&EPA
United States
Environmental Protection
Agency
Office of
Federal Activities
Washington, D.C.
EPA/130/9-90/001
February 1990
SUMMARY REPORT OF
FEDERAL AGENCY
TITLE III PROGRAMS
INTERIM FINAL REPORT
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Summary Report of
Federal Agency Title III Programs
-«.
Interim Final Report
Office of Federal Activities
U.S. Environmental Protection Agency
February 1990
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Acknowledgement
This document was developed by EPA's Office of Federal
Activities (OFA) with assistance provided by Booz*Allen and
Hamilton Inc. in partial fulfillment of Contract No. 68-W8-0097.
Kathleen A. Hutson served as EPA Project Manager, with assistance
from the EPA Federal Facilities Title III Workgroup. The Booz
Allen project team included Amelia Heffernan/ Gabriele Loebbert and
Ted Yoder.
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TABLE OF CONTENTS
INTRODUCTION 1
BACKGROUND 1
FINDINGS 3
Sections 301-303: Emergency Planning 4
Section 304: Emergency Notification .... 5
Sections 311-312: Community Right-to-Know 5
Section 313: Toxic Chemical Release Reporting 6
CONCLUSION 6
APPENDICES
Appendix A: EPA Order on Title III
Appendix B: Memorandum of Understanding between National
Institute of Standards and Technology and the
Montgomery County Emergency Planning Council
Appendix C: EPA Administrator's
Letter to Federal Agencies
Appendix D: Federal Agency Title III
Program Summaries
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SUMMARY REPORT OF FEDERAL AGENCY TITLE III PROGRAMS
INTRODUCTION
This report summarizes Federal agency activities regarding
compliance with the Emergency Planning and Community Right-to-Know
Act of 1986 (also referred to as Title III of the Superfund
Amendments and Reauthorization Act). Title III encourages and
supports emergency planning efforts at the State and local level
and provides residents and local governments with information
concerning potential chemical hazards present in their communities.
Although Federal agencies are not legally obligated to comply with
Title III, it is EPA's goal to encourage Federal agency voluntary
compliance with the emergency planning and notification
requirements so that all citizens can benefit from full
implementation of this1statute.
In an effort to achieve this goal, EPA formed a workgroup to
develop and examine various options to encourage voluntary
compliance. Following a review of several options, the workgroup
developed a letter and questionnaire from the EPA Administrator to
the heads of Federal agencies strongly encouraging voluntary
compliance with Title III and requesting information on the current
status of each agency's Title III program, policies and guidance.
The information presented in this report was obtained through the
letter and questionnaire which was issued on September 30, ;988.
EPA intends to use this information to provide Federal agencies
with technical assistance necessary to develop voluntary Title III
programs, enhance already established programs, help identify the
universe of Federal installations that would be affected by Title
III were they private installations and possibly develop guidance
for Federal agencies concerning various aspects of Title III.
BACKGROUND
Title III of SARA establishes requirements for Federal, State
and local governments and industry regarding emergency planning
and "community right-to-know11 reporting on hazardous and toxic
chemicals. This legislation was enacted on October 17, 1986, to
ensure proper response to incidents similar to the release of
methyl isocyanate in Bhopal, India in 1985. Title III builds upon
EPA's Chemical Emergency Preparedness Program (CEPP) and numerous
State and local programs aimed at helping communities to better
prepare for potential chemical emergencies.
The Title III provisions, which are described in the Findings
section to this report, consist of four major sections: emergency
planning (Sections 301-303), emergency release notification
(Section 304), community right-to-know reporting requirements
(Sections 311-312) and toxic chemical release reporting emissions
inventory (Secti^i 313). These provisions will help increase
public knowledge and access to information on the presence of
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hazardous chemicals in their communities and releases into the
environment. States and communities, working with facilities, will
improve safety and protection of public health and the environment
through compliance with Title III.
Federal agencies are not legally obligated to comply with
Title III requirements, as Federal agencies are not included in
the definition of "person" contained in section 329(7) of the
Statute. However, EPA is encouraging Federal agency voluntary
compliance and has urged Federal facilities to comply with all
Title III reporting requirements. EPA believes it is the
responsibility of all . sectors of society, including Federal
agencies, to work together to prevent, prepare for and respond to
potential chemical hazards. Only through this "cooperative spirit"
can the goal of protecting the health and safety of all citizens
be achieved.
Consistence with its goal to encourage and achieve full
Federal facility compliance, EPA issued Order 1480.1 on March 13,
1989, which addressed EPA compliance with each of. the Title III
provisions. This order was issued to all agency Assistant
Administrators and Regional Administrators,, and directed all EPA
facilities to comply with applicable Title III regulations despite
the statutory exclusion for Federal agencies in the definition of
"person." EPA facilities were instructed to review, the
regulations, determine and comply with all reporting requirements,
and develop and implement a system to monitor compliance. A copy
of this order is provided in Appendix A to this report.
Another accomplishment toward the goal of voluntarily
compliance is the Memorandum of Understanding (MOU) between the
National Institute of Standards and Technology (NIST) and the
Montgomery County, Maryland Emergency Planning Council. This MOU
is the first such agreement to be entered into by a Federal agency.
The voluntary agreement was executed to ensure the best possible
coordination between county emergency facilities and NIST in the
event of an environmental emergency and to promote the availability
of accurate information to all county residents during normal NIST
operation or during an emergency situation involving the institute.
A copy of the MOU is provided in Appendix B.
It is important to note that contract operators of government-
owned contractor-operated (GOCO) facilities are subject to
Title III to the same extent as any other operator. GOCOs,
therefore, are statutorily required to comply with the full
range of Title III planning, notification and reporting
requirements.
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FINDINGS
The EPA Administrator's letter to the Federal agencies urging
voluntary compliance included a request for specific information
relevant to determining the universe of facilities potentially
affected by Title III requirements. A copy of the Administrator's
letter is provided in Appendix C along with Enclosure 3 of this
letter which includes the specific questions directed to each
Federal agency.
EPA requested information from a total of 28 Federal agencies
including EPA. A list of these agencies is provided in Exhibit l.
Of the 28 agencies, 21 are conducting Title III activities, 5.have
determined that their facilities are not affected by Title III, and
2 have not provided responses. Each agency based their decision
of applicability on an evaluation of the quantities or activities
associated with any hazardous substances that may be used on their
facilities. Regardless of whether the agency will comply or not,
all Federal agencies support the concept of voluntary compliance
and will work to promote the "cooperative spirit" of Title III.
Many of the Federal agencies have already issued policies and
procedures concerning compliance with the planning, notification
and reporting requirements of Title III. Specifically, 13 agencies
have issued a directive or some form of guidance. Seven of 1;hese
agencies, the U.S. Departments of Agriculture (USDA) , Energy (DOE) ,
Defense (DOD) and Transportation, EPA, National Aeronautics and
Space Administration (NASA) and the Tennessee Valley Authority
(TVA) have well-established Title III programs. For example, USDA
and NASA notified their facilities as early as January 1987 of
responsibilities under Title III, and DOD issued a policy directive
in July 1987 which was designed to provide substantive compliance
with Title III, by building on existing emergency response plans
and activities. These agencies have also conducted inventories of
hazardous substances on their facilities and notified appropriate
State and local planning authorities.
Provided below is a description of the various Title III
requirements along with a summary of the overall findings by
section. Exhibit 2 provides a summary table of the Federal
agencies' responses. A separate program description sheet for each
of the 21 agencies that are conducting Title III activities can be
found in Appendix D. It is important to note that the findings in
this report are based entirely on the responses received from each
Federal agency. In some cases, agencies may not have provided
specific information requested in the questionnaire. This lack of
information, therefore, may not accurately reflect their ongoing
Title III activities.
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EXHIBIT 1
LIST OF FEDERAL AGENCIES
Federal Agencies That Are Conducting Title III Activities
Department of Agriculture (USDA)
Central Intelligence Agency (CIA)
Department of Defense (DOD)
Defense Logistics Agency (DLA)
Department of the Air Force
Department of the Army
Department of the Navy
Department of Energy (DOE)
Environmental Protection Agency (EPA)
General Services Administration (GSA)
Department of Health and Human Services (HHS)
Department of the Interior (DOI)
Department of Justice (DOJ)
Department of Labor (DOL)
National Aeronautics and Space Administration (NASA)
National Science Foundation (NSF)
U.S. Postal Service
Smithsonian Institution
Department of Transportation (DOT)
Tennessee Valley Authority (TVA)
Department of the Treasury
Department of Veterans Affairs (VA)
Federal Agencies That Have Determined That Their Facilities Are
Not Affected Bv Title III
Department of Commerce
Federal Emergency Management Agency
Department of Housing and Urban Development
National Archives and Records Administration
Nuclear Regulatory Commission
Federal Agencies that Have Not Responded
Department of Education
Department of the State
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EXHIBIT 2
SUMMARY OF FEDERAL AGENCY RESPONSES BY TITLE III
SECTION
AGENCY
Issued
Policies or
Guidances
Sections 301-303
Directed
Facilities to
Determine
TPQs
Conducted
memories
of Hazardous
Substances
Meet or
Exceed
TPQs
Notified
LEPCsof
TPQs
Directed
Facilities to
Designate
Facility Coord.
Contacted LEPC
and/or Design-
ated Facility
Coordinator
Section 304
Directed
Facilities to
Report
Releases
Section 311-312
Directed
Facilities to
Provide List
orMSDSs
Facilities
Have Sub-
mitted List/
MSDSs
Section 313
Exceed Manu-
facturing, Import-
ing and Process-
ing Thresholds
Exceed
10.000
Pound Use
Threshold
Toxic Chem.
Release Forms
Will Be
Completed
Agriculture
CIA
Defense
• Air Force
• Army
• DLA
•Navy
Energy
EPA
GSA
HHS
Interior
Justice
Labor
NASA
NSF
Postal Service
Smithsonian
TVA
Transportation
Treasury
VA
O
o
o
o
o
o
0
o
o
o
o
o
o
o
o
o
Key:
• Federal agency reported that activity has occurred.
O Federal agency reported (hat activity will occur.
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Sections 301-303; Emergency Planning
The emergency planning sections are designed to develop State
and local emergency response and preparedness capabilities through
better coordination and planning, especially within the local
community. The principal components of these sections include the:
o Requirement for each governor to designate a State
Emergency Response Commission (SERC)
o Designation of local planning districts and local
emergency planning committees (LEPCs) whose primary
responsibilities are to develop emergency response plans
o Requirement that any facility that has present any of the
366 Extremely Hazardous Substances in a quantity greater
than the Threshold Planning Quantity (TPQ) is subject to
the emergency planning requirements and, therefore, must
notify the SERCs and LEPCs that they are subject to these
requirements and designate a facility coordinator.
Of the 21 Federal agencies that are conducting Title III
activities, 17 indicated that they will comply with the emergency
planning requirements. In addition:
o ' Seventeen agencies indicated they have directed their
facilities to conduct an inventory of hazardous
substances or to specifically .determine whether TPQs of
Extremely Hazardous Substances have been met or exceeded.
o Of these 17 agencies, 12 agencies have initiated
inventories, with 7 agencies (Agriculture, DLA, Energy,
Interior, NASA, Transportation, and TVA) determining that
1 or more facilities meet or exceed the TPQs.
Agriculture, Energy, NASA, Transportation, and TVA have
notified the SERCs, LEPCs and fire departments of the
TPQs.
o Fourteen agencies indicated they have directed or will
direct their facilities to designate a facility
coordinator or to initiate contact with the State and
local planning authorities. Eleven agencies specifically
mentioned that facility coordinators have been designated
or contact with planning authorities has been made.
Lists of Facility Coordinators are provided with the individual
program description sheets in Appendix C.
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Section 304; Emergency Notification
Facilities are required to immediately notify the appropriate
LEPCs and SERCs if there is a release into the environment of a
hazardous substance that exceeds the reportable quantity for that
substance. The substances subject to this requirement are the 366
Extremely Hazardous Substances or the substances subject to the
CERCLA emergency notification requirements. Notification can be
made by telephone, radio or in person. A written follow-up
emergency notice is also required.
Of the 21 Federal agencies that are conducting Title in
activities, 16 have or will direct their facilities to comply'with
the emergency notification requirements. Another agency, the
National Science Foundation, determined that Extremely Hazardous
Substances are not present at their facilities and, therefore, has
not directed facilities to provide notification. Four agencies did
not provide specific information concerning compliance with Section
304. In several cases, the respondents expressed a concern for the
need to preserve security interests while meeting the notification
requirements.
Sections 311-312; Community Ricrht-to-Know
There are two community right-to-know reporting requirements
within. Title III. Section 311 requires facilities that must
prepare Material Safety Data Sheets (MSDSs) under the Occupational
Safety and Health Administration (OSHA) regulations to submit
either copies of MSOSs or a list of MSDS chemicals to the LEPC,
SERC and local fire department. EPA has established threshold
quantities for Section 311 below which no facility is required to
report.
Section 312 requires a facility, to submit an emergency and
hazardous chemical inventory form to the LEPC, SERC and local fire
department. Hazardous chemicals covered by Section 312 are those
for which facilities are required to prepare or have available an
MSDS under OSHA regulations and that were present at the facility
at any time during the previous calendar above specified
thresholds. The inventory form incorporates a "two-tier" approach.
Under Tier I, facilities must submit specified information for
various hazard categories. The SERC or LEPC also may request the
facility to provide additional Tier II information which includes
specific inventory information by chemical.
Twelve Federal agencies have directed or will direct their
facilities to provide MSDSs or a list of MSDS chemicals to the LEPC
or SERC. Of these 12 agencies, 5 have already done so. The
Department of Agriculture has determined that it does not meet the
reporting requirements of Section 311 and 312/but will provide
lists and MSDSs to the LEPCs when requested, or when the need
arises.
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Section 313; Toxic Chemical Release Reporting
Section 313 requires EPA to establish an inventory of routine
toxic chemical emissions from certain facilities. Facilities
subject to this reporting requirement must complete a Toxic
Chemical Release Form for specified chemicals.
• The reporting requirement applies to owners and operators of
facilities that have 10 or more full-time employees, that are in
SIC codes 20 through 39 and that manufacture, process or otherwise
use a listed toxic chemical in excess of specified threshold
quantities. These thresholds are: .
o Facilities manufacturing or processing any of these
chemicals in excess of:
75,000 pounds in calendar year 1987
50,000 pounds in calendar year 1988
25,000 pounds in calendar year 1989 and thereafter.
o Facilities otherwise using listed toxic chemicals in
quantities over 10,000 pounds in calendar year 1987 and
thereafter.
The forms must be submitted to EPA and the SERCs.
None of the Federal agencies indicated that they manufacture,
import or process toxic chemicals above .the 75,000 pound, 50,000
pound or 25,000 pound thresholds. However, four agencies (CIA,
Energy, NASA and TVA) stated that facilities use these chemicals
in excess of the 10,000 pound threshold, and all four indicated
that they would complete Toxic Chemical Release Forms. In
addition, the Department of Justice and the Postal Service have
directed their facilities to complete the inventories if a
determination is made that compliance is required. The Department
of Defense, however, has determined that Section 313 is procedural
in nature and therefore has npt specifically directed its
components to respond to these requirements.
CONCLUSION
The results of this report demonstrate that Federal agencies
have taken the initiative to voluntarily comply with the Title III
provisions. Furthermore, it appears that only a small number of
Federal agencies are in the planning phase for Title III
initiatives, whereas the majority have issued policy directives or
guidelines and have progressed to the implementation phase.
In summary, a total of ten Federal agencies reported the
number of facilities that are affected by SARA Title ...III
provisions. These 10 agencies represent approximately 214 affected
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facilities or installations. This number, however, is likely to
increase as ongoing facility surveys are completed.
TTT rTEP* intends to submit this interim final report to the Title
III Workgroup members for review and comment, and to update the
f SSSEn *?h "£%* reC6nt F6deral a*enc* Accomplishments in
addition, the Title III Workgroup will continue to develop and
compli6 Vari°US °Ptlons to further promote Federal agency
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APPENDIX A
EPA ORDER ON TITLE III
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Classification No.:
Approval Date:
1480.1
March 13, 1989
Addressee
EPA ORDER - EMERGENCY PLANNING AND COMMUNITY
RIGHT-TO-KNOW COMPLIANCE WITH SARA TITLE TIT
1. PURPOSE. This Transmittal provides a new EPA Order 1480.1 —
Emergency Planning and Community Right-to-Know Compliance with
SARA Title III.
i
2. EXPLANATION. This Order implements an Emergency Planning and
Community Right-To-Know Program at EPA facilities.
3. FILING INSTRUCTIONS. File the attached material in a three-
ring binder established for the Directives System.
Kathy
Management
ruccelli, Director
d Organization Division
Originator
EPA Form 1315-1215-88)
Environmental Health and Safety DivTfeion, Office
of Administration and Resources Management
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A EPA
Classification No :
Approval Date: 1480.1
March 13, 1989
Emergency Planning and Community-Right-To-Know
Compliance with SARA Title III
1. PURPOSE. This Order implements an Emergency Planning and
Community Right-To-Know Program at Environmental Protection
Agency (EPA) facilities.
2. AUTHORITY. The Regulations promulgated in 40 CFR Par.ts 355-
370 support the statutory requirements under the Superfund
Amendments and Reauthorization Act (SARA) of 1986, Sections 302,
303 , 304, 311, 312 and 313.
3. BACKGROUND. In 1986, the U.S. Congress passed the Emergency
Planning and Community Right-To-Know Act (SARA Title III) r.o
ensure that we would properly respond to incidents similar to the
release the methlisocyanate in Bhopal, India in 1985. The Act
mandates emergency planning efforts at the State and local level
and provides residents and local governments with access to
information concerning potential chemical hazards present in
their communities.
Federal agencies are not required to implement the provisions of
SARA Title III because the statutory definition of "person" in
Section 329(7) does not include Federal agencies and the
sovereign immunity of the United States government is not
otherwise waived. However, the EPA believes that all sectors of
society, including Federal agencies, must work collectively to
identify potential chemical hazards and develop emergency
response procedures to cooperatively protect the health and
safety of our citizens. In support of the EPA interest, this
Order implements the provisions of SARA Title III at EPA
facilities.
i .
4. SCOPE. This Order applies to all EPA facilities that use,
store, dispose of, or release chemicals, identified or listed
under the Emergency Planning and Community Right-To-Know Act.
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EPA ORDER 1480.1
March 13, 1989
5. RESPONSIBILITIES.
a. Assistant Administrators and Regional Administrators are
responsible for ensuring that the provisions of this Order are
fully implemented at facilities under their control.
b. The Director of the Environmental Health and Safety
Division is responsible for ensuring that technical assistance is
provided as necessary to implement this Order.
6. IMPLEMENTATION. This Order shall be implemented consistent
with the requirements of the regulations contained in 40 CFR
Parts 355-370. Assistant Administrators and Regional
Administrators shall develop and implement Emergency Planning and
Community-Right-To-Know Programs at facilities under their
control. The implementation programs should encompass:
a. reviewing the regulations;
b. determining reporting requirements and submitting the
appropriate reports to the appropriate State and local
authorities; and
c.. developing and implementing a system to monitor
compliance.
7. AMENDMENTS PROVISION. Changes in the law or the regulations
concerning Emergency Planning and Community-Right-To-Knov
Programs which occur after the effective date of this Order will
automatically come under the purview of this Order on th.e
effective date of the change.
8. EFFECTIVE DATE. Implementation of this Order shall occur
within sixty (60) days of the date that it is signed.
Charl.
Assistant Administrator
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APPENDIX B
MEMORANDUM OF UNDERSTANDING BETWEEN NATIONAL
INSTITUTE OF STANDARDS AND TECHNOLOGY AND
THE MONTGOMERY COUNTY EMERGENCY PLANNING COUNCIL
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MEMORANDUM OF UNDERSTANDING
BETVZEN
THE NATIONAL INSTITUTE OP STANDARDS AND TECHNOLOGY
AND
THE MONTGOMERY COUNTY LOCAL EMERGENCY PLANNING COUNCII
PURPOSE
This Memorandum of Understanding is executed Co ensure the best possible
coordination between county emergency facilities and MIST in the event of an
environmental emergency and to promote accurate information availability to
all county residents during normal MIST operation or during an emergency .
situation involving NIST.
MIST RESPQNftTBLS OFFICIALS
The Chief, Reactor Radiation Division, vill be the MIST initiating official
for all reportable radiological events involving the NIST reactor.
The Chief, Occupational Health and Safety Division, will be the "1ST
initiating official for all reportable events involving environmental
release of hazardous materials other than those falling vlthin the purview
of the TR-5 Reactor License.
The NIST initiating official shall assume the responsibility for proapc
notification ?f the Chief, Public Information Division (PID), whenever a
reportable event occurs. The initiating official shall serve as an
inforaation resource to the PID or to county officials when requested bv -he
Chief. PID. ...
EMERGENCY NOTIFICATION
The NIST Public Inforaation Division shall promptly notify the Montgomery
County Local Emergency Planning Council (LEPC) of any class of emergency
declared at the NIST reactor as a result of an actual or-projected release
of radiological effluent at the NIST site boundary or as a result of a
prolonged fire that threatens the reactor. Definitions of emergency classes
and Nuclear Regulatory Commission notification time limits are given In che
roSR Emergency Plan.
The NIST PID shall promptly notify the Montgomery County LEPC whenever a
regulatory reportable event occurs involving the release of chemical/
hazardous materials into the environment and that may extend beyond the NIST
.site boundary.
For any WIST-sice event not requiring a regulatory report, but in th«
professional judgment of the NIST initiating official could cause
apprehension/alarm to the surrounding community, the initiating official
shall communicate che circumstances of the event to PID with the
recommendation that an informational report should be made to the Montgomery
County LEPC.
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AVAILABILITY
The NIST PID will make available to the Montgomery County LEPC, the NESR
Annual' Report to the U. S. Nuclear Regulatory Commission and the NIST
Radiation Safety Committee's Annual Report to the NIST Director. The NIST
initiating officer will make available to PID any other formal NIST reports
which, in their professional judgment, will assist LEPC in public avareness
during an emergency situation.
Copies of NIST policy or procedure documents which relate to environmental
protection are available from the Chief, Occupational Health and Safety
Division. These documents will be available to county officials as
requested in areas where joint county/NIST planning activities are ongoing.
The county may appoint an observer, with NIST approval, to the annual MIST
Radiation Safety Committee meeting. The observer should be technically
trained and knowledgeable in matters dealing with radiation safety.
Raymond G. Kammer Raaon Granados
Acting Director, NIST Director, LEPC
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APPENDIX C
EPA ADMINISTRATOR'S LETTER
TO FEDERAL AGENCIES
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| UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
SB3 3 0 ic
THE ADMINISTRATOR
Honorable Frank C. Carlucci
Secretary
Department of Defense
3E880 The Pentagon
Washington, D.C. 20301
Dear Mr. Secretary: *
The U.S. Environmental Protection Agency (EPA) has promulgateu
regulations to implement the Emergency Planning and Community Right-to-Know
Act of 1986 (also referred to as Title III of the Superfund Amendments and
Reauthorization Act). This statute, which provides an innovative new
approach to environmental protection, encourages and supports emergency
planning efforts at the State and local level and provides residents and
local governments with information concerning potential chemical hazards
present in their communities. Title III was enacted to ensure that we
could properly respond to incidents similar to the release of methyl
isocyanate in Bhopal , India in 1985.
The requirements of the Emergency Planning and Community Right-to-Know
Act constitute a comprehensive mandate for emergency planning and an
assurance that citizens have the information necessary to understand and
assess chemical hazards in their communities. It is the responsibility
of all sectors of society, including Federal agencies, to work together
to prevent, prepare for and respond to potential chemical hazards. Only
through this "cooperative spirit" can we achieve the goal of protecting
the health and safety of all citizens.
Federal agencies are not legally obligated to comply with the
requirements of Title III, as Federal agencies are not included in the
statute's definition of "person" contained in section 329(7). However,
EPA is encouraging your agency's voluntary compliance with the emergency
planning and notification efforts that are underway and strongly urges
your facilities to comply with all of the community right-to-know
reporting requirements outlined in Enclosure 1. Although several of
the statutory reporting deadlines have passed, it is important that
Federal agencies attempt to fulfill all applicable requirements of the
statute as soon as practicable. EPA is aware of several Federal agencies
that have established or Initiated programs to address implementation of
Title III at their facilities. We commend these efforts and encourage
all Federal agencies to pursue such action.
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Every agency should be aware that contract operators of government-owned,
contractor-operated (GOCO) facilities are subject to Title III to the
same extent as any other operator and, therefore, are statutorily required
to comply with the full range of planning, notification and reporting
requirements of the Emergency Planning and Community Right-to-Know Act.
Federal agencies that have GOCO facilities may wish to determine whether
their contractors know of and are complying with all applicable
provisions of Title III described in Enclosure 1.
EPA realizes that the disclosure of certain Information relating
to Federal facilities or activities may be prohibited under various
statutes governing national security. However, facilities that withhold
information because of national security concerns should, to the extent
possible, provide other information to assist communities in planning for
and responding to emergency situations. EPA is currently examining
alternatives for reporting "classified" information concerning chemical
hazards that will not compromise national security.
We strongly recommend that all Federal agencies develop internal
policies to address all the major provisions of Title III, in particular
the facility requirements under:
0 Sections 301 - 303; Report the presence of extremely hazardous
substances in excess of the Threshold Planning Quantities (TPQ)
to the applicable State emergency response commission (SERC) and
local emergency planning committee (LEPC).
0 Section 304; Provide emergency release notification for extremely
hazardous substances and all CERCLA hazardous substances to the
LEPC and SERC of any area likely to be affected by the release.
0 Sections 311 and 312; Submit a material safety data sheet (MSOS)
for each chemical for which a MSDS must be prepared under the
Occupational Safety and Health Act of 1970 and its implementing
regulations or a list of such substances and a Tier I or Tier II
inventory form to the appropriate LEPC, SERC and fire department.
0 Section 313: Report annually on the amounts of chemicals released
to each environmental medium. The purpose of this reporting requirement
is to Inform the public and government officials about routine releases
of toxic chemicals into the environment.
In- order to assist each Federal agency in developing a comprehensive
Title III program, we would like to extend an invitation to your staff to
attend a workshop on the Emergency Planning and Community Right-to-Know
Act on October 6, 1988. The purpose of this workshop is to provide Federal
agencies with .a thorough understanding of the Title III provisions and
provide technical assistance to enable your agency to design and implement
an efficient voluntary program that, were the Federal agency considered .
a private facility, would satisfy the requirements of the statute.
Additional information concerning the workshop is provided in Enclosure 2.
Representatives from your agency that attend the EPA Federal Agency
Environmental Roundtable have been informed about the upcoming workshop.
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-3-
We would like to request information from each agency on the
current status of your Title III program, policies and guidance as outlined
in Enclosure 3. This information will enable EPA to provide Federal
agencies with technical assistance necessary to develop their voluntary
Title III programs, enhance those that are already established, identify
the universe of Federal installations that would be affected by Title
III were they private installations and possibly develop guidance for
Federal agencies concerning various aspects of Title III.
As stated previously, it is important that Federal agencies initiate
appropriate actions to meet the requirements of the Emergency Planning
and Community R1ght-to-Know Act. A Federal Facilities Title III Workgroup
has been established at EPA to examine various approaches to promote the
voluntary compliance by Federal agencies with the statute and we welcome
your agency's participation in the workgroup. As the workgroup considers
and develops various approaches, we will be seeking your comments and
assistance through agency representatives on the National Response Team
and the EPA Federal Agency Environmental Roundtable.
Finally, it is criticalthat Federal agencies contribute to the
"cooperative spirit" of the Emergency Planning and Community Right-to-Know
Act so that all citizens can benefit from the full implementation of this
statute. Only by ensuring that communtities and States have a complete
picture of all potential chemical hazards can they succeed in meeting the
important goals of Title III.
Please submit, as soon as possible, the name of a contact person for
the October 6 workshop to Ms. Kathy Hutson, Office of Federal Activities
(A-104), U.S Environmental Protection Agency, 401 M Street, S.W., Washington,
D.C. 20460, (202) 475-8789. In addition, your response to Enclosure 3
would be appreciated no later than November 4, 1988.
Thank you for your time and cooperation in this matter. Together
we can make Title III a real success story.
Sincerely,
J>
M. Thomas
Enclosures
cc: Honorable Edward C. Aldridge, Jr. Honorable William L. Ball, III
Secretary of the Air Force Secretary of the Navy
Honorable John 0. Marsh, Jr. Lieutenant General Vincent M. Russo
Secretary of the Army Director, Defense Logistics Agency
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ENCLOSURE 3
INFORMATION REQUESTED ON THE STATUS
OF EACH FEDERAL AGENCY
TITLE III PROGRAM
1. Has your agency issued or are you planning to issue guidance and/or
policies concerning Title III? If so, please provide EPA a copy
of pertinent policies and/or guidance.
2. Has your agency directed facility staff to determine whether any of
the threshold planning quantities of extremely hazardous substances
are present at the facility? If so, do you know how many facilities
have met these thresholds? Have these facilities notified local
planning committees and the appropriate State emergency response
commissions?
3. Have your facilities been in contact with local emergency planning
committees and identified a facilities coordinator (a contacjt person)
to discuss emergency planning concerns with respect to the Federal
facility? If so, could you provide us a copy of a.list of facility
coordinators?
4. Has your agency directed its facilities to report releases of
repoctable quantities (or 1 pound where no reportable quantity
has been assigned) of hazardous substances, including extremely
hazardous substances, to the state emergency response commission
and the local planning committee?
5. Are your facilities going to provide the local emergency planning
committees or the local fire department with lists of "hazardous
chemicals," under the Occupational Safety and Health Act of 1970
and its implementing regulations or Material Safety Data Sheets for
those chemicals, in addition to the lists of extremely hazardous
substances? If so, how many of your facilities have done so?
6. How many of your facilities manufacture, import, process or use any
of the chemicals on the attached list above the following thresholds?
a) Manufacture, import and process:
• 75,000 pounds during calendar year 1987
- 50,000 pounds during calendar year 1988
- 25,000 pounds during calendar year 1989, and subsequent years.
b) Use:
• 10,000 pounds in calendar year 1987 and subsequent years.
c) Are these facilities planning to complete toxic chemical
release forms to be submitted to appropriate State emergency
response commissions and the Environmental Protection Agency?
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APPENDIX D
FEDERAL AGENCY TITLE III
PROGRAM SUMMARIES
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LIST OF FEDERAL AGENCY TITLE III
PROGRAM SUMMARIES
Department of Agriculture
Central Intelligence Agency
Department of Defense
Department of the Air Force
• Department of the Army
Defense Logistics Agency
Department of the Navy
Department of Energy
Environmental Protection Agency
General Services Administration
Department of Health and Human Services
Department of Interior
Department of Justice
Department of Labor
National Aeronautics and Space Administration
National Science Foundation
U.S. Postal Service
Smithsonian Institution
Tennessee Valley Authority
Department of Transportation
Department of Treasury
Department of Veterans Affairs
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Department/Service: Department of Agriculture
Contact/Title: John Teske, Chief
Safety and Occupational Health Branch
Address: Office of Assistant Secretary for
Administration
OFM: SHMO: Room 0324 - South Building
Washington, DC 20250-9000
Phone Number: (202) 382-1045
Progran Description:
The Department of Agriculture has a well established Title III
program. As early as January 1987 the Department notified all
Agriculture Research Service area managers of their
responsibilities under Title III. The Forest Service and the
Agricultural Stabilization and Conservation Service .have also
notified their facilities regarding compliance with Title III.
Program Scope:
Sections 301-303: Two facilities of the Animal and Plant
Inspection Service have accumulated hazardous materials in excess
of the Threshold Planning Quantity (TPQ). One facility formulates
vertebrate control devices and poison grain baits, and local
emergency planning committees have been notified. The second
facility produces a poisonous attractant for insect control. They
have not notified local emergency planning committees since they
are a self-contained facility which is approximately 20 miles from
the nearest fire department and, therefore, have their own fire
fighting capability. In addition, the chemicals are overpacked in
85-gallon drums which are stored in a secure area minimizing the
risk.
The Agricultural Research Service has surveyed their facilities
and found that 30 out of 123 locations had chemicals in excess of
the TPQ. In late spring of 1987, these 30 locations notified their
respective SERCs. Since local planning committees had not been
formed at this time, they were unable to provide notification to
these committees.
Various USD* facilities have been in contact with local planning
committees but specific facility coordinators have not been
designated. Local management handles this on an as-needed basis.
Until facility coordinators are formally designated, the Chief of
the Safety and Occupational Health Branch will serve as a contact
point during emergencies.
Section 304: The Forest Service directed its facilities to notify
the local planning committees in its May 1987 directive. The
Agricultural Research Service directed its facilities to notify
local planning committees in its November 17, 1987, memorandum.
o?
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Sections 311-312: USDA determined that it does not meet the
reporting requirements of Sections 311 and 312 of Title III. USDA
does, however, provide lists and Material Safety Data Sheets to
LEPCs when requested, or when the need arises.
Section 313: USDA does not manufacture, import, process or use
chemicals in excess of the specified threshold quantities.
Program Directives/Guidance:
Forest Service Memorandum May 27, 1987
Department of Agriculture notice September 1, 1987
Regulatory Alert January 13, 1987
Technical Alert February 2, 1987
Number of Facilities Affected:
Two facilities of the Animal and Plant Inspection Service, and 30
facilities of the Agricultural Research Service have chemicals in
excess of the TPQs.
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Departmont/8«rvic«: Central Intelligence Agency
Contact/Titl«: James H. New, Chief
Safety Division
Office of Medical Services
Address: Office of Medical Services
Central Intelligence Agency
Washington, DC 20505
Phone Number: (703) 281-8836
Program Description:
The Central Intelligence Agency (CIA) has initiated actions to
implement the requirements of Title III but has not yet issued any
formal policy. The agency is in the process of determining the
quantities of Extremely Hazardous Substances at each facility.
Program Scope:
•
Sections 301-303: Although no LEPC has yet been established, local
county emergency response personnel are familiar with the
substances used at CIA headquarters.
Section 304: The CIA's Office of Medical Services reports releases
of all hazardous substances to appropriate local and state offices.
All appropriate permits and operating functions are registered with
these officials.
Sections 311-312: The CIA will not distribute Material Safety Data
Sheets (MSDSs) to local emergency response personnel but will
maintain a complete volume of MSDSs in the Security Office, where
emergency response personnel may review MSDSs 24 hours a day.
Section 313: More than 10,000 pounds of chemicals such as
isopropyl alcohol and a solvent mixture called "blanket wash" are
used at CIA headquarters annually. If toxic releases occur at CIA
headquarters, the appropriate local and state officials will be
notified.
Program Directives/Guidance:
Although the CIA has initiated actions to implement provisions of
Title III, no formal policy regarding compliance with Title III
requirements has been issued.
Number of Facilities Affected:
The number of facilities identified with Extremely Hazardous
Substances is considered classified.
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Department/Service: Department of Defense
Contact/Title: Brian Higgins
Environmental Specialist
Address: Defense Environmental Support Office
201 N. Washington Street
Suite 100
Alexandria, Virginia 22314
Phone Number: (703) 325-2211
Program Description:
The Department of Defense (DOD) issued a policy directive on July
3, 1987 to each of the Armed Services concerning the applicability
of Title III provisions to DOD installations. This directive
states that "although neither the substantive nor procedural
aspects of Title III apply -to DOD, all DOD components should comply
with the conceptual objectives of the Act to . the extent
practicable." Specifically, the directive indicates that DOD
components should respond to the requirements, of Sections 301(c),
303(d)l, and 304 of Subtitle A - Emergency Planning and
Notification and not respond to Subtitles B and C which the
directive describes as procedural in nature. ,
The directive also suggests that preventative programs such as
Spill Prevention, Control and Countermeasures (SPCC) plans be
upgraded to address hazardous materials. . Response programs such
as Spill Contingency Plans (SCP) should include requirements for
training On Scene Coordinators (OSCs) in hazardous materials
response, and notification of LEPCs in the event of a release of
a reportable quantity of material. Also, each installation should
identify one official to act as a point of contact for local
preparedness committees such as LEPCs.
[Refer to the program summaries on each DOD component for
additional information.]
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Department/Service: Department of the Air Force
Contact/Title: Major Tim Middleton
Address: Department of the Air Force
Washington, DC 20330-1000
Phone Number: (301) 404-7788
Prograa Description:
The Air Force issued the "Emergency Planning and Community Right-
to-Know Act of 1986 Implementation Guidance" on November 9, 1987,
and intends to issue expanded guidance in the near future. This
guidance is designed to provide substantive compliance with Title
III, by building on existing plans and activities. The Air Force
intends to have installation emergency response plans that are
fully coordinated at the base level and include active
participation in-off-base planning activities at the Federal, State
and local level. Personnel at the base level who are responsible
for disaster preparedness and spill response plans and fire and
safety plans are also responsible for developing and implementing
installation emergency response plans.
Program Scope:
Sections 301-303: The Title III implementation guidance requires
each Air "Force installation to identify a point of contact to the
LEPC to participate in the planning process and in Regional and
State planning activities as well. Installations are also required
to develop response plans (generally already in existence) and
coordinate them with appropriate local authorities. In addition,
Air Force requirements instruct the Base Bioenvironmental Engineer
to develop a comprehensive listing of hazardous chemicals used and
stored on the base and to assess the hazards associated with their
use. This information is to be incorporated into response plans.
Section 304: Air Force installations are required to report all
releases of hazardous substances, as defined in Section 302 of
SARA, which exceed the specified reportable quantities pursuant to
Air Forces Regulations 19-8, para. 5d(l)(c)2. The Air Force plans
to issue updated guidance specifically directing all installations
to report to the SERC and the LEPC.
Sections 311-312: Air Force guidance directs installations to
provide, upon request of the LEPC, unclassified information on the
nature and amount of listed substances used and/or stored on
installations. The guidance further directs installations to
submit Material Safety Data Sheets (MSDSs) or a list of MSDS
chemicals to the LEPC, the SERC and the cognizant fire department.
The base fire departments are updating their hazardous chemical
data bank which will be provided to local fire departments or
planning committees.
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Section 313: The Air Force is not requiring installations to
complete and submit the Toxic Chemical Release Inventory Reporting
Form. Substantive compliance, however, is strongly encouraged
where appropriate.
Program Directives/Guidance:
DOD issued a policy directive to the Armed Services concerning
applicability of Title III to DOD installations on July 3, 1987.
The Air Force issued the "Emergency Planning and Community Right-
to-Know Act of 1986 Implementation Guidance" on November 9, 1987.
Number of Facilities Affected:
Information not provided.
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Department/Service: Department of the Army
Contact/Title: Rhea Cohen
Senior Environmental Protection
Specialist
Army Environmental Office
Address: HQDA, OCE, ATTN: ENVR-EH
The Pentagon
Washington, DC 20310-2600
Phone Number: (202) 693-5032
Program Description:
The Army is revising Army Regulation 200-1, "Environmental
Protection and Enhancement," which provides, in Chapter 8, the Army
policy and procedures for the prevention and control of spills of
oil and hazardous substances. This chapter also addresses prompt
coordinated response to contain and clean up spills that might
occur and conformance to Title III. The Army Environmental Office
has distributed Chapter 8, Oil and Hazardous Substances Spill
Contingency Planning, Control, and Emergency Response as interim
guidance until AR 200-1 is printed and distributed. Chapter 8
requires installations to adhere to the DOD policy to conform to
Sections" 301(c), 303(d)1 and 304 of the act to the greatest extent
possible, as described below.
Program Scope:
Sections 301-303: According to Chapter 8 of AR 200-1, Installation
Commanders have the primary responsibility for emergency planning
activities. This responsibility includes developing and
implementing a Spill Prevention, Control, and Countermeasures Plan
(SPCCP) and the Spill Contingency Plan. All installations will
prepare, maintain and implement the SPCCP for hazardous substances
if: (1) because of location, the installation or activity has the
potential to spill hazardous substances in such quantity that it
would be harmful to human health, welfare or the environment and
(2) one or more hazardous substances are stored in quantities that
would be harmful if a spill were to occur.
Additional planning responsibilities of the installation commander
include:
o Designating an Army employee to represent the installation
commander at LEPC meetings and to provide, to the extent
practical, the information requested by the LEPC or any other
party.
o Responding to LEPC requests for information, when possible,
by providing documents that are available under the Freedom
of Information Act and are not classified, but without
creating new reports or completing additional forms.
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o Identifying those resources and capabilities that could be
made available to the LEPC or Regional Response Team (RRT) if
requested to assist in containing or cleaning up a spill not
due to Army activities.
o Requiring contractors and subcontractors, whether or not
located on the installation, and tenants to comply with all
of the Title III requirements that apply to their operations
on or for the installation.
o Appointing an Installation On Scene Coordinator (IOSC) and an
Installation Response Team (IRT) and ensure they are
adequately trained and prepared to act in accordance with the
National Contingency Plan.
The IOSC has primary responsibility for overseeing response actions
following a spill, coordinating response plans, and providing spill
notification as described below.
Section 304: In the event of a spill, the IOSC will report by
telephone any spill of a reportable quantity of hazardous substance
to the National Response Center (NRC) and State and local
authorities including the LEPC. The IOSC will also prepare a
written report for EPA, if required, and submit a copy concurrently
to the LEPC. All unclassified information concerning a spill of
a hazardous substance will be made available to the public.
Sections 311-312: The July 1987 DOD policy directive concerning
Title III compliance does not require DOD components to respond to
the requirements of Subtitle B which includes Sections 311 and 312.
As described earlier, however, the installation commander will
respond to LEPC requests for information, when possible, by
providing documents that are available under the Freedom of
Information Act and are not classified, but will not create new
reports or complete additional forms.
Section 313: The July 1987 policy directive states that DOD
components should not respond to the requirements of Subtitle B
which includes Section 313.
Program Directives/Guidance:
DOD issued a policy directive to the Armed Services concerning
applicability of Title III to DOD installations on July 3, 1987.
DOD issued Chapter 8, Oil and Hazardous Substances Spill
Contingency Planning, Control and Emergency Response of AR 200-1,
"Environmental Protection and Enhancement,11 as interim guidance
until AR 200-1 is printed and distributed.
Number of Facilities Affected:
Information not provided.
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Department/Service: Defense Logistics Agency
Contact/Title: William Randall
Installation Services and Environmental
Protection
Address: OLA Headquarters
Cameron Station
Alexandria, Virginia 22304-6100
Phone Number: (703) 274-6124
Program Description:
The Defense Logistics Agency (DLA) issued guidance on August 4,
1987, to implement Title III programs for DLA activities. These
programs will ensure that facility emergency plans are comparable
wherever feasible to State Title III programs at DLA-managed
installations. DLA's objective is to establish programs within its
fencelines which provide the same level of hazard awareness and
community protection as the Title III programs established outside
the fencelines. A key aspect of the programs will be the expansion
of existing contingency plans to cover releases during catastrophic
events and the establishment of emergency planning committees.
Prograa Scope:
Sections 301-304: The Agency Title III guidance directed all DLA
activities to establish emergency planning committees that are
analogous to LEPCs. Each committee is required to establish
procedures for receiving and processing information requests and
to expand the Spill Contingency Plan to meet the hazardous
materials emergency plan requirements in Title III. The Agency
guidance also directs each DLA-managed activity to appoint
representatives to local planning committees, where appropriate,
and to identify all sites where Extremely Hazardous Substances are
stored or used and note where Threshold Planning Quantities (TPQs)
are exceeded. The agency has determined that four of the non-
tenant, DLA-managed facilities have TPQs of one or more listed
substances. These facilities have not notified the LEPCs or SERCs.
DLA facilities, however, have been in contact with local committees
and have identified facility coordinators.
Section 304: DLA activities will fully notify LEPCs and SERCs in
the event of a DLA release that might result in exposure to persons
outside of DLA facilities.
Sections 311-312: DLA activities will not comply with reporting
requirements.and other procedural requirements established under
Title III. Inventories, lists of materials or annual reports will
not be submitted to states or local committees. The DLA Title, III
Guidance, however, requires DLA-managed activities to prepare a
central file of MSDSs for all listed Extremely Hazardous Substances
on the installation. The goal is to have current and accurate
-------
manufacturers' MSDSs readily available to fire, spill response and
safety and health personnel.
Section 313: No DLA facilities fall within SIC codes 20 through
29. Therefore, Section 313 does not apply to DLA, and its
facilities will not be completing Toxic Chemical Release Forms.
Program Directives/Guidance:
DOD issued a policy directive to the Armed Services concerning
applicability of Title III to DOD installations on July 3, 1987.
DLA issued "Guidance for DLA Emergency Planning and Community
Right-to-Know Program" on August 4, 1987.
Number of Facilities Affected:
Four of the non-tenant, DLA-managed facilities have TPQs of one or
more listed substances.
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FACILITY COORDINATORS
Defense Logistics Agency
Facility
Coordinator
Telephone No.
[Defense Construction
Supply Center, Columbus, OH
Defense Electronics Supply
Center, Dayton, OK
Defense General Supply
Cea-cer, Riwlimcnd, v:.
Defense Personnel Support
Center, Philadelphia, PA
Defense Depot .Memphis,
Memphis, TN
Defense Deoot Ogden,
Ogden, UT
Defense Depot Tracy,
Tracy, CA-
Mr. Mike Mott
Mr. Dave Wagner
Mr. Ed Grossman
Mr. Fteid Parranore
Mr. Danny Chumney
Mr. David Weaver
Mr. Jim King
(614)238-4220
(513)296-5111
; 804)275-4838
(215)952-5883
(901)775-6969
(801)399-7211
(209)832-9341
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Department/Service: Department of the Navy
Contact/Title: Carl R. Webb
Deputy Chief of Naval Operations
Address: Office of the Chief of Naval Operations
Washington, DC 20360-2000
Phone Number:
Program Description:
The Department of the Navy issued policy guidance, "Navy
Participation in Actions under Title III of the Superfund
Amendments and Reauthorization Act (SARA)" on January 25, 1988.
This policy requires Navy installations to coordinate emergency
planning and release notification activities with State and local
emergency planning organizations.
Program Scope:
Sections 301-303: The policy guidance directs staff to determine
whether the installation (including tenant commands) contains more
than the Threshold Planning Quantity (TPQ) of an Extremely
Hazardous Substance. If TPQs are exceeded, the installation is
subject to State and local emergency planning requirements, while
preserving Navy security interests. Installations not "subject"
to these planning requirements are encouraged to participate in
response planning in order to coordinate efforts with existing Navy
hazardous substance contingency plans. In addition, these
installations are required to designate an individual to serve as
the official point of contact with the LEPC and SERC.
Section 304: The Navy policy guidance directs installations to
notify the LEPC and SERC if there is a release of a listed
hazardous substance that exceeds the reportable quantity for that
substance.
Sections 311-312: The Navy does not intend to comply with the
provisions of Sections 311 and 312 as part of their voluntary
implementation with Title III.
Section 313: These provisions have not been included in the Navy's
voluntary implementation of Title III.
Program Directives/Guidance:
DOD issued a policy directive to the Armed Services concerning
applicability of Title III to DOD installations on July 3, 1987.
The Navy issued "Navy Participation in Actions under Title III of
the Superfund Amendments and Reauthorization Act (SARA)" on January
25, 1988.
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Number of Facilities Affected:
Information not provided.
J
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Department/Service: Department of Energy
Contact/Titl«: Richard Daley
Office of Environmental Guidance and
Compliance
Address: Department of Energy
Washington, DC 20585
Phone Numbers: (202) 586-7117
Program Description:
The Department of Energy (DOE) issued two guidance memoranda
outlining the requirements of Title III and its applicability to
government-owned contractor-operated (GOCO) facilities. Many of
DOE's facilities are GOCOs and therefore are required to comply
with Title III. Although DOE as a Federal entity is not required
to implement a formal Title • III program, the department is
attempting to ensure that its facilities are in full adherence with
the statute.
In response to the EPA Administrator's letter, DOE contacted each
of its Programs, Naval Reactions, Operations, and Power Marketing
Administration offices as well as other offices in the DOE system
to gather information concerning compliance with Title III. ' DOE
received responses for 20 offices, covering 57 facilities and
programs. A discussion of these responses is provided below.
Program Scope:
Sections 301-303: Most DOE facilities have been directed to
determine if they have Threshold Planning Quantities (TPQs) of
Extremely Hazardous Substances. Forty-eight DOE facilities
indicated that they have been so directed, and thirty-six
facilities exceed TPQs with two facilities still uncertain. Each
of the 36 facilities that have exceeded TPQs have notified the
LEPCs and SERCs. In addition, several facilities have notified or
intend to notify the planning committees even though they do not
exceed TPQs. A large majority (49) of the DOE facilities have been
in contact with LEPCs, and two facilities are in the process of
doing so. Finally, out of 57 facilities 45 facilities have
identified a facility coordinator.
Section 304: Most DOE facilities have been directed to report
releases of reportable quantities. Specifically, 45 have been
directed to do so, 2 have not been directed but will notify
authorities if they had such a release, 3 stated that they have
not been directed, 2 anticipate that direction will be provided in
the near future and 4 indicated that the notification requirements
are not applicable to their facilities.
Sections 311-312: Forty-six DOE facilities have already provided
lists of hazardous chemicals to the appropriate emergency response
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Sections 311-312: Forty-six DOE facilities have already provided
lists of hazardous chemicals to the appropriate emergency response
organizations. Five other facilities are in the process of
determining whether this activity applies to their installation and
indicated they would comply if necessary.
Section 313: None of the DOE facilities indicated that they
manufacture, import and process toxic chemicals above the 75,000
pound, 50,000 pound or 25,000 pound thresholds or fall under the
applicable SIC Codes. Twenty-six facilities indicated, however,
that they use these chemicals in excess of the 10,000 pound
threshold. Of these 26 facilities, 14 are planning to complete
Toxic Chemical Release Forms and 8 are not planning to do so
because they fall outside of the applicable SIC Codes. Three of
the remaining sites did not provide a reason and one site is
determining whether it needs to do so. In addition, four
facilities that do not exceed the 10,000 pound threshold are
planning to complete the forms.
Program Directives/Guidance:
SARA Title III - Emergency Planning and Community Right-to-Know
Memorandum, May 14, 1987.
"Clarification of the Applicability of SARA Title III," July 22,
1988.
Number of Facilities Affected:
As stated above, 36 DOE sites indicated that they exceed TPQs for
Extremely Hazardous Substances, and 26 sites use "toxic" chemicals
in excess of the 10,000 pound threshold.
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of Energy
CONTACT
FACILITY
Chicago Ops.
Office
Ames
Argonne
3roo*haven
Fermi
PPPL
SERI
Oak Ridge Ops.
Office
Idaho Ops
Office
Albuquerque
Ops.Office
Richland Ops.
Office
San Franc!
Ops.Office
FMPC
PORTS
ORGDP
PGDP
ORNL
Y-12
RMI
CEBAF
SPR-PMO
INEL
West Valley
Kansas City
Los Alamos
Mound
Pantex
Pinellas
Rocky Flats
Sandia-Albuquerque
Sandia-Livermore
WIPP
Hanford
SLAC
ETEC
LBL
LLNL
CERCLA Title III
DOE Site .
Emergency
Coordinators
Lowell Mathison
Ronald Kolzow
Leonard C. Emma
Rudolph Dorner
John E. Anderson
Dave Stewart
Richard Debusk
Carl Weghorst
John Boiling
Norm Windt
Joe Inman
Larry Moore
Rick Mason'
Tom Hassler
None
G. C. Bowman
T. G. Adams
P. T. Hoopes
D. K. Winston
David Heitz
Bob Gage
David Ingle
H. L. Turner
0. L. Hughes
V. W..Ormond
K. T. Campbell
Larry Musen
Paul Dana
Steve Lafflam
None
None
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CONTACT
FACILITY
Savannah River
Ops.Office Savannah River Plant
Nevada Ops.
Office
Nevada Test Site
Tonopah Test Range
EG&G North Las Vegas
EG&G Sunset-Clark Cnty
Bartlesville
Proj.Office NXPER
.METC
PETC
Naval Reactors
Bettis, West Mifflin
Naval Reactors, INEL
Knolls, Niskayuna
Kesselring, West Milton
Windsor Site
Alaska
Power Admin. Facility No. 1
Facility No. 2
Bonneville
Power Admin.
Southeastern
Power Admin.
Southwestern
Power Admin.
western A
Power
NPR - Calif.
CERCLA Title III
DOE Site
Emergency.
Coordinators
Dave Lassiter
Stephen A. .Wellington
Stephen A. Mellington
Jackson P. Maddox
No response
Greg Steele
Judy Anderson
John E. Sourbeer
C. K. Gaddis
G. C. Bowman
C. Schimikowski
T. M. Mauser
K. A. Berta
None
None
None
None
None
None
Steve Toth
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CONTACT
FACILITY
Naval Petrol/
Oil Shale N'PR-3, Wyoming
Reserve, CO, NOSR-1, Colorado
UT, WY NOSR-3, Colorado
NOSR-2, Utah
Civilian
.Radwaste Mgmt
CERCLA Title III
DOE Site'
Emergency
Coordinators
Dave McCallister
Dave McCallister
Dave McCallister
Dave McCallister
N/A
LEGEND
PPPL - Princeton Plasma Physics Laboratory
SERI --Solar Energy Research Institute
FMPC - Feed Materials Production Center
PORTS - Portsmouth Gaseous Diffusion Plant
ORGDP - Oak Ridge Gaseous Diffusion Plant
PGDP - Paducah Gaseous Diffusion Plant
ORNL - Oak Ridge National Laboratory
RMI - RMI Co. Extrusion Plant .
CEBAF - Continuous Electron Beam Accelerator Facility
SPR-PMO - Strategic Petroleum Reserve Project Mgt. Office
INEL - Idaho National Engineering Laboratory
WIPP - waste Isolation Pilot Plant
SLAC - Stanford Linear Accelerator
ETEC - Energy Technology Engineering Center
LBL - Lawrence Berkeley Laboratory
LLNL - Lawrence Livenoore National Laboratory
NIPER - National Institute for Petroleum and Energy Research
METC - Morgtntovn Energy Technology Center
PETC - Pittsburgh Energy Technology Center
NPR - Naval Petroleum Reserve
NOSR - Naval Oil Shale Reserve
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Department: Environmental Protection Agency
Contact/Title: Howard Wilson, Manager
Environmental Compliance Program
Environmental Health and Safety Division
Address: 401 M Street, SW
Washington, D.C. 20460
Telephone: (202) 382-3640
Program Description:
On August 28,1987, EPA issued a memorandum to facility
environmental compliance coordinators clarifying that the statute
was not applicable to Federal facilities but urged EPA field
offices to comply with information requests from local governments
and private parties. As a follow-up to this 'memorandum, EPA issued
an order on March 13, 1989, which dealt with EPA facility
compliance with SARA Title III. EPA Order 1480.1 was sent to all
Assistant Administrators and Regional Administrators; in addition
to all of the individual laboratory facilities across the country.
The order instructed EPA facilities to disregard the statutory
exclusion for Federal agencies under the definition of "person",
and to reexamine the regulations, determine reporting requirements,
submit appropriate reports to Federal, State and local authorities,
and implement a system to monitor compliance with SARA Title III.
EPA Headquarters helps to ensure environmental compliance by
performing comprehensive environmental compliance audits at all of
the field laboratories and research facilities on a biannual basis.
SARA Title III is one of the environmental regulatory areas
addressed in these audits. Results of the audits are compiled in
written reports and are also entered into a database tracking
system at Headquarters. In this manner Headquarters has the
capacity to track SARA Title III compliance at all of its
facilities.
Program Scope:
Sections 301-303: Environmental audits identified two EPA
facilities that were for a brief time subject to Sections 301-303
due to the presence of Extremely Hazardous Substances in excess of
TPQs. The facilities were in compliance with the emergency
planning requirements. All EPA facilities have assigned personnel
to act as facility coordinators, and all facilities have been
instructed through the EPA Order to comply with this requirement
if they meet TPQs.
Section 304: No EPA facility has encountered a situatipn where
they have had to report emergency releases of hazardous substances.
All EPA facilities have been instructed to comply with this
provision should a release occur which meets the criteria in
Section 304.
-------
Sections 311-312: Certain EPA facilities have been requested to
submit MSDSs by local fire response personnel even through they did
not meet applicable thresholds. EPA has instructed its facilities
to submit such informaton when requested by fire response and
emergency personnel. No EPA facility has yet exceeded the
threshold for submitting Tier I and Tier II forms under Section
312.
Section 313: No EPA facility has exceeded the thresholds for
required reporting of toxic chemical releases per Section 313. EPA
facilities have been instructed to comply with these requirements
should they meet the applicable thresholds and reporting criteria.
Program Directives/Guidance
Memorandum to Facility Environmental Compliance Coordinators
Concerning Implementation of Title III, August 28, 1987.
EPA Order 1480.1 March 13, 1989
Number of Facilities Affected:
The EPA Order was sent to all 34 EPA field facilities under the
supervision of the Environmental Health and Safety Division. All
facilities have been instructed to comply with applicable
provisions of Title III. All 34 facilities are potentially
affected by this EPA Order.
-------
Department/Service: General Services Administration
Contact/Titl«: James Hensley, Chief
Environmental Management Branch
Address: Public Buildings Service
Washington, DC 20405
Phone Number: (202) 566-1464
Program Description:
The General Services Administration (GSA) intends to develop and
implement a program designed to comply with the conceptual
objectives of SARA Title III. GSA plans to develop a program
during fiscal year 1990.
Program Scope:
Information not provided.
Program Directives/Guidance:
None
Number of Facilities Affected:
No information was provided on the number of facilities affected
by SARA Title III.
-------
Department/Service: Department of Health & Human Services
Contact/Title: Jim Johnson, Director
Division of Special Programs Coordination
Address: Room 4700, Cohen Building
330 Independence Avenue, SW
Washington, DC 20201
Phone Number: (202) 245-7426
Program Description:
The Department of Health and Human Services (HHS) fully supports
compliance with Title III requirements and has initiated a survey
of its facilities to determine the applicability of Title III to
HHS activities.
Program Scope:
Information not provided.
Program Directives/Guidance:
HHS issued a directive on July 6, 1989.
number of Facilities Affected:
Information not provided.
-------
Department/Service: Department of the Interior
Contact/Title: Bruce Blanchard, Director
Office of Environmental Project Review
or
Libby Stone
Address: 18th & C Streets, NW
PEP, Room 4239
Washington, DC
Phone Numbers: (202) 343-3343 (Blanchard)
(202) 343-3891 (Stone)
Program Description: -
The Department of Interior (DOI) reports that currently 25
facilities meet the reporting and notification criteria under Title
III. DOI encourages its facilities to comply with the emergency
planning and notification requirements of Title III. DOI guidance
will be prepared following an inventory of its facilities.
Program Scope:
Sections 301-303: Information not provided.
Section 304: Information not provided.
Sections 311-312: Submission of Material Safety Data Sheet (MSDS)
lists will be coordinated with the local fire departments, and
SERCs may be contacted.
Section 313: Information not provided.
Program Directives/Guidance:
DOI will prepare guidance following an inventory of its facilities.
Number of Facilities Affected:
Currently there are 25 facilities, out of 1500, which have been
identified with Extremely Hazardous Substances above the Threshold
Planning Quantities (TPQs).
-------
Department/Services: Department of Justice
Contact/Title: Marvin Fink, Manager
Safety and Health
Address: 5111 Main Justice Building
Tenth Street and Constitution Avenue, NW
Washington, DC 20530
Phone Number: (202) 633-5076
Program Description:
The Department of Justice (DOJ) recently completed an audit of
their facilities for the presence of Threshold Planning Quantities
(TPQs) of Extremely Hazardous Substances. The results of the audit
revealed that only small amounts of chemical reagents were stored
or used in the analytical laboratories. Therefore, most DOJ
facilities do not meet the criteria established for
reporting/notification under Title III. However, the agency
intends to issue a draft Order to all Department components that
establishes a hazardous waste management program and discusses the
requirements of Title III. The Order will require DOJ facilities
which meet the applicable statutory criteria to comply with 'all
aspects of Title III, as described below.
Program Scope:
Sections 301-303: The draft Order will require that if a facility
should have Extremely Hazardous Substances that exceed the TPQs
they are to cooperate with and notify the SERC. Also, the Order
will state that "each facility in the Department shall cooperate
with the local emergency planning group within their State and
shall develop the plans necessary for identifying hazardous
materials and their potential for release." In addition, there are
trained safety personnel at all Bureau of Prisons and DOJ
laboratories who can serve as the facilities coordinator with State
and local planning committees.
Section 304: DOJ will direct that if a release of an Extremely
Hazardous Substance occurs, the operator of the facility must
immediately report the release as required by Sections 304 and 313
of Title III.
Sections 311-312: The draft Order will stipulate that the operator
of each facility is required to prepare or have available Material
Safety Data .Sheets (MSDSs) for each hazardous chemical defined
under OSHA and as required under Title III. Reporting of chemical
inventory forms also will be accomplished as described by .the
appropriate regulation. At this time, however, there are no DOJ
facilities which meet the thresholds for reporting as required by
Sections 311 and 312.
-------
Section 313: DOJ facilities will report as required by this
section if a release of an Extremely Hazardous Substance occurs.
Program Directives/Guidance:
None.
Number of Facilities Affected:
Currently, there are no DOJ facilities that have been identified
with extremely hazardous substances above the TPQs.
-------
Department/Service: Department of Labor
Contact/Title: Charles I. Hochman
Safety and Health Manager
Address: Office of the Assistant Secretary
for Administration and Management
Washington, DC 20210
Phone Number: (202) 523-6687
Program Description:
The Department of Labor (DOL) has developed two paragraphs .(887
and 888) relating to SARA Title III compliance which are proposed
for inclusion in the DOL policy document DLMS 4, Chapter 800.
Program Scope:
Sections 301-303: Paragraph 887 of the DOL policy document
requires that DOL facilities support emergency planning efforts at
the State and local level.
Section 304: No information provided.
Sections 311-312: Paragraph 888 of the DOL policy document
requires that DOL facilities submit Material Safety Data Sheets
and chemical inventory forms to State and local planning
commissions and the local fire department.
Section 313: Response from DOL reveals that there are no
facilities which use chemicals that exceed threshold quantities of
10,000 pounds in a calendar year.
Program Directives/Guidance:
Proposed paragraphs 887 and 888 for the DOL policy document DLMS
4, Chapter 800.
Lesson 8, DOL Hazard Communication Training Program.
Number of Facilities Affected:
No information provided.
-------
Department/Service: National Aeronautics and Space
Administration
Contact/Title: Michael Green
Facilities Engineer
Address: Facilities Operation and Maintenance
Division
NASA Headquarters
Attention: NXG
Washington, DC 20546
Phone Number: (202) 453-1962
•t..
Program Description:
The National Aeronautics and Space Administration (NASA) issued
memoranda in January and April 1987 recommending that NASA centers
conduct an inventory of their facilities and notify the State of
listed materials exceeding Threshold Planning Quantities (TPQs).
NASA advised the centers that Title III does not apply to Federal
facilities, but they should make a decision regarding voluntary
compliance locally. Contractor-operated facilities have been
advised .that they are subject to the legal requirements of the law.
Surveys of the facilities have indicated good voluntary
participation, and thus NASA has no plan to issue further guidance
or policies.
Program Scope:
Sections 301-303: NASA centers have, when appropriate, notified
State and local authorities of the presence of Extremely Hazardous
Substances and provided contacts to the LEPCs. Thirteen centers
meet these thresholds, five centers do not meet the thresholds, and
one center is currently performing an inventory and will report if
necessary.
Section 304: All centers indicate that they would notify
authorities of releases of reportable quantities of hazardous
substances.
Sections 311-312: Fourteen centers have provided an inventory to
the local fire departments. Four centers are still compiling their
inventory and will submit it when complete. One center has
determined that it is exempt from the reporting requirements due
to a laboratory exclusion.
Section 313: No NASA center manufactures, imports or processes
any Section 313 chemicals. Seven centers do, however, use some
chemicals in excess of the 10,000 pound threshold. Three of these
centers are contractor operated and fall within the covered SIC
Codes and have submitted forms under this section.
-------
NASA issued guidance memoranda on January 14, 1987 and April 20,
1987.
Number of Facilities Affected:
Thirteen NASA centers have TPQs of Extremely Hazardous Substances
and are therefore subject to requirements under Sections 301-303.
One center has not yet determined its inventory of these
substances, and five centers do not meet the thresholds.
Fourteen centers meet the thresholds under Sections 311-312 and
are therefore subject to MSDS and inventory reporting. Four
centers have not yet determined their inventory, and one center
has determined it is exempt.
5
-------
FACILITY COORDINATORS
National Aeronautics and Space Administration
Ames Research Center, CA Ms.
Dryden Flight Research Facility, CA
Edwards Test Station, CA Ms.
.Ellington Field, TX Mr.
Goddard Space Flight Center, MD
Goldstone Communications Complex, CA
Jet Propulsion Laboratory, CA Ms.
Johnson Space Center, TX Mr.
Kennedy Space Center, FL Mr.
-Langley Research Center, VA Mr
Lewis Research Center, OH
Marshall Space Flight Center, AL Mr.
Plum Brook Station, OH Ms
Rockwell. - Downey, CA
Stennis Space Center, MS Ms
Santa Susana Field Laboratory, CA Ms
Wallops Flight Facility, VA Ms
White Sands Test Facility, NM Mr
Sandy Olliges
Mr. Tom Ambrose
Vanessa Damron
Ken Gilbreath
Mr. Joe Letourneau
Mr. Harold Anderson
Elizabeth Stetz
Ken Gilbreath
Kirby Key
John Lee
Mr. Michael Mapp
Marshall Corlew
Amy Bower
Mr. Jerry Tucker
Becky McCaleb
Michelle Levesque
Terry Rodriguez
I.D. Smith
-------
Department/Service: National Science Foundation
Contact/Title: Julian Shedlovsky, Chair
Committee on Environmental Matters
Address: Office of the Assistant Director for
Geosciences
1800 G Street, NW
Washington, DC 20550
Phone Number: (202) 357-9752
Program Description:
The National Science Foundation (NSF) has directed facility staff
to determine whether Threshold Planning Quantities (TPQs) of
Extremely Hazardous Substances are present at their government-
owned contractor-operated (GOCO) facilities. Because there are no
Extremely Hazardous Substances present at these facilities, NSF has
not directed its facilities to report releases .of reportable
quantities of these substances. NSF does, however, encourage its
facilities to comply with Title III and will provide written
guidance to the facilities.
Program Scope: • •
Sections 301-303: NSF reports that one of its GOCO facilities has
selected a facility coordinator to interact with LEPCs, and has
initiated discussions with the fire marshall.
Section 304: As stated above, facilities have not been directed
to provide notification because Extremely Hazardous Substances are
not present at these facilities.
Sections 311-312: No facilities have provided LEPCs or local fire
departments with Material Safety Data Sheets for hazardous
chemicals defined under OSHA and as required under Title III.
Section 313: NSF facilities are not subject to this reporting
requirement because their facilities do not manufacture, import,
process or use any hazardous chemicals above designated thresholds.
Program Directives/Guidance:
NSF will provide written guidance to the facilities directing them
to comply with Title III requirements.
Number of Facilities Affected:
NSF currently operates 11 GOCO facilities, and none have been
identified with Extremely Hazardous Substances above the TPQ.
-------
FACILITY COORDINATOR
National Science Foundation
1 of 4 GOCO facilities has named a facility coordinator
National Center for Atmospheric Research (NCAR) Facilities
located in Boulder and Broomfield, Colorado, and at
Maunaloa, Hawaii
Steve Sadler, NCAR Safety & Environmental Services Manager
-------
Department/Service: United States Postal Service
Contact/Title: Frank Lundblad
Headquarters Industrial Hygienist
Address: Office of Safety and Health
475 L'Enfant Plaza, SW
Washington, DC 20260-4231
Pbone Number: (202) 268-3692
Program Description:
The Postal Service issued a memorandum on March 15, 1989 to field
and headquarters facility managers relating to Title III
compliance. Managers are expected to assess the use of hazardous
chemicals in their facilities and comply with all regulations if
necessary.
Program Scope:
Section 301-303: The memorandum directed managers 'to inventory
all hazardous substances. This process will be facilitated by the
Postal Service's compliance with the Occupational Safety and Health
Administration's Hazard Communication Standard, which requires an
inventory of hazardous materials. The Postal Service does tnot
anticipate any facilities having-Extremely Hazardous Substances on
hand. Although maintenance centers do conduct some limited metal
stripping and painting operations and use solvent dip tanks, the
type and quantity of materials should not come under the Act.
Many facilities are already in contact with local fire departments
and other agencies as part of the Postal Service's internal program
to deal with spills and leaks of limited quantities of hazardous
materials encountered in the mails. Facility managers will be
directed to follow Title III requirements, if necessary, regarding
emergency planning.
Section 304: The memorandum requires facilities to notify
appropriate agencies of releases of hazardous chemical releases.
Sections 311-312: The memorandum outlines Material Safety Data
Sheets, Tier I and Tier II requirements and provides schedules for
phased-in thresholds and reporting dates.
Section 313: The memorandum requires compliance with toxic
chemical release reporting. The Postal Service considers it
unlikely, however, that any of their facilities will be required
to comply.
-------
Program Directives/Guidances:
The Assistant Postmaster General issued a memorandum on March 15,
1989, to all field units.
Number of Facilities Affected:
The Postal Service did not provide information on the number of
facilities affected by Title III.
s
-------
Department/Service: Smithsonian Institution
Contact/Title: F. William Billingsley, Director
Office of Environmental Management
and Safety
Address: 955 L'Enfant Plaza, Suite 3300
Washington, DC 20560
Phone Number: (202) 287-3611
Program Description:
The Smithsonian is developing a policy document about Title III and
its application to Smithsonian facilities and museums. The
Smithsonian conducted a review of its facilities in March 1988 and
determined that no facilities are affected by SARA Title III.
Program Scope:
Sections 301-303: The Smithsonian has been in contact with the
SERC of the District of Columbia. Additionally, the Smithsonian's
Office of Risk Management is developing a disaster preparedness
plan which will include hazardous material emergencies.
Section -304: Once the Smithsonian's Title III policyt is
implemented, each facility will be required to report any releases
of reportable hazardous substances to the local and state
committees.
Sections 311-312: The Smithsonian will provide the LEPCs and local
fire departments with copies of Material Safety Data Sheets and/or
an inventory list of hazardous chemicals at each facility.
Section 313: There are no Smithsonian facilities that meet any of
the applicable thresholds for toxic chemical release reporting.
Program Directives/Guidance:
None
Number of Facilities Affected:
A survey of Smithsonian facilities determined that no facilities
are presently affected by SARA Title III.
-------
Department/Service: Tennessee Valley Authority
Contact/Title: M. Paul Schmierbach, Manager
Environmental Quality Staff
Address: 201 Summer Place Building
Knoxville, Tennessee 37902
Phone Number: (615) 632-6578
Program Description:
The Tennessee Valley Authority (TVA) has issued an internal
memorandum directing all TVA offices to comply with the substantive
requirements of Title III. This directive includes planning,
notification and reporting requirements.
Program Scope:
Sections 301-303: TVA has determined that the Threshold Planning
Quantity of Extremely Hazardous Substances was exceeded for at
least one chemical in 99 facilities, and those facilities have
notified the appropriate SEP.Cs and LEPCs.
•
Section 304: Emergency release notification will also be provided
to the appropriate SERCs and LEPCs when spills of reportable
materials have occurred.
Sections 311-312: Numerous facilities, where there are chemicals
for which MSDSs are required, have provided MSDSs to the LEPCs,
SERCs and fire departments.
Section 313: Currently only one TVA facility needs to complete
the Toxic Chemical Release Form, and it has already submitted its
annual report.
Program Directives/Guidance:
The Director of the Environmental Quality Staff issued an internal
memorandum dated May 1, 1987 stating that it is TVA's policy to
comply with the Title III requirements.
Number of Facilities Affected:
TVA has identified approximately 100 facilities as affected by
Title III requirements, all of which have made efforts to comply
with the reporting requirements.
5'
-------
FACILITY COORDINATORS
Tennessee Valley Authority
Facility
Albertville 161-kV Substation
Alcoa'l61-kV Substation
Allen Fossil Plant
Ardmore 161-kV Substation
Athens 161-kV Substation
Athens 161-kV Substation
Basin 161-kV Substation
Belfast 161-kV Substation
Bellefonte Nuclear Plant
Boone Hydro Plant
IEPC
Browns Ferry Nuclear Plant
Bull Run Fossil Plant
Notified
Notified
Shelby County LEPC
Notified
Notified
Notified
Notified
Notified
Notified July 15, 1988.
Sullivan County LEPC
Bowling Green 161-kV Substation Notified
Notified April 20, 1988
Anderson County
Facility Coordinator
Vernon McDonald or
J. B. Hendrix
(205) 386-2841
Freddy R. Home
(615) 632-6750 •
Frank Dominions
(901) 789-0860
(125) 721-1206 (PAX)
Vernon McDonald or
J. B..Hendrix
(205) 386-2841
Vernon McDonald or
J. B. Hendrix
(205) 386-2841 .
Freddy R. Home
(615) 632-6750
Freddy R. Home
(615) 632-6750
G. Glenn Burgess
(615) 360-1562
Roy Russell
.(205) 574-8210
George Sykes
(615) 542-2922
(125) 529-1112 (PAX)
6. Glenn Burgess
(615) 360-1562
Hike Bolch
(205) 729-2038
James Rouse
(615) 945-3430
(125) 524-1245
Chem.
or
MSOS
Report
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
-------
Calvert 161-kV Substation
Center/Hie 161-kV Substation
Charleston 161-kV Substation
Chesterfield 161-kV Substation
Chickamauga Hydro Plant
Clarksville 161^kv Substation
Colbert Fossil Plant
Columbia 161-kV Substation
Columbia 46-kV Substation
Concord 161-kV Substation
Cordova 500-kV Substation
Covington 161-kV Substation
Cullman 161-kV Substation
Cumberland Fossil Plant
Davidson -500-kV Substation
Douglas Hydro Plant
Oyersburg 69-kV Substation
Notified
Notified
Notified
Notified
Chattanooga-HamiIton
County LEPC
Notified
Colbert County EMA
Notified
Notified
Notified
Notified
Notified
Notified
Stewart County
Notified
Sevier County LEPC
Notified
Glenn E. Parrish Ye'
(901) 668-6136
6. Glenn Burgess Ye'
(615) 360-1562
Freddy R. Home Ye-
(615) 632-6750
Glenn E. Parrish Ye
(901) 668-6136
H. H. Hodges Ye
(615) 697-4170
(125) 240-1112
G. Glenn Burgess Ye-
(615) 360-1562
Jeff Littrell Ye
(205) 383-8605
(125) 324-1381 (PAX)
G. Glenn Burgess Ye
(615) 360-1562
G. Glenn Burgess Ye
(615) 360-1562
• •
Freddy R. Home Ye
(615) 632-6750
Glenn E. Parrish Ye
(901) 668-6136
Glenn E. Parrish Ye
(901) 668-6136
Vernon McDonald or Ye
J. 8. Hendrix
(205) 386-2841
J. W. Steele Ye
(615) 827-2472
(125) 425-1272 (PAX)
6. Glenn Burgess Ye
(615) 360-1562
Joe H. Epps Ye
(615) 475--3415
(125) 521-1112 (PAX)
Glenn E. Parrish Ye
(901) 668-6136
-------
E. Bowling Green 161-kV Substation Notified
East Cleveland 161-kV Substation Notified
Fontana Hydro Plant
Fort Payne 161-kV Substation
Franklin 500-kV Substation
Freeport 500-kV Substation
Gallatin Fossil Plant
Goose Pond 161-kV Substation
Haney Building
Hiwassee Hydro Plant
Hopkinsvllle 161-kV Substation
Hopkinsville 69-kV Substation
John Sevier Fossil Flint
John Sevier Fossil Plant
Johnsonville Fossil Plant
Graham County
Notified
Notified
Notified
Sumner County
Notified
Chattanooga-Hamilton County
Hickory Valley 161-kV Substation Notified
Cherokee County EMS
Notified
Notified
Hawkins County
Hawkins County
Humphreys County
G. Glenn Burgess * Yes
(615) 360-1562
Freddy R. Home Ye«
(615) 632-6750
L. J. Miller Yes
(615) 986-8139
(125) 234-1112
Vernon McDonald or Ye'<
J. 8. Hendrix
(205) 386-2841
Freddy R. Home Ye<
(615) 632-6750
Glenn E. Parrish Yes
(901) 668-6136
M. w. Stanfield Yes
(615) 452-2202
(125) 429-1212 (PAX)
•
Vernon McDonald or Yes
J. B. Hendrix
(205) 386-2841
Henry F. lackenby Yes
(615) 651-7326
Glenn E. Parrish Yes
(901) 668-6136
D. M. Keith Yes
(704) 644-5121
(125) 534-1112
G. Glenn Burgess Yes
(615) 360-1562
G. Glenn Burgess Yes
(615) 360-1562
Ed Pace Yes
(615) 272-8152
(125) 523^1391 (PAX)
Art Williams
(615) 272-8152
(125) 523-1245 (PAX)
Chester Vole Yes
(615) 535-2501
(125) 430-1221 (PAX)
-------
Kingston Fossil Plant
Lafayette 161-kV Substation
Land Between the Lakes
Lawrenceburg 46-kV Substation
Lebanon 161-kV Substation
Lonsdale 161-kV Substation
Madison 500-kV Substation
Marshall 500-kV Substation
Martin 161-kV Substation
Maury 500-kV Substation
Mayfleld 161-kV Substation
Mayfield 69-kV Substation
Melton H111 Hydro Plant
Milan 46-kV Substation
Mocassin 161-kV Substation
Monsanto 161-kV Substation
Montgomery SOO-kV Substation
Morris town 161-kV Substation
Roane County
Notified
Trigg County
Notified
Notified
Notified
Notified
Notified
Notified
Notified
Notified
Notified
Loudon County
Rick Keyser . ye
(615) 376-6135
(125) 224-1272
6. Glenn Burgess Ye-
(615) 360-1562
E. Keith Pardue Ye-
(502) 924-5602
6. Glenn Burgess Ye'
(615) 360-1562
G. Glenn Burgess Ye
(615) 360-1562
Freddy R. Home Ye'
(615) 632-6750
Vernon McDonald or Ye
J. B. Hendrix
(205) 386-2841
Glenn E. Parrish Ye
(901) 668-6136
Glenn E. Parrish Ye'
(901) 668-6136
i
G. Glenn Burgess Ye'
(615) 360-1562
Glenn E. Parrish Ye:
(901) 668-6136
Glenn E. Parrish Ye:
(901) 668-6136
Lewis J. Miller Ye:
(615) 986-8139
(125) 521-1112 (PAX)
Notified
Notified
Notified
Notified
Notified
Glenn E. Parrish
(901) 668-6136
Freddy R. Home
(61S) 632-6750
G. Glenn Burgess
(615) 360-1562
G. Glenn Burgess
(615) 360-1562
Freddy R. Home
Ye:
Ye-
Ye:
Ye:
Ye:
(615) 632-6750
-------
Mt. Pleasant 161-kV Substation Notified
Hurfreesboro 161-kV Notified
N. E. Johnson City 161-kV Notified
Substation
N. Nashville 161-kV Substation Notified
National Carbide 161-kV Substation Notified
National Fertilizer
Development Center
Norris Hydro Plant
Oglethorpe 161-kV Substation
Paradise Fossil Plant
Pnipps Bend 500-kV Substation
Pickwick Hydro Plant
Power System Control
Raccoon Mountain
Pumped Storage
Radnor 161-kV Substation
Roane 500-kV Substation
S. Jackson 161-kV Substation
Sequoyah Nuclear Plant
Colbert County
Anderson County
Notified
Huhlenbert County
Notified
Hardin County
Notified
Marion County LEPC
Notified
Notified
Notified
Notified August IS, 1988
G. Glenn Burgess Yes
(615) 360-1562
G. Glenn Burgess Yes
(615) 360-1562
Freddy R. Home Yes
(615) 632-6750
G. Glenn Burgess Yes
(615) 360-1562
Glenn E. Parrish Yes
(901) 668-6136
Jack Henson Yes
(205) 386-2183
Joe H. Epps Yes
(615) 475-3415
(125) 521-1112 (PAX)
F. R. Home Yes
(615) 632-6750
Dennis Allen
(502) 476-2250
(125) 428-1466 (PAX)
Freddy R. Home ' Yes
(615) 632-6750
Frank Cagle Yes
(901) 925-4342
(125) 328-1212 (PAX)
Freddy R. Home Yes
(615) 632-6750
Gilbert F. Lindsey Yes
(615) 751-8096
(125) 237-1112 (PAX)
G. Glenn Burgess Yes
(615) 360-1562
Freddy R. Home Yes
(615) 632-6750
Glenn E. Parrish Yes
(901) 668-6136
T. H. Youngblood, Jr. Ye;
(615) 874-5095
-------
Shawnee Fossil Plant
Shelby 500-kV Substation
Shelby vine 46-kV Substation
W. Nashville 161-kV Substation
Wartrace 161-kV Substation
Watts Bar Hydro Plant
Watts Bar Nuclear Plant
Weakley 500-kV Substation
Wheeler Hydro Plant
widows Creek Fossil Plant
Wilson 500-kV Substation
McCraken County
Notified
Notified
South Nashville 161-kV Substation Notified
Sullivan 500-kV Substation Notified
Summer Shade 161-kV Substation Notified
Trinity 500-kV Substation Notified
Volunteer 500-kV Substation Notified
W. Cookeville 161-kV Substation Notified
Notified
Notified
Rhea County LEPC
Notified March 25, 1988
Notified
Lawrence County EMA
Jackson County
Notified
Oavid F1sh Yes
(502) 433-3626
(125) 435-1272
Glenn E. Parrish Yes
(901) 668-6136
6. Glenn Burgess Yes
(615) 360-1562
G. Glenn Burgess Yes
(615) 360-1562
Freddy R. Home Yes
(615) 632-6750
Glen Burgess . Yes
(615) 360-1562
Vernon McDonald or Yes
J. B. Hendrix
(205) 386-2841
Freddy R. Home Yes
(615) 632-6750
6. Glenn Burgess Yes
(615) 360-1562
• •
6. Glenn Burgess Yes
(615) 360-1562
G. Glenn Burgess Yes
(615) 360-1562
Ralph Finch Yes
(615) 365-6300
(125) 235-1221 (PAX)
0. E. Crawley Yes
(615) 365-8821
Glenn E. Parrish Yes
(901) 668-6136
L. I. Harmon Yes
(205) 247-0153
(125) 326-1112
Ed Jones Yes
(205) 437-2937
(125) 225-1235 (PAX)
6. Glenn Burgess Yes
(615) 360-1562
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Wilson Hydro Plant
Winchester 161-kV Substation
Colbert County EMA
Notified
Fred W. German
(205) 386-2422
(125) 344-1212
Freddy R. Home
(615) 632-6750
Yes
Yes
C
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Department/Service: Department of Transportation
Contact/Title: Charles James, Mechanical Engineer
Address: Real Property Division
400 Seventh Street, SW
Washington, DC 20590
Phone Number: (202) 366-0038
Program Description:
The Department of Transportation (DOT) has issued two policy
directives that address compliance with the requirements of Title
III. These policy directives clearly state that the department's
facilities will comply? with emergency planning and notification
requirements for Extremely Hazardous Substances pursuant to
Subtitle A, section 302(a). Emergency release notification will
be made to the SERC and LEPC for Extremely Hazardous Substances
and all CERCLA hazardous substances. For all facilities where
there are chemicals for which MSDSs are required under OSHA, the
facility manager will establish a point of contact with the SERC,
LEPC and local fire department. In addition, DOT facilities will
coordinate MSDSs with LEPCs and provide copies of such information
upon request.
Program Scope:
Sections 301 - 303: As stated above, DOT facilities will report
the presence of Extremely Hazardous Substances in accordance with
Title III requirements.
Section 304: All facilities have been directed to provide
notification.
Sections 311-312: Chemicals required to have MSDSs under OSHA will
be provided to the appropriate LEPC, SERC and fire department upon
request.
Section 313: Facilities do not meet the criteria outlined in 40
CFR 372.22.
Program Directives/Guidances
DOT issued two policy directives on February 5, 1987 and December
29, 1988.
Number of Facilities Affected:
Four DOT facilities with Extremely Hazardous Substances above the
Threshold Planning Quantities have been identified. A facilities
coordinator has been designated and the LEPCs notified.
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FACILITY COORDINATORS
Department of Transportation
Mr. Murrey Chappell
U.S. Coast Guard Support Center
Elizabeth City, NC
CDR Hopkins
U.S. Coast Guard Yard
Curtis Bay, MD
Mr. Jim Long
Mike Monroney Aeronautical Center
Oklahoma City, OK
Mr. Mike Beres
Federal Aviation Administration
Technical Center
.Atlantic City, NJ
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Department/Service: Department of the Treasury
Contact/Title: Tony DiSilvestre
Environmental Programs Officer
Address: 1500 Pennsylvania Avenue, NW
Washington, DC 20220
Phone Number: (202) 634-2292
Program Description:
The Department of the Treasury intends to issue a Treasury
Directive which will establish policy and procedures implementing
Title III.
Program Scope:
Sections 301-303: The Bureau of Engraving has designated a Title
III contact and provided information to District of .Columbia
officials.
Section 304: Information not provided.
Sections 311-312: Information not provided.
Section 313: Information not provided.
Program Directives/Guidance:
A Treasury Directive on Title III is planned.
Number of Facilities Affected:
Treasury consists of twelve bureaus, however, there is no
information at present on how many bureaus and corresponding
facilities are affected.
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Department: Department of Veterans Affairs
Contact/Title: Jack Staudt, Chief
Hazardous Materials
Management Division
Address: Office of Facilities
Washington, DC 20420
Phone Number: (202) 233-3729
Program Description:
The Department of Veterans Affairs (VA) is currently preparing
directives for their facilities to use in establishing SARA Title
III programs. These directives have been circulated in draft form
within the VA for comments. The VA is currently incorporating
these comments into final directives.
Program Scope:
Sections 301-303: Through the directives, the VA will instruct its
facilities to contact the state and local planning authorities
concerning Title III responsibilities. The VA has not directed
their facilities to evaluate whether Threshold Planning Quantities
of hazardous chemicals are.present. '
Section'304: The VA will direct its facilities to report any
chemical releases to the SERC or LEPC.
Sections 311-312: Facility directors have been instructed to
maintain a list of hazardous chemicals and Material Safety Data
Sheets, but have not been directed to forward a copy of the list
to LEPCs.
Section 313: The VA does not monitor whether it has facilities
that manufacture, import, process or use chemicals in quantities
exceeding established thresholds. ••
Program Directives/Guidance:
None
Number of Facilities Affected:
The VA provided no information on number of facilities affected by
Title III.
7o
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