&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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                                    -2-
      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

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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.

-------
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

-------
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.

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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.

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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.

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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.

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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).

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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.

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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.

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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.

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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

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                      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

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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.

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                      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

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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.

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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

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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.

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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'

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                                 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

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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

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 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)

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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

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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

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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

-------