictate its handling and dis- position A substantial por- tion of EPA's hazardous substance research is de- signed to develop methods of identifying these proper- ties. These programs are conducted at EPA's Environ- mental Monitoring Systems Laboratory in Las Vegas, Nevada Major research ef- forts there include • Evaluation of proposed sampling, analysis and classification pro- cedures; • Improvement of monitoring procedures at disposal and cleanup sites, and • Development of a quality assurance pro- gram to guarantee the reliability of data EPA files document many cases of damage to life and the environment from im- proper disposal of hazard- ous substances or acciden- tal spills Dangers also develop from release of such substances into rivers, lakes and other surface waters, from air pollution, fire, explosions and soil contamination Although the responsible party may satisfactorily clean up the release of a hazardous substance, Superfund and Section 311 of the Clean Water Act now permit the highest de- gree of inter-governmental coordination and effective- ness whenever private in- dustry requests emergency assistance. This inter-governmental coordination, together with constantly improving tech- nology and a growing en- vironmental awareness by industries which generate, transport and dispose of hazardous waste, is being translated daily into in- creased environmental pro- tection and safety for the American public. US. Environmi Region V, Li aso so-jt _ Chicago, ttttnols Street 60604 20 ------- EPA Regional Emergency Response Offices Region I Chief, Oil and Hazardous Materials Section Surveillance and Analysis Division 60 Westview Street Lexington, MA 02173 (617) 861-6700 Region II Chief, Emergency Response Branch Office of Emergency and Remedial Response Edison, NJ 08837 (201) 321-6657 Region III Chief, Superfund Branch Curtis Building 3HW-20 6th and Walnut Streets Philadelphia, PA 19106 (215) 597-9492 Region IV Chief, Emergency Remedial and Response Branch 345 Courtland Street, N E Atlanta, GA 30365 (404) 881-3931 Region V Chief, Spill Response Section Environmental Services Division 5-SEES 536 South Clark Street Chicago, IL 60605 (312) 353-2102 Region VI Chief, Emergency Response Branch 6ES-E 1201 Elm Street Interfirst-Two Building Dallas, TX (214) 767-2720 Region VII Chief, Emergency Planning and Response Branch Environmental Services Division 25 Funston Road Kansas City, KS 66115 (913) 236-3888 Region VIII Chief, Emergency Response Branch Environmental Services Division 1860 Lincoln Street Denver, CO 80295 (303) 234-6069 Region IX Chief, Emergency Response Section T 3-3. Field Operations Branch Toxic and Waste Management Division 215 Fremont Street San Francisco, CA 94105 (415) 974-7511 Region X Chief, Environmental Emergency Response Team Environmental Services Division 1200 6th Avenue Seattle, WA 98101 (206) 442-1263 ------- Superfund/RCRA Hotline (800) 424-9346 for information on programs or (202) 382-3000 National Response Center (80CU 424-8802 to report oil and hazardous substance releases ------- |