Puna Emergency Response
v *
Report on the Review of Hawai'i County Emergency Operations Plan and
Puna Geothermal Venture Emergency Response Plan
Visits to Hawai'i August 5-9,1996 included:
COUNTY OF HAWAI'I CIVIL DEFENSE, FIRE DEPARTMENT AND OTHER
LOCAL AGENCIES
PUNA GEOTHERMAL VENTURE, 14-3860 Kapoho-Pahoa Road, Pahoa, HI
STATE OF HAWAI'I DEPARTMENTS OF HEALTH AND CIVIL DEFENSE
Final Report
August 2000
United States Environmental Protection Agency, Region 9
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REPORT DISCLAIMER
The contents of this report reflect information concerning the County of Hawaii and
Puna Geothermal Venture obtained during a U.S. Environmental Protection Agency
(U.S. EPA) review. The emergency response plans review visits were conducted
from August 5-9, 1996 and observations as presented in this report provide a
snapshot of conditions existing at the facility at that time. They do not represent
proposed or ongoing changes at the facility or Hawaii County. The
recommendations and observations contained in this report are not mandatory
actions that the facility or Hawaii County must implement. In addition, the U.S. EPA
makes no assurances that if implemented, the recommendations and observations
contained in this report will prevent all future chemical accidents, equipment
failures, or unsafe management practices, and/or provide protection from any future
enforcement actions under any applicable law or regulation. EPA takes notice that
some of the recommendations in the draft report have been adopted already.
11
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TABLE OF CONTENTS
GLOSSARY vi
EXECUTIVE SUMMARY vii
1 INTRODUCTION 1
1.1 Purpose 1
1.2 Scope 1
1.3 Community Concerns 2
1.4 Legal Authorities 2
1.5 Background 3
2 THE REVIEW TEAM 17
3 PLANNING AND OPERATING SAFELY 18
3.1 Guidelines for Facility Emergency
Response Planning 18
3.2 Guidelines for County Emergency
Response Planning 20
3.3 Operating Safely 23
4 HOW THE REVIEW TEAM EVALUATED
THE EMERGENCY RESPONSE PLANS 25
4.1 General 25
4.2 Hawai'i County Emergency Operations Plan 25
4.3 Criteria for Review of the Hawai'i County
Emergency Operations Plan 25
4.4 Puna Geothermal Venture Emergency
Response Plan 25
4.5 Criteria for Review of the PGV
Emergency Response Plan 25
5 COUNTY OF HAWAI'I EMERGENCY
OPERATIONS PLAN 27
5.1 General 27
5.2 Basic Plan 28
5.3 Annexes 29
5.4 Geothermal Incident Standard Operating Procedure 31
5.5 Findings and Recommendations 31
iii
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6 PUNA GEOTHERMAL VENTURE
EMERGENCY RESPONSE PLAN 40
6.1 General 40
6.2 Employee Emergency Plans and Fire
Prevention Plans - 29 CFR 1910.38
Findings and Recommendations 41
6.3 Hazardous Waste Operations and
Emergency Response - 29 CFR 1910.120
Findings and Recommendations 42
7 OVERARCHING ISSUES 48
7.1 General 48
7.2 Findings and Recommendations 48
TABLES
Table 1: Summary of Hydrogen Sulfide Releases 5
Table 2: Summary of Public Comments 8
Table 3: Components of PGV's Emergency Response Plan 18
Table 4: NRT Guidance 21
Table 5: Summary of Prevention Requirements 24
APPENDICES
Appendix A: Visits to State and County Departments and Agencies - Field Notes
Appendix B: Visit to the Puna Geothermal Venture Facility -- Field Notes
Appendix C: Emergency Response Plan, Version 6.3, Table of Contents
Appendix D: HAZWOPER/Emergency Response Guidelines and Training Program
Appendix E: PGV Emergency Action Plan and Notification Guidelines
Appendix F: Hawai'i County Emergency Operations Plan, Table of Contents
Appendix G: Hawaii County Fire Department, Emergency Response Procedure
to PGV
Appendix H: Request for Documents to Review
w
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APPENDICES [Continued]
Appendix I: Health Consultation
Appendix J: Integrated Contingency Planning "Oneplan" Guidance and EPA Chemical
Accident Prevention Regulations 40 CFR Part 68
Appendix K: Compilation of Recommendations
Appendix L: Letter to U.S. Senator Daniel Inouye from Felicia Marcus, EPA Regional
Administrator
Appendix M: Correspondence on January 2000 Release
Appendix N: Comment Letters to Draft Report
Appendix O: EPA's Response to Comments
Appendix P: Referral Letters
Appendix Q: Hydrogen Sulfide Literature Review
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Glossary of Acronyms
CAMEO Computer Aided Management of Emergency Operations
CAP Chemical Accident Prevention Program
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
CFR Code of Federal Regulations
CSA Chemical Safety Audit
DOI Department of the Interior, U. S.
DOL Department of Labor, U. S.
DOT Department of Transportation, U. S.
EAP Emergency Action Plan
EMT Emergency Medical Technician
EOC Emergency Operations Center
EOF Emergency Operations Plan
EPA Environmental Protection Agency, U. S
EPCRA Emergency Planning and Community Right-to-Know Act
ESRF Emergency Steam Release Facility
ERP Emergency Response Plan
FEMA Federal Emergency Management Agency
HAZMAT Hazardous Materials
HRS Hawai'i Revised Statutes
H2S Hydrogen Sulfide
ICS Incident Command System
IDLH Immediately Dangerous to Life and Health
NICS National Institute for Chemical Studies
NRT National Response Team
NRT-1 National Response Team-1 emergency planning guidance
NRT-1A National Response Team-1A emergency planning guidance
OSC On-Scene Coordinator
PGV Puna Geothermal Venture
PHA Process hazards analysis
PM10 Paniculate Matter 10 microns or less in diameter
PPE Personal Protective Equipment
ppm parts per million
PSM Process Safety Management
RBDS Radio Broadcast Data System
RMP Risk Management Plan
RMPP Risk Management and Prevention Program
SARA Superfund Amendments and Reauthorization Act
SOP Standard Operating Procedure
UFC Uniform Fire Code
USC United States Code
VI
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August, 2000 Final Report
Executive Summary
This report summarizes a review of emergency response capabilities for Hawai'i
County and Puna Geothermal Venture (PGV). The U. S. Environmental
Protection Agency (EPA) assembled an independent team of experienced
individuals (the "Review Team"). EPA tasked them to review emergency
response plans and conduct site visits and interviews. This project was a follow-
up to the EPA's 1995 compliance inspection of the PGV facility and a response to
community requests. The purpose of the project was to provide an independent
evaluation of the emergency response plans, with the long-term objective of
preventing chemical accidents and improving emergency response capabilities.
The review team conducted site visits in Hawai'i from August 5 through August
9,1996. During that time, team members received information from state and
local agencies, PGV, and the community (composed primarily of area residents).
EPA held public meetings at the Pahoa Community Center and the University of
Hawai'i, Hilo Campus Center to discuss the review. These meetings offered the
review team an opportunity to meet with residents of the Puna area.
Many who attended the public meetings expressed strong concerns about their
health and safety being jeopardized by the operation of the PGV facility. A major
release of hydrogen sulfide from the facility is the principal hazard to the
community. The public also expressed concern about the need for public alert and
notification systems and plans for shelter-in-place and evacuation. Some meeting
attendees raised concerns that PGV management was concealing details about
operations and potential emergencies from the neighboring community. Other
meeting attendees expressed confidence in the capabilities of the PGV
management to operate the facility safely and efficiently.
The Hawai'i County Emergency Operations Plan is a multiple hazards plan that
primarily addresses natural disasters, terrorism, and war. Annex M of this plan,
the Oil and Hazardous Substances Response Plan, was the section reviewed in
detail by the review team. The review team found Annex M in urgent need of an
update to bring it into compliance with Emergency Planning and Community
Right-to-Know laws and address public concerns. Annex M is not complete, and
the County and State have not updated the plan since they signed it in 1990.
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August. 2000 Final Report
The Oil and Hazardous Substances Response Plan (Annex M) acknowledges
accidental releases of hazardous substances as human-made hazards. However, it
does not address the public and environmental threats from a serious release of
hazardous substances from an operating facility (e.g., PGV). The plan also lists
several appendices as "under preparation." However, at the time of the review,
these appendices were still missing.
In particular, the Review Team was concerned about the capability of local
responders to carry out a timely response in the PGV facility. Hawai'i County
responders need to evaluate their capacity for emergency response and their
ability to participate as part of an Incident Command System. The Hawai'i
County Fire Department, Pahoa Substation should work with PGV to gauge the
potential severity of an incident.
During the site visit to PGV, facility personnel explained both the technology and
procedures within their respective areas of responsibility. Overall, the facility's
internal planning, preparedness and response activities are covered in PGV's
Emergency Response Plan. PGV seems able to respond to most incidents, except
fire. However, at the time of the review the PGV Emergency Response Plan did
not fully address coordination issues between the facility and the local response
agencies. The Review Team has concerns over public alert and notification
procedures and the ability of the facility and County to carry out a coordinated,
timely response. PGV's historical, and continuing, reluctance to communicate
and cooperate with its neighbors interferes with effective emergency management.
The Review Team recommends that the County form a technical work group to
evaluate evacuation needs, resources, and procedures. The technical work group
should include representatives from the County Civil Defense Agency and Fire
Department, HDOH, the University of Hawai'i, and EPA. Work group members
should confer with PGV technical staff on the details of facility operations.
Technical issues under evaluation are extremely important and will require a great
deal of thought, research, and professional judgement.
Both PGV and the County need to coordinate their planning activities and conduct
joint training exercises before they can understand the capabilities of local fire,
police and medical units. The results of the initial training exercise will likely
reveal deficiencies in the emergency response plans. Joint exercises held at least
annually would identify how to update and improve the emergency response
plans. Periodic exercises also would be refresher training for PGV personnel and
local hazardous materials (hazmat) responders. As required by the Emergency
Planning and Community-Right-to-Know Act, the County and PGV need to
designate community and facility emergency coordinators. These emergency
coordinators should take the lead on planning and carrying out the exercises.
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August. 2000 Final Report
The review team concluded its work with specific findings and recommendations
for improving emergency response capabilities and safety management systems.
These recommendations address Hawai'i County and PGV emergency response
plans and procedures. EPA issued the draft report for a 100-day public review
and comment period, after which EPA reviewed and responded to all
commenters' letters.
Comment letters and EPA's response to comment document are included as an
attachment in the final report. In closing, the review team must emphasize that an
emergency response plan alone does not directly protect the public and the
environment. The plan is only a detailed blueprint of an emergency response
program designed for a facility or community, with the purpose of protecting the
environment and the public. Emergency response programs are the
comprehensive approach to protecting the public.
In addition to complete, updated and coordinated emergency response plans,
jurisdictions and industries must have the required resources, equipment and
trained personnel, to be fully prepared to implement the plans and respond to
accidents resulting from man-made hazards as well as natural disasters. Finally,
the authorities responsible for the emergency response programs must be assured
at all times that the programs are workable. They need feedback through the
results of scheduled periodic exercises.
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August, 2000 Final Report
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1 Introduction
1.1 Purpose
This report presents a review and evaluation of emergency response capabilities for
Hawai'i County and Puna Geothermal Venture (PGV). The purpose of this review was to
provide an independent evaluation of emergency response plans, with the long-term
objective of preventing chemical accidents and improving emergency response
capabilities. The U. S. Environmental Protection Agency (EPA) assembled an
independent team of experienced individuals and tasked them to conduct the review. The
Review Team functioned in an advisory role. Although all recommendations are based
on laws, regulations or good management practices, this report is not an enforcement
document.
1.2 Scope
The scope of the independent review was to:
1. Provide a desk review and evaluation of the emergency response plans for the County
of Hawai'i, Puna Geothermal Venture (PGV) and local responders and provide
constructive comments;
2. Meet with representatives of state agencies to discuss issues of concern regarding
geothermal in Hawai'i;
3. Meet with Hawai'i County Civil Defense, the Hawai'i County Fire Department and
other local agencies to evaluate the capability of Hawai'i County, PGV and local
responders to carry out the emergency response plans;
4. Review the roles and responsibilities of these agencies in protecting the public and the
environment from hazardous material releases, particularly in populated areas near PGV;
5. Visit the PGV facility and meet with the facility management to learn of its plans for
prevention of hazardous material releases; further review the facility's emergency
response plan, concept of operations, organization, incident command system, protective
actions, and supporting systems required to carry out the plan;
6. Evaluate chemical hazards associated with substances handled and stored in the PGV
facility and learn what the management of the facility recognizes as the hazards posing
acute health effects;
7. Meet with public officials in Hawai'i County and residents in the Puna area to learn
their concerns about chemical hazards, risks, and chemical accident preparedness;
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August, 2000 Final Report - 2
8. Attend public meetings conducted by EPA to hear public concerns and questions
about the emergency response plans.
1.3 Community Concerns
EPA held public meetings in Pahoa and Hilo, Hawai'i on August 7 and 8,1996. During
the meetings community residents raised concerns about hazards that could have acute or
chronic health effects. Acute health effects can result from exposure to high
concentrations of hazardous substances. Long term exposure to lower concentrations of
hazardous substances can cause chronic health effects. The focus of the Emergency
Response Review was acute health effects resulting from accidental releases, and the
Review Team did not look at chronic effects. Table 2 at the end of this section
summarizes specific comments and questions community residents asked during the
public meetings.
1.4 Legal Authorities
Multiple legal authorities govern the releases of hazardous substances. The Review
Team worked under the authorities of the following laws:
• Comprehensive Environmental Response, Compensation, and Liability Act, 42 U.S.C.
§§ 9601 - 9675 (1995). Sections 9604(b) and 9604(e) authorize EPA to enter a facility
and gather information when illness or complaints of illness may be attributable to
exposure to a hazardous substance. This is the legal authority that EPA used to enter
PGV and seek information during the Review Team's site visit;
• Emergency Planning and Community Right-to-Know Act (EPCRA),
42 U.S.C. §§ 11001 - 11050 (1995). EPCRA requires local emergency planning
committees (LEPCs) to develop emergency response plans to prepare for and respond to
potential chemical accidents. Sections 11001-11003 address emergency planning and
require community and facility emergency coordinators, who make determinations
necessary to implement the plan. Section 11001 requires LEPCs to establish rules by
which they function, that include provisions for public access to committee activities and
emergency response plans. LEPCs are also required to establish procedures for receiving
and processing requests for information from the public, and emergency plans, chemical
inventory reports and emergency notification reports are available to the public. Section
11003 also requires LEPCs to gather appropriate information to develop and update their
emergency response plans, and facilities to provide information to LEPCs. Section
11004 requires emergency release notification.
Sections 11011-1101-2 cover reporting requirements, including requesting and obtaining
EPCRA information from a facility when a request for such information is made by the
public. Section 11013 specifies toxic release inventory ("TRI") reporting, and EPA is
the agency responsible for enforcing this law. Section 11044 requires LEPCs to publish
as a legal notice in a newspaper an annual notice of public availability of EPCRA
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reporting information.
• Clean Air Act, Prevention of Accidental Releases, 42 U.S.C. § 7412(r) (1995), and 40
CFR Part 68 Chemical Accident Prevention: Regulated Substances for Accidental
Release Prevention and Risk Management Plan Requirements. Under the general duty
clause in § 7412(r)(l), each industrial owner or operator has a general duty to design and
maintain a safe facility, taking such steps as are necessary to prevent releases. They also
have a duty to minimize the consequences of accidental releases which do occur. EPA is
the agency responsible for enforcing this law.
In addition, the Review Team was aware of State laws pertaining to emergency planning.
• 1994 Supplement to the Hawai'i Revised Statutes, Volume 3, Chapter 128D
Environmental Response Laws and Chapter 128 E Hawai'i Emergency Planning and
Community Right-to-Know Act;
• Paragraph 128E-5, in Chapter 128E of the Hawai'i Emergency Planning and
Community Right-to-Know Act describes the establishment and function of LEPCs. At
least one local emergency planning committee has to be established in each county. The
committee is subject to the requirements of both Chapter 128E and section 11003 of the
Emergency Planning and Community Right-to-Know Act described above.
1.5 Background
In 1991 two incidents occurred at the PGV facility during the drilling of geothermal wells
KS-7 and KS-8. On February 21,1991 a steam kick occurred at well KS-7; this incident
is described in Table 1 at the end of this section. On June 12,1991 a blowout at well KS-
8 resulted in a 31-hour release of steam and approximately 2,247 pounds of hydrogen
sulfide (H2S), and the County evacuated nearby homes. A characteristic of a well
blowout is a sudden, very forceful, uncontrolled release to the atmosphere. This high
pressure release transported large volumes of brine, steam, and gases from the deep
geothermal reservoir through the well. When a release contains hazardous materials such
as H2S, and if at sufficiently high concentration levels, it can pose an immediate danger to
the facility employees, the public, and the environment.
In 1992 three releases occurred at PGV during well drilling, testing, and plant startup; the
following year several releases occurred as well. Although most of these releases of H2S
have been small and below the reportable concentration of 25 ppb, the concentrations
have been measurable and have occurred throughout the years since 1991. PGV has
reported many H2S releases, neighbors to the facility have measured or sensed some
releases, and local newspapers have reported others. These smaller releases are a
continuing cause of concern among some residents adjacent to the PGV facility. As
noted in the summary of public comments in Table 2, some residents have expressed a
distrust of the safety aspects of well drilling and the operation of PGV's geothermal
facility overall.
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Through all of this, the affected public did not receive first hand, detailed knowledge of
what caused the releases or what could be done to prevent them. Some community
residents expressed a lack of confidence in the facility operators to control releases of
hazardous materials and in State and County authorities to provide a proven workable
emergency response plan. Thus, the EPA assembled an independent team of experienced
individuals, the "Review Team," and tasked them to review the emergency response
plans for Hawai'i County and Puna Geothermal Venture.
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Table 1. Summary of Hydrogen Sulfide (H2S) Releases. From 1991 to 1996, several releases of hydrogen sulfide occurred at
PGV during well drilling, testing, and plant startup. Information about these releases, summarized below in Table 1, is provided as
background information and to clarify the causes, duration, emissions and sources of information of each release.
Release and Date
Cause and Duration
H2S Emissions
Source of Information
Steam kick of short
duration occurred at the
KS-7 injection well being
drilled by PGV.
February 21,1991
"Well KS-7 was drilled through an intensely
mineralized zone, had minor mud flow returns
during connections below 1500', and blew out at
1678', injuring a right hand. The driller quickly
closed the annular preventer and vented fluid out a
3-inch diverter, before closing the diverter and
securing the well. At the time of the incident, the
annular preventer, which was secured to 13-3/8
inch casing cemented at 1020', served as the sole
BOPE. The well was subsequently plugged and
suspended. According to PGVs proposal, flow
into the hole was not anticipated to occur at this
relatively shallow depth."
Not stated Independent Technical
Investigation of the Puna
Geothermal Venture
Unplanned Steam Release
June 12 and 13. 1991.
Report prepared by Richard
Thomas, Dick Whiting, James
Moore and Duey Milner for
The Honorable Lorraine R.
Inouye, Mayor, County of
Hawai'i, and The Honorable
William W. Paty, Chairperson,
Board of Land and Natural
Resources, July 1991.
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August, 2000 Final Report
Release and Date
Cause and Duration
H2S Emissions
Source of Information
Blowout of well KS-8
June 12, 1991
"The blowout caused an unabated release of steam
for a period of 31 hours before PGV succeeded in
closing in the well. The report finds that the
blowout occurred because of inadequacies in
PGV's drilling plan and procedures and not as a
result of unusual or unmanageable subsurface
geologic or hydrologic conditions."
"Not only did PGV fail to modify its drilling
program following the KS-7 blowout, but they
also failed to heed numerous "red flags" (warning
signals) in the five days preceding the KS-8
blowout, which included a continuous 1-inch flow
of drilling mud out of the wellbore, gains in mud
volume while pulling stands, and gas entries while
circulating mud bottom up, in addition to lost
circulation, dial had occurred earlier below the
shoe of the 13-3/8-inch casing."
"PGV personnel took appropriate steps to control
the well following the kick. However, there were
certain inadequacies in PGV's drilling operations
and blowout prevention equipment. The mud
cooler being used was inefficient. Monitoring
equipment was not strategically placed. A
sufficient supply of cold water was not available
to pump into the wellbore to properly kill the well
in die event of a blowout. The choke line was not
of sufficient diameter to handle the volume of
fluid that had to be vented, and there was no
silencer on the end of die choke manifold line to
reduce noise."
Approximately 2,247
pounds of H2S were
released during the
period June 12 through
June 14,1991.
Independent Technical
Investigation of the Puna
Geothermal Venture
Unplanned Steam Release
June 12 and 13, 1991.
Report prepared by Richard
Thomas, Dick Whiting, James
Moore and Duey Milner for
The Honorable Lorraine R.
Inouye, Mayor, County of
Hawai'i, and The Honorable
William W. Paty, Chairperson,
Board of Land and Natural
Resources, July 1991.
Puna Geothermal Venture
Compliance Investigation,
NEIC report dated March
1996 (for emission data).
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August, 2000 Final Report
Release and Date
Cause and Duration
jS Emissions
Source of Information
Release at well KS-9
February 8,1993
"Thirty minute clean out caused excessive
emissions from the cyclonic muffler over two to
four minute period. Inadequate mixing with
NaOH in the flow line."
"SE station 23 ppb
hourly average.
Mobile H2S
concentration 250 ppb
spike."
Puna Geothermal Venture
Compliance Investigation,
NEIC report dated March
1996.
Release at Brine Booster
pump
October 4, 1996-Note
that this release occurred
after the Review Team
visited PGV.
An abnormal condition occurred due to a
separator level control valve malfunction causing
a loss of lubncant to the Brine Booster pump
mechanical seal. This upset condition resulted in
an inadvertent discharge of injectate and steam.
Monitor Station A
recorded an emission
peak of 301.7 ppb and
an hourly average of
46.9 ppb.
PGV Incident Report #961004
submitted to Nolan S. ffirai.
State ofHawai 'i Department
of Health, Clean Air Branch,
by Darren Hunt, PGV
Environmental/Safety
Coordinator on 10/9/96.
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Table 2. Summary of Public Comments. EPA received the following comments during public
meetings held August 7,1996 at the Pahoa Community Center and August 8,1996 at the
University of Hawai'i, Hilo Campus Center. The purpose of these public meetings was to allow
members of the Review Team to hear community comments, including existing emergency
response capabilities and plans and other general comments. The comments made during the
two meetings are grouped under general categories of concerns pertinent to the elements in the
PGV Emergency Response Plan as required by the Geothermal Resource Permit Condition #26
and the Emergency Planning and Community Right-to-Know Act.
General Comments
Specific Questions and Comments
Facility Description with
Potential Hazards
1. What is coming out of the geothermal wells, and is it
toxic to humans? What is the well constituency?
2. What is in the brine (geothermal constituency)? What is
the composition of geothermal fluids?
3. How does geothermal "soup" act?
4. What is pentane? Where does it go? No one has
accounted for the amounts.
5. What are the health effects of pentane?
6. What records are required for pentane and caustic soda
and where are they maintained?
7. Is PGV required to report amounts used? Are the
reviewers looking at safe storage and use?
8. Are lead or other chemicals going into water catchment?
9. Emergency response to what?
10. We cannot limit the emergency response plan to
hydrogen sulfide.
11. Concerned about paniculate matter (PM10) and sulfa
treat.
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August, 2000 Final Report
Potential Emergencies
\. Concerned about respiratory problems.
2. Smell odd chemical smell.
3. How would one know of exposure to pentane?
4. The community is suffering from many symptoms.
5. Smell hydrogen sulfide strongly.
6. Concerned about the health effects of noise.
7. Concerned about the low level exposure to chemicals
(chronic effects).
8. Compare people (health impacts) in Upper and Lower
Puna.
9. We have sensitive populations ~ from infants to senior
citizens.
10. They did not provide reference documents to the public.
11. School children are within a four-mile radius of the
facility (PGV).
12. We should be considered a sensitive community at risk.
13. Affected on hourly basis.
14. Ten percent of school children have asthma and
respirators.
15. An emergency exists now.
16. We need complete information. A hazards analysis
should be based on complete geochemical data.
17. People have a right to know what "they" are being
poisoned with, especially regarding organic farming and
effect on crops.
18. Problems with data information especially about leaks
(from DOH, for example).
19. In the past, air data came late and was placed in Hilo.
Citizens should receive immediate response.
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JO
Natural Hazards and
Potential Emergencies
1. What is the nature of the geology?
2. Unique geographical area — lava fields. The island of
Hawai'i is on the East Rift Zone with the most active
volcano in the world —look into the geology of the island.
3. Concerned about geothermal / seismic activity.
4. Will the Review Team meet with the U. S. Geological
Survey to discuss the relationship with PGV and natural
factors (geologic issues)?
5. Please assess volcanic hazards and corroborate with
experts.
6. Talk with local geologists.
7. Study the history of PGV/problems — bulldozes over
well.
8. Concerned about the blowout of 1991.
9. Do not know how to cap wells.
10. Concerned about emergency steam release from the
facility (PGV).
11. Concerned about problems with well casings and casing
embrittlement.
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Emergency Communication
With Residents, Potential
Emergencies and Response
Measures
1. PGV has not installed any lead or radon monitors.
2. Are air monitors in proper areas? We need one in
Pahoa?
3. How are they monitoring other chemicals? (Other than
hydrogen sulfide?)
4. We need a reality check on monitors.
5. They need data to do air modeling / scenarios properly.
6. Stationary monitors all run by electricity (then no data
available).
7. Public agencies need an answering service. We have
had delays in getting information from stationary monitors
(this is especially bad on weekends and at night).
8. Timely access to monitoring data should be available to
families so they can decide what their emergency response
should be - even without a major incident.
Coordination with Outside
Parties and Emergency
Communication with
Residents
1. People most affected by PGV are requesting the
Emergency Response Plan. They should be the focus of the
plan.
2. Who is left "holding the bag" for the costs of the
Emergency Response Plan?
3. What will be necessary to bring the facility into
compliance?
4. Confidential business information re: the emergency
response plan is an issue.
5. How can they promulgate the plan without addressing
geothermal resource issues?
6. PGV should make its emergency response plan available
to the public they alert (violating the permit).
7. How does the plan deal with peoples' culture?
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Emergency
Communications with
Public Agencies and
Residents
1. Public is not aware of County Emergency Operations
Plan or PGV Emergency Response Plan / denied process.
2. PGV version 6.0 (older) is available in the library.
3. How will we know about releases of reportable
quantities of other chemicals (refer to page 34 of the NEIC
report)?
4. They do not provide information.
5. One commenter was not in the loop for documents.
Warning Systems
1. Releases into the neighborhood. Air monitors reported
spikes of 1,000 parts per billion (ppb), and they notified no
one.
2. We cannot hear the siren; we have no coverage in our
area.
3. Who will notify neighbors in Kehena Beach?
4. They cannot get people out in emergencies.
5. How will they notify schools?
6. Does County Civil Defense think they can make
notification?
7. Have toxicologists review a draft report.
8. Company decides if an emergency exists.
9. Will they notify National Response Center?
10. Who is in charge of deciding there is an emergency?
11. No warning, no alert given for 1992 incident (bulldozers
on I-beams on well) — do not know current condition of that
well. We at least need a "warning system."
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Evacuation Plans
1. What is the radius for evacuations from a hydrogen
sulfide release?
2. What roads will we use for evacuations?
3. Who will call and they will call who for evacuations?
4. Buses take two loads of children — in evacuations.
5. How can we evacuate the area in a worst-case scenario?
6. How do authorities plan to evacuate most of the
population of Puna?
7. Lightening strikes can hit transmission lines.
8. We need a contingency to handle the flow when an
emergency is occurring.
9. Do people know evacuation routes?
10. Alternate evacuation routes are nonexistent.
11. Concern over only (!) road and ability to evacuate large
number of people.
Chain of Command
1. Is this plan implementable?
2. Sign-off on PGV's Emergency Response Plan should be
by County Civil Defense — not the mayor.
Response Equipment
1. We do not have enough ambulances and fire
equipment/supplies.
2. How will the Review Team determine if workers can
properly use safety equipment?
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Fiscal Concerns
1. What are the costs of the Review Team for travel and
services? Is the EPA paying these costs with our tax dollars?
Who invited the Review Team?
2. What is the complete accounting of what a blow out cost
the county? How much has it cost Hawai'i County to deal
with geothermal?
3. PGV should be required to carry insurance to cover all
damages caused by accidents.
4. Does the EPA have the authority to look at economic
impacts as part of the ER plan?
5. How do we balance impacts on nearby community and
larger community?
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Emergency Response Plan
Review Process
1. Do review completely and analytically.
2. Need the complete story to know what impacts would
be.
3. What will happen if they do not adopt
recommendations? What will happen if PGV is not in
compliance?
4. Confer with Dr. Wilson Goddard. Nothing has been
done with Dr. Goddard's recommendations.
5. When will PGV supply additional info?
6. Dr. Rifferstein (?), Sulfide Institute, Alberta, Canada.
Talk to him.
7. Fact finding vs. inspection. These are ERP reviews.
8. Has the EPA received all data from wells?
9. Where else in the last few years has EPA Region 9
reviewed ERPs for other geothermal facilities?
10. What authority does the EPA have to conduct such a
review?
11. What sanctions are there?
12. What are the specific questions the Review Team will be
asking the workers?
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Other Concerns
1. Political issues get overlooked.
2. This is not a new or static situation.
3. Kittens are dying.
4. Why is there a plant in a neighborhood — no SARA
involvement? Why not?
5. DOH deficiencies for managing environmental
programs.
6. OSHA documentation is a concern.
7. OSHA criteria are not applicable to the surrounding
community.
8. Air modeling for various chemicals (twelve scenarios) in
light of new info.
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2 The Review Team
The Review Team comprised the following persons who brought considerable experience
in chemical accident prevention, chemical safety reviews, and emergency and risk
management planning. Team members also had experience working in the private sector
and local, state, and federal governmental departments and agencies.
Paul Hill, Ph.D., in 1996 was the Executive Director of the National Institute for
Chemical Studies, in Charleston, West Virginia. Since the site visit, the Congress has
funded Dr. Hill to serve on the Chemical Safety and Hazard Investigation Board in
Washington, D.C.
Randy Sawyer, Manager of the Risk Management and Prevention Program, in Contra
Costa County, California, has worked in the private and public sectors in emergency
management, accident prevention and community notification systems.
Mark Zusy, Supervisor of the Chemical Accident Prevention Program for the State of
Nevada, is a chemical engineer and a licensed mechanical engineer. His experience
ranges from process and mechanical design to operating procedure development, operator
training and startup coordination.
The following people worked with the review team to complete this project:
Mike Ardito, EPA Region 9, Superfund State Project Officer Chemical Emergency
Prevention and Preparedness (CEPP) Coordinator for Hawai'i, has worked in emergency
management programs for FEMA and EPA since 1987.
Ake Jacobson (Senior Environmental Enrollee), a member of EPA Region 9's chemical
accident prevention program, is a chemical engineer with experience as project engineer
and project manager in engineering and construction of chemical process plants.
Dianna Young, EPA Region 9, Community Involvement Coordinator (for public
meetings in Pahoa and Hilo).
Sandra Carroll, EPA Region 9, CEPP Coordinator for Nevada, was the Risk
Management Program Manager for Region 9 at the time of the site visits. Currently a
Ph.D. student at the University of Nevada, she wrote and edited this report.
Vicki Rosen, EPA Region 9, Community Involvement Coordinator, has written fact
sheets and met with community members to discuss their concerns.
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3 Planning and Operating Safely
3.1 Guidelines for Facility Emergency Response Planning
Before the Review Team could evaluate emergency response plans and capabilities for
PGV, Team members first had to review the requirements that PGV followed to prepare
its emergency response plan. In 1989, the Hawai'i County Planning Commission
required PGV to prepare an emergency response plan, as Condition #26 of PGV's
Geothermal Resource Permit. PGV wrote and submitted its emergency response plan to
the Administrator of the Hawai'i County Civil Defense Agency, who then reviewed and
approved it in August 1990. The emergency response planning requirements in
Condition #26 are presented below in Table 3.
Table 3. Components of PGV's Emergency Response Plan. The Hawai'i County
Planning Commission required that PGV's plan include but not be limited to the following
elements. The Commission also required PGV to make its plan available to the public.
Planning Elements
Description
Geothermal Resource Permit Condition #26
a. Facility Description >
b. Local Responders X
c. Chain of Command >•
A description of the project facilities and operations,
with site plans identifying areas of potential hazards,
such as high pressure piping and the presence, storage
and transportation of flammable or hazardous
materials, such as lubrication or fuel oil, pentane,
hydrogen sulfide, and sodium hydroxide.
A description of emergency services available off-site
to respond to any emergency.
A description of the current onsite chain of command
and responsibilities of project personnel in the event
of an emergency.
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d. Potential Emergencies and
Response Measures >
A description of potential project emergency
situations, such as loss of well control, chemical
spills, hydrogen sulfide exposure, pipeline rupture,
fires, contaminated solids, etc. identifying:
(I) technical data on the nature of the hazard (for
example, the concentrations of hydrogen sulfide in
the various areas and the hazard associated with these
concentrations, the corrosive characteristics of the
abatement chemicals), or any data regarding the
possible aerial extent of each potential emergency
situation;
(ii) the warning systems (such as hydrogen sulfide
detectors) used to alert personnel of the hazard;
(iii) the location and use of equipment used to
control the hazard (such as fire protection equipment
or isolation valves) or repair hazardous equipment
(such as welding equipment or casing sleeves), and
safety equipment for personnel (such as respiratory
packs), including identification of the personnel
trained in the use of that equipment; and
(iv) provisions for the monitoring, detection, and
inspection of wells and plant facilities for the
prevention of emergency situations.
e. Natural Hazards >•
Provisions to address natural hazards (such as lava
flows, earthquakes, and storms) that identify warning
systems, control options, steps for securing and
shutting down the facility, personnel evacuation, and
notification to appropriate agencies;
f. Medical Services >•
The location and capabilities of available medical
services and facilities and plans for treating and
transporting injured persons;
g. Evacuation >•
Evacuation plans, including meeting points,
personnel rosters, and escape routes;
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h. Training >
Training requirements for personnel, including
procedures for emergency shutdown, handling of
emergency equipment, spill prevention, first aid and
rescue, fire fighting procedures, and evacuation
training;
I. Drills >
Provisions for periodic emergency preparedness drills
for personnel;
j. Coordination with
Outside Parties >
Detailed procedures to be used to facilitate
coordination with appropriate federal, state, and
county officials during and after any emergency
situation; and
k. Emergency Communication with
Residents >
Procedures to be used to identify and inform all
residents within applicable distances of the project of
the possible emergency situations, warnings, and
responses in advance of commencement of project
operations and the methods by which all individuals
affected by a given emergency will be notified and
evacuated, as necessary.
3.2 Guidelines for County Emergency Response Planning
In reviewing the County of Hawai'i Emergency Operations Plan, the Review Team used
the National Response Team's recommended criteria for reviewing emergency response
plans. This guidance, Criteria for Review of Hazardous Materials Emergency Plans
(NRT-1 A), serves as a supplement to the National Response Teams's Hazardous
Materials Emergency Planning Guide (NRT-1). The National Response Team developed
NRT-1 and NRT-1 A according to the Emergency Planning and Community Right-to-
Know Act (EPCRA). NRT requirements are summarized below in Table 4.
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Table 4. NRT Guidance for Preparing a Hazardous Materials Emergency Plan.
Summarized in this table are the key components of a hazardous materials emergency plan for
local governments. The National Response Team developed this guidance to clarify the
requirements of the Emergency Planning and Community Right-to-Know Act (EPCRA).
Planning Elements
Description
Summary of "Hazardous Materials Emergency Planning Guide" (NRT-1)
a. Introduction >•
b. Emergency Assistance Telephone
Roster >•
The introduction includes a summary of information
on past incidents, a promulgation document, legal
authority and responsibility for responding, table of
contents, abbreviations and definitions, assumptions
and planning factors, concept of operations with
governing principles, organizational roles and
responsibilities, and relationship with other plans. It
also includes instructions on plan use with purpose
and plan distribution, and a record of plan
amendments.
EPCRA Requirements: designation of a community
emergency coordinator and facility emergency
coordinators, who shall make determinations
necessary to implement the plan; methods for
determining the occurrence of a release.
Contact names, addresses, phone numbers, and other
pertinent information are included.
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c. Response Functions >•
Included are initial notification of response agencies,
direction and control, communications among
responders, warning systems and emergency public
notification, public information and community
relations, resource management, health and medical
services, and response personnel safety. Also
included are personal protection of citizens (indoor
protection, evacuation procedures, and other public
protection strategies), fire and rescue, law
enforcement, ongoing incident assessment, human
services, public works, and any other response
functions that are specific to local conditions.
EPCRA Requirements: methods and procedures to
be followed by facility owners and operators and
local emergency and medical personnel to respond to
any releases of extremely hazardous substances;
procedures providing reliable, effective, and timely
notification by the facility emergency coordinators
and the community emergency coordinator to persons
designated in the emergency plan, and to the public,
that a release has occurred. A description of
emergency equipment and facilities in the community
and at each facility in the community subject to
EPCRA, and an identification of the persons
responsible for such equipment and facilities.
Evacuation plans, including provisions for a
precautionary evacuation and alternative traffic
routes.
d. Containment and Cleanup >•
Techniques for spill containment and cleanup, and
resources for cleanup and disposal are included.
e. Documentation and Investigative
Follow-up >
Requirements, procedures and formats are included.
f. Procedures for Testing and
Updating the Plan >•
This includes exercises, incident review, training,
keeping the plan up-to-date, internal and external
review, and plan approval.
EPCRA Requirements: Training programs,
including schedules for training of local emergency
response and medical personnel. Methods and
schedules for exercising the emergency plan.
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g. Hazards Analysis >•
A summary of hazards identification, vulnerability
analysis, risk analysis, and facility information are
included.
EPCRA Requirements: methods for determining the
area or population likely to be affected by a release of
extremely hazardous substances; identification of
facilities subject to EPCRA that are within the
emergency planning district; identification of routes
likely to be used for the transportation of substances
on the list of extremely hazardous substances; and
identification of additional facilities contributing or
subjected to additional risk due to their proximity to
facilities, such as hospitals or natural gas facilities.
h. References >•
Among the key references are laboratory, consultant,
and other technical support resources, and a technical
library with pertinent data bases.
3.3 Operating Safely
Both EPA and OSHA have recently adopted identical requirements for preventing
accidental releases and improving safe work practices. They include the prevention
requirements summarized below in Table 5. The prevention requirements also are
included in the Integrated Contingency Plan guidance, known as "Oneplan," adopted by
the EPA, U. S. Department of Transportation, U. S. Department of the Interior, and U. S.
Department of Labor. The "Oneplan" guidance is an optional format for facility
emergency response planning. Both the prevention requirements and the "Oneplan"
format are included in this report as Appendix J.
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Table 5. Summary of Prevention Requirements. EPA and OSHA have published the
complete text of their prevention requirements in the Code of Federal Regulation (CFR). The
citation for EPA's prevention regulation is 40 CFR Part 68, and the citation for OSHA's
prevention standard is 29 CFR 1910.119.
E Process Safety Information.. Identify and understand all process hazards.
E Process Hazard Analysis... Evaluate the potential for accidental releases.
E Operating Procedures Provide workers with clear, written instructions.
B Training Teach both the hazards and safe work practices.
E Mechanical Integrity Use best engineering and management practices.
B Management of Change Understand the technical basis and effects of
change.
B Pre-startup Review Confirm that construction followed the design.
B Compliance Audits Verify and certify compliance with standards.
B Incident Investigation Thoroughly analyze and resolve findings.
B Employee Participation Involve workers in safety management.
B Hot Work Permit Issue a permit for any electric or gas welding.
B Contractor Safety Carry out safe work practices with contractors.
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How the Review Team Evaluated
The Emergency Response Plans
4.1 General
The primary tasks of the Review Team were to provide an independent review and
evaluation of the emergency response plans for Puna Geothermal Venture and Hawai'i
County. Team members focused on the longer-term objective of preventing chemical
accidents and improving emergency response capabilities.
4.2 Hawai'i County Emergency Operations Plan
The Review Team evaluated the 1989 version of the Hawai'i County Emergency
Operations Plan. The State Civil Defense Division prepared this plan for the Hawai'i
County Civil Defense Agency. The Review Team also evaluated a Geothermal Incident
Standard Operating Procedure that the Administrator of the Hawai'i County Civil
Defense Agency gave to the Team. This standard operating procedure does not show
which department or agency is responsible for its development or when it was issued,
except a penciled-in date of July 30,1992. The Review Team also evaluated a two-page
plan for an emergency response at PGV prepared by Hawai'i County Fire Department.
4.3 Criteria for Review of the Hawai'i County Emergency Operations Plan
As stated earlier in Section 3.2, the Review Team used, in part, the National Response
Team's recommended criteria for reviewing emergency response plans. This guidance,
Criteria for Review of Hazardous Materials Emergency Plans NRT-1 A, serves as a
supplement to the National Response Teams's Hazardous Materials Emergency Planning
Guide NRT-1.
4.4 Puna Geothermal Venture Emergency Response Plan
The Review Team reviewed version 6.3 of the Puna Geothermal Venture Emergency
Response Plan dated January 30,1996, and the Puna Geothermal Venture Emergency
Action Plan revised February 23,1996. Review Team members also reviewed the
HAZWOPER/Emergency Response Guidelines and Training Program, revised February
23,1996.
4.5 Criteria for Review of the PGV Emergency Response Plan
The Review Team evaluated the PGV Emergency Response Plan following EPA
Chemical Safety Audit Guidelines and OSHA Process Safety Management and
Hazardous Waste Operations HAZWOPER Standards. Audit teams use Chemical Safety
Audit Guidelines in conducting safety reviews of facilities producing and handling
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hazardous chemicals. The Chemical Safety Audit Program, as directed by the Chemical
Emergency Preparedness and Prevention Office of EPA, is part of its Chemical Accident
Prevention Program. The EPA has structured the Chemical Safety Audit Guidelines to
address each of the major elements of chemical process safety management at the facility
being audited. While no statute links the Chemical Safety Audit and EPCRA programs,
similar goals between the two programs include:
• Increased preparedness for responding to accidental releases both at a facility and in a
community;
• Increased awareness and understanding of chemical hazards; and
• Increased levels of safety practices related to producing, treating, handling, disposing,
and transporting of hazardous substances at a facility.
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5 County of Hawai'i
Emergency Operations Plan
5.1 General
This section covers the Review Team's assessment of the Hawai'i County Emergency
Operations Plan, from now on called the "Plan." The Review Team presents findings and
recommendations for the Plan, including the Basic Plan and Annexes.
The Plan is a multiple hazards plan that "is designed to provide guidance to emergency
managers to cope with every possible type of hazard—natural, technological and war." A
primary focus of the Plan is preparedness and emergency response to floods, volcanic
activity, earthquakes, tsunami, drought, and fire. It also integrates emergency response
capabilities along functional lines.
The Plan covers transportation and industrial accidents, utility failures, and pollution
including marine oil spills and accidents involving oil and hazardous substances. It also
covers health, including epidemics and infestations, and major public disorder and unrest.
All of these are called "human-caused" disasters. Annexes to the Plan present more detail
on emergency response procedures for utility failures, oil and hazardous substance
accidents, and health hazards. The Plan lists the other human-caused disasters for
reference only. It states that such disasters could occur more frequently if the
urbanization, tourism and economy of the County continue to expand.
The Plan covers human-caused spills and releases of hazardous substances as disasters if
the destructive event is great in size and scope. This would justify carrying out as much
of the organization and response portion of the Plan as the County determines is
necessary. The Plan presents an "Oil and Hazardous Substances Response Plan" in
Annex M. Specifically, Annex M addresses emergency response to spills and releases of
hazardous substances.
The Plan provides a basis for emergency managers of government agencies and private
organizations to develop internal preparedness and response procedures. Each county
agency is responsible for developing and maintaining disaster response plans, Standard
Operating Procedures (SOPs), or checklists in support and conformance with the Plan.
The State Civil Defense Division prepared the Plan for the Hawai'i County Civil Defense
Agency. The Hawai'i State Director of Civil Defense and the Mayor of Hawai'i County,
also serving as a State Deputy Director of Civil Defense, signed the Plan on March 8,
1990. Hawai'i County distributed copies of the Plan to all cooperating agencies and
offices in local, state, and federal government. Notably, they included the Federal
Emergency Management Agency Region IX - San Francisco in the distribution list. As
of August 1996, the State and County had made no revisions to the Plan from the date of
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approval, as recorded on the page provided for this purpose.
5.2 Basic Plan
Hawai'i County Emergency Operations Plan includes a Plan for Emergency
Preparedness. This Basic Plan defines the purpose, scope, authority, and organization for
a governmental or private sector response in the County. Section III of the Basic Plan
also defines the responsibilities and functions of the County, State and Federal
departments, agencies, and offices, and other supporting organizations.
Section IV of the Basic Plan describes emergency procedures during disasters and
coordinating instructions. Included is a description of response plans that each County
department, agency and office, and State district and branch office will develop,
including an annual update. Each agency will ensure that Standard Operating Procedures
(SOPs) or checklists include complete, understandable instructions for carrying out and
coordinating activities under emergency conditions. Appendix I to the Basic Plan
contains a sample of the disaster response checklist.
Section V "Direction and Control" includes paragraphs that describe the organizational
structure and role of the County Civil Defense Agency. This agency and its administrator
are responsible for promptly and efficiently carrying out the County Emergency
Operations Plan. This includes the review and coordination of supporting plans
developed by governmental and private agencies in the County. Section V also describes
the responsibilities of the head of each County and State department, agency, and office.
This section covers warning and evacuation, access to disaster areas, communications,
reports and reporting, damage assessment, public information, training tests and drills,
no-fault coverage and effective date.
Section VI "Readiness Evaluation" describes a State and County Civil Defense assistance
program for reviewing response plans (including operating procedures, checklists, and
agreements). This program aids County departments and agencies, State district and
branch offices, and private organizations in identifying and correcting deficiencies. Also,
the assistance program helps to conduct emergency training exercises and critiques,
participate in post disaster critiques and evaluations, and program and budget for
operating requirements and improvements. If a County department or agency was not
complying with provisions of the Basic Plan, the County Civil Defense Administrator
would prepare a disaster readiness evaluation. The Administrator would cite the agency
as delinquent in the evaluation and include these findings in a periodic report to the State
Deputy Director of Civil Defense.
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5.3 Annexes
5.3.1 Annex A: County of Hawai'i Disaster Response Organization
The organization chart in Annex A identifies the Hawai'i County Civil Defense
Agency as the lead agency in a disaster. During a disaster response, this agency
has command and control responsibility for the activities of the police and fire
departments. The chart also defines the organizational responsibilities and
relationships between county and state departments, agencies and offices in
providing support to the Hawai'i County Civil Defense Agency. The chart does
not show a role for a site incident commander or on-scene coordinator. In the role
of State Deputy Director of Civil Defense, the Hawai'i County Mayor is
ultimately responsible for disaster response preparedness and the performance of
the Hawai'i County Civil Defense Agency.
5.3.2 Annex B: Hazards Analysis
In Annex B, Hazards Analysis, the authors of the Plan recognize that a thorough
analysis of all hazards is fundamental to all effective disaster preparedness and
response plans. Annex B includes accidental release of hazardous substances as
human-caused hazards. Accordingly, an industrial accident like a release of H2S
at Puna Geothermal Venture is a human-caused emergency when it seriously
threatens the loss of life or damage to property. Annex B, Section II, "Types of
Hazards," lists human-caused hazards separately from natural disasters. The
authors make this distinction because human-caused hazards can occur more
frequently and develop suddenly and unexpectedly. They require a prompt,
effective and coordinated response to protect lives and property.
While Annex B includes accidental releases of hazardous substances as
human-made hazards, it does not address such releases as a threat to the public
and the environment. The authors have not listed this category in Section III
"Vulnerability."
5.3.3 Annex C: Warning and Evacuation
Annex C describes the County disaster warning system and the responsibilities
and functions of the Hawai'i Civil Defense Agency in coordinating a disaster .
warning. The County Civil Defense Administrator may direct an agency to sound
an Attention/Alert siren when a local disaster threatens the immediate welfare of
the County. An announcement over the radio and television will accompany the
Attention/Alert signal using the local Emergency Broadcast System.
Section III A of Annex C describes the actions citizens should take when they
hear an Attention/Alert siren. The actions include tuning a radio to any local
station, listening for emergency information and instructions, and taking
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necessary protective actions as directed. Information in Appendix 4 "Hazards" is
inconsistent with "Warning Time" information in Section III, based on
discussions with Mr. Harry Kim. According to Appendix 4, the County will
notify the 'community' at risk. Section III describes the Emergency Siren Signal
system that provides warnings throughout the county.
While this warning system is set up to alert the public of natural hazards that have
warning time, they recognize that some hazards will occur with no warning.
Appendix 3 to Annex C lists such hazards: local tsunamis, flash floods, water
spout tornados, and earthquakes. In an urgent local tsunami warning, the Central
Police Dispatch (County Warning Point) in Hilo has the authority to sound the
Attention/Alert signal immediately.
Notably, the list of hazards also includes human-induced events that could be
catastrophic to the community. Any of these hazards could result in a sudden
unexpected effect with little time for official warning: explosions, fires, and
transportation or industrial accidents. Appendix C does not specify whether the
County has extended an urgent alerting authority to the Central Police Dispatch
for other hazards that may occur with little warning time.
5.3.4 Annex D: Civil Defense
Annex D clearly describes the County of Hawai'i Civil Defense Agency and the
organizational structure of its Emergency Operating Center. Appendix 1 to
Annex D is a guide to the disaster communications capability of the organization.
This guide lists the participating agencies and how a basic radio communication
system links them. The guide also includes a list of commercial radio stations
that would broadcast emergency bulletins from the Civil Defense Agency. The
organizational structure does not include a list of people the County would notify
by telephone.
5.3.5 Annex M: Oil and Hazardous Substances Response Plan
Annex M "Oil and Hazardous Substances Response Plan" states the following --
"Proper handling of a hazardous material emergency requires that certain
information pertaining to the released material be obtained before any
personnel or public are exposed during a subsequent effort to mitigate the
emergency. The listing of these materials and information is attached to
each individual facility appendix of this Annex."
However, the Review Team found no such appendices attached to Annex M.
Annex M does not contain a list or any information about hazardous substances in
the PGV facility. Also, it does not describe any public or environmental threats
that could result from a serious release of hazardous substances.
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5.4 Geothermal Incident Standard Operating Procedure
The Basic Plan requires police, fire and other emergency support organizations to include
Standard Operating Procedures (SOP) for warning and evacuating residents. Emergency
response organizations have prepared a Geothermal Incident SOP for a major H2S release
from the PGV facility. The SOP is a checklist of tasks and responsibilities the emergency
managers use when Hawai'i County opens its Emergency Operations Center. Police,
Fire, Health, and Public Works departments, and the Red Cross use their SOP for
notifying the public of any threat from a geothermal hazard.
The Geothermal Incident SOP dated July 30,1992 does not describe how to do the tasks,
nor does it provide clear definitions of responsibilities and duties. For example, the SOP
shows that a task of the Emergency Operations Center is to direct the response operations
and to establish an On-Scene Coordinator. The main tasks of the On-Scene Coordinator
are to (1) establish communications with the Emergency Operations Center, responding
agencies, and the community, (2) prepare a hazard assessment, and (3) coordinate the
response, including warning and notification, evacuation, and securement. The SOP
splits the management functions of directing and coordinating between the Emergency
Operations Center and the On-Scene Coordinator, leaving uncertainties about who is in
full command. We note that the On-Scene Coordinator described above should not be
confused with a predesignated federal official. The federal official coordinates federal
activities at a hazardous material incident and monitors the incident for compliance with
federal pollution control laws.
The Geothermal Incident SOP does not describe any likely geothermal incidents for
which the plan is directed. The SOP identifies PGV as a location of direct impact and
includes a table with H2S release scenarios that have the PGV facility as a source. The
SOP does not describe any response actions the County and local responders would take
in the PGV facility. It does not mention coordinated preparedness among the County,
local responders and PGV.
5.5 Findings and Recommendations
5.5.1 Finding:
The Basic Plan clearly states its purpose to achieve effective governmental and
private sector preparedness for prompt, fully coordinated, flexible response and
assistance when natural, human-caused disaster or acts of war threaten or occur
anywhere in the County of Hawai'i. As reflected in this statement and throughout
the plan, little recognition or attention to "chemical" or "industrial" issues occurs.
Annex M, the Oil and Hazardous Substances Response Plan, is underdeveloped
considering the island's continuing economic growth.
Recommendation:
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The County Department of Civil Defense should review and revise the Hawai'i
Emergency Operations Plan to update and replace the 1989 Plan. They should
update the Plan in cooperation with all County agencies, local code enforcement
and emergency response departments and other interested parties. The basic Oil
and Hazardous Substances Response Plan, as described in Annex M, is not a plan
for field operations. The Plan should describe the relationship between Federal,
State and local response plans for hazardous materials. This document should
contain three parts: basic plan, local jurisdiction information, and pertinent source
material.
Part I- the basic Oil and Hazardous Substances Response Plan (Annex M) should
provide the framework to bring together, in one place, information describing the
elements of hazardous materials incident planning and response in the County of
Hawai'i including:
a. Establishing roles and responsibilities for government agency actions required
to protect life, the environment and property from the effects of any hazardous
materials release or threatened release that impacts any part of the County of
Hawai'i;
b. Identifying procedures Hawai'i County will use to coordinate the management
of hazardous materials emergency response;
c. Meeting the requirements for the County that also carry out the requirements
for the State of Hawai'i;
d. Substantially addressing each element listed in the SARA Title III and in the
Hazardous Materials Emergency Planning Guide (NRT-1) issued by the National
Emergency Response Team. Objectives include the following:
1. Providing guidance to those required to provide services in case of a hazardous
materials incident;
2. Describing pre-emergency preparations, concept of operations, organization,
incident command, protective actions, and supporting systems required to carry
out the plan;
3. Defining responsibilities and functions of each participating organization,
public or private; and
4. Establishing lines of authority and coordination.
Part II- Each lead agency with planning and response roles should provide local
jurisdiction information. Local jurisdictions should provide information for the
following:
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a. An information sheet with contacts;
b. A narrative report describing local capabilities and resources; and
c. Supplemental information showing assigned responsibilities.
Part III- Appendices should include, at a minimum, references to all source
documents that provide the foundation for the basic Oil and Hazardous
Substances Response Plan (Annex M) including:
a. County and Operational Plan;
b. Local Police and Fire Service;
c. County Central Fire Protection District Hazardous Materials Operations Guide;
and
d. PGV Emergency Response Plan.
5.5.2 Finding:
While the Basic Plan mentions 'private sector' assistance, this is not well defined
for the role of facilities that may experience hazardous materials accidents. Many
organizational graphics (see Annex D-l) do not include assistance from the
private sector.
Recommendation:
Planners should address and define the role of facility personnel if facility
chemical emergencies are to be coordinated with the county plan. They should
also specify how, when, and under what conditions facility (private sector)
personnel would interface with other authorities. Concerning the Oil and
Hazardous Substances Response Plan (Annex M), EPCRA laws require the
designation of a community emergency coordinator and facility emergency
coordinators who will make determinations necessary to implement the plan.
5.5.3 Finding:
Annex C, Section III, Civil Defense Siren Signals and Appendix 4, Hazards with
Warning Time are inconsistent based on discussions with Mr. Harry Kim. While
the Emergency Siren System described in Section III provides warnings
throughout the county, Appendix 4 says they will notify the 'community' at risk.
Recommendation:
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Emergency managers have found many ways to alert and notify the community
when a human-made disaster affects only the area local to the source. Below are
some ways that Hawai'i County working with PGV could improve their alerting
and notifying:
• Both Hawai'i County and PGV should explore the technical and economic
feasibility of upgrading the system. The upgrade should include the capability to
provide alerts within a single community (such as Pahoa or Hilo) without
unnecessarily alerting the entire island. This would allow them to use the system
as Annex C, Appendix 4 intends — the notification of a specific community at
risk;
• Install tone-alert radios that a Radio Broadcast Data System (RBDS) signal
could activate in the homes surrounding PGV or where sensitive population
centers exist (e.g., schools, hospitals, day care centers);
• Use a telephone call-down system, which can make many telephone calls
simultaneously, to get emergency information to the community;
• When sirens are sounded, in response to an accidental release of a hazardous
material, use the existing connections with the television and radio stations to
notify the public what is occurring and protective actions they should to take; and
• Educate the public on how to "shelter-in-place" and turn on their radios or
televisions to receive instructions on the appropriate protective action, when a
they hear a siren. With some modifications to the Hawai'i County systems, they
could provide an excellent means of alerting and notifying the community
surrounding the PGV facility. The County could also instruct the public about
what actions they should take during an emergency.
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5.5.4 Finding:
Some hazards will occur with almost no warning time. Appendix 3 to Annex C
lists local tsunami, flash floods, water spout tornado, and earthquake as such
hazards. Notably, the list of hazards also includes human-induced events that
could be catastrophic to the community. Any of these hazards could result in a
sudden unexpected effect with little time for official warning: explosions, fires,
and transportation or industrial accidents. In an urgent local tsunami warning, the
Central Police Dispatch (County Warning Point) in Hilo has the authority to
sound the Attention/Alert signal immediately. Appendix C does not specify
whether the County has extended an urgent alerting authority to the Central Police
Dispatch for other hazards that may occur with little warning.
Recommendation:
The Plan should include a procedure allowing the Pahoa Substation of the
Hawai'i County Fire Department to make emergency decisions, such as sounding
sirens. The Pahoa Substation could then manage the emergency until personnel
from Hawai'i County Civil Defense have time to arrive and take command. This
could shorten the time needed to alert and notify the public after a release.
Hawai'i County Civil Defense, the Pahoa Substation, PGV, and representatives of
the community should work together and determine how they will manage an
accidental release. This could include setting up different levels of incidents.
This group could also determine the appropriate response for each level of
incident and when to notify Civil Defense, the Pahoa Substation, and the
community.
5.5.5 Finding:
Annex M, Section I "Overview" does not address public or environmental threats
caused by a serious release of hazardous substances from a facility. The appendix
listing hazardous materials for individual facilities is also missing.
Recommendation:
Puna Geothermal Venture and other facilities in Hawai'i County that handle
hazardous materials should submit information on all hazardous substances as
required by EPCRA. In addition, each facility should prepare a hazards analysis
including a worst-case scenario and off-site consequence analysis. If the hazards
analysis shows a serious threat to the public and the environment, the County
should list it in Annex B, Hazards Analysis, Section III - Vulnerability. The
County also should address it in Annex M "Oil and Hazardous Substances
Response Plan."
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In September 1998, Hawai'i County Civil Defense Agency informed EPA that
each individual facility appendix is available on the Hawai'i County Fire
Department computer. A paper copy is also located at the Civil Defense
emergency operations center, but it should be updated. These appendices are
commonly referred to as the "individual facility profiles for SARA Title III."
5.5.6 Finding:
Annex M, Section III, Concept of Operations (Step C) states that "the Chief of the
Hawai'i Fire Department, or his designee, assumes the role of Incident
Commander until relieved by the Hawai'i County Civil Defense Agency upon
activation of County of Hawai'i Emergency Operations Plan." However, the
emergency response plans for Puna Geothermal Venture designate facility
personnel to fill the role of incident commander. Thus, the county and facility
plans are inconsistent.
Recommendation:
PGV and County personnel should jointly assess the emergency and the necessary
response activities. PGV personnel will better understand the response level
required within the plant boundaries. However, the County agencies should also
assess the emergency, as PGV may call them to provide backup for personnel
rescue, medical assistance and fire fighting within the plant boundaries.
Additionally, the County agencies should decide the need for offsite evacuations.
Refer to the recommendations in Section 4.2.4.
5.5.7 Finding:
In Annex M, Section VII, Warning and Evacuation, the County determines the
evacuation area based on information from the computer program CAMEO
(Computer Aided Management of Emergency Operations). They do not define
the parties responsible for modeling in the procedure. Additionally, they do not
define procedures for obtaining necessary input variables to run the computer
program. Variables include industrial process and meteorological information
that should be available quickly.
For planning purposes, PGV has prepared advanced modeling of anticipated worst
case release scenarios for H2S and effects from pentane fires. This information is
presented in the Plan. The models show no life threatening effects at the nearest
residential location, which is approximately 2,000 feet. However, the public is
concerned about model accuracy. One local resident stated that during a blowout,
concentrations of 30 parts per million (ppm) were present at the resident's home,
but the PGV models predicted only 1.1 ppm. The EPA has not confirmed the
PGV model accuracy or the resident's statement.
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Recommendation:
a. Identify a responder responsible for CAMEO modeling and identify where to
obtain meteorological input data. Identify a PGV source to provide release
information. This procedural information may be better placed in the Hawai'i
County Fire Department plan for Emergency Response to Puna Geothermal
Venture. The County Emergency Operations Plan is more general in nature.
b. Hawai'i County (with support from EPA) should confirm PGV model
accuracy, determining if PGV's input is appropriate and if the model results are
reasonable. Additionally, Hawai'i County and PGV should evaluate other hazard
scenarios. One example of a hazard scenario is the failure of caustic injection at
the Emergency Steam Release Facility when this facility experiences maximum
flow. Another example is the effect of discharges from pressure relief valves on
the pentane, steam, and process sides of the operation. The "process" at PGV, as
defined by Process Safety Management (29 CFR 1910.119), includes the pentane,
steam, and condensate systems, as they are all interconnected by pipeline.
5.5.8 Finding:
Annex M, Section VII, Warning and Evacuation says that each facility appendix
lists individual evacuation plans. The Review Team did not see a facility
appendix for PGV. Additionally, the public has raised several concerns related to
evacuation:
a. They do not know where to evacuate.
b. They do not know how the County will notify them of an evacuation.
c. Residents southwest of PGV are concerned that their only evacuation route is
toward the facility, and that electric power transmission lines run along this road.
For example, the power lines could fall onto the road during a major earthquake,
and this same earthquake could also cause a major accidental release from PGV.
If the release required an evacuation, and the only evacuation route was
impassable, residents would be at risk of injury.
d. They are concerned about housing for evacuees.
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e. They state that too few (only two) buses are available for evacuating children
from school in Pahoa. They do not know how the County will notify the school
of an evacuation.
f. They are concerned about the County Civil Defense's ability to notify the
residents in the adjacent housing if they need to evacuate quickly.
Recommendation:
a. Initially, the local responders and PGV should resolve all coordination issues
identified previously in these findings and recommendations.
b. After Hawai'i County, with EPA support, confirms release scenario models,
local responders should define public evacuation routes and safe congregation
areas. Although maps show releases as circles concentric to the release point, the
actual release will take the shape of a plume. Consequently, local responders
should define alternate evacuation routes considering different wind directions.
c. A plan to evacuate the schools at the Pahoa K-12 complex should be in place.
If too few buses are available, perhaps the County should consider using private
vehicles. Local responders should also work with the schools to develop an
emergency plan which includes shelter-in-place procedures.
d. Local responders should develop a plan to ensure the public follows proper
evacuation routes and that they reduce traffic congestion.
e. The County should publish additional information in the individual facility
appendix of Annex M addressing - (1) indoor protection and (2) the evacuation
procedures detailed in Function 9, Page 56 of the NRT-1 guidance. Evacuation
procedures should address housing for evacuees.
f. The local responders should review the evacuation plan with the public and
consider public participation to the plan.
5.5.9 Finding:
Annex M, Section X -Training provides little information beyond the County's
intent to provide training.
Recommendation:
Annex M, Section X -The County should develop training for hazardous
materials response to include both frequency of delivery (a schedule) and
emphasis on joint activities with private sector facility personnel. Joint training is
vital for addressing and exercising the interface mechanisms (cited above) which
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avoid confusion in real-world events.
5.5.10 Finding
The State Department of Civil Defense prepared the Hawai'i County Emergency
Operations Plan for the County of Hawai'i. On March 8,1990, the Mayor of the
County (who is also the State Deputy Director of Civil Defense) and the Director
of Hawai'i State Civil Defense signed the Plan. The document as signed was
incomplete. However, they have made no revisions to the Plan since the date of
acceptance. The Emergency Planning and Community Right-to-Know Act, 42 U.
S. C. § 11003 (1995), states that each local emergency planning committee
(LEPC) "shall review such plan once a year, or more frequently as changed
circumstances in the community or at any facility may require."
Recommendation:
Hawai'i County should review, update, and complete the Plan, including SOPs.
The Review Team suggests that the County refer to the Hazardous Materials
Emergency Planning Guide, document NRT-1, and the Criteria for Review of
Hazardous Materials Emergency Plans, document NRT-1 A. The National
Response Team prepared both documents as guides for reviewing and updating
emergency response plans.
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Puna Geothermal Venture
Emergency Response Plan
6.1 General
The PGV Emergency Response Plan and other facility documents describe some
pertinent types of incidents and who will be contacted during an incident. The
Emergency Response Plan describes who will be the Incident Commander during certain
times. The only person specified as the Incident Commander is the Site Manager or the
Operations and Maintenance Manager "if pre-qualified." The Emergency Response Plan
designates the Incident Commander as the person responsible for confirming that PGV
notifies all agencies and others quickly.
The Emergency Response Plan includes several different release scenarios. Some of
these scenarios involve hydrogen sulfide, diesel fuel, pentane, brine and steam. OSHA
Process Safety Management (PSM), 20 CFR 1910.119, requires regulated facilities to
take steps to prevent or minimize the consequences of catastrophic releases of toxic,
reactive, flammable or explosive chemicals. PGV is subject to this regulation because it
handles pentane, which is a flammable substance. Among the requirements of PSM are
emergency planning and response.
PGV addresses emergency response in the following several documents: the Emergency
Response Plan, Version 6.3, dated February 1,1996 and referenced as ERP below; the
HAZWOPER/Emergency Response Guidelines and Training Program, revised February
23,1996 and referenced as HAZWOPER below; and the PGV Emergency Action Plan
and Notification Guidelines, revised February 23,1996 and referenced as EAP below.
Under federal requirements for hazardous waste operations and emergency response
(HAZWOPER) 29 CFR 1910.120, the emergency response plan is required to address,
"Pre-emergency planning and coordination with outside parties." All emergency
response plans list County Civil Defense and other non-PGV responders on the external
call list.
The Review Team noted that these plans appeared to lack several emergency response
requirements as mandated by OSHA. Although EPA is not asserting responsibility for
enforcing OSHA requirements, these findings and recommendations for correcting the
deficiencies include specific regulatory references.
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6.2 Employee Emergency Plans and Fire Prevention Plans — 29 CFR 1910.38
6.2.1 Finding:
Under 1910.38(a)(2)(ii), the plan is required to include, "Procedures to be
followed by employees who remain to operate critical plant operations before they
evacuate." PGV notes equipment removal activities in case of a natural hazard in
Table 5-1 of the ERP. Due to time constraints, the Review Team scanned the
procedures in the emergency response documents. The Operations and
Maintenance Manual table of contents did not state clearly whether emergency
shutdown procedures do exist.
Recommendation:
PGV should have emergency shutdown procedures. If these procedures exist
already, PGV should cross-reference the procedures for an emergency shutdown
with its emergency response procedures. [Please note: the Review Team was not
given the opportunity to review the PGV Operations Manual, and EPA did not
receive a copy for review. HIOSH informed EPA during a teleconference
November 3, 1999, that HIOSH is satisfied with the written emergency shut down
procedures in PGV's emergency response plan.]
6.2.2 Finding:
Under 1910.38(a)(2)(iv), the plan is required to include, "Rescue and medical
duties for those employees who are to perform them." The ERP states that at least
three people with first aid training will work on every shift. At the time of the
review, it was not clear in any emergency response document how the facility
identified individuals with first aid training during an emergency or what their
role was on the response team. PGV has since indicated to EPA that all PGV
employees are certified for first aid and cardiopulmonary resuscitation or CPR.
Recommendation:
The emergency response procedures should clarify the role of first aid responders
to ensure they are available to administer first aid when required.
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6.3 Hazardous Waste Operations and Emergency Response — 29 CFR 1910.120
6.3.1 Finding:
Under 29 CFR 1910.120(q)(2)(I), the emergency response plan is required to
address, "pre-emergency planning and coordination with outside parties." From
discussions with County Civil Defense and local responders, the Review Team
found that coordination with outside parties is practically nonexistent. The
emergency response plans do not address responders' roles or coordination of
response activities with local responders. At the time of this review, PGV's stated
position was that it will handle all incidents internally in its facility, except fire
incidents. Insufficient coordination with outside parties is the primary cause of
concern over PGV's need to improve its emergency response capability. Some of
the specific concerns are described below, in paragraphs 6.3.2 through 6.3.6.
Recommendation:
PGV should improve its emergency response capability by --
1. Clarifying in writing the local responder responsibilities and
2. Communicating with outside parties during pre-emergency planning.
PGV responders may need backup from the Hawai'i County Fire Department and
its HAZMAT, hazardous materials, or EMT, emergency medical technician,
teams. A facility emergency could include a fire, explosion, hazardous substance
release, or all three at the same time, in which case PGV could become
overwhelmed. Given a very serious emergency, local responders may need to
rescue PGV responders.
6.3.2 Finding:
The Hawai'i County Fire Department and its HAZMAT team members said they
were uncertain what their role would be in an emergency response at PGV. The
assistant fire chief also stated that he would not send County responders beyond
the plant boundary without understanding the facility and the County's role in the
response. PGV personnel noted that they do not expect the fire department to
respond to releases of hazardous substances in their facility. However, PGV
would call Hawai'i County Fire Department for assistance if it had a fire in its
facility. For example, if the pentane cycle or any component of the entirely closed
cycle caught fire, PGV would call the fire department.
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Recommendation:
PGV should work with the Hawai'i County Fire Department to refine the Fire
Department's procedure entitled, "Emergency Response to Puna Geothermal
Venture." The Fire Department should incorporate the response of its newly
formed HAZMAT team. Also, PGV should work with the Fire Department to
clearly define the possible response scenarios, both inside and outside the plant
boundaries. Some of these scenarios involve hydrogen sulfide, caustic soda,
diesel fuel, pentane, brine and steam. If other hazardous chemicals are present in
the steam from geothermal wells, the Emergency Response Plan should include
them as well. EPA notes that specific conditions render chemicals hazardous
rather than their presence alone. Defining these scenarios and the anticipated
level of backup from the Fire Department and the HAZMAT team will require
PGV participation.
PGV should work with Hawai'i County Civil Defense Agency and Fire
Department, Pahoa Substation, to establish how and whom PGV will notify
during an incident. For example, a situation could arise in which PGV personnel
are injured during an emergency response, and PGV would need to call County
Fire for rescue or backup. PGV and the County should address emergencies
involving both hazardous materials and fire in the facility.
6.3.3 Finding:
Version 6.3 of the Emergency Response Plan states that the County "Civil
Defense Agency has the responsibility of providing the warning to, and to effect
the implementation of, the evacuation of any residents or other members of the
public from the appropriate hazard area surrounding the site, as necessary."
However, this plan does not clearly state the order in which PGV personnel
should notify County responders. The lack of clarity may cause a delay in County
response, such as evacuation, that could have serious consequences. PGV does
not address pre-emergency response planning activities with outside parties, e.g.
the community, in any planning document.
Version 6.3 of PGV's Plan states that "PGV anticipates no project-created
situation which would not provide sufficient time for the Civil Defense Agency to
warn or evacuate the public, as appropriate." PGV's release history does not
support this statement. In the past, incidents have occurred quickly and without
sufficient warning to notify or evacuate the public before they were exposed to
hazardous substances. According to the County Civil Defense Administrator,
incidents also have occurred in which neighbors to PGV phoned-in complaints of
H2S releases, and PGV did not report these same releases. Copies of letters
between EPA and PGV regarding one such release in January, 2000 are appended
to the final report.
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Recommendation:
With PGV's assistance, Hawai'i County Fire Department personnel should
evaluate and determine if release or fire situations require outside response. The
State of Hawai'i has adopted the 1988 edition of the Uniform Fire Code by
reference into its State Model Fire Code. The Uniform Fire Code section 10.101
authorizes the County Fire Department to direct an operation as necessary at the
scene of a fire or other emergency involving the protection of life or property.
Section 10.101 also empowers the County Fire Department to perform any rescue
operation or take any other action necessary in the reasonable performance of its
duty. Both PGV and Hawai'i County Fire Department have emergency response
capabilities and responsibilities. PGV should improve its coordination with
outside parties and its outreach activities. PGV should involve both local
responders and the community in its pre-emergency planning.
6.3.4 Finding:
This finding pertains only to hazardous materials releases. By not incorporating
the ranking outside responder into the Incident Command System (ICS) for
hazmat response, PGV is directly or indirectly making decisions that affect
outside emergency response personnel and the public. For example, PGV will
define the severity of an accidental release scenario or the potential severity of the
release. Then the outside responders will base their action on the PGV
assessment.
Recommendation:
PGV and Hawai'i County should modify the PGV Emergency Response Plan and
the Hawai'i County Emergency Operations Plan to coordinate a joint incident
command system. Both a PGV official and the ranking outside responder should
share the responsibility for incident command. The PGV Emergency Response
Plan should clarify that the PGV control room operator will serve as the Incident
Commander during every shift, including off-hours, until relieved by the
Operations and Maintenance Manager or Site Manager.
6.3.5 Finding:
The Review Team was not able to review and determine if PGV had conducted a
thorough process hazards analysis (PHA), such as a hazard and operability study,
for the entire PGV facility. As of August 1996, PGV had not reviewed its PHA
on well blowouts and pentane fires with outside responders. Thus, they may not
have identified emergencies beyond well blowouts and pentane fires that could
require outside emergency response. EPA takes notice of PGV's more recent
efforts to work with response agencies and its willingness to share process hazards
analyses.
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Recommendation:
PGV should continue to review the results of its PHAs with outside responders to
identify the hazards that may require outside emergency response.
6.3.6 Finding:
Under 1910.120(q)(2)(viii), the emergency response plan should address,
"Emergency medical treatment and first aid." The ERP discusses first aid but
does not clarify the coordination with outside responders to provide emergency
medical treatment.
Recommendation:
PGV should address medical treatment beyond first aid, such as acute exposure to
H2S and severe bums. PGV also should identify offsite responders and the
hospital in Hilo that can handle such emergencies. EPA has discussed this issue
with HIOSH and takes note that PGV has made improvements since the Review
Team's site visit in 1996.
6.3.7 Finding:
Under 1910.120(q)(2)(iii), the emergency response plan is required to address,
"Emergency Recognition and Prevention." The ERP discusses recognition of an
H2S emergency. However, it does not discuss recognition of combustible gas
leaks and fires in any of the emergency response procedures. The ERP references
pentane leak rupture and fire in the Operations and Maintenance Procedures, but
PGV did not make these procedures accessible to the Review Team. Thus, the
Review Team cannot comment on the content. The Operations Manager advised
the Review Team that as of August 1996, PGV was developing the emergency
procedure for fire.
Recommendation:
If PGV addresses combustible gas leaks and fires somewhere, then it should either
incorporate them into the emergency response procedures or cross-reference them.
If PGV has not addressed gas leaks and fires, it should incorporate them into the
ERPorEAP.
6.3.8 Finding:
Under 1910.120(q)(3)(I), "The senior emergency response official responding to
an emergency shall become the individual in charge of a site-specific Incident
Command System (ICS)."
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Recommendation:
PGV and the local Fire Department's HAZMAT Team should consider the Joint
Incident Command System for a coordinated emergency response. Both parties
should formalize the joint command structure so everyone will know who is
responsible for all tasks.
6.3.9 Finding:
Under 1910.120(q)(3)(v), "The individual in charge of the ICS shall limit the
number of emergency response personnel at the emergency site, in those areas of
potential or actual exposure to incident or site hazards, to those who are actively
performing emergency operations. However, operations in hazardous areas shall
be performed using the buddy system in groups of two or more." HAZWOPER
discusses control zones, but at the time of this review in August 1996, none of the
emergency response plans addressed control of the number of personnel or use of
the buddy system.
Recommendation:
In its ERP or EAP, PGV should include a discussion of using the buddy system
and controlling the number of response personnel. This should also be included
in PGV's Annual Safety Training Program which is in Section 6 of the ERP.
6.3.10 Finding:
Under 1910.120(q)(3)(viii), "When activities are judged by the safety official to
be an Immediately Dangerous to Life and Health (IDLH) condition and/or involve
an imminent danger condition, the safety official shall have the authority to alter,
suspend, or terminate those activities." The PGV emergency response plan does
not give this authority to the safety officer.
Recommendation:
PGV should provide this authority to the safety officer or provide some type of
check support to the incident commander's authority. PGV should add a clear
statement of authority or check support to its ERP. The term "check support"
means a system of checks and balances on the authority of the incident
commander.
6.3.11 Finding:
Under 1910.120(q)(4), "temporary employees who are needed to perform work on
an emergency basis, such as operating cranes or earth moving equipment, are not
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required to be trained in the emergency response plans, but should be briefed in
the hazards, proper Personal Protective Equipment (PPE) to be used and the duties
to be performed." This issue is not addressed in the emergency response plans. •
Recommendation:
PGV should amend the ERP to satisfy this requirement.
6.3.12 Finding:
Under 1910.120(q)(10), "chemical protective clothing used for emergency
response shall meet the requirements of 1910.120(g)(3-5)." Personnel protective
equipment (PPE) and clothing available for emergency response are listed in
HAZWOPER and the EAP. PGV's plans do not discuss what type of clothing and
PPE its personnel will use for different types of emergency response.
Recommendation:
PGV should clarify what appropriate clothing and protective equipment its
personnel will use for different response activities.
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7 Overarching Issues
7.1 General
Although the focus of this review was evaluating the emergency response capabilities of
Hawai'i County and PGV, the Review Team did discover some issues and concerns that
related to emergency response but were outside the reviewers' fields of expertise.
Review Team members also learned about other important emergency planning issues of
overlapping responsibility among PGV, Hawai'i County, and the State of Hawai'i. These
overarching issues are presented in this final section of the report because the issues are
important and relevant to emergency planning and response. The Review Team suggests
that all parties work together to resolve each issue.
7.2 Findings and Recommendations
7.2.1 Finding:
In 1991, the State of Hawai'i Department of Health (HDOH) identified levels of
hydrogen sulfide (H2S) that emergency managers could use for alert, warning, and
emergency levels of H2S in the air. The alert level is 10 ppb H2S averaged over a
24-hour period, the warning level is 100 ppb averaged over a one-hour period, and
the emergency level is 1,000 ppb averaged over a one-hour period.
Emergency managers at Hawai'i County and PGV also have identified H2S levels.
Hawai'i County has identified the 1,000 ppb level averaged over a one-hour
period as an evacuation trigger. In its ERP, PGV has listed a watch level of 25 ppb
averaged over a one-hour period and a warning level of 1,000 ppb averaged over a
one-hour period.
The Review Team found that the stationary H2S air monitoring network around
PGV's perimeter is currently not set to measure ambient H2S levels greater than
500 ppb. HDOH and PGV operate stationary monitors around the PGV
perimeter, which are set to monitor from 0 to 500 ppb1. The monitors are capable
of measuring different ranges, up to 20 ppm or 20,000 ppb, if recalibrated.
Because the monitors are currently set to measure from 0 to 500 ppb, the
stationary H2S air monitoring network around PGV cannot adequately measure
the data necessary to make evacuation decisions if ambient H2S concentrations
exceed 500 ppb2.
1 The monitors are currently set to a range of 0 to 500 ppb to ensure that the H2S ambient requirements in
the HDOH air operating permit can be adequately enforced. However, monitors with a wider dynamic range, from
five to 1000 ppb, are now available, and monitoring equipment is fundable under EPA's Clean Air Act Section 105
grant to HDOH.
2 The Review Team recognizes that PGV and HDOH currently have portable monitors that are available
to measure ambient H2S levels greater than 500 ppb.
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Recommendation:
The Review Team recommends that stationary air monitors around the facility
perimeter should measure continuously the higher H2S concentrations, greater
than 500 ppb. This is to ensure that local authorities can alert, warn, or evacuate
the public quickly. PGV should share its real-time air monitoring data with the
Pahoa Substation, so the local responders will know exactly what is occurring at
PGV during an emergency.
The Review Team also recommends that the County form a technical work group
to evaluate evacuation needs, resources, and procedures. The technical work
group could begin by reviewing H2S trigger levels, types of incidents, and the air
monitoring network around PGV. The technical work group also may want to
consider if stationary monitors should have alarms set to notify the County Civil
Defense Agency and Fire Department automatically when H2S concentrations
reach the alert, warning, or emergency levels.
Technical work group members should include representatives from the County
Civil Defense Agency and Fire Department, HDOH, the University of Hawai'i,
and EPA. Work group members should confer with PGV technical staff on the
details of facility operations. Technical issues under evaluation are extremely
important and will require a great deal of thought, research, and professional
judgement.
Public participation should be included when setting new evacuation trigger
levels. Based on comments EPA received regarding the draft report, EPA
suggests that at least one member of the technical workgroup could represent the
community-at-large.
7.2.2 Finding:
The perimeter H2S air monitors are on an interruptible power supply.
Circumstances causing power disruptions also may cause accidental H2S releases
from the PGV facility. PGV personnel can monitor ambient conditions with
hand-held H2S monitors.
Recommendation:
The Review Team suggests that PGV and HDOH install, for their respective
monitors, an adequate backup power source for the stationary H2S monitors.
HDOH and PGV should maintain stationary H2S monitoring during power
disruptions.
7.2.3 Finding:
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Hawai'i County Fire Department personnel noted that not all shifts from the
Pahoa Substation have received site tours to familiarize them with the PGV
facility or training in the hazards unique to PGV. This was a discussion item
during the combined meeting with firefighters at the Pahoa Substation on August
8,1996. The meeting included Hawai'i County Fire Department personnel, the
EPA Review Team, and members of PGV management.
Recommendation:
The Review Team suggests that PGV provide site familiarization and training for
all shifts of fire and HAZMAT response personnel from the local fire department,
including:
1. An overview of plant operations and process hazards,
2. H2S and any other hazards unique to PGV,
3. Safe handling practices of H2S and any other hazards unique to PGV,
4. Facility procedures, information, and personnel responsibilities for emergency
response; this should include the locations of all water hydrants, hydrocarbon
monitors, and point source monitors for H2S.
EPA notes that for the purposes of the PGV plan the hydrogen sulfide (H2S)
monitors should measure air quality in the "breathing zone" of approximately six
feet. There are no federal regulations which prescribe the requirements of siting
hydrogen sulfide monitors. EPA monitoring regulations [40 CFR Part 58] address
the monitoring of "criteria" pollutants, i.e. ozone, particulate matter, carbon
monoxide (CO), sulfur dioxide (SO2), nitrogen dioxide (N02), and lead. In
general, EPA, State and local agencies collect data on these pollutants for use in
regulatory programs mandated by the Clean Air Act. EPA monitoring regulations
contain specific siting criteria for monitors that measure these pollutants. In order
for the data collected to be valid for regulatory use, the criteria pollutant monitors
must meet all relevant siting criteria, including probe height. However, since H2S
is not a criteria pollutant, these regulations can be used as simply a guide to siting
the samplers, not a requirement.
Minimum probe heights for collecting ozone, CO, S02 and NO2 data are three
meters (about 10 feet). For particulate matter and lead monitoring, the minimum
probe height is two meters (about 6.5 feet). The reason the minimum probe
heights are set where they are is to obtain the most representative sample of
ambient air in order to measure concentrations of a particular air criteria pollutant.
If the probe is too close to the ground, the air sampled may be influenced by the
effect of ground turbulence or near ground sources (e.g. automobile exhaust).
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August, 2000 Final Report - 51
Since the object of the monitoring of H2S is to provide information to the
community on H2S levels they are exposed to, not to implement a regulatory
program mandated by the Clean Air Act, it is absolutely appropriate to site the
monitor probes at the breathing height level (six feet). The data collected will be
used to indicate whether certain actions in the emergency response plan should be
triggered. If there are concerns about where the H2S is coming from (i.e. PGV,
natural vents, automobiles, etc.) then supplementary monitors can be set up at
different heights to try to assess contributions from different sources. The
primary purpose of the H2S monitoring is to protect the health of the community;
therefore, the monitoring sites operated by the Hawai'i DOH should sample air at
breathing height (six feet).
5. Where the outside agencies will meet, including alternate locations, when an
incident occurs, and
6. The interface between the agencies and the facility and the different
responsibilities of each; this should include coordinated drills for rescuing injured
PGV employees.
Subsequent to the Review Team's visit, PGV stated that it has provided increased
site familiarization for all shifts of fire and HAZMAT response personnel in
Pahoa and Hilo.
7.2.4 Finding:
PGV's Emergency Response Plan (ERP) addresses magma intrusion. The ERP
seems to imply that this event is controllable, but does not discuss the severity or
likelihood of this event.
Recommendation:
Knowledge of this type of occurrence is outside the expertise of the review team.
PGV should evaluate the likelihood of occurrence and the severity of a magma
intrusion. PGV could draw upon the expertise of the University of Hawai'i,
Center for the Study of Active Volcanoes and the U.S. Geological Survey's
Hawai'ian Volcano Observatory. PGV should share the results of the evaluation
with the public.
7.2.5 Finding:
The effects of an earthquake of magnitude seven or greater on the PGV facility,
including pentane piping and tanks and underground well casings, are unknown to
the emergency response agencies. Seismic activity and its effects on structures
are outside the expertise of the Review Team.
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August, 2000 Final Report - 52
Recommendation:
PGV should consult with a qualified and respected engineering firm to review and
comment on the structural integrity of the facility, existing geothermal wells, and
any new wells yet to be drilled. This engineering review should address whether
the PGV facility would likely withstand earthquakes of magnitude seven or
greater in the Puna locality.
7.2.6 Finding:
In Hawai'i, the Emergency Planning and Community Right-to-Know (EPCRA)
Tier Two filing fees currently go directly to the State's Superfund environmental
response revolving fund and not to the Local Emergency Planning Committees
(LEPCs). The Review Team finds that these funds are not returning to local
agencies for emergency responder training. A lack of funds may compromise the
training of local response personnel.
In 1998, the Hawai'i County LEPC nominated two PGV employees to serve on its
reactivated committee. The Hawai'i State Emergency Response Commission
(SERC) confirmed their membership in August 1998.
Recommendation:
a. The LEPC should evaluate the training for local responders to decide if it is
adequate and evaluate ways to improve training where appropriate.
b. The Review Team encourages participation of industry on the Hawai'i County
LEPC. This will greatly improve communication between responders and
facilities and help to improve the quality of individual emergency response plans.
c. The State of Hawai'i should channel some Tier Two filing fees to LEPCs for
use in the training of HAZMAT response personnel.
7.2.7 Finding:
Hawai'i County has not recently conducted an exercise for hazardous materials
response, and PGV has never participated in one. The last time the EPA co-
sponsored a HAZMAT exercise for Hawai'i County was 1993. Then, the exercise
planning team mentioned PGV as a possible focus of the exercise. However, the
hazardous materials exercise scenario selected by the planning team was the Port
of Hilo in an industrial part of the city.
On October 4,1996, PGV had a release of H2S that exceeded the limit under the
state's air permit. The County and PGV should conduct a joint hazardous
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August, 2000 Final Report - 53
materials response exercise to prepare for this type of release. FEMA's guidance
for training exercises suggests a progression, from less difficult to more difficult
exercises. First a jurisdiction should conduct a tabletop exercise, then a functional
exercise, and finally a full-field exercise.
Recommendation:
The Review Team recommends that local and state agencies and PGV plan and
conduct a multiple jurisdictional hazmat response exercise. Participants should
include Hawai'i County Civil Defense, Hawai'i County Fire Department, Hawai'i
County and Keeau Police Departments, Hawai'i Department of Health and other
agencies. Before conducting an exercise, participants should resolve many
coordination issues and update their emergency response plans.
Hawai'i County should conduct the complete series of exercises -- tabletop,
functional and full-field, as recommended by FEMA. Additionally, exercise
evaluators should critique each exercise and make this information available to
the public.
PGV should initiate and actively participate in at least one of these exercises with
Hawai'i County. A tabletop or functional exercise between PGV and Hawai'i
County should have a target completion date no later than two years after the
release of this report.
7.2.8 Finding:
Under 29 CFR 1910.120(q)(2)(I) and (ix), the emergency response plan should
address "pre-emergency planning and coordination with outside parties" as well
as "emergency alerting and response procedures." At the time of the review, the
EAP did address internal alerting but did not clearly define the alerting of offsite
emergency responders.
Recommendation:
In cooperation with the County of Hawai'i Civil Defense, both the Pahoa
Substation and PGV should develop local emergency alert, warning and response
procedures. Hawai'i County also should educate the public near the PGV facility
regarding appropriate action that may be necessary.
Hawai'i County and/or PGV should equip the Pahoa Substation with a
combustible gas monitor, H2S detector, and UV/IR flame detector. PGV should
work with the County to identify the appropriate equipment, train the Pahoa
Substation personnel, and help maintain the equipment. PGV's EAP or ERP
should describe what actions operators will take when they hear a high alarm from
one of the point source monitors for hydrogen sulfide and hydrocarbons. This
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August, 2000 Final Report - 54
information should be communicated to the Pahoa Substation for the use of its
first responders.
7.2.9 Finding:
The Review Team found that public communications and access to chemical
emergency planning information from PGV could improve. This is based on the
EPA's experiences with community requests for information, such as requests
under the Freedom of Information Act. Community residents also raised
comments about the availability of information during the August 1996 public
meetings. Public comments are summarized in Table 2 at the end of Section 1.
Recommendation:
The Review Team strongly recommends that PGV improve and expand a program
for proactive community outreach. One objective is to increase the flow of
information for chemical emergency planning. Another important objective is to
further improve the working relationship between the community and PGV.3
3 PGV has recently provided updated information to EPA regarding its public outreach program. PGV
reports that an average of one hundred visitors per month have toured the plant. In addition, PGV personnel have
participated as guest lecturers at local schools and business organizations. PGV is maintaining published telephone
lines which allow the general public to speak to plant personnel, ask questions, obtain information on plant activity,
and file complaints. Through the Hawai'i Department of Health, PGV provides 24-hour-a-day hydrogen sulfide
tables and charts from each of its air monitoring stations. PGV is constructing an Internet web page to allow
electronic interaction with the community. Completion of the web page is expected by the end of the first quarter of
1999. PGV also reports that it provides other services and contributions to the community. For example, during
the recent drought, PGV provided fire fighting equipment and water to assist the local fire department respond to a
fire in the nearby Leilani Subdivision.
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August, 2000 Final Report - 55
The Review Team recommends that Hawai'i County agencies ensure that EPCRA
Tier Two information from all applicable facilities is readily available for
emergency planning and response.
In closing, the review team must emphasize that an emergency response plan
alone does not directly protect the public and the environment. The plan is only a
detailed blueprint of an emergency response program designed for a facility or
community, with the purpose of protecting the environment and the public.
Emergency response programs are the comprehensive approach to protecting the
public.
In addition to complete, updated and coordinated emergency response plans,
jurisdictions and industries must have the required resources, equipment and
trained personnel, to be fully prepared to implement the plans and respond to
accidents resulting from man-made hazards as well as natural disasters. Finally,
the authorities responsible for the emergency response programs must be assured
at all times that the programs are workable. They need feedback through the
results of scheduled periodic exercises.
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APPENDIX A
Visit to State and County Departments and Agencies - Field Notes
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VISIT TO STATE AND COUNTY DEPARTMENTS AND AGENCIES —
FIELD NOTES
Hawaii State Department of Health
Meeting notes were not taken
By request, the Hawaii State Department of Health, on behalf of the Hawaii State
Emergency Response Commission, provided EPA with a copy of the State of Hawaii
SARA Title m*. Section 312 annual report filed in February 1996 by Puna Geothermal
Venture. A copy of the report, referred to as a Tier H Form, is attached. By law, a facility
must report the annual inventories of hazardous chemicals that arc present in the facility,
their chemical description, associated physical and health hazards and storage codes and
locations. As the Tier H Form shows, PGV reported inventories included: sodium
hydroxide, pentane, unleaded gaoline, No. 2 diesel fuel, nitrogen, baroid silica and calcium
chloride. Not included in this report is a site plan showing hazardous chemicals locations at
PGV, which PGV attached to the Tier n Form.
*
-SARA Title ffl is used in refering to the Title HI of the 1986 Superfund Amendments and
Reauthorization Act (SARA). Title ffl is a provision called the Emergency Planning and
Community Right-to-Know Act (EPCRA)
State of Hawaii Department of Labor & Industrial Relations Hawaii Occupational
Safety & Health Division
Notes were not taken
State of Hawaii Civil Defense
Frank Fronczkowski, Civil Defence Planner
Lines of authority: Governor, Director of Civil Defense (appointed). Deputy Director of
Civil Defense (also island mayor, elected). Civil Defense Administrator.
A siren system is in place, primarily to warn inhabitants of tsunamis. County plans are
drafted by the state in conjunction with the individual counties. The county must ask the
state for assistance. The state supports civil defense training.
Hawaii County Civil Defense
Briefing with Hawaii County Civil Defense Administrator, Harry Kim.
There is a statutory requirement for the mayor and board to review the ERPs and
understand their responsibility.
A volcano located 20 miles southeast of Hawaii has been experiencing increased seismic
activity (from 2-3 magnitude to 3-4 magnitude).
Harry's perception of the public's concerns:
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(1) PGV needs to be closely monitored;
(2) Structural integrity of well casing during blowouts;
(3) The need for all hazards to be identified;
(4) concerned that they be notified of evacuation when hazard poses a risk and
(5) does not trust the county and state. The public feels that local government failed them
during the blowout
Harry did not approve the ERP, the mayor did. Harry did not feel it was possible to
adequately address all of the hazards associated with PGV without a complete analysis of
the geothermal streams.
The sirens on the island are currently sounded all at once. His goal is to enable the
operation of each of the 64 sirens on the island separately. Harry responded favorably to
Randy's suggestion for a siren at PGV, but said that it should be equipped with a speaker,
and PGV could not activate it
It is notable that Harry claims there is no backup for him at this time.
Harry's perception of the Emergency Response Plan:
(1) he believes it is generally good, but does not feel it is complete because the
geochemical analysis is lacking;
(2) he is uncertain if all of the hazards have been adequately addressed and
(3) he is uncertain how the plant will respond to a 6 to 7 magnitude earthquake.
Hawaii County Central Fire Department
H. Onouye - Assistant Fire Chief
R. Enriques - Hazmat Team
H. Silva - Hazmat Team
S.Ozaki- Hazmat Team
J. Gushiken - Hazmat Team
The ERP review team met with Harry Onouye, Assistant Fire Chief, and four members of
the newly formed HAZMAT team on August 7,1996.
The HAZMAT team has been trained in the response to chemical accidents including spills
and releases of hazardous substances. At the time of the meeting, the HAZMAT team was
not yet fully equipped but level A protection equipment was on order. They did have level
B.
The assistant chief indicated he would like to see joint exercises with the Pahoa station and
the HAZMAT team. He would also like to have portable HiS monitors.
In response to a question about a chemical release within the fence line of the PGV facility
Mr. Onouye indicated that the HAZMAT team would stop at the gate to PGV and provide
assistance as requested. The Team is not trained to enter the facility. He will not send his
people into an unknown. One HAZMAT team member voiced concern that PGV may be
acting guardedly when assessing an incident and may not act expeditiously.
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State of Hawaii Department of Labor & Industrial Relations Hawaii
Occupational Safety & Health Division
Notes were not taken
-------
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State of Hawaii Civil Defense
Frank Fronczkowski, Civil Defence Planner
Lines of authority: Governor, Director of Civil Defense (appointed), Deputy Director
of Civil Defense (also island mayor, elected), Civil Defense Administrator.
A siren system is in place, primarily to warn inhabitants of tsunamis. County plans
are drafted by the state in conjunction with the individual counties. The county must
ask the state for assistance. The state supports civil defense training.
-------
Hawaii County Civil Defense
Briefing with Hawaii County Civil Defense Administrator, Harry Kim.
There is a statutory requirement for the mayor and board to review the ERPs and
understand their responsibility.
A volcano located 20 miles southeast of Hawaii has been experiencing increased
seismic activity (from 2-3 magnitude to 3-4 magnitude).
Harry's perception of public's concerns:
1. concerned that PGV be monitored.
2. concerned over structural integrity of well casing during blowouts.
3 concerned that all hazards are identified.
4 concerned that they be notified of evacuation when hazard poses a nsk.
5*. does not trust the county and state. The public feels that local government failed
them during the blowout.
Harry did not approve the ERP, the mayor did. Harry did not feel it was possible to
adequately address all of the hazards associated with PGV without a complete
analysis of the geothermal streams.
The sirens on the island are currently sounded all at once. His goal is to enable the
operation of each of the 64 sirens on the island separately. Harry responded
favorably to Randy's suggestion for a siren at PGV, but said that it should be
equipped with a speaker, and PGV could not activate it.
It is notable that Harry claims there is no backup for him at this time.
Harry's perception of the Emergency Response Plan:
1. He believes it is generally good, but does not feel it is complete because the
geochemical analysis is lacking.
2 He is uncertain if all of the hazards have been adequately addressed.
3 He is uncertain how the plant will respond to a 6 to 7 magnitude earthquake.
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Hawaii County Central Fire Department
H. Onouye - Assistant Fire Chief
R. Enriques - Hazmal Team
H.Silva-HazmatTeam
S. Ozaki- HazmatTeam
J. Gushiken - Hazmat Team
The ERP review team met with Harry Onouye, Assistant Fire Chief, and four
members of the newly formed HAZMAT team on August 7,1996.
The HAZMAT team has been trained in the response to chemical accidents
including spills and releases of hazardous substances. At the time of the meeting,
the HAZMAT team was not yet fully equipped but level A protection equipment
was on order. They did have level B.
The assistant chief indicated he would like to see joint exercises with the Pahoa
station and the HAZMAT team. He would also like to have portable H2S
monitors.
In response to a question about a chemical release within the fence line of the
PGV facility Mr. Onouye indicated that the HAZMAT team would stop at the .
gate to PGV and provide assistance as requested. The Team is not trained to enter
the facility. He will not send his people into an unknown. One HAZMAT team
member voiced concern that PGV may be acting guardedly when assessing an
incident and may not act expeditiously.
The Fire Department would want to have joint exercises with the PGV facility to
test the emergency response plan. The benefit of such exercises is recognized,
however, emergency response exercises have not yet been scheduled. About two
years ago a hydrogen sulfide awareness class was given on site by PGV to the
Hawaii County Fire Department
The Fire Department has access to Blackhawk helicopters for emergency
response. The mobilization time of 2-1/2 hour is required to pull a team together
in Hilo and get down to Pahoa. One team member claimed that it would take
approximately 2 hours to evacuate (by helicopter) individuals trapped by a
release.
The PGV Emergency Response Plan, Section 4 Response Facilities, Table 4-1
Off-site Emergency Facility Capabilities needs to be revised to include the
HAZMAT capability now that there is a hazmat team.
The Fire Department reported that a call of 911 from Puna would go to Hawaii
County's Central police department in Hilo.
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County of Hawaii Meeting on August 6,1996 in Hilo
Steven Todd - State Department of Business, Economic Development, and
Tourism. (Hawaii Island Community Development Specialist)
Erik Tanaka - Department of Land and Natural Resources
Virginia Goldstein - County Planning Department •
Jay Sesan - Safety Coordinator, Hawaii County Division of Industrial Safety
Regarding PGV, so far complaints haven't been seen as violations. As a
condition of permit, PGV informs county when they receive calls about HaS
smells.
It was reported that there are natural emissions at the PGV site coining out that
are not H2S.
Other complaints include noise and lights from the PGV facility. Shielding has
been installed by PGV as noise barrier. Noise problems arc not a part of permit
corrections.
The public was involved and concerned during the permit phase. No background
data was ever taken prior to development. They used mediation to develop permit
conditions. In retrospect, they could have gone with a contested case. It would have
presented the technical issues.
No modifications have been made to the county permit. However, after the '92.
blowout, DOH made a permit modification and reporting measurements were
changed from ppm (parts per million) to ppb (parts per billion).
Part of PGV royalties go to Hawaii County and State of Hawaii affairs.
PGV pays royalties to the state. The royalty money is set aside to relocate people
within one mile of PGV. One claim has been filed for relocation. Only 18 of 33
qualified residents indicated interest in being re-located.
Just gone through a hearing on rules permit for re-location. Only 4 or 5 persons
attended, mostly Realtors.
The PGV plant is located on the most active volcanic rift hi the world.
It was reported that out of the approximately 22 members currently on the Hawaii
County Local Emergency Planning Committee, three were from the media, seven
members were general representatives of the community at-large, and one member
was the general manager of a chemical and pesticide distributing company. There
-were currently no representatives of the petroleum storage or geothermal industry.
-------
Keeau Police Department
Briefing was held with Police Officer Thomas Lonokapu, on August 8,1996.
PGV incident call is referred to County Civil Defense. A police officer would go
to PGV area to check for H2S smell.
Evacuation could become a problem of manpower. Only seven officers are on
duty. No evacuations have been done in the PGV area. The police has only gone
down to secure the area.
It would be good to have local siren warning system. An incorporated area like
Leilani Estates would take several hours to announce by PAs.
PGV has an on site siren, however the range is not known.
Keeau has not had to respond to a community call since the last PGV protest on
February 8,1993.
Officer Lonokapu checked records and no recent reports of HaS were found.
There has been no formal ICS training for police officers. There have been no
exercises, and no drills. There were only actual response to incidents.
Keeau Police Department refers calls to the County Civil Defense to make a
determination of action. People may be calling the County Civil Defense directly
to expedite the system.
Keeau Police Department should have a copy of the PGV Emergency Response
Plan in the station. Familiarity with the plan would help officers in an emergency.
-------
Pahoa Fire Department Substation on August 8,1996
Fire Department personnel has attended a County Civil Defense meeting to
review the PGV Emergency Response Plan.
Some but not all fire department personnel know about PGV emergency
evacuation/notification procedures.
Fire Department personnel has done sight familiarization tours with PGV.
4 U^ ***** *xyy*"» •• • •^••-- * •
resources than Pahoa Fire Department
Pahoa Fire Department personnel would only go on site by advise of the PGV
management
The Pahoa and Keeau Fire Departments, each has six persons on duty per shift. It
is estimated that 15-20 people would be involved in a response.
Among the numerous training courses received by the Pahoa Fire Department are
basic awareness training for pentane and H2S at facilities.
Prior to a drill, the emergency response plans should be reviewed for
coordination amongst the plans. The drill would include Hawaii County Civil
Defense, Fire Department, Police Department, and PGV.
September 1996 was the mandate for elevating the hazmat response team from
the educational phase to the implementation phase. The team needs exercises so
it can move from being "book-smart" to being "road-smart". (There are two
hazmat teams for the Big Island - one in Hilo and one in Kona.
The hazmat response team recently received $350,000 from Hawaii County for
hazmat response equipment and training.
Pahoa Fire Department has emergency phone numbers to contact PGV facility
but no radio contact.
In an emergency the Kapoho Road 137 would be provide an ideal entry to the
PGV facility. Leilani Estates Road could be used as an alternate depending on the
wind direction.
Pahoa Fire Department has medical support in addition to a second unit out of
Keeau. The closest hospital is in Hilo.
Pahoa Fire Department expressed the need for a copy of the current edition of the
PGV Emergency Response Plan. PGV management reported that it relies on the
Hawaii County Planning Department to disseminate plans (such as to the public
libraries in Pahoa and Hilo).
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APPENDIX B
Visit to the Puna Geothermal Venture Facility - Field Notes
-------
VISIT TO THE PUNA GEOTHERMAL VENTURE FACILITY,
FIELD NOTES
The following personnel were present on site at some time during the site visit:
Jack Dean Vice President & General Manager, PGV
Darrcll Stoval Site Manager, PGV
Darren Hunt Environmental & Safety Coordinator, PGV
MikeKaleikini Operations Manager, PGV
KentMcCue Plant Engineer, PGV
Barry Mizuno Financial Manager, PGV
Bruce Davis Ass. Gen. Counsel, Constellation Holdings
Peggy Stover-Catha EH&S Manager, Constellation Holdings
Visit August 7,1996
The site was visited at 1:00 PM by the review team. Present from PGV were
Jack Dean, Peggy Stover-Casa, Bruce Davis, Darrel Stoval, and Darren Hunt.
Darren provided a brief safety presentation prior to entering the plant for a tour as
follows:
1. A plant siren (air raid siren sound) means to report to the shop
building.
2. The major hazards are steam (1000 psi and 600 *F), HiS in steam,
n-pentane, caustic, liquid Nz, and power up to 69 kV.
3. The plant early monitoring/detection system includes36 fixed HzS detectors
set at 10 ppb in the plant and 5 ppb at the fence line.
4. There are UV/IR flame detectors and combustible gas monitors.
5. Darren claimed that they work with the fire department
6. The facility includes a unique "Relase Protection Feature" ESRF
(Emergency Steam Release Facility). The ESRF removes non-condensible
gases from the steam in the event steam would be relased to the
atmosphere.
A driving tour was provided to the team. The following general information was
obtained:
1. The plant is controlled by a GJL Series 6 PLC. There are redundant CPUs
with a UPS backup.
2. One Onnat Energy Conversion (DEC) Unit can make the plant self-
sufficient on power.
3. There is an Edwards vapor recovery unit used to capture non-condensable
from the pentane system.
4. The fire water pump is diesel driven and is tested periodically.
5. Fifty percent caustic is diluted on site for use in the ESRF
6. Production wells have 4 casing strings.
7. They have a corrosion monitoring program.
8. Plant has four groups of three (3) operators to cover the three shifts
supervised by the operations manager. Maintenance has three (3)
-------
mechanics and two (2) Instrument and Electrical Technicians, supervised
by a maintenance manager. There is also one Plant Engineer, an
Environmental and Safety Coordinator, and the Site Manager.
Visit August 8,1996
Theplantwasvisitedat9:30AMbyMarkZusyandAkeJacobson. Theother
team members were visiting the police and fire departments in Pahoa and Keeau.
Bruce Davis and Peggy Stover-Casa reviewed the available emergency response
documents. These documents are the Emergency Response Plan, Version 6.3, dated
February 1,1996; HAZWOPER/EMERGENCY RESPONSE, Guidelines and
Training Program, Revised February 23,1996; and the Emergency Action Plan and
Notification Guidelines, revised February 23,1996.
A statement was made by PGV personnel that the Emergency Response Plan did
not cover emergencies that did not go outside the fence line.
A walking tour was conducted in the afternoon with all members of the team.
The system is a binary Rankine cycle using normal pentane in the organic turbine
loop. Other notes were made as follows:
1. System corrosion is a major concern since the steam contains HzS.
Corrosion coupons are used, ultrasonic thickness is routinely measured and
conosometers provide real time corrosion indication. Piping on the steam
side is X-H carbon steel; on the non-condensable gas side, it is stainless
2. A portable caustic skid is used for pipeline neutralization. It is stored at the
well site. . _,
3. The areas of the Onnat Energy Converter systems and associated pentane
systems are classified electrically hazardous (likely ID2). There is one
UV/IR flame detector and one combustible gas sensor for each of 10 OEC
units.
4. The Pentane storage tanks have redundant UV/IR flame detectors that
activate a hard-piped deluge system.
5. There is a 500,000 gallon fire water storage tank.
6. Fugitive measurements are done on the pentane system to verify system
integrity.
7. Turbine seals and steam line vents are sent to Sulfa Treat vessels. The
vessels are operated in series and are sampled manually and automatically
to verify proper operation. •
8. An Emergency Steam Release Facility (ESRF) provides emergency outlet
for steam. Caustic is injected into a pipe upstream of the Rock Mufflers to
abate the HaS.
Visit August 9,1996
At 9:30 AM, the team generally reviewed plant operations and maintenance
programs. First, general safety information was reviewed by Darren Hunt as
follows:
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General Safety Information:
1. Weekly safety meetings are held (tailgate meetings).
2. They have a STOP program for supervisors and employees.
3. They conduct practice drills with Self Contained Breathing Apparatus,
four times per year.
4. Regarding contractors, PGV:
- Reviews their safety records (OSHA 200 log).
- Approves all chemicals to be brought on site.
- Reviews the EAP.
- Reviews the site hazards.
- Issues safe work and hot work permits daily.
5. Regarding line breaking:
- They evacuate to the Sulfatreat Units.
- The lines are neutralized with portable abatement skids.
6. Instrument and Electrical Technicians are on call to respond to
problems on site.
7. Work orders and safe work permits involve both the craft and a plant
operator. The operator and craft must also close out the work order.
8. They have a team to investigate incidents. This same team also reviews
Process Safety Management's, Management of Change items.
9. Employees are apprised of all Process Safety Management activity
through weekly safety meetings and the monthly posting of such
information.
Maintenance
Plant maintenance was reviewed with Kent McCue. The maintenance manager,
John Gerbitz. was not in the plant during this trip. PGV uses the Mainsaver
Maintenance program. The following information was provided about
Mainsaven
1. It is work order driven.
2. Preventive maintenance (PM) activities are scheduled in the program.
The program automatically generates work orders for these items.
PMs are based upon vendor recommendation or upon plant experience.
3. Corrective maintenance is also logged through this system.
4. The program prints an exception report weekly to flag incomplete
work orders.
5. The program is used to track parts inventory.
6. Work orders are generated by the program and include any simple
maintenance procedures.
The following maintenance and inspection was discussed:
1. Vibration analysis is conducted on turbines, generators and large pumps.
Radian is contracted to conduct these analyses monthly and provide results
and recommendations within 48 hours of inspection.
2. Corrosion control and monitoring was discussed. An outline of the
corrosion control and monitoring program was provided. In general,
ultrasonic thickness testing is done on piping, pressure vessels and
wellheads; boroscope inspections are conducted on the turbines annually;
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corrosion coupons are monitored in steam and reinjection condensate lines.
3. Ultrasonic thickness testing is done in-house. Records of profile areas are
noted on isometric drawings.
4. The following activities are contracted:
-Welding
- Application of complicated coating systems
- Corrosion monitoring
• Drilling and Workovers
-Well logging
Training for mechanical and instrument & electrical (I&E) technicians was
reviewed by PGV staff. Under the maintenance manager, there are maintenance
mechanics, I&E technicians, and a well field technician. All receive initial
qualification training which includes an overview of the hazards of the process.
Additional training is specific to the discipline and is outlined as follows:
Instrument and Electrical Technicians I and H: Training is documented on sign
off sheets and testing is required. Training records were seen, dated March,
1996.
Mechanic I, H and HI: Training is documented on sign off sheets and testing is
required. Additionally, ORMAT personnel were on site for two weeks and
trained three mechanics. Training records were seen, dated March, 1996.
Well Field Technician: He was also responsible for establishing well PM
activity.
It was also noted that cross-training is encouraged between the disciplines.
Operations:
A review of operations and training was provided by Mike Kaleikini. Each shift
is staffed with three operators; a lead operator (who is in charge of the shift), a
plant operator, and a control operator. The review team was not granted access to
the operations procedures, but from a review of the operating procedure table of
contents, it appears as though the procedures generally cover topics essential to
the safe operations of the facility. Startup, shutdown, handling process
deviations, emergency procedures and normal operating procedures are covered.
Training was also discussed. The review team did not review training records.
Operators are provided progressive training, starting with introductory training.
The operator then progresses through three levels, each requiring a written
exam to demonstrate proficiency: Plant Operator Trainee, Plant Operator, and
Control Operator (board operator). PGV is aware of the PSM requirement to
conduct refresher training every three years. Mike Kaleikini and the lead
operators conduct refresher training every year on the whole plant
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Other Information
The perimeter H2S analyzers are not on backup power or an unintenuptable
power supply (UPS). The following is backed up by emergency power
generation:
- Caustic pumps (for ESRF)
- NCG compressor
. Ground water pumps??
-Condensate pumps
- OEC auxiliary systems
•Fin fan coolers
- Any sensors powered by UPS system
• Air compressor
Process and Environmental Monitoring
HaS Monitoring by PGV
Monitoring stations are located within and on the perimeter of the plant
(primarily for H2S only). Backup power supplies are not included in the current
system; if power goes down, monitors go off line. Portable (handheld) HzS
sensors are used in this event according to employees.
There are a number of H2S point source monitors throughout the PGV facility.
The alarm concentration settings on these monitors are higher and designed to
alert the operators when there is a potential problem or leak of HaS. The HzS
monitors are located approximately throughout the facility where there could be
leaks of HzS. The operators know how to respond to an alarm from one of these
point source monitors to mitigate the leak, respond to the leak and notifying Civil
V^. _ f .
Defense.
HzS Monitoring by the Public.
There are three IfcS monitors in the community placed there by the Hawaii
Department of Health. The data from these monitors are given to the community.
Public Safety and Information
Alert and Notification Procedures
PGV recognizes that HzS is a key area of concern for geothermal energy
development in the County of Hawaii. As a result the PGV ERP focuses
predominantly on H2S. PGV indicates that the total HaS "inventory", frw
L__ j.._*:~_ n..1lk.«^ »« inijwrinn moll hoart is l«es than 400 IbS at a 30 M\
• yww ff** ^™» •
PGV faculty.
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Employees indicated that notifications were made only as part of Geothermal
Resource PeimiL No dissemination of information was made by the plant to
community or county.
- Does PGV work with LEPC in Hawaii County? No.
-Does PGV train or conduct exercises with Pahoa Fire, Keeau Police,
Hawaii County Civil Defense? No.
Confusion at PGV/community interface seems evident by all parties.
We recommend that PGV work with The County of Hawaii Civil Defense,
Pahoa Fiie. Keeau Police, the LEPC and the local community in developing
appropriate alerting, notification and emergency response. This group could work
in developing appropriate alerting, notification and emergency response. This
group could work in developing the following:
• Determine the different levels needed;
• What kind of notifications should be done for different levels of incidents;
• Determine the different types and ways to alert and notify the community
when there is an accidental release of a hazardous material and what means
should be used for each level of incidents;
• Determine what hazardous materials pose the greatest threat to the
community; and
• Work together in educating the community how to "shelter-in-place".
Exit Briefing Meeting
At the exit briefing meeting EPA personnel and each of the independent reviewers
took turns offering perspectives on their visit Ideas were also exchanged regarding
recommended improvements for the observed deficiencies. Final inquiries were
made for lingering or unanswered questions of the reviewers.
A major hindrance for this process was the Confidential Business Information claims
by PGV and the inability to access several P&I diagrams, reference documents and
(initially) the latest version of the PGV response Plan itself. Facility managers and
key personnel were courteous and afforded the team then1 time and attention. After
some legal discussions between EPA Region IX and PGV counsels, certain
documents were determined (by PGV) to be off limits to the independent review
team. Thus, external reviewers were unable to conduct a thorough assessment
PGV employees were overall very sharp and dedicated. They did an excellent job of
explaining both technology and procedure within their respective areas of
responsibilities. Their attitudes and respect for safety seemed genuine - a likely
result of both good policy and training. PGV has invested in a level of sophisticated
technology which provides employees with detailed and instantaneous information
on which to base their response behavior. •
By most facility standards PGV is clean and well rn*'tnti"n*A This fact is far from
the public perception due in part to 1. lack or current information and 2. past history
at the site. While industrial technology will never *i««iiiiata errors, accidents, or
' emergencies, these must be addressed, eliminated and, rn'nifi"™d if at all possible.
At least one significant leak even occurred during the development of this report
However, PGV seems to be making a conscientious effort to address accident
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prevention and mitigation as is evidenced in all three areas of: 1. Employee attitude
and training, 2. advanced technology for monitoring, abatement and communication,
and 3. planning and corporate policy.
While these issues were in evidence during the review, PGV is not making a
conscientious effort to communicate this information to the surrounding public. To
some extent, PGV seems to be the victim of past investors and managers of the site
but has not communicated the "now philosophy", ownership or management policy
to the outside.
Management at PGV listened patiently to the reviewers critique with few exceptions.
Communication is the major shortcoming identified by the review. Reviewers were
made aware of the past history of the site, legal challenges, the "unique island culture"
and the desire by some local residents to live in complete isolation or at least without
dependence on modem conveniences (utilities, infrastructure, etc.). While these
issues may be considerable obstacles in Hawaii County, lack of effort does not abate
the continuing problems. Several outreach concepts and strategies were shared with
management.
This lack of communication was evidenced in numerous meetings with residents,
agencies and public officials. Private citizens have many unfounded fears and
allegations about PGV in the information and trust vacuum which currently exists.
Citizens have no mechanism to sort out rumor, hearsay and fact. Responders don't
understand PGVs response procedures and do not conduct joint exercises. PGV
does not participate in local emergency planning, community forums or other
functions which could serve as a conduit for factual communication or collateral
response. Public trust is difficult to achieve and easily lost. Unfortunately, it seems,
no evidence of trust-building has even begun in Hawaii County.
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APPENDIX C
PGV Emergency Response Plan, Version 6.3, Table of Contents
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EMERGENCY RESPONSE PLAN
aamtam
Version 6.3
January 30, 1996
Geothermal Resource Permit: GRP 87-2
MK: 1-4-01: por. 2,3, por. 19 & 58
Puna, Hawaii
Island of Hawaii
Puna District
Puna Geothermal Venture
P.O. Box 30
Pahoa, Hawaii 96776
Ti\ADMINMANUALS\ERPTOC.WPD
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TABLE OF CONTENTS
1 INTRODUCTION 3
1.1 Objective 3
13 Scope 3
2 REGULATORY AUTHORITY AND DEFINITIONS g
2.1 Regulatory Authority g
2.2 Definitions ••»••••••••.«••••.••••.«•••«.................... o
3 NOTEFICATIONANDCHAIN.OF-COMMAND 11
3.1. Notification Lists 11
3.2 PGV Emergency Response Organization ../ 15
33 Notification to Public 19
33.1 Public Notification During Nuisance/Disturbance Situations .... 19
4 RESPONSE FACILITIES 22
4.1 Emergency Facilities Available Off-Site 22
43 On-Site Safety Facilities 22
43 On-Site Meeting Points 22
5 PGV EVACUATION PLAN 30
5.1 Evacuation of Persons On-dte 30
53 Evacuation of Nearby Residents 33
53 Removal of Equipment 33
6 PGV PERSONNEL TRAINING 35
6.1 Drilling 35
6.1.1 H,S Safety Training 35
6.13 H,S Emergency Response Drills 36
6.13 Blowout Prevention Training ..36
63 Blowout Emergency Response Drill (Drilling Operations Only) 37
63 Power Plant Construction 37
6.4 Power Plant Operation 37
7 PGV EMERGENCY DRILL 39
8 HAZARD ANALYSIS AND PGV RESPONSE PROCEDURES TO POTENTIAL
EMERGENCY SITUATIONS: -. 40
8.1 Natural Hazards ; 40
8.1.1 Volcanic Activity < 41
8.13 Magma Intrusion 41
8.13 Earthquake ;.. 43
8.1.4 Hurricane 44
8.13 Lightning •>.••...••«.................«................44
8.1.6 Brush Fire ...45
83 Upsets 46
83.1 Geothermal Steam and Fluid Releases* 51
833 Fire Hazard 59
833 Noise Hazard 61
83.4 Spills and Leaks , .........63.
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TABLES
Table 1-1 Index of Grp Condition #26 Requirement* In the Emergency Response
' Flan .« •• ;?
Table 3-1 Emergency Notification Contact list 12
Table 3-2 Puna Geotherxnal Operations Staff Responsibilities During Emergency
Situations 15
Table 3-3 Response to Public Request For Information or Complaints 21
Table 4-1 Off-site Emergency Facilty Capabilities 26
Table 4-2 Oit-slte Emergency And Safety Equipment ..27
Table 4-3. On-site Hydrogen Sulfide Detection Equipment 28
Table 4-4 On-site Pentane Detection Equipment 29
Table 5-1 Equipment Removal Activities And Procedures 34
Table 8-1 Site Releases Under Routine And Upset Conditions 47
Table 8-2. Summary of Modelled H,* Emissions 54
Figures
Figure 1.1 Site Location Map 6
Figure 1-2 Site Vicinity Map • J
Figure 4-1 Off Site Emergency Facilities 23
Figure 4-3a Wellpad Potential Hazard Areas And Safety Equipment Locations
(Typical When Drilling Only) 2*
Figure 4-3b Well Pad Potential Hazard Areas fit Safety Equipment
Locations for Operations 25
Figure 5-1 Meeting Points And Primary Evacuation Routes 32
Figure 8-1 Worst Case "Type 1" Hydrogen Sulfide Scenario 10
Is Located in Volume U S6
Figure 8-2. Worst Case "Type 2" Hydrogen Sulfide Scenario
Is Located in Volume U S7
Figure 8-3 Hazard Limits of a Fire or Leak Involving Pentane
Tanks at the PGV Power Plant Is Located in Volume H 60
Figure 8-4. Predicted Noise Level Contours For a Well Blowout or Pipeline Rupture
Figure 8-4 Is Located in Volume II 62
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APPENDIX D
HAZWOPER/Emergency Response Guidelines and Training Program
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HAZWOPER/EMERGENCY RESPONSE
GUIDELINES AND TRAINING PROGRAM
PUNA
GEOTHERMAL VENTURE
HAWAII
REVISED FEBURARY 23, 1996
T:\ADMDf\SAFOT\HAZWOFEILWPD
February 23.1996
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PUNA GEOTHERMAL VENTURE
HAZWOPER/EMERGENCY RESPONSE
GUIDELINES AND TRAINING PROGRAM
Table of Contents
1. SCOPE AND PURPOSE .......................................... 1
2. DEFINITIONS ................................................ 1
3. RESPONSIBILITIES ................................ • • • • ........ \
3.1 ORGANIZATION STRUCTURE (Emergency Response Team) ....... 4
4. TRAINING GENERAL .......................................... S
4.0.1 First Responder Awareness Level ...................... 5
4.0.2 Hazardous Materials Technician ....................... *
4.03 Hazardous Materials Specialist ........................ 6
4.0.4 On-scene Incident Commander ........................ 7
4.1 TRAINING PROGRAM ................................. 7
4 .2 TRAINING REQUIREMENTS ............................ *
5. SAFETY & HEALTH PROGRAM
6. PRE-EMERGENCY PLANNING ................................. •" *
6.1 POTENTIAL HAZARDOUS MATERIAL
RELEASE EMERGENCY SITUATIONS ...................... 9
6.1.1 Hazardous Materials ............. •...•••••••••9
6.1.2 Waste Management ........................... '
6.13 lire or Explosion ............................ 10
6.1.4 Other ................................... 10
62 POTENTIAL SPILL VOLUMES AND RATES ................. 10
63 EMERGENCY RECOGNITION AND PREVENTION ............ 10
6.4 RESPONSE PROCEDURES ............................. 11
T:\ADMIN\SAFETY\HAZWOPER.WPD February 23,1996
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7. MEDICAL SURVEILLANCE •' U
8. EVACUATION ROUTES AND PROCEDURES 12
8.1 SAFE DISTANCES AND REFUGE 13
9. COMMUNICATIONS D
9.1 SITE SECURITY AND CONTROL 14
10. DECONTAMINATION PROCEDURE 14
11. PJJE AND EMERGENCY EQUIPMENT u
12. CRITIQUE OFRESPONSE AND FOLLOW-UP 15
13. PROGRAMREVIEW 16
APPENDIX 1 JJ
DEFINITIONS 18
APPENDIX 2 5
TRAINING REQUIREMENTS AND RECORD 22
TRAINING REQUIREMENTS AND RECORD 23
TRAINING REQUIREMENTS AND RECORD 24
TRAINING REQUIREMENTS AND RECORD 25
APPENDDI 3 2fi
SITE PLAN LOCATION AND APPROXIMATE QUANTITY
OF HAZARDOUS MATERIALS 26
APPENDDI 4 27
MATERIAL SAFETY DATA SHEETS (MSDSs) ..27
APPENDIX 5 28
POTENTIAL RELEASE SCENARIOS 28
APPENDIX 6 •• 34
EVACUATION ROUTES 34
APPENDIX? ....35
CALL LISTS 35
APPENDDI 8 38
DECONTAMINATION PROCEDURE 38
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ND EMERGENCY RESPONSE EQUIPMENT
CTOTCRmQUEF^^
45
«•
49
50
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PUNA GEOTHERMAL VENTURE
HAZWOPER/EMERGENCY RESPONSE
3UIDELINES AND TRAINING PROGRA1
1. SCOPE AND PURPOSE
PUNA GEOTHERMAL VENTURE has developed this plan to meet the requirements
according to the applicable guidelines as set forth in CFR 1910.120 (q) sections 1 through
H and Hawaii Regulation Statute.
This plan has been developed to meet the requirements of employers to protect the
employees who respond to emergency releases of, or substantial threats of releases of,
hazardous substances and to prevent potential environmental damage.
The plan applies to an employees at the facfliry and establishes employee requirements and
restrictions. Outside contractors who bring hazardous substances on site will be covered
by their own response plan.
This plan covers only those responses by employees to "emergency" releases or threats of
such where the nature of the incident or 'emergency" has a potential risk for employee
exposure or a safety hazard such as a fire or explosion potential. Any response to
"incidental releases" where no potential safety or health hazard exists, is not considered
an "emergency response.
2. DEFINITIONS
See Appendix 1.
T:\ADMIN\SAFETY\HAZWOPER.WPD 1 February 23,1996
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PuMGeathemd Venture
3. RESPONSIBILITIES
Should an emergency situation occur, specific management personnel will assume
ZJ^SXi emergency response scenario. Tnese key positrons and bas*
responsibilities are as Mows:
Incident Commander
Manages the overall Emergency Response
Responsible for safety of visitors, contractors, employees
Minimize loss of property & property damage
Determines when an emergency is under control or when to withdraw
Performs administrative and organizing duties
Communicates internally and externally
Directs security force
Ensures training is adequate and current
Hazardous Materials Specialist
• Determines level of initial response required
• Directs appropriate level of notification
. Supervises direct action to mitigate spills or releases of hazardous materials or
substances
• Develops decontamination procedure
Hazardous Material Technician
. Inspect all emergency response equipment on a monthly basis
Safety Officer
• Reports to the Incident Commander
• Responsible for safety of public, contractors, employees
• Responsible for safety of the emergency xesponders
Security
• Perform head counts at gates and knows personnel on-site at all times
• Ground and traffic control
2 February 23,1996
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Media Coordinator
• Functions as company spokesman with media
AH Plant Personnel (First Responder level)
• Anyone who becomes aware that an emergency situation has occurred or might
occur must i""™*fat*iy contact the lead Operator who notifies Incident
Commander and other key personnel of emergency or potential emergency
situations. If you are trained only at the First Rcsponder level, you will not take
any further action unless trained in other levels of response.
T:\ADMIN\SAFETY\BAZWOPEII.WPD 3 February 23,1996
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3.1
ORGANIZATION STRUCTURE (Emergency Response Team)
The function of the Emergency F.-jponse Team (ERT) is to provide for the safe and
orderly containment of a site emergency.
Incident i
Hazardous Materials
Specialists
Hazardous Material
Xechnicians
Darrell Stovall
Darren Hunt
BQ1 Wiebe
Jim Fordham
Steve Wong
Mike Kim
Ron Quesada
KellettPark
Al Beaver
John Boots
Les Doctor
John Tompkins
Lee Zimmerman
DanVesey
Larry Harrison
JoeyFonseca
Rodney Wynn
JohnGerbltz
MikeKaleOdni
^•^^^^^^^^^M^^^^wi
Randall Brady
Bob Cuban
RickDuVoisin
Howard Burdett
Security Coordinator
Richard Dods
Media Coordinator/
Spokesperson
Lynn White
Barry Mizuno
First Responder
Awareness Level
All Personnel
Post Emergency
Responder
Darren Hunt
Outside Contractor!
Environmental Firms
Safety Official
Darren Hunt
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February 23,1996"
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PIHIJ Ceotheimfl Venture
4. TRAINING GENERAL
Training requirements are based on the levd of response **^ ***£;*$
MnJovee. Tie response levels include first responder awareness (lowest levd of
technician, hazardous materials specialist and on-scene
4.0.1 First Responder Awareness Levd
Employees at this levd are individuals who are likdy to witness or discover a hazardous
substance release and who have been trained to initiate an emergency response sequence
by notifying the Lead Operator of the release. THey do not take any action beyond
notifying the Lead Operator of the release. They must be trained to:
Have an understanding of what hazardous materials are, and the risks associated
with them in an incident.
. Have an understanding of the potential outcomes associated with an emergency
created when hazardous materials are present.
• Have the ability to recognize the presence of hazardous materials in an emergency.
• Have the ability to identify the hazardous materials, if possible.
• Have an understanding of the roll of the first responder awareness individual in the
employer's emergency action plan, induding site security and control and the US
DOT'S Emergency Response Guidebook.
• Have the ability to realize the need for additional resources, and to make the
appropriate notifications to the communication center (CSC).
4.0.2 Hazardous Materials Technician
These employees are individuals who respond to releases or potential releases for the
purpose of stopping the release. They assume a more aggressive role than a first responder
at the operations levd in that they will approach the point of release to plug, patch or
otherwise stop the release of a hazardous substance. They must receive at least 24 hours
T:\ADMIN«AFETY«AZWOPER.WPD 5 February 23,1996
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Renonie GuidclinotndTnininePro
Puna Geothemul Vertuic
of training, covering the areas listed above in addition to the following areas:
Know how to implement PGVs emergency action plan.
. Know the classification, identification and verification of known and unknown
materials by using field survey instruments and equipment
Be able to function within an assigned role in the Incident Command System.
. Know how to select 'and use proper specialized chemical personal protective
equipment provided to the hazardous materials technician.
• Understand hazard and risk assessment techniques.
. Be able to perform advanced control, containment and/or confinement operations
within the capabilities of the resources and personal protective equipment available.
. Understand and implement decontamination procedures.
Understand basic chemical and toricological terminology and behavior.
4.03 Hazardous Materials Specialist
These employees are individuals who respond with and provide support to hazardous
materials technicians. Their duties parallel those of the hazardous matenak technician,
however, these duties require a more directed or specific knowledge of the various
substances they may be called upon to contain. The hazardous matenals specialist my
also act as the rite liaison with Federal, state, local and other government authorities
. reeardine site activities if designated by the Incident Commander. These employees must
SSeat least 24 hours of training equal to the technical level, and additionaUy they
must have competency in the following areas:
• Be familiar with the pertinent elements of the County and local ERP.
• Know how to implement the employer's emergency action plan.
Understand classification, identification and verification of known and unknown
riai« by using advanced field survey instruments and equipment.
Know of the State Emergency Response Plan.
6 February 23, 1996
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ithemul'Veimi
Hatwoper/EmCTgeney Roponie CuideEna ind Training Protnm
•• Be able to select and use proper specialized chemical personal protective equipment
provided to the hazardous materials specialist.
• Understand in-depth hazard and risk techniques.
• Be able to perform specialized control, containment and/or confinement operations
within the capabilities of the resources and personal protective equipment available.
• Be able to determine and implement decontamination procedures.
• Have the ability to develop a site safety and control plan.
• Understand chemical, radiological and lexicological terminology and behavior.
4.0.4 On-scene Incident Commander
Incident commanders who will assume control of the incident scene beyond the first
responder awareness level must receive at least 24 hours of training at the first responder
operations level and in addition have competency in the following areas:
• Know and be able to implement the employer's incident command system.
ho™ to implement the ate emergency action plan and Hazwoper/ Emergency
Response guidelines.
• Know and understand the hazards and risks associated with employees working in
chemical protective clothing.
• ' • Be familiar with the pertinent elements of the County and local ERP.
• Know and understand the importance of decontamination procedures.
4.1 TRAINING PROGRAM
Trainers who *""•* any of the training in this section will be done only by qualified
trainers.
AQ employees win receive the training necessary for the first responder awareness level
Employees with more active roles in emergency response will receive the training
necessary to perform t^«r duties. Appendix 2 lists the training sessions and other cnfe"*
T:\ADMIN\SAFETY\HAZWOPER.WPD 7 February 23, 1996
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Pum Geothennil Venture
necessary to qualify for each position. It is also a record of the training provided to each
employee.
4.2 TRAINING REQUIREMENTS
Hrst responder
(awareness) level
HAZMAT technician
HAZMAT specialist
On-the-scene
incident commander
Sufficient training
or proven experience in
specific competencies
Annual refresher
24 hours and
proven experience in
specific competencies
Annual refresher
24 hours and
proven experience in
specific competencies
Annual refresher
24 hours and
additional competencies
5. SAFETY & HEALTH PROGRAM
The PGV Safety Manual contains safety and health procedures and programs applicable
to aU employees.
6. PRE-EMERGENCY PLANNING
Pre-Emergency planning for a release or a threat of a release orasists of the establishment
and nuintaining of engineering controls designed to prevent releases, ininimize releases
or contain the threat of a release. (Additional Pre-Emergency planning includes,
communication, training, and frequent tours to outside emergency responders to maintain
current knowledge of the facility and associated equipment)
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February 23,1996
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(voftenii Vennne Hmroper/Emergencr RCTPOMC GuMeEna ind Ttiinine Propim
6.1 POTENTIAL HAZARDOUS MATERIAL RELEASE EMERGENCY
SITUATIONS
6.L1 Hazardous Materials
Designated response personnel are trained to recognize a potential hazard before it may
become a threat of a ndease through training and preventive measures. Releases may
relate to the following:
Material handling and storage
Bulk chemical transfer
Plant process equipment failure
Fluid handling
Transfer piping
Valves and fittings
The following substances may involve an Emergency Response unless deemed to be levels
that could be incidental releases:
Hydrogen Sulfide
Sodium Hydroxide
N-Pentane
Oxy-11
Millsperse 802
WPD 11-306
Nitrogen
Fuels: diesel fuel or unleaded gasoline
The locations of these materials are marked on the site plan in Appendix 3. This appendix
lists the capacity of the storage containers. Appendix 4 contains the Material Safety Data
Sheets for these materials.
6.L2 Waste Management
Any waste generated by a spill or release that can be gathered or accumulated will be
secured. The Environmental/Safety Coordinator must be notified of the waste generated.
The Environmental/Safety Coordinator will make the appropriate determination of proper
disposal.
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„ t ,„ HMwmer/Emerecncy Reroonie Cu-deline» and TnininB Proetim
Puni Geothennil Venture
6.1 J Fire or Explosion
Tte primary source for a fixe or explosion would be from flammable materials used and
stored at the facility. Other materials stored at the fealty may ignite under certain
conditions including elevated temperatures, exposure to noncompatible material, and
pressure. Fire or explosions associated with these sources are avoided through proper
handling and storage including grounding containers while in storage and when
Unanticipated fires or explosions may result from natural acts such as electrical storms and
wild fires, as well as acts of terrorism, and utility interference.
6.1.4 Other
Additional emergency situations may arise from flooding (natural and man-made),
tornados, hurricanes, earthquakes, volcanos, and facility degradation due to age. Weather-
related conditions which could have an impact on facility operations will be monitored as
necessary by local media sources (See sections 8.0 in the ER.P).
6 .2 POTENTIAL SPILL VOLUMES AND RATES
Where experience indicates a reasonable potential for equipment failure, such as tank
overflow, rupture, or leakage, this plan is required to include a prediction of the direction
and rate of flow, and total quantity of material which could be discharged as a result of
each major type of failure. Appendix 5 presents possible facility release scenarios.
6 J EMERGENCY RECOGNITION AND PREVENTION
PGV has assessed the potential exposure from releases of the substances stored and used
on site. (See Section 6.1 Potential Hazardous Material Mease Emergency Situations
Appendix 5 Potential Release Scenarios.) In addition, PGV has an Emergency Response
Plans (ERP) that includes natural disasters due to volcanic activity, magma intrusion,
earthquakes, brush fires, hurricanes, and lighting.
PGV has made efforts to minimize potential releases. These efforts include plant design
to the applicable standards, secondary containment for tanks, PGV Process Safety
Program, Fixed Fire and Gas detection devices, H2S detection devices, preventive
maintenance programs and procedures, work practices and procedures, and employee
training.
T:\ADMIN\SAFOT\HAZWOPER.WPD 10 February 23, 1996
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IH.n.Geo.hcnnilV^ H.r^/E.ncrpcncv U^m Guideline. »d Tniinine
6.4 RESPONSE PROCEDURES
Response activities begin the moment that an employee becomes aware that there is a
release. The most important consideration in any emergency response is employee safety
Do Not Attempt to Respond if Response Action Cannot be Performed Safely.
7.nn«K
During each response situation involving a hazardous material the Incident Commander
will designate cold. warm, and hot control zones. These zones, established to protect
public and employee exposure to potentially hazardous materials, will be defined as
follows:
Cold Zone: The area containing support functions deemed necessary to control the
incident. Access is restricted to the employees, contractors, and visitors
not directly involved in the response. No contaminants will enter the cold
zone.
Warm Zone: The area where support to the hot zone takes place. Decontamination of
personnel and equipment is also performed in this zone thereby reducing
contaminant access to the cold zone.
Hot Zone: The area immediately surrounding a hazardous material incident which
extends far enough to prevent adverse effects to Personnel outside the zone.
The highest level of personal protection for a given incident will be worn
in the hot zone.
7. MEDICAL SURVEILLANCE
the baseline physical examination for Waymat Team members and Hazardous
Material Specialists, any of these Emergency Response Employees who exhibit signs of
symptoms which may have resulted from exposure to hazardous substances during an
emergency incident at PGV, will be provided (either immediately or subsequently) medical
consultation. If the examining physician determines that follow-up examinations or
consultations axe medically necessary, they will also be provided.
The physician win be provided a copy of OSHA Regulation 1910.120, Hawaii OSHA and
appendices, a description of the employees' duties as they relate to the employee's
exposures, the employees' exposure levels or anticipated exposure levels, a description of
any personal protective equipment, and information from previous medical examinations
T:\ADKON\SAFETY\HAZWDPEILWFD 11 February 23, 1996
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Piini Geotheimil Venture
to the examining physician. A copy of the
provided to the employee and shall contun .data
Dr.Caraett.
EVACUATION ROUTES AND PROCEDURES
or spin the first action will be to call CSC of ndio. If you do
to thTcSC and notify the Lead Operator Personnel wdl be
?n or leak by means of the phntradios tf the "
is other than incidental, the Lead Operator wJl
L If the ea s oter an ,
t siren. (Which sounds like a steady rising-tone siren). This alarm is sounded from
the SsowL The lead operator will then initiate the EAP TTpnn hpanng this
cr..~i ,iarm, the initial area for personnel to report to are as follows:
The Response Team Members will report to the rnnrrnl Unnm which will serve as the
Central Command Post
Maintenance personnel wfll report to the Mninfpmnrp Wnrkshnp where the MainL
Manager will take a head count, or to the Meeting Point 2 if the plant is unsafe.
dminlstratiye staff will report to the A dmln 1 frailer where Plant Engineer or Office
*****«&'
Visitors on-site will proceed to the Miinfpminrp Shnp and check in. Contractors
working in the plant area will proceed to the Maintenance Workshop and wiU check in
with the Maintenance Manager. If the plant is not safe, report to the Second Meeting
Point, Meeting Point 2.
Drilling personnel will report to well pnfl «*tf*T arm and await further instructions
from the Incident Commander. If these are unsafe, they will report to the Maintenance
Shop.
NOTE: Traffic control (Guards) will have radios for communication with the incident
commander. All dreg"8*"* ?*»"*««» checkers will have radios for communication with
the Incident Commander.
H evacuation of aO personnel on she is required, the Incident Commander win notify
all group leaders. See Evacuation Routes. (Appendix 6)
T:VADMIN\SAFETY\HAZWOPER.WPD
12 February 23,1996
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nhenMTVentuie HizwBper/EtneT?ency Response CuideEnet ind Turning Propim
8il SAFE DISTANCES AND REFUGE
When instructed to evacuate the faculty, PGV has set up several routes to evacuate. AH
OOQ emergency response personnel wffl proceed to evacuation route 81. If that evacuation
route is unsafe, then proceed to the evacuation xoute #2. Hie first meeting point for refuge
is located in fiont of Admin. 1. Second area is located down at the saging area. Third and
final is at the intersection of Kapoho/Pohild road. See Appendix 6 for map.
9. COMMUNICATIONS
Timely and efficient communications axe essential to deal with an emergency response
situation. For that reason, the following requirements have been established.
Only the following personnel are permitted to use the telephone lines during an
emergency:
• Incident Commander
• Media Coordinator/spokesperson
• Designated Notification Person (Lead Operator/Plant Engineer)
t Hazardous Material Specialist
Only the following personnel are permitted to use hand held radios during an emergency:
Incident Commander
Hazardous Material Specialist
Evacuation Meeting Area Leaders
Security Coordinator and/or Gate Guards
Others as designated by the Incident
Use of hand held radios:
• Keep message brief and simple
• Communicate using position titles
• Yield to those individuals using the hand held radios who are the most directly
involved in the emergency response activity
X
If radio communications are not clear (Le., radio problems) proceed to CSC.
AH internal communications on hand held radios wfll be on C***""*^ !•
The I *ad Operator must have the base station radio in the "scan" mode to receive all
T:\ADMBTOAFCTY\HAZWOPER.WPD 13 February 23, 1996
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, Emmie Guidelines MidTrminine Prog
channels that could be used.
All hand held radios are recharged daily with backup batteries ready for use.
The Plant siren is tested monthly to assure effective operation.
For off-shift communication to alert key persoimd, the Mowing requirements have been
established:
TUe Lead Operator will initiate the (EAP) by phone calling primary personnel as identified
in the (EAP) If primary personnel cannot be reached First by phone, then dial the
person's pager number and then 911 press the V key. If this fails, begin
notification of designated alternates.
Internal/External call lists. (See Appendix 7)
9.1 SUE SECURITY AND CONTROL
Should an Emergency situation occur, the Incident Commander will notify the Security
Coordinator of the occurrence. The Security Coordinator will then call out additional
security personnel as deemed necessary. Traffic Control on normal workdays will also be
notified of the situation and will be instructed to supply the Incident Commander with a
current list of personnel on rite in the event of an ordered evacuation.
(See appendix 7 for the external call list).
10. DECONTAMINATION PROCEDURE
Decontamination is the systematic removal of hazardous matrrials from structures,
personal protective equipment, and emergency responders. Decontamination of the release
area is dependent on the type of material released and will be assessed by the Incident
Commander.
This facility uses seventeen decOTtamination lines for response personnel and an equivalent
decontamination line for protective equipment which is not disposable. Disposable
equipment used in an emergency incident is collected and managed according to its
potentially hazardous characteristics.
Decontamination lines are staffed by qualified individuals wearing a minimum of (Level
D personal protective equipment).
T:VADMimsAFETY\HAZWopER.wpD 14 February 23,1996
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ithemiil-Ve
Htiwocer/Emergencv Raponie Guideline* and Turning Program
Decontamination of personnel and equipment takes place in the warm zone. Hie
decontamination line begins at the edge of the hot zone and ends at the outer edge of the
warm zone, Responders leaving the cold zone will not be allowed to reenter the warm or
hot zone until they have received clearance by the Incident Commander and have donned
the appropriate personal protective equipment
The M decontamination line consists of seventeen stations. Before any decontamination
activities, plastic sheeting shall be provided as a foundation to prevent migration of
contaminants or rinse waters. Rinse water will be collected for proper disposal.
Appendix 8 contains the decontamination procedures.
11. P.P.E AND EMERGENCY EQUIPMENT
PGV's facility is equipped with a variety of emergency response equipment to handle any
emergency that may occur. (See Appendix 9.)
12. CRITIQUE OF RESPONSE AND FOLLOW-UP
Should an emergency situation occur, the Incident commander will evaluate the completed
Emergency response in writing within 48 hours, and call a special group meeting with the
Emergency Response team. Appendix 10 contains the Incident Critique Form. The
Incident Commander will issue a report to the Plant Manager and Safety Official.
PGV conducts Emergency Response drills every quarter. The Incident Critique Form will
be used to evaluate each drilL
Following the occurrence of a spill of a reportable quantity or any emergency situation
described in this plan, and in compliance with the GRP, ATC, and other County or State
requirements, an incident report will be prepared by the PGV Environmental
Representative and be transmitted to the appropriate individuals and agencies after review
by PGV.
See the Jnterra^ Notification and EJLP for required notifications and documented Incident
reporting.
The Plant Engineer, Environmental Representative and Safety Official shall compile all
HnffMmpqfrffofl and perform a post-event investigation. Appendix 10 contains an Incident
Critique Form and a Release Report Form, immediate performance of this activity will
aid in determining the exact circum stances and cause of the inc*dgnt. Issues to be
T:\ADMIN\SAFETY\HAZWOPEILWPD IS February 23, 1996
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Pimi CcothermtT
13.
determined include:
• Cause of the incident
• Effectiveness of the emergency xesponse procedure
• Need for amendments to the response plan
• Need for additional respondents and training programs
PROGRAM REVIEW
or
simulated release, regulations are revised, op^ns at the feohty
change, and response equipment is updated or additional equipment is purchased
T:\ADKONVSAFETY\HAZWOPER.WPD
16
February 23,1996
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Puni Geothenntl Venture
r Response Guideline* ind Turning Prog
•He dates listed bdow reflect the Plan's review and/or revision dates.
Changes Made to
Plan
Reviewer's Signature
Review/Revision
Date
T:\ADMIN\SAFEnrVHAZWOFER.WFD
17
February 23,1996
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APPENDIX 1
DEFINITIONS
These definitions are taken fiom OSHA Regulation 1910.120.
Buddy System is a system of organizing employees into work groups so that each employee of
is designated to be observed by at least one other employee m the work group.
the buddy system is to provide rapid assistance to employees in the event of an
emergency.
Clean up Operation is an operation where hazardous substances are removed contained
incinerated, neutralized, stabilized, cleared-up, or in any other manner processed or handled with
the ultimate goal of making the site safer for people or the environment
Decontamination is the removal of hazardous substances from employees and their equipment
to the extent necessary to preclude the occurrence of foreseeable adverse health effects.
Emergency Response or Responding to emergencies is a response effort by employees fiom
outside the immediate release area or by other designated responders (Le., mutual aid groups,
local fire departments, etc.) to an occurrence which results, or is likely to result, in an
uncontrolled release of a hazardous substance. Responses to incidental releases of hazardous
substances where the substance can be absorbed, neutralized, or otherwise controlled at the time
of release by employees in the immediate release area, or by maintenance personnel are not
considered emergency responses within the scope of this standard. Responses to releases of
hazardous substances where there is no potential safety or health hazard (Le., fire, explosion, or
chemical exposure) are not considered emergency responses.
Facility is (a) any building, structure, installation, equipment, pipe or pipeline (including any pipe
into a sewer or publicly owned treatment works), well, pit, pond, lagoon, impoundment, ditch,
storage container, motor vehicle, rolling stock, or aircraft, or (b) any site or area where a
hazardous substance has been deposited, stored, disposed of, or placed, or otherwise come to be
but does not include any consumer product in consumer use or any water-borne vessel
Hazardous materials response (HAZMAT) team is an organized group of employees, designated
by the employer, who are expected to perform work to handle and control actual or potential leaks
or spills of hazardous substances requiring possible dose approach to the substance. The team
members perform responses to releases or potential releases of hazardous substances for the
T:\ADMIN\S AFFTYVHAZWOPER.WPD
18 February 23,1996
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r Reiponte Guideline* ind Training Program
ouTDOse of control or stabilization of the incident A HAZMAT team is not a fire brigade nor is
Atypical fire brigade a HAZMAT team. A HAZMAT team, however, may be a separate
component of a fire brigade or fire department.
Hazardous substance is any substance designated or listed under (A) through (D) of this
defirition, exposure to which results or may result in adverse effects on the health or safety of
employees
(A) Any substance defined under section 101(14) of CERCLA;
ffi) Any biologic agent and other disease causing agent which after release into the
environment and upon exposure, ingestion, inhalation, or assimilation into any
person, eilher directly from the environment or indirectly by ingestion through the
food «*•»•", will or may reasonably be anticipated to cause death, disease,
behavioral abnormalities, cancer, genetic mutation, physiological malfunctions
(including a malfunction in reproduction) or physical deformations in such persons
or their offspring;
(Q Any substance listed by the U.S. Department of Transportation as hazardous
under 49 QFR 172.101; and
(D) Hazardous waste as herein defined.
Hazardous waste is-
(A) A waste or combination of wastes as defined in 40 CFR 261.3, (or)
(B) Those substances defined as hazardous wastes in 49 CFR 171.8.
Hazardous waste operation is any operation conducted within the scope of this standard.
Hazardous waste site or site is any facility or location within the scope of thirstandard at which
hazardous waste operation take place.
Health hazard is a chemical, mixture of chemicals or a pathogen for which mere is statistically
significant evidence based on at least one study conducted according to established scientific
that ante or <**?nie health affeets may occur in exposed employees. The term "health
hazard" jndwfcy cherts mat are carcinogens, toxic or highly toxic agents, reproductive toxins,
irritants, corrosives, sensitizers, hepatoxins, nephrotoxins, neurotoxins, agents that act on the
hematopoietic system, and agents which damage the lungs, skin, eyes, or mucous membranes.
T:\ADMIN\SAFETY>HAZWOPER.WPD 19 February 23, 1996
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H also includes stress due to temperature extremes. Further definition of the terms used above can
be found in Appendix 1 to 29 CFR 1910.1200.
or Immediately dangerous to Bl e or health is an atmospheric concentration of my toxic,
cve^ph^Sstance that poses an immediate threat to life or would interfere with
an individual's ability to escape from a dangerous atmosphere.
oncentration of oxygen by volume below which atmosphere supplying
beprovided. It exists in atmospheres where the percentage of oxygen
by volume is less than 19.5 percent oxygen.
Permissible exposure limit is the exposure, inhalation or dermal permissible exposure limit
specified in 29 CFR Part 1910, Subparts G and Z.
Published exposure level is the exposure limits published in 'NIOSH recommendations for
Occupational Health Standards' dated 1986 incorporated by reference, or if none is specified, the
exposure limits published in the standards specified by the American Conference of Governmental
Industrial Hygienists in their publication -Threshold Limit Values and Biological Exposure Indices
' for 1987 - 88" dated 1987 incorporated by reference.
Post emergency response is that portion of an enu^ency respcnise perfomed after the imme^
threat of a release has been stabilized or eliminatedandcleanupof mesitehasbegu^ Ifpost
emergency response is performed by an employer's own employees who were part of die initial
response, it is considered part of the initial response and not post emergency response. However,
if a group of an employer's own employees, separate from the group providing initial response,
performs the clean up operation, then the separate group of employees would be considered
forming post^mergency response and subject to paragraph (q)(ll) CFR Part 1910.120 of this
section.
Qualified person is a person with specific training, knowledge and experience in the area for
which the person has the responsibility and the authority to control.
Site safety and health supervisor or official is the individual located on a hazardous waste site
who is responsible to the employer and has the authority and knowledge necessary to implement
the site safety and health plan and verify compliance with applicable safety and health
requirements.
Small quantity generator is a generator of hazardous wastes who in any calendar month
generates no more than 1,000 kilograms (2,205 pounds) of hazardous waste in that month.
T:\ADMIN\SAFETY\HAZWOPE2LWFD
20 February 23,1996
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KT Reapotue CuMeEne* and Training Program
Uncontrolled hazardous waste site is an area where an accumulation of hazardous waste creates
a threat to thehealm and safety of individuals or the envinmmenl orboth. Some sites ate found
on public lands, such as those created by former mumc^ cc^ w state landfills whereffle^l
waste disposal has taken place. Other sites axe found on private property,
Examples of such sates
o
^^^ but are not limited to, surfcce impoundments, landfills, dumps, and tank or drum farms.
Normal operations at TSD rites are not covered by this definition.
T:VADKflN\SAEETY\HAZwopER.wro 21 . February 23,1996
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Puiu CeethennilVertiire.
APPENDIX 2
TRAINING REQUIREMENTS AND RECORD
=— — — — — •
First Responder Awareness Level
Training Session or Other Criteria
Instructon
Date
Dumber of Hours
Applicable to This
Level of Hazwoper
T:\ADMIN\SAFETY\HAZWOPER.WD
22
February 23,1996
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PUBJ Geothemul Venture
; GuideEng and Training Proenm
APPENDIX 2
TRAINING REQUIREMENTS AND RECORD
.
HAZMAT Technician
Instructor;
Training Session or Other Criteria
Date Completed
Number of
Hours
Applicable to
This Level of
Hazwoper
Trainii
T:\ADMIN\SAFETY\HAZWOPER.WPD
23
February 23,1996
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PiinaGeothetnulVe
me Cuidelinei and Training Proj
APPENDIX 2
TRAINING REQUIREMENTS AND RECORD
^Bass-as^m
HAZMAT Specialist
Instructor
Training Session or Other Criteria
Date Completed
Number of
Hours
Applicable to
This Level of
Hazwoper
T:\ADNON\SAFETY\HAZWOPeiLWPD
24
February 23,1996
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Puni Ceotheimil Venture
H«gwoner/EmeTteney Reroonie Cuidelina ind Training Prog
APPENDIX 2
TRAINING REQUIREMENTS AND RECORD
On-Scene Incident Commander
Employee's Name: Instructor
Training Session or Other Criteria
.
Date Completed
Number of
Hours
Applicable to
This Level of
Hazwoper
======£=
T:\ADMimSAFETYUIAZWOFEILWFD
25
February 23,1996
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HtTHOferfBioerseaey Rerenue GuMeBna tnd Trainin
APPENDIX 3
SUE FLAN.
LOCATION AND APPROXIMATE QUANTITY
OF
HAZARDOUS MATERIALS
Februaiy23,1996
-------
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h Power Plant Area
O«* !«•». IUWM
00/K7/95 | f
R. IVjtly
-------
PuniGeethetnul Venture Hizwoper/Emeotcncy RMPOMC GuideEna ind Turning Precim
APPENDIX 4
MATERIAL SAEE1V DATA SHEETS (MSDSs)
Table of Contents
Hydrogen Sulfide
Sodium Hydroxide
N-Pentane
Oxy-11
Millsperse 802
WPD 11-306
Nitrogen
Fuels: diesel fuel or unleaded gasoline
T:\ADMiN\SAFETY\HAZwopER.wro 27 February 23,1996
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RS 23 Y\*r\jiTl*GJflf* L& Responsible Care.*
^^yClf Wf IwFaff® ^rAPubllcCommitment
MATERIAL SAFETY DATA SHEET
__^«_—•^•••••^•i
MSDS NUMBER : M77B7
MSDS DATE :. 04-12-93 I APR 2 7 1993
PRODUCT NAME : 80% CAUSTIC SODA-MEMBRANE
24 HOUR EMERGENCY PHONE: 1-80G-733-366S OR 716-278-7021
I. PRODUCT IDENTIFICATION '
HMIS HA2ARP RATINGS
HEALTH HAZARD 3 FIR* HAZARD 0 REACTIVITY 2
Based on tn« National Paint & Coatings Association HMIS rating system.
SARA/TITLE Ml HAZARD CATICORIES (S«« Section I)
i: NO
Fire Hazard. NO
MANUFACTURER'S
. NAME AND
ADDRESS
CMe*nical Corporat
*
OcciaentaT Tower.
75380 (1-806-752-5151)
CHEMICAL NAME: Sodium Hydro-iae CAS NUMBER: 1310-73-2
SYNONYMS/COMMON NAMES: Sodium Mydro«ide: NaOH
CHEMICAL FORMULA: NaOH
DOT PROPER SHIPPING NAME: Sodium Hydroxide. Llauid
DOT HAZARD CLASS: Corrosive) Material
DOT I.D. NUMBER: UN1824
DOT HAZARDOUS SUBSTANCE: RQ 1OOO Ibs.
II. HEALTH HAZARD INFORMATION
EMERCZMCY AMD TIRST-AID PROCEDURES
EYESOBJECT'IS TO FLUSH MATERIAL our IMMEDIATELY THEN SEEK J
ATTENTION. IMMEDIATELY -flusn eyes witn larg» J'"®""!? ?J,1?2
at least IS minutes. noKaine lids apart to •n«"^«J,iu*'?12
entire surface. Wasnine «y«« »1th1ne5av2£»Jf.««c5T™T?a3
to acnieve maximum effectiveness. SEEK MEDICAL ATTENTION
IMMEDIATELY.
-------
OCCIDENTAL CHEMICAL P'
uene MLJUBER* M/7H7
PROOUCT^AME: sei CAUSTIC SCOA-MEMBRANE
II. HEALTH HAZARD INFORMATION (Continued)
IMMEDIATELY wash with plenty of water for at I**** *S minutes.
Remove contaminated clothing and footwear. Wash clothing before
ro^M and diacard footwear which cannot be decontaminated. SEEK
MEDICAL ATTENTION IMMEDIATELY.
INHALATIONS
Remove to fresh air; if breathing 1» difficult have trained
peP.cS administer o.cygen. If raso^ration stoos. give
mouth-to-moutn resuscitation. SET MEDICAL ATTENTION.
N ANYTHING BY MOUTH TO AN UNCONSCIOUS PERSON. If
shallowed DO NOT INDUCE VOMITING. Give large Quantities of
-«er If SSaVlable.^Tv. several O^BOS^m^.lf
occurs soontaneously. keep airway clear. SEEK MEDICAL
IMMEDIATELY.
ROUTES Of EXPOSURE
I NHALAT I OK •
Breathing dust, mist or spray may cause damage^ to t£e yoe«'>
resoiratory tract and lung tlssvie prooer wmcj could proe*je-
cnemical pneumonia, depending upon seventy of exposure.
SK1XContaet produces severe burns and destroys tissues. Irritation
may be delayed.
EYE burns tnat resu1t m damage to the eyes and
possibly blindness.
severe burns to mucous membranes of the mouth, throat.
esopnagus. and stomacn.
KTMCTS OF OVEREXPOSURI
XCUT?orroslve to all body tissues by all routes °lj««O8ur?-_ .I
effect of local dermal e«ooaure may consist of mu 1 tip l e a reas
""<
effect o oca erma e«u
supSrf icial destruction of the skin or of primary ^«""<
aermatitis. Similarly, inflation of dust, soray. or mist may
- in varying degrees of irritation or damage to tne
r-afiult in varyng egrees o
rSsoiratoVy tra« tTlsues and an increased susceptibility to
respiratory illness.
CHRONIC:
No known chronic effects.
TOXICOLOGY DATA:
Caustic soda is a corrosive m*'**r1?«B« ~_
Acute Dermal LD50 (rabbit) 1350 mg/kO
Mutnan Pftrmn^ EyPPSwro^ eeverlty of damage and extent
af itsi rreversib lilt y increases with- length of contact time.
Prolonged coStSS w?th iodlum'SJdro-ide -olu^iona of |1X c-n
cause a htgn degree of tissue destruction. The 'fi**?**"^?™
f el lowing skin contact during which noaenaat Ion of irritati
occurs, vanes from several hours for O.« - 4« solution to 3
minutes with concent rat ions of 25X or greater.
-------
FE3-E3 96
Pace 3 of 9
OCCIDENTAL CHEMICAL Q4- 12-93
CAUSTIC SODA-MEMBRANE
HI. IMPORTANT COMPONENTS
CAS NUMBER / NAME
7732165 Water
D«nncinv LIMITS PERCENTAGE
EXPOSURE LIMITS vo, NQ
PEL-Not f»t«*»J <«£•?. WT 48.50-91
TLV-Not Establ
COMMON NANESl
Listed On (List Legend Below):
19 23
'310732 Sodium hydroxide (Na(OH) )
BPOSOWUMITS
"
COMMON MAKES:
CAUSTIC SODA
Listed OnlList Legend Below):
13 18 21
Sodium cMlor^de (NaCI)
76^7 14S
EXPOSURB LIMITS ND
PEL=None established v°L Q-
TLVoNone e*tao l ¥fT
COMMON NAMES:
SALT
Listed OnfList Legend Below):
23
777S099 Chloric add. sodium salt
PERCENTAGE
EXPOSURE LIK1TS P
PEL-Not Established ^- Q,Q 30
TLV-Not Estaolisned "" w °-JC
COMMON NAMES:
SODIUM CHLORATE
Listed On (List Legend Below):
12 21 _ _____ _____ . __ .... _________
All comoonents of this product that are required to be on the TSCA
Inventory are listed on the inventory.
Not listed as carcinogen - I ARC. NTP. OSHA
SUBSTANCE 13 PA NVIROM6NTAL MAZ SUBSTANCE
-
AA
18 NY HAZARDOUS SUBSTANCES »9 PA REOU I RE JjENT- 3» OR GglJ^I"
PIAL HEALTH HAZ SUB 23 NJ REQUIREMENT- IX OR GREATER
-------
OCCIDENTAL CHEMICAL P"°O4- 12-93
IV. FIRE AND EXPLOSION DATA
FLASH POINT: NA AUTOIGNITIOf* TEMPERATURE: Nonf 1 aimwD 1 a
FLAMMABLE LIMITS IN AIR. X BY »->LUME- " JJJ
EXTINGUISHING MEDIA: _ ^^
This product is not combustible. Foeun. carbon dioxide or dry
chemical may be used where this product i* stored.
SPECIAL FIRS FIGBTIXG PROCEDURES:
wear full protective clothing. Avoid direct contact of this
• product with water as this can cause a violent exothermic
reaction.
UNUSUAL F I RE AND EXPLOSION HAZARD:
01 red contact with water can cause violent exothermic
reaction.
V. SPECIAL PROTECTION
VENTILATION REQUIREMENTS:
Soedal ventilation is not reouired under normal use. Use
local e«haust ventilation wnere dust. mat. or spray may be
Generated. NOTE: Where caroon monoxide or other reaction
Products may be oenerated. special ventilation may be required.
SPECIFIC PERSONAL PROTECTIVE EQUIPMENT
RESPIRATOR?*
Resoiratory protection is not reauired under normal use. Use
NIo!5/MSHA aapr^veS respirators -nere dust. mist, or spray may be
generated.
EVK*
wear cnemical safety ooeoles plus *ull face shield to protect
against splashing (ANSI Z87.1).
wear chemical resistant gloves such as natural •?£ butyl
ruboer. Gloves may be decontaminated by washing with mild soap
and water.
OTHER CLOTHING AND EQUIPMENT:
Impervious protective clothing and ehe-Meally 2
w
mv *
shoes should be worn to minimize contact . .w"*^ eontaminatad
clothing wixn soao and water and dry before reuse . Emerg •"cy
snower and eyewash facility should be in close proximity. IANSI
Z3S8 . 1 ) .
-------
FE5-23 56-04:09
OCCIDENTAL CHEMICAL PaQa4
U • SZ'CAUSTIC SODA-MEMBRANE
VI. PHYSICAL DATA
pkfVSICAL STATS:
BOILING POINT.*
LIQUID
760 mm Ha. *C:
Cone«n*r
.IB za.
1 16 1 13
. - ,«e_
ifl
119
W«Mt*Vt
4£
129
x
144
FREEZING POINT. «C: -»• ~32 ® IS 12
VAPOR PRESSURE, mm Hg • 60«C: 135 110 76 46 13
SPECIFIC GRAVITY "15.6-C/15.6-C: 1.11 1.22 1.33 1.43 1.53
DENSITY. Ibs/oallon a 1S.6-C/1S.B-C: 9.27 1O.20 11.11 11.97 12.76
SOLUBILITY IN HgO. X by wt. completely soluble
VAPOR DENSITY (Air • I): Not Applicable
APPEARANCE AND ODOR: Clear liould with no distinct odor
ODOR THRESHOLD (PPM): Not Available
EVAPORATION RATE: Not Known
COEFFICIENT WATER/OIL DISTRIBUTION: Not Available
pH: 7.5X solution has pH 14.0
VII. REACTIVITY DATA
CONDITIONS CONTRIBUTING TO INSTABILITY:
Under normal conditions, this product is staole.
INCOMPATIBILITY: _ __ .
See Section VIII. Avoid contact with water. This product may
be acded slowly to water or acids with dilution andconstant
stirnno to avoid a violent exothermic reaction. When handling
*r«i« product, avoid contact with aluminum, tin. zinc, and alloys
tnese metals. Do not mia with strong adds without
.
dilution and agitation to prevent violent or e*olosive reaction.
Avoid contact with leather, wool, acids, organic hal
compounds and organic nltro compounds.
HAZARDOUS DECOMPOSITION PRODUCTS:
CONDITIONS CONTRIBUTING TO HAZARDOUS POLYMERIZATION:
Material is not known to polymerixe.
-------
OCCIDENTAL CHEMICAL P*°B4,- 12^93
*• ~
MtlURPR-
ROOUCTNAME: oi CAUSTIC SOOA-MEMBRANE
VIII. HANDLING AND STORAGE
RAMBLING AND STORAGE PRECAUTIONS:
Do not get mto eyes. on skin, on clothing.
Avoid breathing dust, m1«t«. or spray.
n and wear respiratory protection
to dust mist or spray 1s possible.
-eaV^hemical splash eogglss. face shield, rubber
«2sMi swa
appropriate tank entry procedures (ANSI
SPECIAL MIX1HG AKD HANDLING INSTRUCTIONS
Product can react violently •"•"* "ater- C°?£™fori* wnSn '*
nonarared when proouct 18 mimed with water. TheroTore. wnen
S2h?nS -olSTonS Sl-S« carefully follow these steps:
wear ALL protect we clothing described above. NEVER aod
1s being completely dissolved as it is added.
i« -.-.-.,*. -.» IK an<4A<4 *oe rapidly, or without stirring, and
solut 1on.
NOTE: Never add more product tn-",""^?-*^^'"^.^ solution
wr,7le maintaining temperature bslow 200°F (• sea level) to
prevent boiling and spattering.
Product can react EXPLOSIVELY with acids.
otneroroamc chemicals - «nen mixing Product »
containing such chemicals, follow all of •bova 1r_1na
instruct ions, and add product vfflcx gradually, while stirring
constant ly .
unknown residue.
BU0P ' ion a |-v«,c*in^i«ri« k «wi •«. "— -— • •••
all federal, state, and DOT regulat _^ _
soda snould be removed from containers prior to
-------
FE3-23 96 04:iB fmiBOBGR EWIROweffft. 80B-52E7S30
5e5 ?£>;
OCCIDENTAL CHEMICAL Paoe 7 of 9
MSOS NUMBER; . .M7767 ^4-iI-93
PRODUCT NAME: SOX CAUSTIC SODA-MEMBRANE
IX. ENVIRONMENTAL PROCEDURES
STZPS TO BK TAJQEM If KITXRIAL IS RTLSASED 08 SPILUD:
Leaks should be stopped. Spills should toe contained and
cleaned up immediately. Spills should be removed by using a
vacuum truck. Neutralize remaining traces of material with anv
dilute inorganic acid such as hydrochloric, sul-furic. nitric
phosphoric, and acetic acid. The soil! area should then be
flushed with water followed by liberal covering of sodium
bicarbonate. All clean-up material should be removed and placed
in approved containers, labeled and stored in a safe place to
await proper treatment or disposal. Spills on areas other than
pavement, e.g.. dirt or sand, may be handled by removing the
affected soils and placing m approved containers. Persons
performing clean-up work should wear adequate personal protective
eauioment and clothing. Spills or releases Should be reported
if required, to the aoproonate local, crate and federal
regulatory agencies.
CAUTION: Caustic soda may react violently with
acids and water.
HASTE DISPOSAL METHOD:
THe materials resulting from clean-uo operations may be
hazardous wastes and. therefor*, suojec-r to specific regulations
Package, store, transoort . and dispose of all clean-up materials
and any contaminated equipment m accordance with all applicable
federal, state, and local health and environmental regulations
Snioments of waste materials may be subject to manifesting
requirements oer aepl 1 cable regulations. Appropriate disposal
will oenend on the nature of each waste material and snould be
performed by comoetent and properly permitted contractors.
Ensure tnet all resoonsible feoeral. state, and local aoeneies
receive proper notification of spill anc disposal methods.
X ADDITIONAL INFORMATION
OSHA Standara 29CFR 191O.J20O requires that information be
orovioeo to employees regarding The hazarcs of chemicals by means
or a hazard communication program including labeling, material
safety data sheets, training and access to written records. We
r*2°ast that you. and IT is your legal duty to. make all
information in this Material Safety Data Sheet available to your
.employees. *—*-
AT»r 1n complying with regulatory requirements.
sJ[*«J.! ?IXT5axaC5 c<"2°or,JS* for th1s product are indicated
Sect ion I. if the word "YES" appears next to any category.
r«D£°difCi^«maX,D* reportable by you under the reouirements of
CFR Part 37O. Please consult those regulations for details.
XI. PREPARATION INFORMATION
,T health, safety, or environmental
on telepnone (716) 2B6-3O81. or write to:
Occidental Chemical Corporation
Product Stewardship Department
Suite 4OO
360 Rainbow Boulevard South
Niagara. Falls. NY U302
For Eaargencics: 24 HOUR EXTRCENCV PHOKt: l-800-733-3ee5
This MSDS replaces MSOS Number M7767 dated ©1/18/93.
-------
OCCI DENTAL CHEMICAL Pago 6 of 9
MSOS NUMBER: MT767 04-12-93
PRODUCT NAME;. SOX CAUSTIC SODA-MEMBRANE
WARNING LABEL INFORMATION " "~ ~~~
SIGNAL WORD: DANGER
STATEMENT OP HAZARDS:
CAUSES SEVERE BURNS TO SKIN. EYES AND MUCOUS MEMBRANES.
CONTACT WITH EYES CAN CAUSE PERMANENT EYE DAMAGE.
INHALATION OF DUST. MIST. OR SPRAY CAN CAUSE SEVERE LUNG DAMAGE.
CAN REACT VIOLENTLY WITH WATER. ACIDS. AND OTHER SUBSTANCES.
PRECAUTIONARY STATEMENTS:
Do not oat into eyes, on skin, on clothmo.
Avoid breathing dust. mist, or spray.
Do not take internally.
Use with adeouate ventilation and emoloy resolratory orotaction
wnen exposure to dust. mist, or spray 1s possible.
when Handling, wear cnemieal splash goggles, face shield, rubber
gloves and protective clothing.
Wash thoroughly after Handling or contact - exposure can cause
burns which are not imnediately painful or visible.
Keep container closed.
Proeuct can react violently witn water, acids, and other substances
- read Handling and Storage instructions carefully before using.
Product 1s corrosive to tin. aluminum, zinc, and alloys containing
these metals, and Mill react violently with these metals 1n
powoer form.
Hazaroous carbon monoxide oas can form upon contact with food and
oeverage products m enclosed spaces and can cause death. Follow
appropriate tank entry procedures.
FIRST AID:
FOR EYES:
OBJECT IS TO PLUSH MATERIAL OUT IMMEDIATELY THEN SEEK MEDICAL
ATTENTION. IMMEDIATELY flush eyes with large amounts of water for
at loasT IS minutes forcibly holding 1 ids apart to ensure
flushing of entire surface. Washing eyes within several seconds
15 essential to acmeve maximum effectiveness. SEEK MEDICAL
ATTENTION IMMEDIATELY.
FOR SXIN:
IMMEDIATELY wash with plenty of water for at least IS minutes.
Remove contaminated clothing and footwear. Wash clothing before
reuse and discard footwear wmch cannot tie decontaminated. SEEK
MEDICAL ATTENTION IMMEDIATELY.
IF INHALED:
Rnmnv* *« *•--«.*» -.«- ••• «• • •• •
-------
FE5-c3 56 i-l:
OCC I DENTAL CHEMICAL P"°©A? jI-93
S£6CAUSTIC SODA-MEMBRANE
WARNING LABEL INFORMATION (Continued)
at 1s oenera.ed -hen product 1. "»••-"«$
wa hefor? -heVTmaklng solutions always carefully folio.
tltose stapa:
ALL or escribed protective clothlno- NEVER add
eS£ lately dissolved as it is added.
^'&^s
SSo VIOLENT ERUPTION
solut ion
^^
prevent boll mg and spattering.
consTantly .
pr
unknown res1due
soa snoud Doov from cotainers prior
sted eauipnienT iri »&*•*« **•••••«• 7 • •• • , ~ T:::L_
inS local health environmental regulations.
il. state, and local agencies
receive proper notification of disposal.
IHFORXATIOH RZQUIRZD BY FZDERAL, STATE OR LOCAL REGULATION:
This product contains:
CAS* . NAME
7732 IBS Water
1310732 Sodium hydroxide (Na(OM))
7647145 Sodium chloride (NaCI)
777S099 Chloric add. sodium salt
KMIS RATIXG SYSTEM: HEALTH 3 . FLAHKABILITY 0 REACTIVITY 2
FOR IMBUSTRIAL USE OKtY LABEL 043X7767
-------
575 Mountain Avenue
Murray HiH
New Jersey 07974
Teieohone: 201-«4-8100
TWX: 710-984-7970
MATER AL SAFETY
DATA SHEET
CHEMICAL FAMILT: Inert CM
PRODUCT SAME __
Refrigerate
SYNONYMS: Nitrogen
CAS NUMSE3: 7727-37-9
•
CHEMICAL FORMULA: Liquified V2
DOT BAZASD CLASS: Nonflasaable Gas
DOT IDENTIFICATION NUMSEB: UN 1977
CHEMTSEC: 800-424-9300
HEALTH HAZARD OA7A
TIME VETCHTSP AVERAGE EXPOSURE LIMIT;
N««. «t«bl-shed. Nitrogen if defined as a srmple asphyxiant. Oxygen levels
:;::^i ^*« - u- *- » *«-« « °— ^>ur
which is equivalent to a partial pressure of 135 una Hg. (ACGIH.
SYMPTOMS OF EXPOSURE;
Effect, of exposure to high concentrations so a, "displace the oxygen i. air
necessary for life «y include at^. .U or pone of the following.
Loss of balance or dizziness;
Tightness of Che frontal area of the forehead:
Tingling of the- tongue, fingertips or toes;
Weakened speech leading Co the inability Co otter sounds;
Rapid reduction in 'the. ability to oerfora aovements;
Loss of tactile sensacionr:
Heightened oeatal activity;
Tc should be recognized that it is possible, that none of Che above ,y»pto«s
My occur in nitrogen asphyxia so that there are no definite "7"*
,y»pto«s. Contact with cryogenic- liquid or- cold. piping "ntaininj J *• WJ
can cause tissue freezing or frostbite on dermal contact or if splashed in the
eyes. .. _. ... ..... ... — .......--
• ,
Vote: Except vhere specified. Che health hazard data and mosC of *••«*"
•daca in this material safety data- sheet are 'for gaseous, nitrogen. .One volume
flr liauid nitro«n at its bo^mr point and atmospheric '7""™""
- and
into annrox. MS volumes of
'TOnCOLOCTCAL PROPERTIES:
s-'-' :
nitrogen «t 7Q-F CZl.l
»^ .7s-'-' :.."" r>'-^w-«:'*-»--.'— . .. - ••-*•*- -.*-•• .--*- ?"——•..-!*: —.-•-.-. •-•• "»• ~i-' •>' 1^_.
•: '«icrogen is nontoxic-buc' the libefaeion- of •* large amount in- a confined: are
could displace the amount of oxygen xn air necessary to support lite-
•Frostbite effects'are' change in' e»rorTof ^liejskin Co gray or white possibly '•
followed by blistering- ' — •
-------
Special Fire Fighting Procedures: W.A.
Unusual Fire and Explo.ion Ba»ard«; »/A
"RJArTTVTTY PAf
Stabilitv: Stable
to Avoid); »oae
u-».-..rdBUa Per •«'*•• Productsj. Sone
I,--.-.. ».l«-rlMri«.; Will not occur
Procedures
vac
aum-jackeced "liquid" cylinders.
issnediacely.
tfaste Disposal Meehodr -"•'••_-_ ;. J"J.
Do noc ac:e-PC to dispose of "resid^'or'
for proper disposal.
. Becurn » Airco
SVECTAL PBOTgcnON TNFOKilA'iiUj
•v-.—
""-£*•*
for emergency use
.
.....-•
ventilation: See local exhaust.
.. local Exhaust: To prevent accusation of high concentration, so as
* level in the air to less than 18 percent.
Other: Sone •
•
Protective Cloves: Loose fitting, insulated
*•-?!":Eye Protection: Safety goggle, or gla»ses, plu^-lace. shield .'- .^.:
•' ••• •• ^ ^ ™ " •""•.•••• , • *
7£ "Other Prqtecci\re_1EqjuipmentL -.Safety «b°e*- I-L: • i—^—.«--
-------
©
Data Jttuoa: '.2/08/90
Sup«rc*CM: 10/24/90
TEXAC3 -UM_
MATERIAL SAFETY OAT* SHEST
uno.rtt.nc Mat.M*. 5»f.ty O.t. «*•" b.f.r« Handling or OlfO.ing 0. procuct
CHEMCAL PRODUCT AIO CS»ANY IDENTIFICATION
MATERIAL. IDENTITY
Prwct CM. MM Saws
OC38S TDC1CC UNUAOEO
Mam» ane/or family or
ana Acar«««: ^
«X «na MtrkBtirS' •"
P. a. Box SS33S nou«ton. TX 7. OBI
Ta'.aonona
JMSaCeNC" C3«O«fTyi (SU)
a. ss«Pos:T:sN/:NFOMttT:oN a*
-«n:y of «..
.re srwicnao parsfflnie nycrwaraon.. ol••
• :ra. syclcs«rif-1nt ra irw^tio.. Th. fejn-
-.n. eanttr-: noPiMlly v«n« from 0.2-3.W
wttn * ?yp:c«1 v«lu« ef l.*X. Th« MT1E con-
tent vtr-.M froa C-18S. .
?»3cuet it
. - ,-»»,.«*.» . « 8SHA l^'l^V-Wr."- •
" :•- • canoon«r^<») it nasarseu* aeesretng ta 3»* ^r^erw or ~'^ _ —
•i- <> stst* 8i8n*-'S3'Hno* la«t. • . •
3. HAZAU IOEKT:FISATUN
EMEROCNCT OVWVIEW •".••'• •" '" . i '
ana floor: -Ltent straw to tlgnt f*A t!8U1«
3ANGHI
USUXO AM VAFCR
INHAL80
MAY CAUSE OIZ1INESS AIO OROVSZNCSS
MAY CAUSE EY8 AW SXXN XMiWRCN • •
MAT ae MAiwrui. rr ABSCRBCT TI«CUGM J«N
ASPtaATXCN HAZARa It JVAL^WW ~ CAN IHTM
LUNGS AND CAUSE OAMAOf
ATTE.NT:3NI KSSXSLl CANCER MAIARO J*: .:-
MAY CAUSE CANCER BASED ON ANIMAL DATA. .*
NTfA
2
4
HMltn:
Special
._ J>OTSNT:AL HEALTH EFFECTS ..
Primary fteuta o« Expacuro:
EYS
X
SKIN
":NHAUT:CN
t I
N.;. - .vet 2«tiratr.ae
< - tess "Man
N.A. - Met
> - Cr«at«r
N.7. - Net TM
-------
,BC- ..... £. .--M aata
roues UNLIACEO •
'4. KMT AID KCASUAM (CSNT)
Otnor Xrjtrue'tfani:
NCTJ 73 »-YS:C:AMS A«oir»ticn at tru gpoeust curing Inaucod «•••!• etn
r«*utt in lung injury, if avacuatten of atsnacn santanta ti ssnsiaarod
n«oa»py. uao s«noa luit loan OP launaop slotting scikad or tellM with tfti«
MT«pi«l o«fap« •••ui*. Dry c1««nlng of santMlnatia slotning My B«
MPO «#f«cttv« trun MPIMII Uuraoping. Infer* iralviaumli r««oon§iBlo fop
eloan'ng of potomul Rartrai •••oet«?«e wltn ncnallna
eletning.
a. fue-^:aHT:Na MCASUMS
f. (Motiwa): -40*
(UcanMPMd F1r«- Iact1r>sul«ning Agan-u And So«e1«1
Aeearstne TO NFa* auico. u«« spy .en** is* I, fosn, OP s*rwn eiexieo. VATIP
n«y s« ip«ff«c^iv« or flM«i. ftuV «rcv;!3 bo UMO *e eaol f*^«-«xco«oo
esnt«in«ri. If • INK OP ram *•• not icnitoa. uoo *«tor raroy :a
eite«r«« •.•)• vacori ana ;a pp?vio« srstie^:on for aopsonnol iT^ocating ;o
STOB ;n« :••*.
wn«n rtrc'ing. uoo aon*«eopKino taoli. gpsuna tno sens all contatnopi.
Unuoual OP Explootv* Hazara:
o«acitr« VIOSPI apo .loaviop t.ran §ir ane aay travel a sanaiaapaaja ainanco
:c a ieup?o of ignition ana flaan aaei. Mowing ;a«ottno can aanopato
•tat ic •iae^p'.sity ane eauao a fip« ••slot ion if a toapk cceart ifi a
f:«fflflaol« vaaop-aip a?»oaonop«. «hon ranoltng. uao ron-toap»lng_tS3H,
grouno ITS sona all eantairapo, Consult Nf»» T7 fer :no praeor nsnaltng
proeautient.
8. ACSrCEMTAL RCLl&se MEASURES (Trtnreorutton Sot IIS Call: SHOCXCe (100) 424-S300)
?roe«aur«« in Caso of Aesioantal taloaa*. Ii^akaoo or
£5inii-.»i» all lenitlen aoupsoa inelbof.ig mtarr.al eosauosien oncinoo ana
POMOP tsslr. Vor-«i«-« ar«a. K«OO aoeaU.avay. Stay UDwina ara varn of
peavic:* scwnwi.-e oxelooion nazapa. AVOID opvatning WCPOP. Map aolf-
esn?a*r«c sroatriine. aeaapatu*. Avois eantae; witn iKtn. oyoa OP elotntng.
Uaa tolf-ssntainae armatning aesapa*ua or auaalioa alp-mote for UPT*
aaMlfl ar-sanftp«a ar«ao. Contain •oil! If eoaaiblo. Roaovo witn in«Pt
aaaoraon;. Provont ontpy inta IOWOPS ana •«itn*ayi.
7. HANDLINO AND ITaUOC
pp*e»utlona to M Taxan In Handling and Stop*?*!
Tranteept. nanol*. ana •TOP* in aesarsare* «
-------
MCWCT KAMI: TSXAC9 UM.UOU . i.re.a
-,. TcxiauaxcAL INTOKHATICN (ear)
Otnar:
Stuataa In laeorstary ,-aia via «ie. a»pasad to oonitant t aval a of
vaoor-sao unlaaeaa s*io1ina for am heura par day. five saya a«r vaa« for
two yaart cauaaa Moray sung* «nd kiorwy eane«f ir ul« rtt» ana liw
moor* in fwtl* •!£•. Many ic:antff:> oo nar a«li«v« tntt tiM Mlt rit It
tn tBoroacutt prislctar ef huuri Kiervy 3 !••«•• toe ar« not In agrtCMnt
on :«a MlatfoPtnie tatM«n tlvar tuoers in laeoratary anloaU ana nuoan*.
ana r«0««t«d •meavtr* to fearzan* haa eau««a ammla. tyi^hon. and
otf»r eanear*. m fabaratary anioali. Sanxan* haa aaan tnovn to cauca
aBorve/f«?a1 .tmetty ana str-tn «a^ae» in laooratar/ anlaals. out only at
ttaaa -men eauaa aatarnal toxletty (I. a.. Htnaaa in tna •etrar).
13, DISPOSAL
WASTE o:aniAL NCTWSS
Thit 3i-sawet (aa pr«atnt!y caRStitutao) haa tn« «C»* elaaairteation af
banana ^mieiTy ana lent twit <*y. If diicareaa «« iti praaant for*, tt
M9wl3 rtiva tft* nasarsoua waato nuaoora OOlt and 500 1 ra«oactca:
n.a.
TM: M0»« SHZPVINQ HMNS; N.8.
4. uftuurarr
A. SAM TITW «S
T1;!".-:: siietiof. an
*«uto Cirontc Flro Prvaaur* Raaetlvo Net ApoMeao1.*
~ — 5 — _ . _
-------
MCOUC7 CCCE: OC3i*
PRODUCT NAME: TE*ASO UNLSACE;
' , ?^
Oat* :t«u«d: 13/CB/flO
Sbo«rcedea: 10/34/00
/
14. RfiCULATCRY XNPCRMATSON (CSNT)
Title III Section 313 Toxic CM
aenzene
Toluene
Etnyl benzene
Xylere
Pieucccuaene
Matnyl tirt-sutyl etnar
"•1e»J« ^
" "1433
1CMI3
108414
1330307
•ac3«
1634044
»«r-«r-*
1-3. ••
4-10.M
1-3. •»•
4-1C.M -
1-3. *•
0-l9(vo1«)
B. WMZS CLAaWICATICN
c. «w:a*N CRITICAL MATERIALS •
1.4% serr«n«, tstuene arw xyl«r« «t «-i0.3»X
is. CTHSS XNPORMAT:SN
T-E
r-is pacsucT :s ;NT:NCEC FOR JS2 AS
Texaco recamenaa tnat an axaoaurtt
any potential aeverae neal;n effect*.
CNUT.
tnia preouet be
l2»« BY
ivota
CCNTAINSS :-Ea-:N :s ts'.isvss TO >E AcrjRATi. :? :$ »«v:5io :«cMNoeNTLY
5F THE HCCUCT >Sa P'JRPCSE Cf MAliSO ^MMUNlCATtCN AS *AflT SP 7«JCiC2'S PBCSUCi
.- »« ve- •MT*M!»> TO C3NSTirj7£ •ERPCaMANCS INF3XMA7J2N CCNCI3NINQ THE PtCSUST.
.. .» .-IB. ..m-iii... ,« op macMANTAirLTiY :a ^tTNiss pea A >AflT:cuua PURPOSE :s
WITH QES9*C~ ?0 THE PHC2UCT 08 THE INPCaMATICN CCNTAINEC HWEI.V. 8A7A SrCSTS A3£ AVAXUBi:
rea ALL TSXACS'PRCSUCTS. vsu jia: UBSZO TO MTAIM DATA SHESTS wa AU. TSXACS ''coucrs
ou BUY. PRCSSSS. yst ca.a:sra:aun AND YCJ A«E SNcauaAOEO AW *E«;M,B TO ACVISE THOSI
JHO MAY C=« IN 5CNTACT WITH SUCH PUCOUCTS Zt THE INfCSMATISN CSNTAaES MERC-N.
T3 SETSSMINC IPO'-rCitrLrTY SB EP'SCT 5P ANY LA» 0« "'SUT*!15!!^:^*^^!
USES SWUL3 CSNSULT MIS LE9AL ASVISCR OR THE AP»«CP*iiTS COVESNUENT AGENCY.
SCES NCT UNDERTAKE 73 fVSHlS* AOVIC2 3N SUCH MATTERS.
Susereeaea:
MSCS eneula M e
Taxaea Inc.
uanacer. ?»3cu=t Safety
•.3. Sox 3C9
Beaean. N.Y. 139M
to:
SEC NEXT PAOE TOR PR06UCT LAICL
N.:. - Net 3«t«riinae
< - '.••• Than
M.A. - NOT
> - Qreater Than
«.'. - not
-------
•!:'.?«CCUCT C3CE: CC3CB
'..'PROCUCT NAME: T«AC3 UNLEADED
Data ZtauaO:12/C9/90
Suparcadtt: '0/24/flC
11. •iwoucT met.
ftCAO AND UNDERSTAND MATOIAL fcVfTY DATA SHCET 8EFWJ HANDUMI M OXSPCSINO OF PROOUCT
00348 TSXACO UNLSAOC9
VAPOR MAY-CAUSI rusM
HARMPUL ir :N*ALID
MAT CAUSI DZZZ:NMS ANO OMCVS:NESS
MAY SAUII IY5 ANO SKIN IRRITATION
MAT ic HARMFUL if ABSORBED TMRCUOH SXIN
ASPIRATION HA2AAO 17 SWALL^Vta — OK EMTCR
LUNflS AND CAUSE CAJU<1I
ATTZNTIONr WSSIICJ CONCEil HAZARD
MAT CAUSI CANCSa BASES ON ANIMAL DATA
AVOID p«.oLCN065 sajATMiwo zr M:ST :a VAPOR
AVC:3 CONTACT WITH «YtS. 5XIN. ANC CLSTHINO
KZIP CSNTAIMER CLSSED
USE WITH AOECUATS VENTIUTISN
NIVtR SIPHON BY MOUTH
WASH THOROUGHLY AFTER HANOLINQ
K£*P AWAY FROM MEAT. SPARKS ANO FLAME
rrurr AIB
. oat inaaatata avdtcal attention. pNLY Inouca vent ting aa
oirtctaa Dy a aoetor. Never aiva Anytning ay aoutn to an uncanieteua or
ssrwilaino person.
XNXALATION:
ta frnn air. if not srvatMng. £iva artificial raae. - ••.*••
to OSHA or on, or .or.
• Mist •
",,*. ' '•. .• • •' .-
.A J«Mtl¥lty i O .
: A Special : .
Prepar Shipainc. »M..; .OaaoHn, ._
BCTMazaraoua Claaa • FUiwiioU_Llflii
National F1ra Protactlen A>«oc'«t1en
Haaltn : r Raaetivity : 0
FlMualHtyi 3 Soacial : -
-------
'flocucr c=i: ooa«a
PRODUCT NAJili TtXACa
18. PRODUCT UBU. (C3KT)
eont.in«r. m.ont C.M.
or .-PC.* te oe«n ft»« or h..t.
cant* In*-
Mmnufictuwi Nam: T*juio 9«f intng and Marketing. Inc.
>.fl. 3ox 32332 Houston. TX 77012 •
HJALTW
CCBMnyi
CHCMTilECi
I31-34CO
434<«300 '
(»i4) I31-34QO
„
* • "
-------
MUfCIII BOWK W*««l"«A<-w«M€t«III|M*4til
REGIONAL PHONE NUMBERS
PM21SIHI-MII
Ml|313)llt-2ttt
CA (714)117-2171
* - ' MATERIAL SAFETY DATA SHEET
?xss
1
CHEMICAL KANEi
CKBIXCAL
^_
SUPPlIIIi Seect Jp«ci*lty CAMS
AOOR£SSi Kouta (11 North
FAKZLTi Acid CM U
Hlftur*
C7HZ1 OESXOCATIONi -Non«
IN CASt OF
KECXONAl PtAKT KASACtl
k lCf
?. SZgTIOH IIl"r-gK
YSICA^
DATA
Balaaea
Ttv
BOI11HC JOINT (Tit
VA?0!t PRISSUSIi .K/
s?scxrxc GIUVZTT (K.o • DI N/X
• •
PE5CSXT. VOLATXU BT VOLGM2 t lt> i
VAPOR OEHSirt (A:» - i>. o.»«7 SVAPOPJTION EATS^ ^
-JSILlrr IK WATI» v/v «0'Ci «.4
UiO COOfti CalerUss. o
odcr - ra::ta t;si
' SECTION IV
AfID EXJLOSIOM ttASAM 0*TA
i
POINT A
K/A
KSTSC3
LIMITS
I
0«. vh«s 1* «ppcoprUt« for
Jlrt.
MIXED CASES •^^BOBBnHB
Hydrogen Sulfide H:S
CwcmiraOwi*
is*
CCA3»
Hl-Uppm-
0.1 .1%
200
112
•
*
31
Bd
Hd
Kid
110 d
lid
. Bd
a*
KOO
200
2CCO
2900
»*•**. MM 0100.* 10.
DOT*
"V
ai«....
oorm
cCuid
*!•
. IdlHi
• am •««••• ton i
UVI MM IMMM. bic* «•.
-------
Juno 30. 1995
Material Safety Data Sheet
USA and "WORLDWIDE
n-PENTANE (S)
PHONE XUMBE3S
—
si
A. Product Identification
Synonyms: Mom.! Pentane, Pentane, Commercial Grade Normal
Pentane(s)
Chemical Name: n-Pentane
Chemical Fully: Aliphatic hydrocarbon
Chemical Formula: C5K12
CAS Reg. No.': 109-66-0
Product No.: 000004
Product and/or Components Entered on EPA's TSCA Inventory. Yes
This product is in O.S. commerce, and is listed in the Toxic Substance,
SnteJl Art (TSCA) Inventory of Chemical,: hence, it may be subject to
applicable TSCA provisions and restrictions.
-i_^-—.,__.Isopentane. _^;..
'^. ^-^l-T.Rera.tedJiTdzaca
*?*-"*---:?^ - -TV^- . -. - - ~. = • • • i**- -
g^ggfe^jv^gg^
-------
C Personal Protection Information
.Ventilation: Us. adequate ventilation to control exposure
below recoMended levels.
E,.
HIOSH/MSHA approved air purifying respirator.
...-55;
liquid contact could occur.
professional be sought.
Z). Handling and Storage Precautions
.*. •* -. .
HnditioM w£raK Ksh thoroughly after handling. Launder
contaminated clothing before reuse. Use with adequate ventilation.
Ceeo away from heat, sparks and flaste. Store in -ell -ventilated
««. Store in tightly closed container. Bond and ground during-
liquid transfer.
'•"•' .E~ Reactivity Data'--.2gr-
-. '-'-..v- Stability: Stable
•- 'Conditions'to Avaid: Hot Applicable
"s-to Avoid): Oxygen, and strong
"" • " **" ~ — *""••!».^~» " ^»
Hazardou's' Polymerization: Will Hot Occur . ..j]
Conditions to Awdd: --- —"-•"- —
-------
Acute Effects of Overexposure:
Eye: Li«uJd « vapors .ay bo .ildly irritating.
Prolonged or repeated contact with
defatting of the skin resulting in
possibly blistering.
t«
lng.stion:
g
lung* .
«d possible flu" .ccu.ul.tion in the
Subchrooic and Chronic Effects of Overexposure:
Mo known applicable effects.
Other Health Effects:
n-Pentane was non»ut.genic in the Sanonella typhi»uriu» assay.
A Toxicity Study Su-ary for Pentane, Co«.ercial Grade, is available
upon readiest.
Health Hazard Categories:
-r-, ••' .:• --
.'.V. . '.Animal ..HuMir . ^=^^ .
iLj-^'^zlT- - Toxlc
V-L.T_;.^lsuspect-Carc.iaogBn«^=_-— -_^_-' ;•
_• ,' •-. - M«t:»irelt • ; jJ-^~ ^•'-—^l '
-iHui-^^T^^toge^&C^-.r^^iJ:^----^ • -.r-
^ • —-i_-x»i i __^^«. Gmttfttlfmr
Target Organ Toxin
~l-T^All«5irSensTtiier ZI I- • . • Specify - Lung-Aspiration jg^-^rr*"^—^
-------
G. Physical Data
Appearance: Colorless liquid
™0dor: Mild, gasoline odor
Boiling Point: **r*3S'.6C\ ,„„- tyt acl
Vapor Pressure: 15.9 psia a 100F (37.8O
Vapor Density (Air « 1): 2.««
•^ffss^A^;«> «*-"-«"
Percent Volatile by Volume: 100
Evaporation Rat. (Butyl Acetate • ^j ^^ ^^ ^ (2QC)
H. Fire and Explosion Data
Fl
Flash Point (Method Used): <;*OF (-MC) (TCC. ASTM DS6)
•able Li.it. (X by Volua. in Air): LEL - 1.J
Fire Extinguishing Media:" Dry chemical, foa. or carbon dioxide
(C02)
Special Fire Fighting Procedures:
Evacuate area of all unnecessary
personnel. Use H10SH/MSHA approved
self-contained breathing apparatus and
other protective equipment and/or
garments described in Section C if
exposure conditions warrant. Shut off
source if possible. Hater fog or
spray may be used to cool exposed
containers and e
-------
/. DOT Transportation
Shipping Ka««: Pentane* ,j_.4Ji
Hazard Cla«»: 3 (Flammable liquid)
ID Number: UN 1265
Packing Group: I _
Harking: Pentanes, OH 1265
Label: Flauablo liquid
Placard: Fla««able/1265
ft*T3&a
•
K. RCRA Classification - Unadulterated Product as a Waste
Ignitail. (D001)
required. Reference 10 CFR Part 261
L. Protection Required for Work on Contaminated Equipment
sf^f^^ -
I2«ion C if expoiur* conditions warrant.
M. Hazard Classification
CFR Section 1910.1200):
__ Co^stible Liquid __ Fla-able Aerosol __
Cv.
JT*^" • • — " •
r**--4'-- v/-.~-i.:-->'-5.-*-*r-.r33?SP."•*"?"—H? T.~"-.
J. ' „•-. >"•_ "• WS-"-.. • '- *•
*. ;-lr:-'«-.ir'r^-^AicS^-ii.--'", r7_
;^u«.« n».rjJ*^S.-»»—-' ' ..-- -
•Jf." • ,-.'«
.—*«•»•• .-c-_l^
• r^g-SE^
• -^Sa^ ^iSs*7-^
" ~Tr^-.^ : «.?g/ jy?ar.^as.:iai.i<^-
. ' •
.; ..,-r.--. ,v.\s.=a^.:rC-i-..-_ .-
.•VrT**t J • -— -*"^'-%J' ^J— mmr—k^ *"^" " , . •• ~
-•- • . -• -=-._£^^i;5!i'
. . - -. -Tf--r?vir*:-i**T%
• . «t^ • _ ^ t" ™
SfeK^^-^^^w^r^w^ • :"i^?SSS^^«:^ -.
.• -e,.— • : •. - : • * -•_ ' • —»v u»u'^i» •'trT'^Pus^iCafCTTL^'*' ^~ "
^* *>Peiitanc (S) (CS027950V "nr~ *^--.T" J"r~'.^^ .r^r-^^- y**vai«aj.aIragexrtr'hj.. ^j^. ^ _
-------
/V. Additional Comments
SARA 313 ...
1 or cne«ic«*» »i*nj««.« — - * rj
BSafflS.'SWte 23 &MriH
HFPA 704 Hazard Cedes
Health : 1
Flauability: 4
Reactivity : 0
Special Haz.: •
Signals
Least - 0
Slight - 1
Moderate - 2
High - 3
Extreae • «
and
NO vjuuuLvrr OF Mxauxnmuct.
-------
MATERIAL SAFETY
DATASHEET
000*51
WPD 11-306 CORROSION INHIBITOR
' THIS -SOS CC-PL1ES «TH 29 CFR 1910.1200 (T* H*A» O-UUCATION
„,„,„••••••••••••••••••••••••••••••••
•••••••••••••••••••••••*•*""**"**"**"" •
Proauct N_tt MOD 11-306 CORROSION IUCBXTOR
00 10 044 64803-012
?agi
PUNA
MX 96T7«
Data Shoot HOI 0186290-004.085
i {{ffi/SJ
oI 12/17/94
POOA
G«Mr»l or GonortC Ml CORROSION INHIBITOR
DOT t*»rt CUM"lestfoni KIT APPUCA8LE
INGREDIBT
SECTION I I - COMPONENTS
PEL
TI.V
otaB*
_ _
*LCOHOL
*: 64-17-5
Kotos:
{ 1) PEL/TIV NOT ESTABLISHED FOR THIS MATERIAL
{ 2) PEL/TUT NOT esTABuae FOR THIS MATERIAL
10-25
1-10
1-10
1-10
NOTt
( 1)
( 2)
10
1000
10 PPM - SUN
1000
SECTION III-PMYSICAL DAIA
Boiling Point
Vaoor Prissun
Soodf 1c Vioer Dmlty
Sooclfic Gravity
Pvreonr Volatllot
Evwx>r»tien tato
(*
f or COMPONeffC 70-6M)
'or CONPONB*T(
70-85*)
212.00 0»g '
( 100.00 Otg C)
4 760.00 • na
17.50 — H|
9 68.00 Dog F.
( 20.00 Otg C)
KeAVIBl THAN AIR
.032
'( isiSo&c)
9 77.00 Dig
.00
70-6»
SLOBS*
Stau
RA9i POINT NOT*PPUC*BU
•LQHER- 1JV
f ^o» "••*
.•MAZUniS DKOMPOSTTTIM PRODUCTSl TUJMAL OEUJMWfti nB».OR- COMBUSnON MAY
EXPLOSIVE, LDOT^.• (LOHEST VALUE tr ..— ..—.,, ( +,*."•.**.*..
' EXniOUlS«NS.MfflIAi CARBON OIOXXOE OR DRV OHBOCU.' «..~:: -•"•-•
>£%&.°%Z^&?
PRESSURE POM*) MODE AND FULL I
SPECIAL FTRB IP BPLOSON MAZMBSi NOT APPUCABLC
HfiALTH- 9 PUMMABILrrV- t
;,.-CARBON DIOXIDE. CARBON
«r f
OPSUTH) IN TX POSITIVE
• «E*cnvrr*->
CONTINUED ON PAGE:. 2
-------
MATERIAL SAFETY
DATA SHEET
Drew Industrial Division
>
OM Or«w Plau. ioonton. Now Jcruv 07005
Phom (2011 263-7600/Tolo* 1364*4
CC02S1
THIS MSDS
MILL5PERSE 802 ANTISCALANT
WITH 29 OR 1910. ISOO (THE HAZARD OmwICATION STAWARO)
Eaerjency
Teltphone
1(800) 274-5263 o
1(800) ASHLAND
Page:
PUNA GEOTHBBUL vanuiE
^H^«W2^^> «u
"*** . W 96H8
00 IS 131 64803-OU
0019W04
0>t« 9M«t No: 0186241-001.COO
PnowMt 09/12/85
Suo«r««OMi ( KM )
ATIHi 0*VE
seeriON i-PHOOUCI
or Generic IDt
DOT Hazard Claulfleatloni NOT APPLICABLE
Notes:
( :) PEL/TU NOT ESTABLISHEO FOR THIS MATERIAL
^ -
Bol ling Point • f or CONPCNEKT( 85-100*)
( lOOlOO 0.0 C)
• 760.00 •• MB
Vaoor PrtMura for CDNPONEHT( 8S-^CCW , 0:30 Deg''
Soedf 1C Gravity
State
*( 25.'5o Oeg C)
1 .4 - 2.2
UOUIO
. — ^— ^^»^
11 .... ^rr.n- lU-UBE AND EXPLOSION . N.- OH *AI . -- !
FLASH POINT NOT APPLICABLE "
EXPLOSIVE U«T NOT APPLICABLE
ecnNCUISMNB MEDIAt
MZARDOUS OECSffOSITION PRODUCTSi TMBWAL OECOWOSITION OR COMBUSTION Mtt PRODUCE:. CARBW DIOXIDE AKC CAR80N
URESt NOT APPLICABLE
PIREFIGHTING P
SPECAL FIRE « EXPLOSION HAZARDSl NOT APPLICABLE
PERMISSIBLE EXPOSURE LEVEL. NOT ESTABUSHEDt SEE SECnON VIII.
EFFECTS OF ACUTE OVEREXPOSUREi
EVES - CAUSES IRRTTATTOHj BURNS IP NOT REMOVED.
HAZARD DATA
SMLUMNG - CAN CAUSE GAS1
FIRST AIOi
LATION OP VAPORS CAN CAUSE NASAL AMD RESPIRATOR1
^NTESnN^RIUTATIONTNAUSEA. VOMTWG. *«
TDRV
TATION.
IF ON SKIN: •nCPOUGH.V MASH EXPOSED AREA WITH SOAP AND BATCR. REMOVE COKTAWIUTED CLOTmHS. LAUNDER
ING B -
CONTAMINATED CLOTHING BEFORE RE-USE.
IF IN EVES: IMMEDIATELY FLUSH WITH LARGE AMOUNTS OF
OCCASIONALLY. GET IMMEDIATE MEDICAL ATTENTION.
MATER FOR AT LEAST IS UNUTES. LIFTING UPPER AND LCXfl LIBS
CONTINUED ON PAGE: 2
-------
HaiuopCT/Emtrtttncv Resraaie Guidelines and Traimr.c Program
•
Potential Event
.
Wellhead steam piping
or valve ruptures or
leaks. Hydrogen sulfide
eas released.
NCG compressor
ruptures or leaks.
Hydrogen sulfide gas
released.
Pentane tanker truck
ninturt
Pentane tanker truck
lo.il-
I lea*
North pentane storage
North pentane storage
ranlr Iralf
South pentane storage
tank rupture
South pentane storage
tank lead
Pentane turbines rupture
Pentane turbines leak
=======
Location
=====
Well pads to power
plant
1
Southwest comer of
power plant
Plant Roadways
Plant Roadways
__— — •
South end of power
plant
South end of power
plant
South end of power
plant
South end of power
Power Plant
Power Plant
=^==^=
Volume
(gallons)
^^^S^^SSS^SSim
??
??
6,000
6,000
9,000
9,000
9,000
9.000
3,000 ea.
3,000 ea.
Spill Rate and
Direction
s^^=— ^-^^
Instantaneous or
continuous to
atmosphere.
Instantaneous or
continuous to
atmosphere.
instantaneous to
ground in most cases.
Non-instantaneous to
ground in most cases.
Instantaneous to
containment
Non-instantaneous to
containment
Instantaneous to
containment
Non-instantaneous to
containment
Instantaneous to
ground (no
containment)
Non-instantaneous to
eround
-------
PunaCeothemulVcntt
HazwopCT/Emergcncy Reaoome Cuidefinq tnd Tim'mine Ptotimm
Potential Event
====================
South pentane
storage tank lead
Pentane turbines
rupture
Pentane turbines
leak
Pentane transfer
piping or valve
failure
Sodium hydroxide
50% solution
storage tanks (2)
rupture
Sodium hydroxide
50% solution
storage tanks (2)
leak
Sodium hydroxide
tanker truck
rupture
Sodium hydroxide
tanker truck leaks
Location
=====
South end of
power plant
Power Plant
Power Plant
Power plant
Southeast corner
of power plant
Southeast corner
of power plant
Plant roadways
Plant roadways
Volume
(gallons)
9,000
3,000 ea.
3,000 ea.
??
12,000 ea.
12,000 ea.
5,000
5,000
Spill Rate and
Direction
Non-instantaneous to
containment
Instantaneous to
ground (no
containment)
Non-instantaneous to
ground
Instantaneous Or
non-instantaneous to
ground in most
cases.
Instantaneous to
containment
Non-instantaneous to
containment
Instantaneous to
ground"
Non-instantaneous to
ground
T:\ADMIN\SAFETY\HAZWDPEILWPD
29
February 23,1996
-------
Puni GeothCTiMTVctHine
emergency Response Guideline! tnd Training Program
L
Potential Event
,.
Sodium hydroxide
15% solution day
tank rupture
Sodium hydroxide
15% solution day
tank leak
Emergency
generator diesel
fuel storage tank
rupture
Emergency
generator diesel
fuel storage tank
leak
Emergency fire
pump diesel fuel
storage tank
rupture
Emergency fire
pump diesel fuel
storage tank leak
Diesel tanker
truck ruptures
Diesel tanker
truck leaks
•
Location
==
Southeast corner
of power plant
Southeast corner
of power plant
South end of
power plant
South end of
power plant
Southeast corner
of power plant
Southeast corner
of power plant
Plant roadways
Plant roadways
Volume
(gpllops)
500
500
1,500
1,500
500
500
5,000
5,000
Spill Rate and
Direction
Instantaneous to
containment
•
Non-instantaneous to
containment
Tnst?ntjmeQUS tO
containment
Non-instantaneous to
containment
jn?t?Tl*9neous to
containment
NoTi-instflTit?nftfMlg to
containment
Instantaneous *o
ground in most cases
Non-instantaneous to
ground in most cases
TAADMIN\SAFETY\HAZWOPER.WPD
30
February 23,1996
-------
Hmuwper/EmentencT Reroonie Guideline! Mid Training Program
Potential Event
=====
Gasoline tanker
truck ruptures
^ ^^^^^^
Gasoline tanker
truck leaks
Electric
transformer (10)
rupture
Electric
transformer (10)
leak
Lube oil drum
rupture
Lube oil drum
leak
Used oil tank
rupture
Used oil tank leak
WPD 11-306
water treatment
solution storage
tank rupture
1 ~"F
Location
=====
Plant roadways
Plant roadways
Power Plant
Power Plant
South end of
power plant
South end of
power plant
South end of
power plant
South end of
power plant
South end of
power plant
SSaCSSEK^E:
Volume
(gallons)
5,000
5,000
150 ea.
150 ea.
55 ea.
55 ea.
500
500
275
Spill Rate and
Direction
Instantaneous to
ground in most cases
Non-instantaneous to
ground in most cases
Instantaneous to
ground (no
containment)
Non-instantaneous to
ground (no
containment)
Instantaneous to
concrete pad (no
containment)
Non-instantaneous to
concrete pad (no
containment)
Instantaneous tO
containment
Non-instantaneous to
containment
Instantaneous to
ground (no
containment)
T:W3MIN\SAFErY\HAZWOPER.WPD
31
February 23,1996
-------
Puni Gcothcrinil Venture
*.
Potential Event
==BB=
WPD 11-306
water treatment
solution storage
tank leak
Diesel fuel storage
tank rupture
Diesel fuel storage
tank leak
Gasoline fuel
storage tank
rupture
Oxy-11 solution
storage tank
rupture
Oxy-11 solution
storage tank leak
Millsperse 802
solution storage
tank rupture
Millsperse 802
solution storage
tank leak
_ aasBncnosE
Location
======
South end of
power plant
Northwest
corner of power
plant
Northwest
corner of power
plant
Northwest
corner of power
plant
Well pad D
Well pad D
Well pad D
Well pad D
KOBI^BBESnEI
Volume
(gallons)
=======
1,000
1,000
1,000
270
270
270
270
Spill Rate and
Direction
Non-instfiiit?r>pnilg to
ground (no
containment)
Instantaneous to
containment
Non-instantaneous to
containment
Instantaneous to
containment
Instantaneous to
ground (no
containment)
Non-instantaneous to
ground (no
containment)
Instantaneous to
ground (no
containment)
Non-instantaneous to
ground (no
containment)
T:\ADMIN\SAFETY\HA2WOPER.WPD
32
February 23,1996
-------
Puni Ceothemul Venture
Hummer/Emergency Rooonie CuMelSna Mid Training Proems
L
Potential Event
5=3=:==
Liquid Nitrogen
storage tank
rupture
Liquid Nitrogen
storage tank leak
Abatement skid
15% sodium
hydroxide solution
tank rupture
Abatement skid
15% sodium
hydroxide solution
tanlr lealr
—======
Location
======
Southwest comer
of power plant
Southwest corner
of power plant
Well pads during
annual well tests
Well pads during
annual well tCStS
Volume
(gallons)
_ ^ •— ^-"
??
??
275
275
Spill Rate and
Direction
Instantaneous to
ground' and air (no
containment)
Non-instantaneous to
air or ground (no
containment)
Instantaneous to
ground (no
rnntainmenrt
Non-instantaneous to
ground (no
containment)
T:\ADMIN\SAF]nY\HAZWO!'ER.WPD
33
February 23, 1996
-------
Putu GeotheTmiTVcnture
Ha**>Der/EmeT«ncv Raoonic Guideline* and Training Pnean
APPENDIX 6
EVACUATION ROUTES
T:\ADMIN\SAFETY\HAZWOPER_WPD
34
February 23,1996
-------
Puni Geothenntl Venture
APPENDIX?
CALL LISTS
INTERNAL/EXTERNAL CALL UBTS
AFTER HOURS
BUS. PH.
as^^s^aa
965-6233
Site Manager
Danell Stovall
Plant Engineer
Kent McCue
Operations
Manager
MflceKaleikini
Manager
John Gerbitz
General
Manager
Lvnn White
Financial
Manager
Barry Mizuno
Environmental
Safety Coord.
Darren Hun
T:VADKON\SAFEIY\HAZWOreR.WD
35
February 23,1996
-------
ftm. CmthemiifVenBife
r Remonie GuideEnq and Training Program
TATT. T.TSTS
EXTgJUXA^. irmirmini
POSITION
1/Nvil TVfrrne Apencv
. yJlVll l/Cicnac /ijtwiwy
2. Department of Health
HUo
•
Honolulu
Qean Air
Drinking Water
Noise
Haz Evaluation/Emergency
Resp.
1A Hour - Operator
3. Fire Department/Ambulance
4. Police Department HUo
Pahoa
5. DepL of Land and Natural
Resources
HUo
Honolulu
MTanouye
G.Aldta
6. County Virginia Goldstein
BUS. PH.
935-0031
933-4552
933-4371
1-5864200
1-586-4258
1-586-4701
1-586-4249
961-6022
935-3311
966-7432
933-4279
587-0266
587-0227
587-0230
961-8288
AFTER
935-3311
959-1440
934-7581
959-4289
959-7942
936-6987
969-5206
1-734-2161
1-247-2191
961-6022
935-3311
966-7432
961-6586
PAGER
987-9184
T:\ADMIN\SAFETY\HAZWOPER.WPD
36
February 23,1996
-------
Pmu Ceothemul Vented
CTTERNAL (SECONDARY)
AFTER HOURS
PGV Information Line
For itpottabb qoant&iM: (H2S ZL 100
SM; caistie i. 1,000 BM.; peouoo i 100
1-247-2191
961-6022
1^86-4249
961-6022
*. Htwiii Stot« Emergency RespoaM
(SERC)
b. Hawaii County Fin Deputmo*
e. Hawaii County Divirioa of bdnttxial
Safety (LEPC)
-------
r Response CuideEng ind Training Program
APPENDIX 8
DECONTAMINATION PROCEDURE
LEVEL B DECONTAMINATION
Equipment Worn
The full decontamination procedures outline is for Hazmat tech. wearing Levd B
protection. Such protection consists of: (See Appendix 8 for set up map.)
1. One piece hooded chemically resistant suit
2. SCBA.
3. Hard hat
4. Chemically resistant boots, steel toe.
5. Boot covers.
6. Inner and outer gloves.
Procedure For Full Decontamination
Station 1: Segregated Equipment Drop
Deposit equipment used on rite (tools, sampling devices and containers, monitoring
instruments, radios, clipboard, etc.) on plastic drop cloths or in different containers with
plastic liners. Each will be contaminated to a different degree. Segregation at the drop
reduces the probability of cross contamination.
Necessary equipment includes:
1. Containers of various sizes
2. Plastic liners
3. Plastic drop cloths
Station 2: Boot covers and Glove wash
Scrub outer boot covers and gloves with decontamination solution.
Necessary equipment includes:
1. Container (20 to 30 gallon)
2. Pccon*i>tt"nfl^nn solution
T:VADMDASAFETY\HAZWOPER.WPD
38 February 23,1996
-------
_ . - r« " " HipDoner/EmergencT Response Guideline* Mid Timinine Preenm
Punt Geotnctnm Venture f
3. Two or Three long handle, soft bristle scrub brush
Station 3: Boot cover and Glove Rinse
Rinse off decontamination solution from station 2 using water. Repeat as often as
necessary.
Necessary equipment includes:
1. Container (30 to SO gallon)
2. Pressure spray unit
3. Water
4. Two or Three long handle, soft bristle scrub brush
Station 4: Tape Removal:
Remove tape around boots and gloves and deposit in container with plastic liner.
Necessary equipment includes:
1. Container (20 to 30 gallon)
2. Plastic liner
Station 5: Boot cover Removal
Remove boot covers and deposit in container with plastic liner.
Necessary equipment includes:
1. Container (30 to SO gallon)
2. Plastic liner
3. Bench or stool
Station 6: Outer Gloves Removal
Remove the outer gloves and deposit in container with plastic liner.
Necessary equipment deludes*
1. Container (20 to 30 gallon)
T:\ADMJN\SAFETY\HAZWOPEILWPD 39 February 23,1996
-------
r Rcipome Guideline* tnd Training Program
2. Plastic liners
Station 7: Suit/Safety Boot Wash
Thoroughly wash suit and boots. Scrub suit and boots with long handled, soft bristle scrub
brush and decontamination solution. Repeat as often as necessary.
Necessary equipment includes:
1. Container (30 to 50 gallon)
2. Decontamination solution
3! Two or Three long handled, soft bristled scrub brushes
Station 8: Suit/Safety Boot Rinse
Rinse off decontamination solution by using water. Repeat as often as necessary.
Necessary equipment includes:
1. Container (30 to SO gallon)
2. Pressure Spray unit
3. Water
4. Two or Three long handled, soft bristled scrub brushes
Station 9: SCBA Tank Change
If a Hazmat Tech. leaves the Exclusion Zone to change an air tank, this is the last step in
the decontamination procedure. The Hazmat Tech. air tank is exchanged, new outer gloves
. and boot covers donned, and joints re-taped. The Ha/mat Tech. then returns to work.
Otherwise, the Hazmat Tech. proceeds to station 10.
1. Boot covers
2. Gloves
Station 10: Safety Boot Removal
Remove safety boots and deposit in container with plastic liner.
Necessary equipment includes:
T:\ADMIN\SAFETY\HAZWOPER.WPD
40 . February 23,1996
-------
Pun. Ceothcn^l Venture H.iwopcT/EmcrEcncv Response Guideline. «nd Ti«n5nR Propim
1. Container (30 to SO gallon)
2. Plastic 1'nM>
3. Bench or stool
4. Bootjack
Station 11: Suit and Hard Eat Removal
With assistance, remove suit and hard haL Hang suits on a rack or lay out on drop cloths.
Necessary equipment includes:
1. Rack
2. Drop cloths
3. Bench or Stool
Station 12: SCBA Removal
While still wearing fax, piece, remove backpack and place on table. Disconnect hose from
the regulator valve and proceed to the next station.
Necessary equipment includes a t?b^gT
Station 13: Inner Gloves Wash
Wash inner gloves with decontamination solution that will not harm skin. Repeat as often
as necessary.
Necessary equipment includes:
1. Basin or bucket
2. Decontamination solution
3. Small table
Station 14: Tnnra- Gloves Rinse
Rinse fa""1 gloves with water. Repeat as often as necessary.
Necessary equipment includes:
1. Water
2. Basin or bucket
TMDMiN\SAFerinHAZwoFER.wFD 41 February 23,1996
-------
. . M.-.u^>^.^».^^n^ Ranome Guideline! tnd Training Program
Puni Ceothentut Vcntm*
3. Small table
Station 15: Face Piece Removal
Remove fece piece. Avoid touching fece. Wash respirator in clean, sanitized solution.
Allow to drip dry and deposit face piece in plastic bag and relabel.
Necessary equipment includes:
1. Plastic bags
2. Sanitizing solution
3. Cotton wipes
Station 16: Inner Gloves Removal
Remove inner gloves and deposit in container with plastic liner.
Necessary equipment includes:
1. Container (20 to 30 gallon)
2. Plastic liners
Station 17: Field Wash
Shower if Sodium Hydroxide is present If shower is not present, wash faces and hands.
Necessary equipment includes:
1. Water
2. Soap
3. Small table
4. Wash basin or buckets
T:\ADMIN\SAFETY\HAZWOPER.WPD 42 February 23,1996
-------
COMPLETE DECONTAMINATION LAYOUT
FOR LEVEL B PROTECTION
t
EXCLUSION
ZONE
Outer Olov*
ftenowil
7«ot
CONTAMINATION
REDUCTION
ZONE
«>•—(,£
Boot Conr Boot Cow 4
OJovoMnM
Drop
HotflM—-i
3i*/3cftty Boot
WuA
Suft/SCaA/Boat/Olov*
RkiM •
Scfety Boot
ftameval
hmr Qlev*
Fae
Rwnovml
MMT CwUlfclQ
WIND
DIRECTION
Control UM
1
SUPPORT
ZONE
43
-------
MINIMUM DECONTAMINATION
LAYOUT
FOR LEVEL B PROTECTION
| Redress: Boot Covers
I and Outer Gloves
WIND DIRECTION
-^
Equipment
Drop
Plastl
^•^^—
-»
c
—————— — •
1 Oecoei
z | Solution
- 1
Oecon Outer >^
Garments >^
^^ QMIVTMM
>^ Beet Covers
^/wA Cuter GIOVM
I' \\
5 1 S«
^ T*
**" 0»n«i
M
•
+ * 6
> + \^
k
nk
i-O«ef
tit
&— *•
!^
• Boots/ Qoves
and
Outer
Garments
(For DUooaal
and Ctl-Ste
Decontamination)
b
Can
*««• A«||M«|
Sieet
(10 cation)
(32 gallon)
REMOVE
SC8A
44
-------
Puni Geothemiil Venture
r Reroonte GuidcSnei tnd Training Praemn
APPENDIX 9
PERSONAL PROTECTIVE EQUIPMENT (PPE)
AND
EMERGENCY RESPONSE EQUIPMENT
T:\ADMDASAFCTY\HAZWOPE1LWD
45
February 23,1996
-------
Puna Ceethennil venture
Reroenie Guidffa« •»* Training Program
1.
2.
P.P .E AND EMERGENCY EQUIPMENT
Central Siren located on CSC building. Activation switch is in CSC.
6 hand held battery powered radios for use by general plant personnel. Approximately 15
backup batteries.
Additionally:
3
Sit* M?nagM"
• l hand held radio and charger system
1 hand held radio and charger system
*
1 hand held radio and charger system
>/aint«»nan^ Manager
• 1 hand held radio and charger system
1 hand held radio and charger system
Phr>n<»<'
• 1 Site Manager vehicle
• 1 General Manager vehicle
• 1 Financial Manager vehicle
1 CSC building
1 Site Manager
1 Plant Engineer
1 Safety Training Coordinator
1 General Manager
1 Maintenance Manager
1 Operations Manager
T:\ADMIN\SAFETY\HAZWOPER.WPD
46
February 23, 1996
-------
Hazwopcr/EmcrEcncy R«pon«c CoideEnci u.«l Tnunin,; ftopnm.
• 1 Instrument Technician
1 Plant Engineer's Office
• 2 CSC Building
g ftfl«» Padin Station?
• Central Station Control
•j Civvial Tp1f»nVER.WPD 47 February 23,1996
-------
Hmwocr/Emergcncy Response Guideline* and Turning Program
Shop)
C. 5 Minute Escape Paks- (Bag over head type):
Located at Wellpad A Safety Trafler.
Special Clothing - Protective Suits in Plant Maintenance Workshop Storage
Room General Storage Inventory:
Rubber Boots
Rubber Gloves (Impervious To Caustic)
Rubber Type Slicker Pants and Jackets
Goggles
Face Shields
T?T.{p,..»n» fnr g^ll / T
Shovels - Shop
Rakes -Shop
Tube Absorbents - Warehouse
Absorbent Pads • Warehouse
Pipe Clamps - Warehouse
Drum of Absorbent - Shop
T:\ADKQN\SAFETY\HAZWOPER.WPD
48
February 23,1996
-------
Punt CeothenriilVentuig,
: BuMelina tnd Training Prog
APPENDIX 10
INCIDENT CRITIQUE FORM/RELEASE REPORT FORM
T:\ADMIN\SAFFTY\HAZWOPEILWFD
49
February 23,1996
-------
_ _ .. -.<,*' HiiwpBer/Emertetiey Rcaponie Guideline* and Training Program
Puru Ceethermtl venture ~ r • r
INCIDENT CRITIQUE FORM
1. Date
2. Time of Incident
3. Location
4. Time to Terminate the Incident
5. Description of Incident
6. Description of Response Action
ANSWER THE'FOLLOWING DURING THE DEBRIEFING SESSION
7. Did the personnel expected to evacuate the area respond appropriately to the established
Emergency Response Plan?
8. Hew was me emergency response team dispatched? Was it through the establish
of
9. Did the emergency response personnel don the correct protective clothing?
T:\ADMBnsAFETYVRAZwopER.w?3 SO February 23,1996
-------
Punm Geothermtl Venture
r Reaponie Guideline* and Training Program
10. Who was involved in the incident and what was their function?
MAME
•Rfff F
11. What procedures need to be changed? What personnel?
12. What procedures are satisfactory, which need additional exercise?
13. What supplies or protective equipment was needed, but was lacking?
14. What supplies/protective equipment needs restocking?
15. Rate the overall Incident Response:
Excellent Good Fair Poor
T:\ADMIN\SAFETY\HAZWOPER.WPD
51
February 23,1996
-------
Punt CeethetniilVehBiie,
PGV RELEASE REPORT
be completed for nomnjurious accident. ^ »^ w *^ ^P !^
S«oao^
Coordinator's office.
Supervisor:.
Witness: —
Personnel Involved: _
Location of Incident:.
.Date:.
. Tune of In^
Description of Incident,
Material Involved:.
Action Taken:,
Damage:.
T:\ADMIN\SAFCTY\HAZWOPER.WPD
52
February 23,1996
-------
APPENDIX E
PGV Emergency Action Plan and Notification Guidelines
-------
PUftA GEOTHERMAL VENTURE
(PGV)
EMERGENCY ACTION PLAN
AND
NOTIFICATION GUIDELINES
Revised February 23,1996
IMPORTANT
• UpO& nfttififfariqn QJ rii«r«rnii»ty of any UpSCt OOPditJOfl Or HtaTfimgrinni
fhaf results in an unplanned release of geothennal fluid/stem
majnr stored Vfflpd spill, the operator in charge of notification
untidy (*ivi1 TVff^y*
. (day. 935-0031/nighc 935-3311 and the Department of Health (see
page 1C); Also see page .11 far reportaUftgoantil^xelease* reporting "
^requirements,' .•
-------
1.0 INTRODUCTION
The following Emergency Action and Notification Guidelines are provided so that all
personnel will understand the uniform practices which are to be employed to provide quick
and effective response to emergencies that might arise at the plant site.
Each employee will be instructed in the proper response to an emergency and these
procedures will be available in the workplace for employee review.
Because the safety of our employees is of primary concern, the Site Manager and each
member of the staff shall be committed to providing a safe, healthy, work environment and
are responsible for insuring the correct implementation of these programs.
The Emergency Action and Notification Guidelines have been prepared in an effort to
ensure that:
• Plant personnel will be protected in the event of release of flammable or toxic materials
• The DerSOnnel involved an* au/ar*1 nf their respnnqhilJTy tn pmtert nenple in the qirmnnriing
area in the event of an incident which could result in toxic vapors traveling beyond the plant
boundaries.
• The personnel involved are an/an* nf thfir responsibility tn notify certain local, state and
federal authorities in the event of an incident which might endanger the general public
and/or the quality of the environment.
• It is the further intent of the plant to insure that proper and immediate action be taken by
responsible people to minimize both the duration and effect of any incident. This plan can
only be successful if an employe* nr wHrity personnel who sees a spill or release
immediately notifies Central Station so that plan procedures can be initiated.
• It is also important to understand that during periods when facility staffing is at a minimum,
such as off-hours and weekends, the operation personnel on shift are required to initiate in-
plant emergency and notification plant should an emergency occur. This means that *aph
Lead Operator must be totally familiar with all emergency plans and procedures and know
how to reach off-duty Management.
• All plant personnel will receive training on these Emergency Action and Notification
Guidelines.
• In the unlikely event that speciality services are required to control an emergency, a
complete site characterization and hazard identification will be completed prior to entry.
T:\ADMINUAFrnrEAP.WPD Mmo? 21.1996
-------
2.0 KEY PERSONNEL AND RESPONSIBIIJnES
'
as follows:
Tnririrnt Hr1™"'1"'
Manages the overall Emergency Response
Responsible for safety of public, contractors, employees
Minimize loss of property & property damage
Determines when emergency is under control or when to withdraw
Performs administrative and organizing duties
Communicates internally and externally
Directs security forces
Ensures training is adequate and current
• Determines level of initial response required
• Directs appropriate level of notification
• Supervises direct actions to mitigate spills or releases of hazardous materials or substances
• Develops decontamination procedures
Him"*"1" M**»"'a' TVrhnipian
• Inspect all emergency response equipment on a monthly basis
• Perform head count at gate and knows how many personnel are on-site at all times
• Ground and traffic control
PnnrHinatnr
• Functions as company spokesman with media
All Want "PgrtnnTH»1
• Anyone who becomes aware that an emergency situation has occurred or might occur must
immediately contact the Lead Operator who notifies Site Manager and other key personnel
of emergency or potential emergency situation using Internal Call List on page nine.
T:\ADUUASAFimEAP. WPD nM7 3.199S
-------
2.1 - JEMERGENCY RESPONSE TEAM
s*£'.*$3$££f$*±
Incident Commander
Hazardous Materials
Specialists
Hazardous Material
Technicians
Security Coordinator
Media
Coordinator/Spokesperson
First Responder Awareness
Level
Post Emergency Responder
PRIMAK^^^^^
Darrell Stovall
Darren Hunt
BillWiebe
Jim Fordham
Steve Wong
Mike Kim
Ron Quesada
Kellert Park
Al Beaver
John Boots
Les Doctor
John Tompkins
Jjfs Zimmerman
Dan Vesey
Larry Harvison
Richard Dods
Lynn White
All Personnel
Darren Hunt
ALTERNATES 'I
John Gerbitz
MikeKaleikini
Randall Brady
BobCulnan
RickDuVoisin
Howard Burdett
Barry Mizuno
T:\ADUmSOSniEAP.WPD
-------
3.0 PERSONNEL REPORTING INSTRUCTIONS
• Upoa finding a release or spill, the first action will be to call CSC by way of radio.
Personnel will be notified of a significant chemical spill or leak by means of fceplant radios
l is incidental. If the leak is other than incidental, the Lead Operator will
the plant siren, (which sounds ^as^y^:tones^ Tnisahrm
from the Control Room. Tne lead operator will then initiate the 0=AP). Upon
*i«™. the initial areas for personnel to report to are as Mows:
The Response Team Members will report to the Cnnfrnl Knnm which will serve as the
Central Command Post.
Maintenance personnel will report to the Miinfpmnrp Workshop where head count will
be taken, or to the Meeting Point 2 if the plant is unsafe.
Administrative staff will report to the A rimin 1 frailer where head count will be taken, or
to the Meeting Point 2 if the plant area is unsafe.
Visitors on-site will proceed to the Viinfpiianrp Shop and check in. Contractors working
in the plant area will proceed to the Maintenance Workshop and will check in with the
Maintenance Supervisor. Secondary Meeting, if the plant is not safe; Meeting Point 2.
Drilling personnel will report to ypll pad staging a™" and await further instructions from
the Incident Commander. If these are unsafe they will report to the Maintenance Shop.
NOTE' Traffic control (Guards) will have radios for communication with the incident
commander. All designated attendance checkers will have radios for communication with the
Incident Commander.
7. \ADMlN\SAfEn\EAf. VPD Ftbnary 21.1996
-------
4.0 DUTIES CHECKLIST FOR EMERGENCY RESPONSE
PGV On-site Personnel (Lead Operator)
1. Immediately notify CDA and other appropriate agencies
2. Obtain facts on the nature of the emergency.
3. Notify Incident Commander
Incident Commander
1. Determine nature and scope of event.
2. Determine if injured employee action is necessary.
3. Determine if evacuation is necessary.
a.) Determine if personnel need to proceed to initial or secondary meeting areas.
b). If evacuation from the meeting area or plant is necessary, the meeting area
leader will be notified by radio.
4. Activate, if necessary, Hazardous Materials Specialists and Technicians.
5. Determine if specialty services are required and conduct preentry briefing
6. Brief Media and Security Coordinators.
8. Authorize Decontamination procedures.
. 9. Develop site characterization and hazard identification for any specialty services prior
to entry.
10. Notify agencies if a reportable quantity release is suspected.
Hazardous Material Specialist
1. Alert Hazardous Materials Technicians.
2. Conduct briefing of response level and activate.
3. Provide updates to Incident Commander.
4. Secure release.
3.199f
-------
5.. .Develop Decontamination procedures and communicate to team members.
6. Assist with site description and hazard identification for special services.
Hazardous Material Technicians
1. Participates in controlling and stopping spills, leaks', or releases that may occur.
Post Emergency Responder
1. Initiate neutralization and cleanup activity, as needed.
2. Assess damage and document findings.
3. Assess Notification and Reporting Activity and document facts.
4. Document facts, action and results of incident and response. Provide copies as
required to management and outside agencies.
T:\ADiaNWFEn\XAf. VPD ftbnarj 33.1996
-------
5.0 -POST EMERGENCY REPORTING PROCEDURES
HP PPT
Following the occurrence of a spill of a reputable quantity or any emergency situations
described in this plan and in compliance with the GRP, ATC, and other County or State
requirements, an incident report will be prepared by the PGV Environmental/Safety
Coordinator and transmitted to the appropriate individuals and agencies after review by PGV.
These include the following:
Federal National Response Center
Hawaii County Civil Defense Agency
Hawaii County Planning Commission
Hawaii State Department of Health, Clean Air Branch "
Hawaii State Emergency Response Commission
FOT T OW-TTP
The Environmental/Safety Coordinator shall compile all documentation and perform a post-
accident investigation. Immediate performance of this activity will aid in determining the exact
circumstances and cause of the incident Issues to be determined include:
• Cause of the incident
• Effectiveness of the emergency response procedure
• ' Need for amendments to the response plan
• Need for additional respondent and training programs
T:\ADUItWfEJTEAf.WPD Ftbnay 33.1996
-------
6.0 COMMUNICATION
Timely and efficient communications are essential to deal with an emergency response
ituation. For that reason, the Mowing requirements have been established.
Only the following personnel are permitted to use the telephone lines during an emergency:
• Incident Commander
• Hazardous Material Specialist
Only the Mowing personnel are permitted to use hand held radios during an emergency:
Incident Commander
Hazardous Material Specialist
Evacuation Meeting Area Leaders
Security Coordinator and/or Gate Guards
Others as designated by the Incident Commander
Use of hand held radios:
• Keep message brief and simple
• Communicate using position titles
. Yield to those individuals using the hand held radios who are the most directly involved in
the emergency response activity
If radio communications are not clear (i.e. radio problems) proceed to CSC.
All internal communications on hand held radios will be on Channel 1.
The Control Room Operator must have the base station radio in the 'scan' mode to receive all
channels that could be used.
All hand held radios are recharged daily with backup batteries ready for use.
The Plant siren is tested monthly to assure effective operation. .
For off-shift communication to alert key personnel, the following requirements have been
established.
1. The lead operator will initiate the (EAP) by phone calling primary personnel as
identified in the (EAP). If primary personnel cannot be reached first by phone,
then dial the person's pager and press the "#" key. If this fails, begin notification
of designated alternates.
T:\ADMIMSAFEmEAP.WPD Ftbnurj U. 1996
-------
7.0 INIZRNAL/ETTERNAL CALL LETS
POsiiJON
BUS. PH.
AFTER HOURS
PAGER
i. SteMuapr
965-033
2. PUntEnfbeer
KentMeCoe
96MZB
3. OpenaoM Muifcr
965-620
5..Ce»cn
LYIU WhrtB
9654233
5.
BuyMituao
96S4Z33
96S-6233
T:\atuunufurur.wro
-------
TATT.T.TSTS
EXTERNAL (PRIMARY)
POSITION
2. Department of Health
Hilo
Hdaohihi
Clean Air
Drinking Water
Noise
Haz Evaluation/Emergency Resp.
24 Hour- Operator
3. Fire Department/Ambulance
4. Police Department
Hflo
S. Dept. of Land and Namral Resource*
Kilo
Honolulu
M.Taaouye
G. Akita
BUS. PH./
9354031
933-1552 ,
933-1371 ;
•
f
B
1-58M200 .
1-586-4258
1-5864701.
1-586-4249}
961-6022 '
935-3311
966-7432
933-1279
5874266
587-0227
AFT£R
935-3311
959-U40
934-1581
959-4289
959-V42
9364987
969-f206
1-73^2161
1-24^^91
,
961&22
935-3311
966-7432
961-6586
PAGER
(
987-9184
T:\ADMItflSAFZTflEAP. WPD
10
Fibmarj 33.1996
-------
EXTERNAL-fSEGONDAJlY)
POSITION
BUS. PH.
AFTER HOURS
PAGER
1. Socuay: Rfeturf Dodi. Bom
6. *PCV RefBooM Lhe
935-0804
9354804
7. "PGVInfbnMaonlJna
934-9072
8. For Kpoxttbb cpuoomat: (H^S Ji 100 tt»;
caustic i 1,000 BM.; peauaa >. 100 Jb».)
*. Hawaii Scua Emetj«cy R«*pon»
b. Hawwi Couay J» Deputmott
c. HktHui Cougy DMaoa of Inrfngn'al
d. Xiriotal Remome Center
1-S85J249
961-60ZZ
9614215
1-800-124-8802
1-247-2191
961-6022
•Call tins «m-i»»« to pn «"i*"t inf'ii"»t"n* to f^ij* openton it tho mpume IBM •"«m>i in* i
•*PCV Infonuarion !-•?•! CSC wiQ ciuage mess&g« to •rr*1*"' «*"•"«««
-------
MESQUTIE GROUP
CTDD WELL CONTROL
RESOURCE GROUP
RESOURCE GROUP
SERVICE & MARINE CO.
HALLIBURTON SERVICES
ENVIRONMENTAL MANAGEMENT
ASSOCIATES
i:
-------
EQUIPMENT AND SERVICE CONTRACTORS.
XUSTICJREMOVAL
PKOPAVF. KFMOVAT,
WF.T .
T:\ADMtfiSAFEn\EAf.Wm
-------
MFETINC POINT 1 \
1 POWER
PLANT
PMOUCIWH Will. (PMOKMU)
nraouciMN wta (OOSIMC)
mccnoH »fu
4 ptuccro «IL
CC011KMM. UASt WUNOMI
A ru.- uowrama SUIKM
PUNA CEOTUERUAL VENTURE
MEETING POINTS
AND PRIMARY EVACUATION
ROUTES
-------
9.0 NON-EMERGENCY RESPONSE PROCEDURES
PUNA GEOTHERMAL VENTURE
AIR QUALITY NOTIFICATION PROCEDURES
Tie following outlines the procedures Puna Geothermal Venture (PGV) personnel will
follow relative to the emission or potential emission of hydrogen sulfide (H,S) or excessive
noise at the PGV project rite. A similar approach will be taken in situations or potential
situations involving other hazardous materials.
Oyprall VftHfiratfo" Pnllry
Provide notification on all routine activities as well as all nonroutine operations as
accurately as possible in a timely manner, based on the "potential" for a problem instead of
waiting for a problem situation to occur.
^ir Quality Monitoring
Monitoring is accomplished on a 24-hour basis through the utilization of three permanent
meteorological and air quality monitoring stations and supplemental mobile monitoring.
Hydrogen Sulfide readings at the three permanent monitoring stations are available on an
hourly average basis and a data acquisition system allows real-time H,S measurements from
monitoring stations.
\frmif orin
Mobile monitoring is done by trained PGV personnel. Permanent monitoring stations are
maintained and monitored daily by a private consultant (INTECH) and by PGV personnel.
Xnf ifirofinn
During drilling a drilling supervisor will be on the pad 24-hours a day and serve as the
"internal" notification person regarding drilling activities. If an incident or event occurs
which could cause H2S or noise issues he will immediately contact the Lead Operator in
Central Station. When drilling operations are in progress, the drilling supervisor will carry
both a beeper and portable radio.
The Lead (or CSQ Operator will perform/direct all initial notification activities for the
power plant and well field. The Incident Comman der upon being alerted of an event wfll
miff, over assurance of required notifications and necessary actions. A dedicated phone line
to Central Station will be p?««taiti»H for incoming agency calls (965*7486).
T:\ADUltnSAFSmEAP.WPD • Ftbmaiy 33. J996
U
-------
Jnt^mal
staff
T;\ADUlN\SAfrrT£Af. WPD Ftbnaiy 23.1996
16
-------
EQUIPMENT AVAILABILITY
1. Central Siren located on CSC building. Activation switch is in CSC.
2. 6 hand held battery powered radios for use by general plant personnel Approximately 15
backup batteries.
Additionally:
fiife Manager?
• 1 hand held radio and charger system
fV)erarinn« Manager?
• 1 hand held radio and charger system
Ope
rator*
1 hand held radio and charger system
Manager*
1 hand held radio and charger system
Plant
Engi
1 hand held radio and charger system
3. Mnhile Phnne**
• 1 Site Manager vehicle
• General Manager vehicle
• Financial Manager vehicle
4. Paeer $y
-------
5 Bay Pafft* T fwarinn*
• Central Station Control
7.
Dedicated line to HELCO (Electric Company)
1 general phone line in CSC
A. Breathing Apparatus • Respiratory Protection Equipment:
• 12 Self Contained Breathing Apparatus (SCBA)
30 minute capacity
Located throughout Power Plant and Active Well field areas.
See map
1 SCBA located in CSC
• 1 SCBA Training Unit located in CSC
Well field: Located On Well Pad A:
• 10 Fifty Foot hoses
• 7 Full Face masks (work paks)
• 10 Bottle • Cylinder Cascade (Breathable Type D Air) System (for
Cylinder refills)
• 7 Egress 5 Minute Cylinders
• 6 Bottle - Cylinder Cascade (Breathable Type D Air) System
Breathable Air is resupplied by :
Telephone Number - 935- 6939 (Nautilus Dive Shop)
C. S Minute Escape Paks - (Bag over head type):
Located at WeUpad A Safety Trailer
Special Clothing - Protective Suits in Plant Maintenance Workshop Storage
Room General Storage Inventory:
• Rubber Boots
• Rubber Gloves (Impervious To Caustic)
• Rubber Type Slicker Pants and Jackets
T:\ADHltflUFEIY&lf. VPO Ftbnaiy 23, 1996
U
-------
Goggles
Face Shields
far
Shovels - Shop
Rakes-Shop
Tube Absorbents - Warehouse
Absorbent Fads • Warehouse
Pipe Clamps - Warehouse
Drum of Absorbent - Shop
T:\ADUMSAFZ7TLiP.WPD
19
Ftbnury U. 1996
-------
C VII11
,II:I:IIHG POINT 2
I
i
Mi;:i.niicj POINT 1
CI.HIIIOI. iiimiiiim
,-\ . ., -%.1-ownii
' \ V -S l'l.AHi^^
*
-------
MEDICAL SURVEILLANCE AND CONCILIATION
Besides the baseline physical exam for Hazmat Team members and Hazardous Material
Specialists, any of these Emergency Response Employees who exhibit signs of symptoms which
may have resulted from exposure to hazardous substances during the course of an emergency
incident at PGV, wffl be provided (either immrdiatfJy or subsequently) medical consultation.
If the examining physician determines that follow-up examinations or consultations are
medically necessary they will also be provided.
Information required and specified in the OSHA Federal Regulation 1910.120 will be provided
to the physician. A copy of the physician's written opinion will be provided to the employee
and shall contain data specified in the OSHA standard.
T:\ADMIMSAfSZrW.Vm ' ftftnu? 23. J99S
21
-------
APPENDIX F
Hawai'i County Emergency Operations Plan, Table of Contents
-------
COUNTY OF HAWAII
EMERGENCY
OPERATIONS
PLAN
PREPARED BY 1NE
SWE CMl DEFENSE DIVISION
fORIHE
HAWAII CIVIL DEFENSE AGENCY
-------
"MVRTJ5 Of CONTENTS
Page
^^
EXECUTIVE SUMMARY ...........................................
Ill
SUPERSESSION ..............................................
TABU! OF CONTENTS ................. •. .........................
v4
RECORD OP REVISIOiiS. •••• ....................................
D1STRIBUTI01I LIST ...........................................
LIST OP COMMON ABBREVIATIONS ................................
BASIC PLAN ..................................................
I. GENERAL ............................................. l
H. MISSION ............................................. 2
TTT. RESPONSIBILITIES AND FUNCTIONS ...................... 2
IV. IMPLEMENTATION ................ i ..................... 5
•
APPENDIX 1 - DISASTER RESPONSE CHECKLIST ........... 15
V. DIRECTION AND CONTROL ............................... 6
VI. READINESS EVALUATION ................................ ll
LI
A. ORGANIZATION.
B. HAZARD ANALYSIS B"1
I. OVERVIEW B-l
n. TYPES OP HAZARDS ••• B'2
m. VULNERABILITY B'4
IV. HAZARD MITIGATIOH B'5
-------
APPENDIX 1 - POTEWIAL VOLCANIC HAZARDS B-l-1
APPENDIX 2 - POTENTIAL FLOOD HAZARDS B-2-1
APPENDIX 3 - TSUNAMI IHUNDATION MAPS B-3-1
C. HAWUMG AND EVACOATIDN C-l
X. OVERVIEW c'1
H. RESPONSIBILITIES AND FUNCTIONS C-4
HI. CIVIL DEFKNSti SIREN SIGNAL C-6
IV. EMERGENCY BROADCAST SYSTEM (BBS) C-8
APPENDIX 1 - CIVIL DEFENSE WARTIME READINESS
CONDITIONS (REDICONS) C-l-1
APPENDIX 2 - ACCIDENTAL MISSILE LAUNCH WARNING C-2-1
APPENDIX 3 - HAZARDS WITH LITTLE/NO WARNING TIME... C-3-1
APPENDIX 4 - HAZARDS WITH WARNING TOffi C-4-1
D. ClVd DEFENSE............»..,......•...•••••»•••••••••••• D~l
EMERGENCY OPERATING CKNTEK ORGANIZATION - Chart D-l
I. EhtiMifcnkY REfituHiilBILAXAiia -D-2
H. DISASTER ORGANIZATION - DUTIES D-3
APPENDIX 1 - DISASTER COMMUNICATIONS CAPABILITY
GUIDE .' D-l-1
APPENDS 2 - REPORTS AND REPORTING PROCEDURES D-2-1
APPENDIX 3 - EMERGENCY PUBLIC INFORMATION
rr*~ f•"••»•-*«-
D-3-1
APPENDIX 4 - SUGGESTED CIVIL DEFENSE. PROCEDURES IN
TERRORIST SITUATIONS D-4-1
E. POLICE E-l
DISASTER RESPONSE ORGANIZATION - Chart E-l
vi
-------
I. DISASTER PREPAREDNESS AMD RESPONSE _ E'2
n. DISASTER ORGANIZATIOM - DUTIES E'3
' APPENDIX 1 - SUGGESTED PROCEDURES HI TERRORIST
SITUATIONS.. • •••• •
P. FIRE-RESCUE
'DISASTER RESPONSE ORGANIZATION - Chart *'1
I. EMERGENCY PREPAREDNESS AND RESPONSE M
H. DISASTER ORGANIZATION - DUTIES F"3
G. PUBLIC WORKS AND ENGINEERING G~1
PUBLIC WORKS AND ENGINEERING DISASTER RESPONSE
ORGANIZATION - Chart G~1
DISASTER PUBLIC WORKS DEPARTMENT FACILITIES - Listing... G-2
I. DISASTER PREPAREDNESS AND RESPONSE
n. DISASTER ORGANIZATION - DUTIES
H. HEALTH AND MEDICAL H~l
HEALTH AND MEDICAL DISASTER KtSPUNbE ORGANIZATION -
Chart H'1
I. DISASTER PREPAREDNESS AMD RESPONSE H"2
H. DISASTER ORGANIZATION - DUTIES H'3
APPENDIX 1 - SPECIAL CONSIDERATIONS DURING AN
EVACUATION.
H-l-1
I. MASS CARE X"1
DISASTER RESPONSE ORGANIZATION - CHART 1-1
I. DISASTER PREPAREDNESS AND RESPONSE I~2
H. WARTIME...; x~*
APPENDIX 1 - PROTECTION OP THE ELDERLY AND
HANDICAPPED I'1'1
vli
-------
APPENDIX 2 - SEVERE HEATHER/TSUNAMI EVACUATION
SHELTERS .............................. 1-2-1
J. SUPPORT AND ASSISTANCE
I. DISASTER PREPAREDNESS AND RESPONSE
jj, RESPONSIBILITIES
X. OTILITIES .................. •••• .........................
UTILITY SERVICES DISASTER RESPONSE ORGANIZATION - Chart. K-l
___ ___ K— 2
UTXLITXBS ...............................................
I. DISASTER PREPAREDNESS AND RESPONSE .................. K-3
n. EMERGENCY ORGANIZATION - DUTIES ..................... *--«
L. RADIOLOGICAL PROTECTION GUIDE ...........................
I. PURPOSE .............................................
H. CONCEPT ........................ \ ....................
•
APPENDIX 1 - RADIOLOGICAL DEFENSE GUIDE ............. L-l-1
APPENDIX 2 - RADIOLOGICAL INCIDENT RESPONSE GUIDE
(UNDER PREPARATION) .................... L-2-1
M. OIL AND HAZARDOUS SUBSTANCES RESPONSE PLAN .............. M-l
I. OVERVIEW ............................................ M-l
H. AUTHORITIES ......................................... M~l
XH. CONCEPT OP OPERATIONS ............................... M-l
XV. RESPQH3I&XLXTIES AND FTuturxUNS.. .............. ...... M-2
V. DIRECTION AND CONTROL ........... • ...................
VI. imyjjf JLCATIOiH HmwiiiiURES. .«..............«.»»«•»»»««•
Vn. WARNING AND EVACUATION .............................. M-2
VXH. RESOURCE MANAGEMENT ................................. M-2
viii
-------
IX. PROCEDURES FOR TESTING AMD UPDATING THIS PLAN M-3
x. TRAINING M"4
XI. ABBREVIATIONS AND DEFINITIONS M-4
N. RECEPTION AND CARE OF EVACUEES AND CONCURRENT
MANAGEMENT OF RESOURCES (UNDER PREPARATION) N-l
0. FALLOUT SHELTERS (UNDER PREPARATION) 0-1
P. EMERGENCY RESOURCES MANAGEMENT (UNDER PREPARATION) P-l
-------
APPENDIX G
Hawai'i County Fire Department, Emergency Response Procedure to
PGV
-------
HAWAII COUNTY FIRE DEPARTMENT (HFD)
ar.? 3S 5 SSSZ
Medic 5 Keaau 2 personnel
Assistant Chief Central 1 P«sonnel
Rescue 2 Waiakea 3 personnel
X^2 Waiakea 2 personnel
All 13 personnel to be equipped with
apparatus (SCBA), personal protective eP™ e encwulated
s«%:«^
SStside tS gate adjacent to PGV Office (PGV Command Post
IPGV-CP]) and assist PGV personnel when ever possible.
To be activated immediately after initial response.
Medic Alpha Unit Kavailani 1 P6"0™^
Medic Alpha Unit Central 1 personnel
The medic alpha unit from Central shall respond.^20 spare
Scott tanks from Central storeroom. On arrival at PGV-CP,
tanks to be transferred to X-2.
Personnel on medic alpha units to be equipped with SCBA, PPE
and raincoat.
Should Civil Defense (CD) decide to activate its
Will be the liason. ^
If hydrogen -sulfide (H2S) levels exceed 'Imparts per billion
(PPB) and CD issues an evacuation order, HFD units will
relocaS to a sub-command Post (s«b-CP) either at the
intersection of Highway 130 and Leilani Blvd.^ or
and Highway 132, depending on wind direction. «*.
ftva emit ion
Evacuation Center shall be the Pahoa Neighborhood Community
Center. 0R~.J^ l*>PJ£A7ap. *
HFD units will not go house-to-house to alert residents
-------
Emergency Response to PGV
Page 2
• ^
When CD issues the evacuation order:
1. Fire Dispatch will notify EMS-1 to activate Medic 5
Alpha to Advanced Life Support status (already ^^pre-
arranged with EMS 1) . Medic 5A to standby at Keaau
Station and assume Medic 5's assignments.
2. Fire Dispatch to notify Engine Co. 5 to recall a*MICT
and eXEMT to nan Medic SA.
3. The medic alpha units from the sub-CP with
and 2 rescue personnel each, shall be SCBA, PPE ana
•raincoat equipped; the drivers with mask on, tank and
unit laying on seat, and Rescue personnel sitting in
patient compartment with fully donned SCBA
The 2 medic alpha units to travel all streets starting
Som PGV, working outward. The Assistant Chief or Eng.
Co. 10 Captain will divide and assign districts to eacn
unit.
Medic alpha units will be on frequency 4 with ™ switch
set on radio mode and volume adjusted for evacuation
alert A unit from sub-CP will also be on frequency 4
witE siren inSand transmit the -Evacuate - Evacuate
wt sren y
- Evacuee" PA mlssage at a good interval, Busing
periodically in case medic alpha units need to com-
&SK "r a-dyi"or »TyS2.-23r JB. next
to^ntir voic?boxes SLitch'their radios off and on.
Medic alpha units to assist residents in »««**»
Sopping and rescue Personnel bringing patients into
patient compartment and administering 02 by masks (M 5 *
M-10 now carry 02 manifolds that hook to large 02 tank ^
and can a'ccomodate 6 masks each) . Patients to be taken
S.S SfnolpiSi-by^-Sr^^^^^
by Public Works, or other
•
Upon completing the wtrte' evacuation area with the
Sitialivacuation order, medic alpha units are to
return to the starting point and covert *e entire
SSSffi ffiU-SSLS?^^
overcome, etc.
Each individual is responsible for monitoring his air-
supply and changing tanks at CP when necessary.
-------
APPENDIX H
Request for Documents to Review
-------
REQUEST FOR DOCUMENTS FOR REVIEW
At the visit to the PGV facility on August 7,1996, the EPA team requested copies
of certain documentation that were needed in the evaluation of the PGV Emergency
Response Plan. In a letter dated November 15,1996, EPA reminded PGV of the
need for that requested information. Mr. Jack A. Dean, Vice President and General
Manager of PGV, in a letter dated March 24,1997, acknowledged the request for
information with a promise to deb'ver. Mr. Dean "apologized for the extended
amount of time required thus far" and stated that "it is anticipated that the data will
be ready to send in the next several weeks."
During a September 1998 meeting between Mr. Dean and EPA in the San
Francisco office, Mr. Dean reported that some of the requested items, such as the
process hazards analyses were measurably too large for photocopying. He offered
to provide the documents at a "to be determined" location for review by available
members of EPA's Review Team. In September 1998, after consulting with a non-
EPA member of the Review Team, it was decided that work schedules were not
conducive for such a document review and at that late date the draft report was
almost complete.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Strtet
Sin Francisco, CA 94105-3901
November 15, 1996
Mr. Jack Dean
Vice President and General Manager
Puna Geothermal Venture
P.O. Box 30
Pahoa. Hawaii 96778
Dear Mr. Dean:
This letter is follow-up to the emergency response plans (ERP) review team visit in
August to Puna Geothermal venture (PGV) and Hawaii County. At that time, we
presented you with a "wish list" for further documents to be reviewed by members of the
team.
According to your letter of August 15,1996, EPA understands that you are
working to provide us with the following documents or information:
t
1. Equipment and instrumentation list
2. List of codes and design specs
3. Safety system description and equipment list
Regarding EPA's requests for process flow diagrams (PFDs) and piping and
instrument diagrams (P&IDs), the EPA has the following:
• One PFD for wellpad A
- Six P&IDs forwarded to the National Enforcement Investigation Center
- One P&ID submitted for the Underground Injection Control (UIC) permit
As pan of our emergency response plan review effort, the review team must be able
to evaluate if the hazards posed by the facility have been identified and appropriately
addressee in the plan. The review team will do this, not by reviewing PGV's twelve
release scenarios alone, but also by reviewing the process hazard analysis (PHA). We
anticipate that a PHA has been done for the pentane system in accordance with 29 CFR
1910.119(e) and that PHAs have also been performed for other parts of the facility. The
EPA does not have a complete set of either the PHAs or P&IDs.
Accordingly, we request a complete copy of all PHAs (covering all parts of the
facility). The P&IDs and PFDs are an integral pan of the PHAs, and a review would not
be possible without them. Please provide EPA with a complete list of all P&IDs and
PFDs. After receiving the lists and the PHAs, EPA will identify which P&IDs and PFDs
will be needed for an adequate review of me emergency response plan.
These requests are being submitted pursuant to Section 104(e) of the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and Reautborization Act of 1986
(SARA), which provides EPA the authority for accessing information.
Pruutt en KrcvclrJ Ftpcr
-------
At this time, EPA is also requesting a copy of PGVs reports on the facility's
incident investigations for the upset conditions in September and October of 1996. Also,
please describe PGVs procedures for investigating any kind of incident.
, fj of PGVs most recent self-audit compliance
report required once every three years under OSHA's Process Safety Management (PSM)
program.
Thank you for providing the ERP review team during our visit with a copy of
PGVs Emergency Action Plan plus the Hazwoper with Emergency Response Guidelines
and Training program. Also, we did receive a copy of PGVs air monitors list and
drawings showing locations—which was provided to EPA at another time.
Again, thank you for your assistance in giving the ERP review team the necessary
information requested in order to provide a thorough review of components that could
impact an emergency response. If you have any questions about these requests, you may
call me at (415) 744-2328.
Sincerely,
Michael Ardito
Hawaii State Project Officer for Supertund
-------
UN 1B/U.J \H-VU NUA 40/fZ/KU
PUNA
fort Office Boa 30
14-3860 Kipoho Piho* Read. Pihoa, Hawiii 96770
Telephone {80S} 96*6233
facsimile (808) 96S-7254
HAWAII
March24,1997
Mr.MiktAnfito
United Stata Environmental Protection Agency
75 Htwthome Street
Sin Francisco, Cafflbrait 94105
Dear Mike:
Juit • short note to Id you know that PGV continues to work on the requested information
reesrding the emergency niponie plan review conducted by the USEPA. We apologize for the
extended amount of time required thui fcr, It ii anticipated that the data will be nady to send in
the next aevenlweeki. I win keep you adviaed.
Mike, thanki for your patience.
Ben Regard*,
Ja^kA-Dean
Vice President and General Manager
A Hawaii Partnership
O39
-------
APPENDIX I
Health Consultation
-------
Health Consultation
PUNA GEOTHERMAL VENTURE
PAHOA (PUNA DISTRICT), HAWAII COUNTY, HAWAII
CERCUS NO. HID984469536
22, 1997
U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES
Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Atlanta, Georgia
-------
Health Consultation: > Note of Explanation
An ATSDR health consultation is a verbal or written response from ATSDR to a specific request
for information about health risks related to a specific site, a chemical release, or the presence
of hazardous material. In order to prevent or mitigate exposures, a consultation may lead to
specific actions, such as restricting use of or replacing water supplies; intensifying environmental
sampling; restricting site access; or removing the contaminated material.
In addition, consultations may recommend additional public health actions, such as conducting
health surveillance activities to evaluate exposure or trends in adverse health outcomes;
conducting biological indicators of exposure studies to assess exposure; and providing health
education for health care providers and community members. This concludes the health
consultation process for this site, unless additional information is obtained by ATSDR which, in
the Agency's opinion, indicates a need to revise or append the conclusions previously issued.
You May Contact ATSDR TOLL FREE at
1-800-447-1544
or
Visit our Home Page at: http://atsdrl.atsdr.cdc.gov:/8080
-------
HEALTH CONSULTATION
PUNA GEOTHERMAL VENTURE
PAHOA (PUNA DISTRICT), HAWAII COUNTY, HAWAII
CERCLIS NO. HD984469536
Prepared by:
Exposure Investigation and Consultation Branch
Division of Health Assessment and Consultation
Agency for Toxic Substances and Disease Registry
-------
BACKGROUND MID STATEMENT OF ISSUES
<
The Hawaii Department of Health. (HDOH) asked the Agency for Toxic
Substances and Disease Registry (ATSDR) to assess the threat to
public health posed by releases of hydrogen sulfide from the Puna
Geothermal Venture.
The Puna District of the Island of Hawaii is an active volcanic
area where natural emissions of steam, sulfur dioxide, carbon
dioxide, and traces of other gases occur continuously, but
variably. Beginning in April 1976, geothexmal wells have been
drilled in the area for use in generating electric power. The
Puna Geothermal Venture (PGV) geothermal plant generates up to
25% of the Island of Hawaii's electricity.
During operation of the geothermal wells, gases may be released
to the atmosphere. These gases include carbon dioxide, hydrogen
sulfide, ammonia, and trace amounts of 222radon. The emission of
hydrogen sulfide gas is considered to be the most important
public health problem related to the operation of these
geothermal wells [1]. Since hydrogen sulfide is heavier than
air, it can accumulate in low-lying areas during temperature
inversions or when prevailing trade winds are calm.
The closest house to the PGV power plant is located about 1800
feet to the southeast in Lanipuna Gardens. Leilani Estates, a
large residential community, is located west of the plant.
Residential lots in this subdivision range in size from 2 to 5
acres. There are about 3,900 residential lots within a one-mile
radius of the plant, and houses have been built on about 140 of
the lots [2].
The HDOK provided ATSDR with ambient air monitoring data
collected near the PGV facility. The Air Quality Monitoring
Program of the HDOH operates two air monitoring stations in
residential areas near the PGV facility: the Lanipuna air
monitoring station, which is located about 450 feet southeast of
PGV, and the Leilani station, which is located about 3300 feet
southwest of PGV. The maximum concentrations of hydrogen sulfide
detected at these stations from January 1996 to April 1997 is
summarized in Table 1. During this time period, the maximum peak
concentration of hydrogen sulfide was 20 parts per billion (ppb),
and the maximum 1-hour concentration was 5.5 ppb. Most of the
hourly hydrogen sulfide levels were non-detectable or less than
1 ppb.
-------
ATSDR also reviewed air monitoring data from the Lava Tree
monitoring station, which is located about 1.5 miles upwind
(northwest) of the PGV facility. From the time period January
1996 through September 1997, the maximum 1-hour air concentration
of hydrogen sulfide detected at this station was 4 ppb.
PGV operates three ambient air monitoring stations along the
fence line of their facility; monitoring data from these
stations are summarized in Table 2. During the time period,
November 1995 through January 1997, the maximum 1-hour
concentration of hydrogen sulfide detected was 46.9 ppb on
October 4, 1996. (The. 1-hour, off-site level measured during
this event was 20 ppb.) ATSDR also reviewed PGV incident
reports, which document leaks and releases of hydrogen sulfide
during plant operations. ATSDR was provided with 29 incident
reports that spanned the time period, June 22, 1996 to July 22,
1997. The maximum peak concentration of hydrogen sulfide
detected during a release event was 301.7 ppb (October 4, 1996);
the second highest peak concentration was 33.66 ppb (June 19,
1997).
DISCUSSION
Exposure to high concentrations of hydrogen sulfide can cause
well-documented, adverse health effects. At high concentrations
(500-1,000 parts per million [ppm]), hydrogen sulfide acts
primarily as a systemic poison, causing unconsciousness and death
by respiratory paralysis. At lower concentrations (50-500 ppm),
it acts as a respiratory irritant, which can lead to pulmonary
edema upon exposure to concentrations in excess of 250 ppm.
Exposure to hydrogen sulfide concentrations of 20-50 ppm may
cause eye irritation and conjunctivitis. The Occupational Safety
and Health Administration (OSHA) has 'established an occupational
standard of 10 ppm in the workplace to protect against eye
irritation and conjunctivitis.
The health effects of chronic, low-level exposure to hydrogen
sulfide have not been well-defined. Several epidemiological
studies have examined the health impact of mid to high level
hydrogen sulfide exposure in workers and residents exposed from
oil refineries, paper pulp mills, and other industrial sources
[3]. These studies have reported respiratory, ocular, and
neurological effects in exposed individuals. However,
interpreting the findings of these studies is hampered by
inadequate data for the exposure levels of hydrogen sulfide,
inability to distinguish between the effect of high-level acute
-------
exposures vs. low-level chronic exposures, concurrent exposures
to other organic sulfur compounds, and the subjective nature of
some of the health endpoints.
In a recent study, health effects and neurophysiological function
were studied in former workers and nearby residents who were
exposed to hydrogen sulfide from a desulfurization unit at an oil
refinery [4]. The study reported that exposed individuals were
more likely to demonstrate persistent alterations in
neurobehavioral function. However, several aspects of the study
confound interpretation of the findings: (1) To create an '
"exposed" cohort, neighborhood residents with relatively low
level exposure were grouped together with ex-workers who likely
had much higher exposures. (2) Exposure data were sparse.
Ambient air data were available for only one week. During this
week, hydrogen sulfide levels were 10-100 ppb, but several other
air contaminants were also detected (dimethyl sulfide,
mercaptans, hydrocarbons, vanadium [V205], thioglycolic acid, and
sulfur dioxide). On site, high air levels of hydrogen sulfide
were detected (0-8,800 ppb), as well as high concentrations of
other contaminants. Therefore, it cannot be determined whether
the effects observed in this study were due to hydrogen sulfide
or to other chemicals from the site.
To date, no epidemiological study has demonstrated that chronic
exposure to hydrogen sulfide at concentrations in the low ppb
range has caused adverse health effects.
ATSDR has developed Minimal Risk Levels (MRL) of 500 ppb for
acute (1-14 days) and 90 ppb for intermediate (15-364 days)
exposures to hydrogen sulfide [3]. MRLs are defined as an
estimate of daily exposure of a human, being to a chemical that is
likely to be without risk of deleterious effects
(noncarcinogenic) over a specified duration of exposure.
The EPA developed a Reference Concentration (RfC) of 1 ug/m3
(0.7 ppb) for chronic exposure to hydrogen sulfide. This value
was derived from an experimental study in which nasal
inflammation was observed in mice that were exposed to 80 ppm
hydrogen siilfide for 90 days. This RfC is very conservative,
since it incorporates an uncertainty factor of 1,000. There is
no direct evidence that exposure to hydrogen sulfide in the low
ppb range causes adverse health effects in any animal, including
humans.
-------
After being absorbed into the blood, hydrogen sulfide is rapidly
metabolized - primarily by oxidation to sulfate, which is then
excreted in the urine [3]. Because of the rapid metabolism and
elimination of hydrogen sulfide/-it would not accumulate in the
body during chronic exposure.
Ambient air concentrations of hydrogen sulfide in residential
areas near the PGV are typically less than 1 ppb. These levels
are similar to naturally-occurring, background levels (0.11 to
0.33 ppb) that have been detected in ambient air at other
locations [3]. There is no toxicological evidence that chronic
exposure to these levels of hydrogen sulfide would have an
adverse impact on public health.
Air monitoring data indicate that hydrogen sulfide releases from
operations at PGV have resulted in off-site peak concentrations
of hydrogen sulfide of 20 ppb for a few minutes duration, or
hourly concentrations of 2-5 ppb. These concentrations are less
than ATSDR's acute MRL of 500 ppb and intermediate MRL of
90 ppb and do not pose a public health hazard. The maximum
concentrations of hydrogen sulfide detected on-site at PGV
monitors (peak - 302 ppb, 1-hour - 47 ppb) are also below ATSDR's
acute MRL and would not be expected to pose a health hazard.
Hydrogen sulfide is a colorless gas with an odor suggesting
rotten eggs. Humans vary in their ability to smell hydrogen
sulfide, and individual odor thresholds range from 3-12 ppb or
higher. Hydrogen sulfide was sporadically detected at
residential air monitoring stations at concentrations that exceed
the odor threshold. This has likely contributed to the numerous
citizen complaints over air quality near the facility.
The upwind, ambient air monitoring station at Lava Tree recorded
hourly hydrogen sulfide levels comparable to those detected at
the Lanipuna and Leilani stations. Therefore, hydrogen sulfide
releases from volcanic activity on the island may be contributing
to background levels of hydrogen sulfide in the Puna District.
Significant releases of hydrogen sulfide reportedly occurred at
the PGV facility in 1991 and 1993. However, the public health
impact of these releases can not be assessed, since no ambient
air data are available for these events. As part of their
Emergency Response Plan, PGV modelled air concentrations of
hydrogen sulfide that could result from an accidental release of
hydrogen sulfide from the facility during worst case conditions
They estimated that a hydrogen sulfide concentration of 12,786
ppb could occur at a distance of 1,300 feet from the plant. This
-------
concentration exceeds OSHA's Permissible Exposure Level of 10 DDT.
for an B-hour exposure for workers; however, it is less than the
American Industrial Hygiene Association's Emergency Response
Planning Guideline-2 (ERPG-2) of 30 ppm. An ERPG-2 is defined as
"the maximum airborne concentration below which it is believed
nearly all individuals could be exposed for up to 1 hour without
experiencing or developing irreversible or other serious health
effects or symptoms that could impair their abilities to take
protective action." The HDOH indicated that an evacuation of the
area would be initiated if an unplanned release of hydrogen
sulfide resulted in air levels of greater than 1,000 ppb [2].
ATSDR concurs that such action would be protective of public
health.
No information was available for ambient air levels of other
gases (e.g., sulfur dioxide, ammonia) that are known to be
present in volcanic emissions. Therefore, the potential health
impact of these other gases, if they are present, can not be
assessed.
CONCLUSIONS
(1) The concentrations of hydrogen sulfide detected in air at
monitoring stations in residential areas near the Puna
Geothermal Venture do not pose a public health hazard.
(2) The HDOH emergency level of 1,000 ppb hydrogen sulfide for
evacuation in the event of an unplanned release is
protective of pubic health.
RECOMMENDATIONS
(1) None
Kenneth G. Orloff, Ph.D., DABT
Senior Toxicologist
-------
Table 1: Maximum 1-hour and peak hydrogen sulfide (H2S)
concentrations detected at Hawaii Department of Health off-site,
ambient air monitoring stations
Date
January 1996
February 1996
March 1996
April 1996
IMay 1996
June 1996
July 1996
August 1996
September 1996
October 1996
November 1996
December 1996
January 1997
February 1997
March 1997
April 1997
H2S concentration
3.2 ppb (hour)
1.7 ppb (hour)
3.3 ppb (hour)
3.5 ppb (hour)
2.9 ppb (hour)
5.5 ppb (hour)
1.9 ppb (hour)
10 ppb (peak)1
1.7 ppb (hour)
7.5 ppb (peak)
3.3 ppb (hour)
20 ppb (peak)
2.7 ppb (hour)
2.6 ppb (hour)
2.2 ppb (hour)
2.0 ppb (hour)
2.3 ppb (hour)
1.9' ppb (hour)
1.6 ppb (hour)
Station
Lanipuna
Lanipuna
Leilani
Leilani
Leilani
Lanipuna
Leilani
Lanipuna
Leilani
Lanipuna
Lanipuna
Lanipuna
Lanipuna
Lanipuna
Lanipuna
Lanipuna
Lanipuna
Lanipuna
Lanipuna
ppb - parts per billion
(1) - this finding was of questionable validity because of the
symmetry of the peak and the lack of other traces around the peak
-------
Table 2: Maximum 1-hour hydrogen sulfide (H2S) concentrations
detected at PGV on-site, ambient air monitoring stations
Date
November 1995
December 1995
January 1996
February 1996
March 1996
April 1996
May 1996
June 1996
July 1996
August 1996
September 1996
October 1996
November 1996
December 1996
January 1997
H,S concentration
3.3 ppb
6.0 ppb
5.1 ppb
3.3 ppb
2.6 ppb
5.8 ppb
1.4 ppb
12.4 ppb
2.8 ppb
1.3 ppb
19.8 ppb
46.9 ppb
3.6 ppb
2.7 ppb
2.7 ppb
Station
B
B and C
A
A
A
A
B
A
B
B
A
A
C
A
A
ppb - parts per billion
A - SE station, topographically down'gradient from PGV facilities
B «= SW station, in the prevailing downwind direction from the
facility
C » W station, selected because of its proximity to a residential
neighborhood
-------
REFERENCES
(1) Hawaii Department of Health; Health Status of County of
Hawaii Populations Exposed to Geothennal and Volcanic
Emissions - Preliminary Report; March 1991.
(2) Barbara A. Brooks; Health Risk Assessment: Evaluation of
potential adverse health effects from short-term exposure to
hydrogen sulfide resulting from an unplanned release from
geothermal wells in Puna, Hawaii; The Hawaii State
Department of Health; August 16, 1993.
(3) Agency for Toxic Substances and Disease Registry;
Toxicological Profile for Hydrogen Sulfide, Draft;
September 1997.
(4) Kaye Kilburn and Raphael Warshaw; Hydrogen sulfide and
reduced-sulfur gases adversely affect neurophysiological
functions; Toxicology and Industrial Health H 185-197
(1995).
-------
APPENDIX I
Health Consultation
-------
Health Consultation
PUNA GEOTHERMAL VENTURE
PAHOA (PUNA DISTRICT), HAWAII COUNTY, HAWAII
CERCLIS NO. HTO984469536
DECEMBER 22, 1997
U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES
Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Atlanta, Georgia
-------
Health Consultation: > Note of Explanation
An ATSDR health consultation is a verbal or written response from ATSDR to a specific request
for information about health risks related to a specific site, a chemical release, or the presence
of hazardous material. In order to prevent or mitigate exposures, a consultation may lead to
specific actions, such as restricting use of or replacing water supplies; intensifying environmental
sampling; restricting site access; or removing the contaminated material.
In addition, consultations may recommend additional public health actions, such as conducting
health surveillance activities to evaluate exposure or trends in adverse health outcomes;
conducting biological indicators of exposure studies to assess exposure; and providing health
education for health care providers and community members. This concludes the health
consultation process for this site, unless additional information is obtained by ATSDR which, in
the Agency's opinion, indicates a need to revise or append the conclusions previously issued.
You May Contact ATSDR TOLL FREE at
1-800-447-1544
or
Visit our Home Page at: http://atsdrl.atsdr.cdc.gov:/8080
-------
HEALTH CONSULTATION
PUNA GEOTHERMAL VENTURE
PAHOA (PUNA DISTRICT), HAWAH COUNTY, HAWAII
CERCLIS NO. HTO984469536
Prepared by:
Exposure Investigation and Consultation Branch
Division of Health Assessment and Consultation
Agency for Toxic Substances and Disease Registry
-------
BACKGROUND AND STATEMENT OF ISSUES
The Hawaii Department of Health . (HDOH) asked the Agency for Toxic
Substances and Disease Registry (ATSDR) . to assess the threat to
public health posed by releases of hydrogen sulfide from the Puna
Geothermal Venture.
The Puna District of the Island of Hawaii is an active volcanic
area where natural emissions of steam, sulfur dioxide, carbon
dioxide, and traces of other gases occur continuously, but
variably. Beginning in April 1976, geothermal wells have been
drilled in the area for use in generating electric power. The
Puna Geothermal Venture (PGV) geothermal plant generates up to
25% of the Island of Hawaii's electricity.
During operation of the geothermal wells, gases may be released
to the atmosphere. These gases include carbon dioxide, hydrogen
sulfide, ammonia, and trace amounts of "'radon. The emission cf
hydroger. sulfide gas is considered to be the most important
public health problem related to the operation of these
geotherr.al wells [1] . Since hydrogen sulfide is heavier thar.
air, it car. accumulate in low-lying areas during temperature
inversions or when prevailing trade winds are calm.
The closest house to the PGV power plant is located about 1BDO
feet to the southeast in Lanipuna Gardens. Leilani Estates, a
large residential community, is located west of the plant.
Resider.tiei lots in this subdivision range in size from 2 to 5
acres. Tnere are about 3,900 residential lots within a one-ir.ile
radius cf the plant, and houses have been built on about 140 o*
the lots [2j .
t
The ROOK provided ATSDR with ambient air monitoring data
collected near the PGV facility. The Air Quality Monitoring
Program of the HDOH operates two air monitoring stations in
residential areas near the PGV facility: the Lanipuna air
of
, the Leilani station, which is located about 3300 feet
southwest of PGV. The maximum concentrations of hydrogen fu!fide
!±C I" thCSe "ati°nS fr0n Janu«y 1996 ^ April ?W7 is
uere
-------
ATSDR also reviewed air monitoring data from the Lava Tree
monitoring station, which is located about 1.5 miles upwind
(northwest) of the PGV facility. From the time period January
1996 through September 1997, the maximum 1-hour air concentration
of hydrogen sulfide detected at this station was 4 ppb.
PGV operates three ambient air monitoring stations along the
fence line of their facility; monitoring data from these
stations are summarized in Table 2. During the time period,
November 1995 through January 1997, the maximum 1-hour
concentration of hydrogen sulfide detected was 46.9 ppb on
October 4, 1996. (The 1-hour, off-site level measured during
this event was 20 ppb.) ATSDR also reviewed PGV incident
reports, which document leaks and releases of hydrogen sulfide
during plant operations. ATSDR was provided with 29 incident
reports that spanned the time period, June 22, 1996 to July 22,
199*7. The maximum peak concentration of hydrogen sulfide
detected during a release event was 301.7 ppb (October 4, 1996);
the second highest peak concentration was 33.66 ppb (June 19,
1997).
DISCUSSION
Exposure to high concentrations of hydrogen sulfide can cause
well-documented, adverse health effects. At high concentrations
{500-1,000 parts per million [ppm]), hydrogen sulfide acts
primarily as a systemic poison, causing unconsciousness and death
by respiratory paralysis. At lower concentrations (50-500 ppm),
it acrs as a respiratory irritant, which can lead to pulmonary
e=e-s upor. exposure to concentrations in excess of 250 ppm.
Exposure to hydrogen sulfide concentrations of 20-50 ppm may
cause eye irritation and conjunctivitis. The Occupational Safety
and Kenlth Administration (OSHA) has established an occupational
standard of 10 ppm in the workplace to protect against eye
irritation and conjunctivitis.
The health effects of chronic, low-level exposure to hydrogen
sulfide have not been well-defined. Several epidemiclogical
studies have examined the health impact of mid to high level
hydrogen sulfide exposure in workers and residents exposed from
oil refineries, paper pulp, mills, and other industrial sources
[3]. These studies have reported respiratory, ocular, ""and
neurological effects in exposed individuals. However,
interpreting the findings of these studies is hampered by
inadequate data for the exposure levels of hydrogen sulfide,
inability to distinguish between the effect of high-level acute
-------
exposures vs. low-level chronic exposures, concurrent exposures
to other organic sulfur compounds, and the subjective nature of
some of the health endpoints.
•
. •
In a recent study, health effects and neurophysiological function
were studied in former workers and nearby residents who were
exposed to hydrogen sulfide from a desulfurization unit at an oil
refinery [4J. The study reported that exposed individuals were
more likely to demonstrate persistent alterations in
neurobehavioral function. However, several aspects of the study
confound interpretation of the findings: (1) To create an
"exposed" cohort, neighborhood residents with relatively low
level exposure were grouped together with ex-workers who likely
had much higher exposures. (2) Exposure data were sparse.
Ambient air data were available for only one week. During this
week, hydrogen sulfide levels were 10-100 ppb, but several other
air contaminants were also detected (dimethyl sulfide/
mercaptans, hydrocarbons, vanadium [V204], thioglycolic acid, and
sulfur dioxide). On site, high air levels of hydrogen sulfide
were detected (0-8,800 ppb), as well as high concentrations of
other contaminants. Therefore, it cannot be determined whether
the effects observed in this study were due to hydrogen sulfide
or to other chemicals from the site.
Tc date, no epidemiological study has demonstrated that chronic
exposure to hydrogen sulfide at concentrations in the low ppb
rar.ge has caused adverse health effects.
ATSDR has developed Minimal Risk Levels (MRL) of 500 ppb for
a=-jte (l-i< days) and 90 ppb for intermediate (15-364 days)"
exposures to hydrogen sulfide [3]. MRLs are defined as an
estimate of daily exposure of a human being to a chemical tha- is
likely to be without risk of deleterious effects
(noncarcinogenic) over a specified duration of exposure.
The EPA developed a Reference Concentration (RfC) of 1 ug/m>
(0.7 ppb) for chronic exposure to hydrogen sulfide. This value
was derived from an experimental study in which nasal
inflammation was observed in mice that were exposed to 60 ppm
hyarogen sulfide for 90 days. This RfC is very conservativT
since it incorporates an uncertainty factor of 1,000. There is
no direct evidence that exposure to hydrogen sulfide in the lo!
incLaing
-------
After being absorbed into the blood/ hydrogen sulfide i? rapidly
metabolized - primarily by oxidation to sulfats, which is then
excreted in the urine [3] . Because of the rapid metabolism and
elimination of hydrogen sulfide/ • it .would not accumulate in the
body during chronic exposure.
Ambient air concentrations of hydrogen sulfide in residential
areas near the PGV are typically less than 1 ppb. These levels
are similar to naturally-occurring/ background levels (0.11 to
0.33 ppb) that have been detected in ambient air at other
locations [3] . There is no toxicological evidence that chronic
exposure to these levels of hydrogen sulfide would have an
adverse impact on public health.
Air monitoring data indicate that hydrogen sulfide releases from
operations at PGV have resulted in off-site peak concentrations
of hydrogen sulfide of 20 ppb for a few minutes duration, or
hourly concentrations of 2-5 ppb. These concentrations are less
than ATSDR's acute MRL of 500 ppb and intermediate MRL of
9C ppb and do not pose a public health hazard. The maximum
concentrations of hydrogen sulfide detected on-site at PGV
r.cr.^tcrs (peak - 302 ppb, 1-hour - 47 ppb) are also below ATSDR's
ar-jre MP.L and would not be expected to pose a health hazard.
Hy=rs=en suifide is a colorless gas with an odor suggesting
r = —er. e==s. Humans vary in their ability to smell hydrogen
sulfise, and individual odor thresholds range from 3-12 ppb or
.-.irr.er. Hydrogen sulfide was sporadically detected at
re-cer.tial air monitoring stations at concentrations that exceed
t.-.e ===r threshold. This has likely contributed to the numerous
cit:=er. complaints over air quality near the facility.
T.ne upwind, ambient air monitoring station at Lava Tree recorded
hcuz.y hysrogen sulfide levels comparable to those detected at
the Lar.ipuna and Leilani stations. Therefore, hydrogen sulfide
re-eases from volcanic activity on the island may be contributino
to background levels of hydrogen sulfide in the Puna District
t releascs of hydr°g«n sulfide reportedly occurred at
y 1991 and 1993-
' the
. these releases can not be assessed, since no ambient
air data are available for these events. As part of their
Emergency Response Plan, PGV modelled air concentrations of
hydrogen sulfide that could result from an accidental release of
:ydroger. sulfide from the facility during worst case cond""ns
:=b--"?"o~ that • hydr0gM SUlfldC «»c«t»tioa of 12 786
,S» .o.« o.cur at a distance of 1,300 feet from the plant This
-------
concentration exceeds OSHA's Permissible Exposure Level of 10 pprr.
for an 8-hour exposure for workers; however, it is less thtn the
American Industrial Hygiene Association's Emergency Response
Planning Guideline-2 (ERPG-2) ox 30 ppm. An ERPG-2 is defined as
"the maximum airborne concentration below which it is believed
nearly all individuals could be exposed for up to 1 hour without
experiencing or developing irreversible or other serious health
effects or symptoms that could impair their abilities to take
protective action." The HDOH indicated that an evacuation of the
area would be initiated if an unplanned release of hydrogen
sulfide resulted in air levels of greater than 1,000 ppb [2].
ATSDR concurs that such action would be protective of public
health.
No information was available for ambient air levels of other
gases (e.g., sulfur dioxide, ammonia) that are known to be
present in volcanic emissions. Therefore, the potential health
impact of these other gases, if they are present, can not be
assessed.
CONCLUSIONS
(1) The concentrations of hydrogen sulfide detected in air e-
ir.or.itcring stations in residential areas near the Puna
Geo^hermal Venture do not pose a public health hazard.
(2) The KDOK emergency level of 1,000 ppb hydrogen sulfide for
evacuation in the event of an unplanned release is
prctertive of pubic health.
RECOMMENDATIONS
(1) None
Kenneth G. Orloff, Ph.D., DABT
Senior Toxicologist
-------
Table 1: Maximum 1-hour and peak hydrogen sulfide (H,S)
concentrations detected at Hawaii Depariarent of Health off-site,
ambient air monitoring stations
IDate
January 1996
February 1996
March 1996
April 1996
May 1996
June 1996
July 1996
August 1996
September 1996
October 1996
November 1996
De eerier 1996
January 199"?
February 1997
March 1997
April 1997
HjS concentration
3.2 ppb (hour)
1.7 ppb (hour)
3.3 ppb (hour)
3.5 ppb (hour)
2.9 ppb (hour)
5.5 ppb (hour)
1.9 ppb (hour)
10 ppb (peak)1
1.7 ppb (hour)
7.5 ppb (peak)
3.3 ppb (hour)
20 ppb (peak)
2.7 ppb (hour)
2.6 ppb (hour)
2.2 ppb (hour)
2.0 ppb (hour)
2.3 ppb (hour)
1.9 ppb (hour)
1.6 ppb (hour)
Station
Lanipuna
Lanipuna
Leilani
Leilani
Leilani
Lanipuna
Leilani
Lanipuna
Leilani ||
Lanipuna |J
Lanipuna
Lanipuna
Lanipuna
Lanipuna
Lanipuna ||
Lanipuna ||
Lanipuna |
Lanipuna ||
Lanipuna
— II
ppb - parts per billion
(1) - this finding was of questionable validity because of the
symmetry of the peak and the lack of other traces around the peak
-------
Table 2: Maximum 1-hsur hydrogen aulfide (H2S) concentrations
detected at PGV on-site, anbient air Monitoring stttians
Date
November 1995
1 December 1995
January 1996
February 1996
March 1996
April 1996
May 1996
| June 1996
BJuly 1996
August 1996
September 1996
October 1996
November 1996
December 1996
January 199"7
BX5 concentration
3.3 ppb
€.0 ppb
5.1 ppb
3.3 ppb
2.6 ppb
5.8 ppb
1.4 ppb
12.4 ppb
2.8 ppb
1.3 ppb
19.8 ppb
46.9 ppb
3.6 ppb
2.1 ppb
2.7 ppb
Station
B
B and C
A
A
A
A
B
A
B
B
A
A
C
A
A
ppb - parts per billion
A - SE station, topographically down-gradient from PGV facilities
B - SW station, in the prevailing downwind direction from the
facility
C - w station, selected because of its proximity to a residential
neighborhood
-------
REFERENCES
(1) Hawaii Department of Health; Health Status of County of
Hawaii Populations Exposed^to Geothezmal and Volcanic
Emissions - Preliminary Report; March 1991.
(2) Barbara A. Brooks; Health Risk Assessment: Evaluation of
potential adverse health effects from short-term exposure to
hydrogen sulfide resulting from an unplanned release from
geothermal wells in Puna, Hawaii; The Hawaii State
Department of Health; August 16, 1993.
(3) Agency for Toxic Substances and Disease Registry;
Toxicological Profile for Hydrogen Sulfide, Draft;
September 1997.
(4) Kaye Kilburn and Raphael Warshaw; Hydrogen sulfide and
reduced-sulfur gases adversely affect neurophysiological
functions; Toxicology and Industrial Health H 185-197
(1995).
-------
APPENDIX J
Integrated Contingency Planning "Oneplan" Guidance and
EPA Chemical Accident Prevention Regulations 40 CFR Part 68
-------
Wednesday
June 5, 1996
Part II
Environmental Protection
Agency
Department of
Transportation
Coast Guard
Research and Special Programs
Administration
Department of the Interior
Minerals Management Service
Department of Labor
Occupational Safety and Health
Administration
The National Response Team's Integrated
Contingency Plan Guidance; Notice
-------
ENVIRONMENTAL PROTECTION
AGENCY
DEPARTMENT OF TRANSPORTATION
Coast Guard
.Research and Special Programs
Administration
DEPARTMENT OFTHE INTERIOR
Minerals Management Service
DEPARTMENT OF LABOR
Occupational Safety and Health
Administration
[FRL-esi2-e]
The National Response Team's
Integrated Contingency Plan Guidance
AGENCY: Environmental Protection
Agency (EPA). U.S. Coast Guard
(USCG). Minerals Management Service
(MMS). Research and Special Programs
Administration tRSPA). Occupational
Safety and Health Administration
(OSHA).
ACTION: Notice.
SUMMARY: The U.S. Environmental
Protection Agency, as the chair of the
National Response Team (NKT). Is
FOR FURTHER INFORMATION CONTACT: -.
William Finan, U.S. Environmental
Protection Agency. Mail Code 5101.401
M Street. SW.. Washington. DC 20460.
at (202) 260-0030 (E-Mail
homepage.ceppo©epamaii.epa.gov—_•
please include "one pbn"in Jhesubiect
line). In addition, the EPCRA/RCRA/
Superfund Hotline can answer general'
questions about the guidance.
For further information and guidance
on complying with specific regulations.
contact: for EPA's Oil Pollution
Prevention Regulation: Bobbie Ltvely-
Diebold. U.S. Environmental Protection
Agency. Mail Code 5203G. 401M Street.
SW.. Washington. DC70460. at (703)
356-8774 (E-Mail
Lively.Barbaraeepamail.epa.gov). or the
SPCC Information Line at (202) 260-
2342); for the U.S. Coast Guard's
Facility Response Plan Regulation:
LCDR Mark Hamilton. U.S. Coast Guard.
Commandant (G-MOR). 2100 2nd
Street. SW.. Washington. DC 20593. at
202-267-1983 (E-Mail MJfcmilton/G-
M03®CGSMTP.uscg.mil): for DOT/
RSPA's Pipeline Response Plan
Regulation: Jim Taylor. U.S. Department
of Transportation. Room 2335.400 7th
Street. SW.. Washington. DC 20590 at
(202) 366-8860 (E-Mail
OPATEAM®RSPAJXJT.GOV); for
pertinent OSHA regulations, contact
either your Regional or Area OSHA
office; for DOI/MMST
on .
to be used by facilities f o prepare
emergency response plans. The intent of
the NRT is to provide a mechanism for
consolidating multiple plans that
facilities may have prepared to comply
with various regulations into one
functional emergency responseplan or
integrated contingency plan (ICP). This
notice contains the suggested ICP
outline as well as guidance on how to
develop an ICP and demonstrate
compliance with various regulatory
requirements. The policies set out in
this notice are intended solely as
guidance.
ADDRESSES: Additional copies of this
one-plan guidance can be obtained by
writing to the following address: '»
William Fman. U.S. Environmental
Protection Agency. Mail Code 5101.401
M Street SW. Washington. DC 20460.
Copies of the ICP Guidance are also
available by calling the EPCRA/RCRA/
Superfund Hotline at (800) 424-9346 (in
the Washington. DC. metropolitan area.
(703) 412-9810). In addition, this .
guidance is available electronically at
the home page of EPA's Chemical
Emergency Preparedness and
Prevention Office (http://www.cpa.gov/
swercepp/).
Facility Response
Plan Regulation: Larry Ake.U.S.
Department of the Interior—Minerals
Management Service. MS 4700.381
Elden Street. Hemdon. VA 22070-4817
at (703) 787-1567 (E-Mail Lany_
Ake©SMTP.MMS.GOV); for EPA's Risk
Management Program Regulation:
William Finan (see above); and for
RCRA's Contingency Planning
Requirements, contact the EPCRA/
RCRA/Superfund Hotline (see above).
The NRT welcomes comments on
specific 'mplementation issues related
to this guidance. Please provide us with
information about the successful use of
this guidance, about ^problems with
using this guidance, as well as
suggestions for improving the guidance.
Send comments to William Finan tsee
above) or to any of the other people
listed in the previous paragraph.
SUPPLEMENTARY INFORMATION:
Presidential Review Findings
Section 112(r)(10) of the Clean Air Act
required the I'resMe" 'o conduct a
review of fetleiu'. -' * -z prevention.
mitigation, one r=s>.,--e authorities.
ThePresidenli.-.l lev: -• was delegated •
to EPA. in roar "-.atio-i with agencies
and department* !•. • c members of
theNalio.-ul . •«. . earn (NRT). The
• Presidential Review concluded that.
' while achieving its statutory goals to
protect public safety and the
environment, the current system is
complex, confusing, and costly. It
•identified several key problem areas and
recommended a second phase to
address these issues. One of the issues
identified by the Presidential Review is
the multiple and overlapping federal
• ' requirements for facility emergency
response plans.
NRT Policy Statement
This one-plan guidance is intended to
be used by facilities to prepare
emergency response plans for
responding to releases of oil and non-
radiological hazardous substances. The
intent of NRT is to provide a mechanism
for consolidating multiple plans that
facilities may have prepared to comply
with various regulations into one
functional emergency responseplan or
integrated contingency plan (ICP). A
number of statutes and regulations.
administered by several federal
agencies, include requirements for
emergency response planning. A
particular facility may be subject to one
or more of the following federal
regulations:
• EPA's Oil Pollution Prevention
Regulation (SPCC and Facility Response
Plan Requirements)— 40 CFR part
112.7(d)endll2.20-.21;
• MMS's Facility Response Plan
Regulation— 30 CFR part 254;
• RSPA's Pipeline Response Plan
Regulation— 49 CFR part 194;
• USCG's Facility Response Plan
Regulation-33 CFR part 154. Subpart F;
• EPA's Risk Management Programs
Regulation— 40 CFR part 68:
• OSHA's Emergency Action Plan
Regulation— 29 CFR 1910.38(8);
• OSHA's Process Safety Standard—
29 CFR 1910.119: , .
• OSHA's HAZWOPER Regulation—
29 CFR 1910.120: and
• EPA's Resource Conservation and
Recovery Act Contingency Planning
Requirements-40 CFR part 264.
Subpart D, 40 CFR part 265. Subpart D.
and 40 CFR 27952.
In addition, facilities may also be
subject to state emergency response
guidance does not specifically address.
Facilities are encouraged to coordinate
development of their ICP with relevant
state and local agencies to ensure
compliance with any additional
Tlalory requirements.
dividual agencies' planning
requirements and plan review
procedures are not changed by the
advent of the ICP format option. This
one-plan guidance has been developed
-------
Federal Register / Vol. Cl. No. 109 / Wednesday. June 5. 1996 / Notices
28643
(o assist facilities in demonstrating
tumpliancfl with the existing federal
emergency response planning
requirements referenced above.
Although it does not relieve facilities
from their current obligations, it has
been designed specifically to help meet
those obligations. Adherence to this
guidance is not required in order to
comply with federal regulatory
requirements. Facilities are free to
continue maintaining multiple plans to
demonstrate federal regulatory
compliance; however, the NOT believes
that an integrated plan prepared in
accordance with this guidance is a
preferable alternative.
The NRT realizes that many existing
regulations pertaining to contingency
planning require review by a specific
agency to determine compliance with
applicable requirements. It is not the
intent of the NRT to modify existing
agency review procedures or to
supersede the requirements of a
regulation.
This one-plan guidance was
developed through a cooperative effort
among numerous NRT agencies, state
and local officials, and industry and
community representatives. The NRT
and the agencies responsible for
reviewing and approving federal
response plans to which the ICP option
applies agree that integrated response
plans prepared in the format provided
* in this guidance will be acceptable and
be the federally preferred method of
response planning. The NRT realizes
that alternate formats for integrating
multiple plans already exist and that
others likely will be developed. Certain
facilities may find those formats more
desirable than the one proposed here.
The NRT believes that a single
functional plan is preferable to multiple
plans regardless of the specific format
chosen. While they are acceptable, other
formats may not allow the same ease of
coordination with external plans, to any
case, whatever format a facility chooses.
no individual NRT agency wifl require
an integrated response planning format
differing from the ICP format described
here. The NRT anticipates that future
development of all federal regulations
addressing emergency response
planning will incorporate use of the ICP
guidance. Also, developers of stale and
local requirements will be encouraged
to be consistent with this document
The ICP guidance does not change
existing regulatory requirements; rather.
it provides a format foe organizing and
presenting material currently required •
by the regulations. Individual
regulations are often more detailed than
• the KT guidance. To ensure full
compliance, facilities should continue
to read and comply with1 all of the
federal regulations that apply to them.
furthermore, facilities submitting an
ICP (in whatever format) for agency or
department review will need to provide
a cross-reference to existing regulatory
requirements so that plan reviewers can
verify compliance with these
requirements. The guidance contains a
series of matrices designed to assist
owners and operators in consolidating
various plans and documenting
compliance with federal regulatory
requirements. (See Attachments 2 and
3.) The matrices can be used as the basis
for developing a cross-reference to
various regulatory requirements.
This guidance also provides a useful
contingency planning template for
owners and operators of facilities not
subject to the federal regulations cited
previously.
Integrated Contingency Plan
Philosophy
The ICP will minimize duplication in
the preparation and use of emergency
response plans at the same facility and
will improve economic efficiency for
both the regulated and regulating
communities. Facility expenditures for
the preparation, maintenance.
submission, and update of a single plan '
should be much lower than for multiple
plans.
The use of a single emergency
response plan per facility will eliminate
confusion for facility first responders
who often must decide which of their
plans is applicable to a particular
emergency. The guidance is designed to
yield a highly functional document for
use in varied emergency situations
while providing a mechanism for
complying with multiple agency
requirements. Use of a single integrated
plan should also improve coordination
between facility response personnel and
local, state, end federal emergency
res
specific regulatory requirements to
ensure that facility plans are consistent
with external planning efforts. Industry
use of this guidance along with active
participation on local and Area
Committees will improve the level of
emergency preparedness and is
therefore highly encouraged.
In some areas, it may be possible to
go beyond simple coordination of plans
and actually integrate certain
information from facility plans with
corresponding areas of external plans.
The adoption of a single, common ICP
outline such as the one proposed in this
guidance would facilitate a move
toward integration of/acility plans with
local, state, and federal plans.
The projected results described above
will ultimately serve thernutual goal of
the response community to more
efficiently and effectively protect public
health, worker safety, the environment.
and property.
Scope
This one-plan guidance is provided
for any facility subject to federal
contingency planning regulations and is
also recommended for use by other
facilities to improve emergency
preparedness through planning. In this
context, the term "facility11 is meant to
have a wide connotation and may
include, but is not limited to. any
mobile or fixed onshore or offshore
building, structure, installation,
equipment, pipe, or pipeline.
Facility hazards need to be addressed
in a comprehensive and coordinated •
manner. Accordingly.4his guidance is
broadly constructed to allow for
facilities to address a wide range of nsks
in a manner tailored to the specific
needs of the facility. This includes both
physical and chemical hazards
associated with events such as chemical
releases, oil spills, fires, explosions, and
natural disasters.
1 nO aOOpUOn Ol B H«iu«u |nou
format should facilitate integration of
plans within a facility, In the event that
Urge facilities may need to prepare •
separate plans for distinct operating
units. The ICP concept should also
allow coordination of facility plans with
plans that are maintained by local
emergency planning committees
(LEPCs).1 Area Committees,* co-
operatives, and mutual aid
organizations. In some cases, there an
•LEFCpUnsara developed by LEFC* la
coordination with facility emergency raspou*
coordinators under wctlon MI of the Emergency
Planning and Community RIghMo-Know AOL
> Area Contingency Plan* are developed by Are*
Committees pursuant le Mdioa 4ZOtfaXS) of lb*
Oil Pollution Act of 1990 (OPAL
Organizational Concepts
The ICP format provided in this one-
plan guidance (See Attachment 1) is
organized into three main sections: an
introductory section, a core plan, and a
series of supporting annexes. It IB
important to note that the elements
contained in these sections are not new
concepts, but accepted emergency •
response activities that are currently
addressed in various forms in existing
contingency planning regulations. The
goal of the NRT Is not to create new
planning requlrements.but to provide a
mechanism to consolidate existing
concepts into a single functional plan
structure. This approach would provide
a consistent basis for addressing
-------
emetgeuuy «»|«w«>» —;—-"-. — •
widespread use among facilities.
The introduction section of the,
format is designed to provide fadl
response personnel, outside respoi
and regulatory officials with basic
information about the plan and the
entity it covers. It callsfor a statement
of purpose and scope, a table of .
contents, information on the cu™11*
revision date of the plan, general facility
information, and the key contadls) for
plan development and maintenance.
This section should present the
information in a brief factual manner.
The structure of the sample core plan
and annexes in this guidance is based
on the structure of the National
Interagency Incident Management
System (NIIMS) Incident Command
Svstem (ICS). NDMSICS is a nationally
recognized system currently in use by
numerous federal, state, and local
organizations (e.g., some Area
Committees under OPA). NDMS ICS is
a type of response management system
that has been used successfully in a
variety of emergency situations.
including releases of oil or hazardous
substances. NIIMS ICS provides a
commonly understood framework that
• allows for effective interaction among
response personnel. Organizing the ICP
along the lines of the NIIMS ICS will
allow the plan to dovetail with '
established response management
practices, thus facilitating its ease of use
during an emergency. '
The core plan is intended to contain
essential response guidance and
procedures. Annexes would contain
more detailed supporting information
on specific response management
functions. The core plan should contain
frequent references to the response
' critical annexes to direct response
personnel to parts of the ICP that
contain more detailed information on
the appropriate course of action for
responders to take during various stages
of a response. Facility planners need to
find the right balance between the
amount ofinformation contained In the
core plan versus the response critical
annexes (Annexes 1 through 3).
Information required to support •»
response actions at facilities with
jlliple hazards will likely be
as manageable as practicable, it is not
. necessary fora plan holder to provide
its field responders with all the
compliance documentation (e.e..
Annexes 4 through 8) that it submits to
regulatory agencies. Similarly, it may
not be necessary for A plan holder to
submit all annexes to every regulatory
agency for review.
Basic headings ore consistent across
the core plan and annexes to facilitate
ease of use during an emergency. These
headings provide a comprehensive list
of elements to be addressed in the core
plan and response annexes and may not
be relevant to all facilities. Planners
should address those regulatory
elements that are applicable to their
particular facilities. Planners at facilities
with multiple hazards will need to
address most, if not all. elements
included in this guidance. Planners at
facilities with fewer hazards may not
need to address certain elements. If
planners choose to strictly adopt the ICP
outline contained in this guidance but
are not required by regutotion to address
all eteroentsaf the outline, they may
simply indicate Vnot applicable" for
those items where no information is
provided. A more detailed discussion of
the core plan and supporting annexes
follows.
Core Plan
The core plan is intended to reflect
the essential steps necessary to initiate.
conduct, and terminate an emergency
response action: recognition.
notification, and initial response,
including assessment, mobilization, and
implementation. This section of the
plan should be concise and easy to the neaim ana saieiy o. *""""?• -T!
follow. A rule of thumb is that the core public, or the environment; and 2) the
plan should fit in the glovebox of a need to communicate critical
response vehicle. The core plan need
not detail all procedures necessary
follow. For a small facility with a
limited number of hazard scenarios, the
core plan may contain most if not all of
the information necessary to carry out
the response thus obviating the need for
more detailed annexes. The checklists.
depending on their size and complexity.
can be in either the core or the support
section.
The core plan should reflect a
hierarchy of emergency response levels.
A system of response levels Is
commonly used in emergency planning
for classifying emergencies according lo
seriousness and assigning an
appropriate standard response or series
of response actions to each level. Both
complex and simple industrial facilities
use a system of response levels for
rapidly assessing the seriousness of an
emergency and developing an
appropriate response. This process
allows response personnel to match the
emergency and its potential impacts
with appropriate resources and
personnel. The concept of response
levels should be considered in
developing checklists or flowcharts
designed to serve as the basis for the
core plan. Note that for those facilities
subject to planning requirements under
OPA. response levels in the core plan
may not necessarily correspond to
discharge planning amounts (e.g..
overage most probable discharge.
maximum most probable discharge, and
worst case discharge).
Facility owners and operators should
determine appropriate response levels
based on 1) the need to initiate time-
urgent response actions to minimize or
prevent unacceptable consequences to
the health and safety of workers, the
mu
JHUIUhftV ••••••BBW •*••• mmv**vmj n
contained in the annexes. Planners at
facilities with fewer, hazards may choose
to include most if not all information In
the core plan. Other annexes (e.g..
Annexes 4 through 8) are dedicated to
providing information that is non-
critical at the time of a response (e.g.. .
cross-references to demonstrate
regulatory compliance and background
planning information). Consistent with
the goal of keeping the size of the ICP
under these phases of a response but
should provide information that is time
critical in the earliest stages of a
response and a framework to guide
responders through key steps necessary
to mount an effective response. The
response action section should be
convenient to use and understandable at
the appropriate skill level
ThelJRT recommends the use of
' checklists or flowcharts wherever
possible to capture these steps In a
concise easy-to-understand manner. The
core plan should be constructed lo
contain references to appropriate
sections of the supporting annexes for
more detailed guidance on specific
procedures. The NRT anticipates that
for a large, complex facility with
multiple hazards the annexes will
contain a significant amount of
information on specific procedures to
I1CT7U M* fcWiiiai•»«••«*••'» •-..-»—-
information concerning the emergency
to offsite authorities. The consideration
and development of response levels
should, to the extent practicable, be
consistent with similar efforts that may
have been taken by the LEPC. local Area
Committee, or mutual aid organization.
Response levels, which are used in
communications with offsite authorities.
should be fully coordinated and use
consistent terminology.
Annexes
The annexes are designed to provide
key supporting information for
conducting an emergency response
under the core plan as well as document
compliance with regulatory
requirements not addressed elsewhere
in the ICP. Annexes ore not meant to
duplicate information that is already
containcG in the core plan, but to
augr.isnl core plan information. The
armir. ' lould relate to the basic
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Federal Register / Vol. 61. No. 109 / Wednesday. June 5. 1996 / Notices
Z8645
dings of the core plan. To.
avijomplish this, the annexes should
contain sections on facility information.
notification, and a detailed description
of response procedures under the
response management system (to.
command, operations, planning.
logistics, and finance). The annexes
should also address issues related to
post accident investigation, incident
history, written follow-up reports.
•.raining and exercises, plan critique and
modification process, prevention, and
regulatory compliance, as appropriate.
The ICP format contained fn this
guidance is based on the NHMSICS. If
facility owners or operators choose to
follow fundamental principles of the
NMMS ICS. then they may adopt NHMS
The owner or operator snuuiu uumm;
\\ here NHMS ICS documentation is *ept
at Ihe facility and how it will be
eccessed if needed by the facility or
requested by the reviewing agency.
Regardless of the response management
svslem used, the plan should include an
organization chart, specific fob
descriptions.* a description of
information flow ensuring liaison with
the on-scene coordinator (OSC). and a
description of how the selected
response management system integrates
wiUi a Unified Command.* If a system
other than NHMS ICS is used, the plan
should also identify how it differs from
NITMS or provide a detailed description
of the system used.
The NRT anticipates that the use of
linkages (i.e.. references to other plans)
when developing annexes will serve
several purposes. Linkages will facilitate
integration with other emergency plans
within a facility (until such plans can be
fully incorporated into the ICP) and
'OPAM planning requirements far marine
transfer facilities (33 CFR IS* 103S) require fob
descriptions for each spin .". 'gemem team
member regardless of the u -pans* management
system employed by the bciiiiy.
• Under NIIMS ICS. the command module has
aaditlonally been represented by • atogh tocidenl
commander (supported by a command sUfQvVo
directs efforts of and receives Input bom the lour
supporting functional areas (planning, logtaio.
opeiaiiont and finance). More noenuy. •United
Command System u dotaltvd In the National Oil
and Hazardous Substances I > !".ilon Contingency
Plan (NCPJ found at «0 CFf . •"* has been used
for Urgeriplll responses »hi:. '•• r*™and
module Is comprised of repicacnutives bore the
federal government (I*, W«> on-seen.
coordinator), slate government (slat
with external plans, such as LEPC plans
and Area Contingency Plans (ACPs).
Linkages will also help ensure that the
annexes do not become too
cumbersome. The use of references to
information contained in external plans
does not relieve facilities from
regulatory requirements to address
certain elements in a facility-specific
manner and to have information readily
accessible to responders. When
determining what information maybe
linked by reference and what needs to
be contained in the ICP. response
planners should carefully consider the
time critical nature of the information.
If instructions or procedures will be
needed immediately during an incident
response, they should lie presented tor
ready access in the ICP. The following
information won't! not normally be
well-suited for reference to documents
external to the ICP: core plan elements.
facility and locality information (to
' allow for quick reference by responders
on the layout of the facility and the
surrounding environment and
mitigating actions for the specific
hazard(s) present), notification
procedures, details of response
management personnel's duties, and
procedures for establishing the response
management system. Although linkages
provide the opportunity to utilize
information developed by other
organizations, facilities should note dial
many LEPC plans and ACPs may no
t detail to
rrently possess sufficient detail to be
of use in facility p
cu
.
a cooponUv* manner. ne
partleVwho have Jurisdiction.! «f
responsibility for the Incident to totally
common.* .1 Incident <*£*5"< ,
Such coordination should be guided byprocedures
found In the NCP (see figure la at« CFR
SOO.lOSMW) and the applicable Area Contingency
Nan. .- '.'.T-
of use in facility plans or th<- ICP. This
information may need to be developed
by the facility until detailed applicable
information from broader plans is
available.
In all cases, referenced materials must
be readily available to anticipated plan
users. Copies of documents that have
been incorporated by reference ne^r1 P rl
be submitted unless it is require*' •
regulation. The appropriate sections of
refcrcncei'. documents t'. -t are unique to
the facility, vhose that are not nationally
recognizer . :hose that ait required by
regulation. and those th.v •• -aid not
reasonably U- expected!. • in the
possession of the reviewir.; agency.
should be provided when the plan U
submitted tor review and/or approval.
Discretion should be used when
submitting documents containing
proprietary data. It is. however.
necessary to identify In the ICP the
specific section of the document being
incorporated by reference, where the
document is kept, and how it will be '
accessed if needed by the lot ' • ' v or •
requested by the reviewing a, In
add ition, facility owners or op- • • • -s
• are reminded to take note ofcuLc •
requirements of specific regulations
when determining what materials to
provide an agency for review as it may
not be necessary to submit all parts of
an ICP to a particular agency.
As discussed previously, this
guidance contains a series of matrices
designed to assist owners and operators
in the plan consolidation process and in
the process of ensuring and
documenting compliance with
regulatory requirements. The matrix in
AlUtthment 2 to this guidance displays
areas of current regulations that align
with the suggested elements contained
in this guidance document. When
addressing each element of the FCP
outline, plan drafters can refer to this
matrix to identify specific regulatory
requirements related to that element.
The matrices in Attachment 3 to this
guidance display regulatory ...
requirements as contained in each of the
regulations listed in the NRT policy
statement above (which are applicable
to many facilities) along with an
indication of where in the suggested ICP
outline these requirements should be
addressed. If a facility chooses to follow
the ICP outline, these matrices can be .
included as Annex 8 to a facility's ICP
to provide the necessary cross-reference
for plan reviewers to document
compliance with various regulatory
requirements. To the extent that a plan
deviates from the si.,,-.**tcd ICP outline,
plan di afters will bavi lu alter the
!nal!.>k-s to ensure that the location of
reguistorv requirements within the ICP
isclearly'idenlified fc ; 'in reviewers.
Integrated Contingency Plan Elements
Presented below is a list of elements
to be addressed in the ICP and a brief
explanation, displayed ;r. italicized text.
of thenalun* of the info?.-. Alton to be
contained ir. •!,:.! section of the ICP.
Aiiac..T-.cni l presents the complete
outline r.f the ICP without the
expL- . "Y text. As discussed
•previou . i he elements are organized
intothn. •«• n sections: plan
introduction. o>re plan, and response
annexes.
Section I—Plan Introduction Elements
1. Purpose and Scope of Plan Coverage
' This section should provide a brief
overview of facility operations and
describe in genera/ the physical area.
andnatureofKazardsoreventsta
which Ihe plan is applicable. This brief
description will help plan users quickly
assess the relevancy, of the plan to a
particular type of emergency in a given
location. This section should also
include a list ofwhkli regulationlsj an
being addressed in tlie ICP.
-------
2. Table of Contents
This section should clearly identity
the structure of the plan andincludea
totnnexes.
use of the plan during an emergency.
3. Current Revision Date
This section should'indicate the date
that the plan was last revised to provide
plan users with information on the
Currency of the plan. More • rfeto/erf
information on plan update history V*-
a record of amendments) may oe
maintained in Annex S (Response
Critique and Plan Review and
Modification Process):
4. General Facility Identification
Information
a. Facility name
b. Owner/operator/agent (include
physical and mailing address and
phone number)
c. Physical address ol the facility
(include county/parish/borough.
latitude/longitude, and directions)
d. Mailing address of the facility
(correspondence contact)
e Other identifying information {e.g.. ID
numbers, SIC Code, oil storage start-
up date)
f. Key contacUs) for plan development
and maintenance
g. Phone numberM for key contacUs)
h. Facility shone number
i. Facility fax number
This section should contain a brief
profile of the facility and its key
personnel to facilitate rapid
identification of key administrative
information.
Section tt -Core Plan Elements
1. Discovery
This section should address the initial
action the personal discovering an
incident will take to assess the problem
at hand and access the response system.
Recognition, basic assessment, source
control (as appropriate), and initial
notification of proper personnel should
be addressed in a manner that can be
easily understood by everybody In the
facility. The use of checklists or
flowcharts is highly recommended^
2. Initial Response
a. Procedures for internal and external
notifications (i.e.. contact.
organization name, and phone
number of facility emergency
response coordinator, facility
response team personnel, federal.
state, and local officials)
b. Establishment of a response
management system
c. Procedures for preliminary
assessment of the situation.
including an identification of
incident type, hazards involved.
magnitude of the problem, and
resources threatened
d Procedures for establishment of
objectives and priorities for
response to the specific incident.
including: ' . . . .
(1) Immediate goals/tactical planning
(e.g.. protection of workers and
• 'public as priorities)
(2) Mitigating actions (e^.. discharge/
release control, containment, and
recovery, as appropriate) >
(3) Identification of resources requiret
for response . >
e. Procedures for implementation of
tactical plan
f. Procedures for mobilization of
resources
This section should provide for
activation of the response system
following discovery of the incident. It
should include an established 24-hour
contact point (i.e.. that person and
alternate who is called ta set the
response in motion) and instructions for
that person on who to call and what
critical information to pass. Plan
drafters should also consider the neea
for bilingual notification. It is important
to note that different incident types
require that different parties be notified.
Appropriate federal. State, and local
notification requirements shouldbe
reflected in this section of the KP. •
Entailed notification lists may.be
included here or in Annex 2. depending
upon the variety of notification schemes
that a facility may need to implement.
For example, the release of an extremely
hazardous substance will require more
extensive notifications (i.e.. to State
Emergency Response Commissions
(SERCs) and l£PCs) than a discharge of
oil. Even though no impacts or
awareness are anticipated outside the
site, immediate external notifications
are required for releases ofCERCLA and
EPCRA substances. Again, the use of
forms, such as flowcharts, checklists,
call-down lists, is recommended.
This section should instruct personnel
in the implementation of a response
management system for coordinating
the response effort More detailed
information on specific components ana
functions of the response management
system (e&. detailed hazard
assessment, resource protection
strategies) may be provided in annexes
tothelCP.
This part of the plan should then
provide information on problem .
assessment, establishment of objectives
and priorities, implementation of a
tactical plan, ana mobilization of
resources. In establishing objectives and
*-
priorities for response, facilities should
perform a hazard assessment using
^sources such as Material Safety Data
Sheets (MSDSs) or the Chemical Hasard
Response Information System (CHRIS)
manual. Hazardous Materiah
Emergency Planning Guide (NRT-1).
developed by the NRT to assist
community personnel with emergency
response planning, provides guidance
on developing hazard onalyses.Ua
' facility elects to provide detailed hatara
analysis information in a response
annex, then a reference to that annex
should be provided in this part of the
C°Mitigating actions must be •".'-. ed to
the type of hazard present, for example.
containment might be applicable loan
oil spill li*.. use of booming strategies)
but would not be relevant to a gas
release. The plan holder is encouraged
to develop checklists, flowcharts, and
brief descriptions of actions to be taken
to control different types of incidents.
Relevant questions to ask in developing
such materials include:
• What type of emergency is
OC!f11 What areas/resources have been or
witt be affected? .
• floweneedonexc/usionzpne?
• h the source under control?
•j»l_—« «.__ _f BAMMAnea MCAIIfm*£
• IS UK? WUf M» M••*«*•• «•»••——--
• What type of response resources
are needed?
3. Sustained Actions
This section should address the
transition of a response from the initial
emergency stage to the sustained action
stage where more prolonged mitigation
ond recovery actions progress under a
response management structure. The
NRT recognizes that most incidents are
able to be handled by a few individuals
without implementing an extensive
response management system. This
section of the core plan should be one/
and rely heavily on references to
specific annexes to the JGP.
4. Termination and Follow-Up Actions
TWs section should briefly address
the development of a mechanism to
ensure that the person in charge of
mitigating the incident can. in
coordination with the federal or stale
OSC as necessary, terminate the •
response. In the case of spills, certain
regulations may become effective once
the -emergency" is declared over. The
section should describe ho* the orderly
demobilization of response resources
will occur. In addition, follow-up
actions associated with termination of a
response (e.g., accident investigation,
response critique, plan review, written
follow-up reports) should also he
outlined in this section. Plan c/ra/rrrt
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Federal Register / Vol. M. No. 109 / Wednesday. June S. 1996 / Notices
28647
mav reference appropriate annexes to
the'lCP in this section of the core plan.
Section III—Annexes
Annex 1. Facility and Locality
Information
a. Facility maps
b. Facility drawings
c. Facility description/layout, including
identification of facility hazards
and vulnerable resources and
populations on and off the facility
which may be impacted by an
incident
This annex should provide detailed
information to responders on the layout
of the facility and the surrounding
environment. The use of maps and
drawings to allow for quick reference is
•farable to detailed written
descriptions. These should contain
information critical to the response such
as the location of discharge sources,
emergency shut-off valves and response
equipment, and nearby environmentally
and economically sensitive resources
and human populations le&. nursing
homes, hospitals, schools). TheACP
and LEPC plan may provide specific
information on sensitive environments
and populations in the area. EPA
Regional Offices. Coast Guard Marine
Safety Offices, and LEPCs can provide
information on the status of efforts to
identify such resources. Plan holders
may need to provide additional detail
on sensitive areas near the facility. In
addition, this annex should contain
other facility information that is critical
to response and should complement but
not duplicate information contained in
part 4 of the plan introduction section
containing administrative information
on the facility.
Annex 2. Notification
a. Internal notifications •
b. Community notifications
c Federal and state agency notifications
This annex should detail the process
of making people aware of an incident
(i.e.. who to call, when the call must be
made, and what information/data to
provide on the incident). The Incident
commander is responsible for ensuring
that notifications are carried oat in a
timely manner but is not necessarily
responsible for making the notifications.
ACPs, Regional Contingency Plans
(RCPs), and LEPC plans should be
consulted and referenced as a source of
information on me rales and
responsibilities of external parties that
are to be contacted. This information is
important to help company responders
understand how external response
officials fit into the picture. Call-down
' lists must be readily accessible to ensure
rapid response. Notification lists
provided in the core plan need not be
duplicated here but need to be
referencea.
Annex 3. Response Management System
This annex should contain a general
description of the facility's response
management system as well as contain
specific information necessary to guide
or support the actions of each response
management function (i.e.. command,
operations, planning, logistics, and
finance) during a response.
a. General
If facility owners or operators choose
to follow the fundamental principles of
A7/MS ICS (see discussion of annexes
above), then they may adopt NHMS /CS
by reference rather than having to
describe the response management
svstem in detail in the plan. In this
section of Annex 3. planners should
briefly address either 1) basic areas
where their response management
system is at variance with HUMS ICS or
2) how the facility's organization fits
into the NIIMS /CS structure. This may
be accomplished through a simple
organizational diagram.
If facility owners or operators choose
not to adopt the fundamental principles
of NIIMS ICS. this section should
describe in detail the structure of the
facility response management system.
Regardless of the response management
system used, this section of the annex
should include the following
information:
• Organizational chart;
• Specific job description for each
position:3
• A detailed description of
inform ation flow; and
• Description of the formation of a
unified command within the response
management system.
b. Command
(2) Information (i.e.. internal and
external communications).
This section of Annex 3 should
address how the facility will
disseminate information internally (i.e..
to facility/response employees) and
externally (i.e.. to the public). For
example, this section might address how
the facility would interact with local
officials to assist with public evacuation
and other needs. Kerns to consider in
(1) List facility Incident Commander
and Qualified Individual (if applicable)
by name and/or title and provide '
information on their authorities and
duties.
This section of Annex 3 should
describe the command aspects of the
response management system that will
be used fte, reference NZZMS ICS or
detail the facility's response
management system). Thelocation(s)of
predesignated command posts should
also be identified. • •
•OPAM planning mqulnBwnti far nube
transfer hcllillef (31CFR 1M.103S) require Job
description! for each will muugancat leam
member regmrdlcct of the lanonie tauugMnent
syitem employed by the bdlHy. " •
WCvd«/•*•••£ •«•••> e^M<*»•»>•• ••••• »»• _•-«_•
release statement forms, plans for .
coordination with the news media.
community relations plan, needs of
special populations, and plans for
families of employees.
(3) Safety.
This section of Annex 3 should .
include a process for ensuring the safety
of responders. Facilities should
reference responsibilities of the safety
officer, federal/state requirements (e.g..
HAZWOPER). and safety provisions of
the ACP. Procedures for protecting
facility personnel should be addressed
(i.e.. evacuation signals and routes,
sheltering in place).
(4) Liaison—Staff Mobilization.
This section of Annex 3 should
address the process by which the
internal and external emergency
response teams will interact. Given that
parallel mobilization may be occurring
by various response groups, the process
of integration (i.e.. unified command)
should be addressed. This includes a
process for communicating with local
emergency management especially
where safety of the general public is
concerned.
c. Operations
(1) Operational response objectives
(2) Discharge or release control
(3) Assessment/monitoring
(4) Containment
(5) Recovery
(6) Decontamination
(7) Non-responder medical needs.
including information on
ambulances and hospitals
(6) Salvage plans
This section of Annex 3 should
contain a discussion of specific .
operational procedures to respond to an
incident, a is important to note that
response operations are driven by the
type of incident. That is. a response to
an oil spill will differ markedly from a
response to a release of a toxic gas to
the air. Plan drafters should taUor
response procedures to the particular
hazards in place at the facility. A
facility with limited hazards may have
relatively few procedures. A largermore
complex facility with numerous hazards
is likely to have a series of procedures
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28648
Federal Register / Vol. 61. No. 109 / Wednesday. June 5. 1996 / Notices
^
designed to address the nuances
associated with each type of incident.
d. Planning
(l) Hazard assessment. Including
facility hazards identification.
vulnerability analysis, prioritiration of
potential risks. •'••
This section of Annex 3 should
present a detailed assessment of all
potential hazards present at the facility.
an analysis of vulnerable receptors (ef..
human populations, both workers and
the general public, environmentally
sensitive anas, and other facility-
specific concerns) and a discussion of .
which risks deserve primary
consideration during an incident. NHT-
1 contains guidance on conducting^
ta/ysis
4 CVfiMMfl* gUJUWllbV w" ww»»v-»"O —
hazard analysis. Also. ACPs and LEPC
plans may provide information on
environmentally sensitive and
economically important areas, human
populations, and protection priorities.
Plan drafters should address the full
range of risks present at the facility. By
covering actions necessary to respond to
a range of incident types, plan holders
can be prepared for small, operational
discharges and large catastrophic
releases. One approach that is required
bv certain regulations, such as the Clean
Air Act (CAA) and OP A is to develop
planning scenarios for certain types and
sizes of releases (i*., worst case
discharge). Facilities may address such
planning scenarios and associated
calculations in this section of Annex 3
or as part of a separate annex
depending on (he size ana* complexity of
the facility.
(2) Protection
This section of Annex 3 should
present a discussion of strategies for
protecting the vulnerable receptors
identified through the Award analysts.
Primary consideration should be given
to minimizing those risks identified as a
high priority. Activities to be considered
in developing this section include:
population protection; protective
booming: disperse/it use. in-sftu
burning, bioremediation; water Intake
protection; wildlife recovery/
rehabilitation; natural remediation;
vapor suppression: and monitoring*
sampling, and modeling. ACPs and
LEPC plans may contain much of this
information.
(3) Coordination with natural lesouroa
trustees.
This section should address
coordination with government natural
resource trustees. In their role as
managers of and experts in natural
resources, trustees assist the federal
OSC in developing or selecting removal
actions to protect these resources. In
this role, they serve as part of the
response organization working for the
federal OSC. A key area to address is
interaction with facility response
personnel in protection of natural
resources.
Natural resource trustees are also
responsible to act on behalf of the
public to present a claim for and recover
damages to natural resources injured by
release. The process followed by the
natural resource trustees, natural
resource damage assessment (NRDA).
generally involves-some data collection
during emergency response. NRDA
regulations provide that the process
may be carried out in cooperation with
the responsible party. Thus, the facility
may wish to plan for how that
cooperation will occur, including
designation of personnel to work with
trustees in NRDA.
(4) Waste management.
This section should address
procedures for the disposal of
contaminated materials in accordance
with federal, state, and local
\irements.
(ifMedical needs of responders
(2) Site security
(3) Communications (internal and
external resources)
(4) Transportation (air. land, water)
(5) Personnel support (e.g.. meals.
housing, equipment)
(6) Equipment maintenance and
support
This section of the Annex 3 should
address how the facility will provide for
the operational needs of response
operations in each of the areas listed
above. For example, the discussion of
personnel support should address issues
such as: volunteer training;
management; overnight
accommodations; meals; operational/
administrative spaces; and emergency
procedures. The NRT recognizes that
certain logistical considerations may not
be applicable to small facilities with
limited hazards.
f. Finance/procuremenl/administration
(1) Resource list
(2) Personnel management
Response equipment
Support equipment
t3
I™ ——«-«- »
(5 Contracting
(6 Claims procedures
(7) Cost documentation
This section of Annex 3 should
address the acquisition of resources
(i.e.. personnel and equipment) for the
response and monitoring of incident-
related costs, lists of available
equipment in the local and regional
area and how to procure such
equipment as necessary should bo
included.Information on previously
established agreements (e.g.. contracts)
with organizations supplying personnel
and equipment (e.g.. oil spill removal
organizations) also should be included. •
This section should also address
methods to account for resources
expended and to process claims
resulting from the incident.
Annex 4. Incident Documentation
a. Post accident investigation
b. Incident history
This annex should describe the
company's procedures for conducting a
follow-up investigation of the cause of
the accident, including coordination
with federal. State, and local officials.
This annex should also contain an
accounting of incidents that have
occurred at the facility, including
information on cause, amount released.
resources impacted, injuries, response
actions, etc. This annex should also
include information that may be
required to "prove that the facility met its
legal notification requirements with
respect to a given incident, such as a
signed record of initial notifications and
certified copies of written follow-up
reports submitted after a response.
Annex 5. Training and Exercises/Drills
This jmnex should contain a
description of the training and exercise
program conducted at the facility as
well as evidence fl.e.. logs) that required
training and exercises have been
conducted on a regular basis. Facilities
may follow appropriate training or
exercise guidelines (e.g.. National •
Preparedness for Response Exercise
Program Guidelines) as allowed under
the various regulatory requirements.
Annex 6. Response Critique and Plan
Review and Modification Process
This annex should describe
procedures for modifying the plan based
on periodic plan review or lessons
learned through an exercise or a
response to an actual incident.
Procedures to critique an actual or
simulated response should be a part of
this discussion. A list of plan
amendments fi.e.. history of updates)
should also be contained in this annex.
Plan modification should be viewed as
a part of a facility's continuous
Improvement process.
Annex 7. Prevention
Some federal regulations that
primarily address prevention of
accidents include elements that relate to
contingency planning (e.g.. EPA's BMP
and SPCCregulations and OSHA's
Process Safety Standard). This annex is
designed to allow facilities to include
-------
Federal Register / Vol. 61. No. 109 / Wednesday. June S. 1996 / Notices
28649
prevention-based requirements (e&.
maintenance, testing, in-house
inspections, release detection, site
security, containment, fail safe
engineering) that are required in
contingency planning regulations or
that have the potential to impact
response activities covered in a
contingency plan. The modular nature
of the suggested plan outline provides
planners with necessary flexibility to
include prevention requirements in the
ICP. This annex may not need to be
submitted to regulatory agencies for
review.
Annex 8. Regulatory Compliance and
Cross-Reference Matrices
This annex should include
information necessary for plan
reviewers to determine compliance witti
specific regulatory requirements. To the
extent that plan drafters did not include
regulatory required elements in the
balance of the ICP. they should be
addressed in this annex. This annex
should also include signatory pages to
convey management approval and
certifications required by the
regulations, such as certification of
adequate response resources and/or
statements of regulatory applicability at
'required by regulations under OPA
authority. Finally, this annex should
contain cross-references that indicate
where specific regulatory requirements
are addressed in the ICP for each
regulation covered under the plan. As
discussed previously. Attachment 3
contains a series of matrices designed to
fulfill this need in those instances where
plan drafters adhere to the outline
contained in this guidance.
Attachment 1—ICP Outline
Section I—Plan Introduction Elements
t. Purpose and Scope of Plan Covengt
2. Table of Contents
3. Current Revision Date
«. General Facility Identification Information
a. Facility name
b. Owner/operator/agent (include physical
and mailing address and phone number)
c. Physical address of the facility (include
county/parUh/borough. latitude/
longitude, and directions)
d. Mailing address of the facility
• (correspondence contact)
c. Other identifying information (e.g.. ID
numbers. SICCode. oil storage start-up
date) , _,
f. Key contacts) for plan development and
maintenance
K. Phone number for key contacts)
h. Facility phone number
1. Facility fax number
Section II—Core Plan Elements
1. Discovery
2. Initial Response
a. Procedures for Internal end external
notification* (i.e.. contact, organization
name, and phone number of facility
emergency response coordinator, facility
response team personnel, federal, stale.
and local officials)
b. Establishment of a response management
c. Procedures for preliminary assessment nf
the situation. Including an identification
of incident type, hazards involved.
magnitude of the problem, and resources
threatened
d. Procedures for establishment of
objectives and priorities for response to
the specific incident, including:
(t) Immediate goals/tactical planning (e.g..
protection of workers and public as
priorities)
(2) Mitigating actions (e.g.. discharge/
release control, containment, and
recovery, as appropriate)
(3) Identification of resources required tor
response
e. Procedures for implementation of
tactical plan
f. Procedure for mobilization of resources
3. Sustained Actions
4. Termination and Follow-Up Actions
Section Ill-Annexes
Annex 1. Facility and Locality Information
a. Facility maps * .
b. Facility drawings
Identification'of facility hazards and
vulnerable resources and populations on
and oft* the facility which may be impacted
by an incident
Annex 2. Notification
a. Internal notifications
b. Community notifications .
c. Federal and state agency notifications
Annex 3. Response Management System
a. General
b. Command
(1) List facility Incident Commander and
Qualified Individual (if applicable) by
nanif andfor title and provide
information on their authorities and
duties
(2) Information (i.e.. Internal and external
communications)
(31 Safety
(4) Liaison-Slalf mobilization
c. Operations
(1) Operational response objectives
(2) Discharge or release control
(3) Assessment/monitoring
(4^Contalnraent
(S) Recovery
(6) Decontamination
(7) Non-responder medical needs including
information on ambulances and
hospitals
(8) Salvage plans
d. Planning
(1) Hazard assessment, including facility
hazards identification, vulnerability
analysis, prioritization of potential risks
(2) Protection
(3) Coordination with natural resource
trustees
(4) Waste management
e. Logistics
(1) Medical needs of responders
(2) Site security
(3) Communications (internal and external
resources)
(4) Transportation (air. land, water)
(5) Personnel support (e.g. meals, housing.
equipment)
(6) Equipment maintenance and -support
f. Fin&nce/piucurement/administration
(1) Roource list
(2) Personnel management
(3) Response equipment
(4) Support equipment
(S) Contracting
(6) Claims procedures
(?) Cost documentation
Annex 4. Incident Documentation .
a. Post accident investigation
b. Incident history
Annex S. Training and Exercises/Drills
Annex 6. Response Critique and Plan Review
and Modification Process
Annex 7. Prevention
Annex B. Rugulatory Compliance and Cross-
Reference Matrices
BILUN6 COO6 VM •»•»
-------
• Attachment 2: ICP Development Matrix
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26SJ«s)
279.52(bX6Xvli)
:M.»(e)
26UKc)
279J2(bX2)(*>
EPA'iOnranallen
Prevention
Reptilian
(40CFRpiitlll)
1 12.20(()
M2.XKhX?Xiv)
FI.TJ
IH20(hXIO)
FI.IO
IUJO(hX1Mlv)
H2.20(hX3X»l)
FIJJ
H2.20(hXIX*)
H2.20(hXIXvi)
H2M(hX)Xl-l!)
M220(hX3X«>
H22IXhX)X*li)
FIJJ . .
ll220tflXIXiv)
H220(hX)Xvl)
H220(hX»)
FIJJ
Fl.(.| .
H2.20(»OOKi«)
H2.2(XhXIXi«>
M2.20(hX)M»0
F1.U
Fl.7.1
IIJ20(hXIM»)
IIJ.IO(hXJX»)
FIJ.4
USCC-FRP
(33 CFR pill 154)
1030(0
IOJ)(bX3)
!03S(bX3Xii>)
I03S(CX3>
!033(cX3)
•
1033(6X3X1*)
!033(tX3)
1037
I02S
!033(bX3Xiii)
!033(bX3XI«>
!033(eX3)
IO)3(bX3Xi*)
DOT/RSPA-FRP
(49CFRpiltl»4)
I94.I07(()
!94.l07(dXIXv)
•
l94.|07(dXIXv)
A-2
IM.I07(dXIX«iii)
OSIIA Emergency
Action rim*
(1* CFR I910JIM)
•M Proccu Sutty
(29 CFR 1910.119)
3SdX2X»)
3S(a)(3)
H9«X3Xiii)
I65(b)
3S(iX3Xi)
IIOOK4)
11901(3)
I6.1(d)
t
OSHA HAZWOPER
(MCFX 1910.120)
UX3XIU)
(pXIXIvXB)
(qX2X«ii)
OX2Kviii)
(PXSXKXH)
(qX2Xviil)
QX2XV)
(PXIXIIXE)
(qX2Xv)
VX2XII)
(pX(XilXB)
(qX2XII)
(qX3Xv).H)
(IX2X«)
(pXSXiiXK)
(qX2XA)
•
CAARMP
(40 CFR put 61)
68.9JUXIX")
-
6t.93»X2)
•
I
S
I
$
o>
*.
Z
o»
«n
ui
-------
ICPDtnMM
0) R«paafi«qripmtiil
(]) Ceatncllat
(6) Qtlttl pfocidufti
(7) CatdotwnmUIlM
i. PatMccUcnt
InTotliitlofl
b. Inddrat history
i. Tratnlflf ind nmlMi/drflto
{.RaponicrlilqMindplm
review Mid BUdUICtmMI pfOCM
if**. . ,
•«— ^—™^"ii^-^i-^"
RCRA(40CTRpin
SM.SobpMtD.40
CPRp>nl6S,
8abpirtD,iiH)40
H«.S1(«)
4SJKO
2UJA*I
•
179Jl(bX«XI«)
264J4
MISd
EPA'tOIIPenmlra
Pf f VCDtWfl
Rctobllon
(40CFRptrtlll)
ll.20(hX3X«l)
PIJJ
Fl.4^
MUWhXS)
FIJJ.PUJ
1
USCC-FRP
DICFRpirtlM)
033(bX4XHD
03«eX3)
IWJ(e)
IOJO
IOJJ
ApptadliD.
louoxt)
!03J(d)
IMS
DOT/RSPA.FRP
(49CTRpittl94)
194 !07(dXIXvU)
194.107(4X1X1*)
194.117
A-6 •
A.T
l94.IQ7(dXIX>>
194 III
194.119
194.111
A-l
OSKA Era«Tf eoqr
Anton Flint
(19CFR1910JI(i))
indFroctttSihty
(19 CFR 1910.119)
•
3KIX1XHO
3S(iX3)
II9UXIXD
119(1)
119(0X0
OSHAHAZWOPER
(»Cre 1910.110) .
(PXSXUXK)
•
(px«x»xn
(aXlXO
(PXSXIIXJ)
OX3Xi«)
(PXIXHI)
(qX6)
OX1X«)
(PXIXUXJ)
(qXIXD
UXIXill)
(PXIXIIXQ
(qXlXUO
i;
CAARMP
(40CFRpirt«t)
.
-------
Federal Register / Vol. 61. No. 109 / Wednesday. June 5. 1996 / Notices
286S7
ATTACHMENT 3: REGULATORY CROSS-COMPARISON MATRICES
ICP Oiatan(s)
RCRA (40 CFR Part 264 Subpart O'. 40 CFR Part 265 Subpart 0 '. 40 CFR Part 27952(b)»)
26452 Content of contingency plan:
(a) Emergency response actions.*
(b) Amendments to SPCC plan.
(c) Coordination wBh Stale and tocal response parties'
(d) Emergency coordtnator(s)
(e) Detailed description of emergency equipment on-site
(I) Evacuation plan H applicable
26453 Copies of contingency plan.
26454 • Amendment ol contingency plan
2645S Emergency coordinator
244.56 Emergency procedures:
(a) Notification —r
(b) Emergency identification/characterization
(c) HeaiWenwonmental assessment
(d) Reporting .«
(e) Containment
(0 Monitonng
(g) Treatment, storage, or disposal of wastes
(h) Cleanup procedures:.
(1) Disposal _____
(2) Decontamination
(i) Follow-up procedures
(l) Follow-up report
265.52 Content of contingency plan:
(a) Emergency response actions.*
(b) Amendments to SPCC plan.
(c) Coordination with Slate and local response partes' —
(d) Emergency coordinator(s)
\\2* 1112.
llJ2.e:
1115.
11.2-a; III.3J>.(1).
112-a: 1112: lll.3jc.|3).
".'.".'." \ W.3.b.<3)'. 111.3 c.(3).
11.4.
|OJ CHICI|JCI~>7 M/W1V«NlM"l0r • .___.
(e) Detailed description of emergency equipment on-site .....
(I) Evacuation plan H applicable
265.53 Copies of contingency plan.
26S54 Amendment of contingency plan
26555 Emergency coordinator.
265.56 Emergency procedures:
(a) Notification ..
....
(b) Emergency idenbfica&onfcharacterization
(c) Health/environmental assessment
(d) Repotng
(e) Containment ——
(f) Monitoring
(g) Treatment, storage, or disposal of wastes
(h) Cleanup procedures:
(1) Disposal
\\2ix. tn.3.a.
U2xl.(3):
I0.3.M4).
: ni.3.f.(3);
1115.
H2a: IH2;
Il2.c: III J.c.(3).
(2) Decontamination
(i) Follow-up procedure: ________
(j) Fr>i:«-up report _.. —
279.52(bjv: Content of contingency plarc
(i) Emc.-.'ncy response actions*
(ii) Amertvnents to SPCC plan.
(Ui) Coocd.u-.iio-. wfth State and local response parties*
(iv) Emergency c/^otfinatonls)
Ill 3 d.(4).
• • ?.s (5)
itf. m.3.a.
(v) Detailed desu+^n of en-*-rgency equipment on-stte
(vi) Evacuation plan V aj/ .Vabte
(3) Copies of contingency pUu..
(4) Arr«id-^ent of contingency plan
(5) Emerge-..-c/iorc'ir
(6) Emergency proce-
(!) Notification
(u) Emergency identificatioa'dtaractcriz
(ii) HealttVenvironmemal assessment.
(iv) Reporting
(v) Containment.
(vi) Monitoring
(vii) Treatment, storage, or disposal of was
(viu) Cleanup procedures:
(A) Disposal
H2.t IIIAf.(t); IIIJ.f.(3);
ni5.
112* IIL3JDX1).
l>2.a; 1112; 10.0/2). •
'-"
112
(B) Decontamination
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28658
Federal Register / Vol. 61. No. 109 / Wednesday. June 5. 1996 / Notices
ATTACHMENT 3: REGULATORY CROSS-COMPARISON MATRicES-^Continued
ICP CftaUorKs)
fm) Follow up report,
III.4JL
EPA'a ON Pollution Pravmtlon Regulation (40 OFR112)
112.7«J)(1) Strong spin
and materials."-11
11220(g) General response planning*
1122000 Response plan elements
ntingency plan and written commitment of manpower, equipment.
•
jirements
jCUVu ne-pensv p-n n-iimw
(1) Emergency response action plan (Appendbt FU):
Rk^arritelep^xxwr«Jrr*)efO^<^iaIif^i«SvH>^(F1i5)
mider-toollridrvidu-ls/oip^n-ationsto .
(S) Description, of information to pass to response personnel in event of a reportable
fry) Description of ladfit/s response equipment and its location (Ft 32)
U.d.(3); 111.6.
2:111.8.
(v) Description ol response personnel capabilities (Ft.3.4)
iv) uescnpoon 01 response peiswuio VJH.-•» _—-.—_ _..___—
(vi) Plans for evacuation of the facility and a reference to community evacuation plans
(vii) Description of immediate measures to secure the source (Ft .7.1)
(vBi) Diagram of the laciEty (F1_»)
(2) Facility information (F12. F2.0)
12.
UI3.e.(3): IU3.e.(6);
III3.M3).
I2.b; 1113; IH3.e.(S): IM3.f.(2):
H3.b.(3): IIIJ.e.(5) •
(3) Infonnation about emergency responses:
(0 Identity of private personnel and equipment to remove to the maximum extent prac-
ticable a VYCO or other discharges (F132. F13/4).
(ii) Evidence of contracts or other approved means tor ensuring personnel and equip-
• ment availability.
(Hi) Identity and telephone of Mividuals/organteations to be contacted m event of a
Discharge (F13.1).
(iv) Description of information to pass to response personnel in even! of a reportable
spil (Ft 3.1).
(v) Description of response personnel capabilities (F13.4)
(vi) Description ol a facility's response equipment, location ol the equipment, and
equipment testing (F132. F133).
' (vD) Plans for evacuation of the facility and a reference to community evacuation plans
as appropriate (F135).
(vS) Diagram of evacuation mutes (F1J9).
fa) Duties Of the qualified individual (F13.6)
(4) Hazard evaluation (F1.4)
(5) Response planning levels (F15. F15.1. F152)
(6) Discharge detection systems (Ft-3. F15.1. F15
(7) Plan implementation (F1.7)
' Response actions to be carried out (Fl.7.1.1).
(EJ Description ol response equipment to be used for each scenario (Fl .7.1.1)
fu) Plans to dispose of contaminated cleanup materials (Ft .72)
frv) Measures to provide adequate containment and drainage of spilled oil (Fl.73).
(8) Self-tospection. drills/exercises, and response training (FUB.1-F1JB32)
(9) Diagrams (PIS)
(10) Security systems (F1.10)
(11) Response plan cover sheet (F2-)).
Fa-Sty response traWng and drills/exercises (Ft 32. F1-B3).
Appendix F Facnity-SpecHic Response Plan:'»
1.0 Model Facility-Specific Response Plaa
1.1 Emergency Response Action Pun.
12 Facility Information i • i • <
13 Emergency Response Information:
13.1 NotTeatton,
Response Equipment Qst
133 Response Equfement TestinoyDeptoyment .
134 Personnel -
135 Evacuation Plans .
13£ OuaHied Individual's Duties -
1.4 Hazard Evaluation -
1.4.1 Hazard IdenfificaHon
1.42 Vulnerabnity Analysis
1A A Analysis of the Potential for an Oil Spin.
1.4.4 Facility Reportable OU SpiB History
15 Discharge Scenarios:
15.1 Small and Medium Discharges _______
152 Worst Case Discharge
1.6 Discharge Detection Systems:
1.6.1 Discharge Detection By Personnel
11.1.8-to.
.4.b-_; MM.
; lll.3.c.(4H5): IM3.e.(5).
12--
HI3: liL3.e.(5);
3):
lH3.f.(3).
H2jd.(t):
1-3-1(1): UI3.L
iH3.f.(D:
niit-c: ui-u.(3t:
11.1.
II-UM; 113; 11.4.
U2-. 1113X1(2).
III3.C.(5H6>
Hi3.d.(2): IH3.d.(4).
III.1JX.
IH3.ej(2).
1115.
12.
13; M« l.4_v-c; MJx II---: IIL1.
•2x1(3): I
«L3.e.(8).
ll2Ji; 1113: III3.K2).
II2&
III3-M1).
UL4__
III3XMD.
IH3-U1).
ILL
-------
286S9
Federal Register / Vol. 61. No. 109 / Wednesday. June 5. 1996 / Notices
ATTACHMENT 3: REGULATORY CROSS-COMPARISON MATRICES-Continued
— ' ' ^^^^^^^^^
U62 Automated Discharge Detection
1.7J ContainmemaMurainagerH"»i»—rv""--
1.8 Self-inspection. CWBs&erdses. and Response Tiawng.
1.8.1 FaaTity Self-Inspection •
- — • •* —u_k. n_n* !£«•••» ifnr
• «»»••• j—-•——--—
Response Trahwig
1.9 Diagrams
1.10 Security
2.0 Response Plan Cover
11.1.
112.
II2.A(3): II2A
IIIJJ.(3H«)-
HIS. . .
1.4: UL14-C
..
1.4.0; 1.4-c; lAh; 111.1.
^^^^^^^^^^^•^^^•^^™^^™^^^^*"^^~™
USCC FRP (33 CFR pait 154)
JIMS
-.51.1029 Worst case discharge
1&O030 General response plan contents-
(a) The plan must be written in English.
(b) Organization el the plan'»
(c) Required contents.
C^cTotr-a^vedln^ JJ^^ '"^
1C) nequireo canreiu».
(d) Sections subrnmed to COTP.
(e) Cross-reterences
'_.V—. • . *>L- ki
|BJ 4XOSS1BICIE11W«v4 Irt-al •nnnrinT
' "*
W W*^««^)fw*
notrfieations to federal, state.
__
'and tocal agendes
Ust ofWipment and
age most probable discharge.
m.
an aver-
111.1.
\AK I.4XX I.4.M
1.4*.
12.
13; 111.6.
\\2K W2A-C.
ill JJ>: 1112^-c.
U2.d/2): HI J.c.(2).
112.
until arrival of qualified individual.
!!^1x^^
fw) Oa spin response organiiationjsysplll management learn avaBabte by contract
n one COTP. the oa-spiUresponse
applicable geograprftKpecHSc ap-
n.i:ii2.
112.
sensitive envi
ACP that are potentially impacted by a WOO.
(ii) List areas and provide maps/charts and desert
(iil List areas ana provwe maps/cnans ano oesom icsfon
(Hi) Equipmert and personnel necessary fa protect ioenuted areas
(5) Disposal 1— —
tons.
112*.
(c) Training and exercises
(d) Plan review and update procedures
(e] Appendices
(1) Facility specific information .
(2) List of contacts _-...
(3) Equipment lists and records.
(4) Communications ph"
Ml w>mniunicBuw"» !•""• ••
(5) Site-specific safety and heatm plan
ULS..
OL6.
Ux;n.1Jb.
..
): iiiAt.(i): IUJ3J.(3H5).
NUJrxCZ).
UL3JbX3): IIU£.(7): IHJje. (1). ' • '
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28660 Federal Register t Vol. 61. No. 109 / Wednesday. June 5. 1996 / Notices
ATTACHMENT 3: REGULATORY CROSS-COMPARISON MATRICES—Continued
ICPCitalionts)
(6) List of acronyms and definitions.
(7) A geographic-specific append*.
154.1040 jyPMHX ICTfMitwuBmj »m »«•»«-•!•.•.- .—... .-. -__- ...
154.1041 Sperferesppr^inlonTOtton to be maintained on m
154.1045 GroqJsHV petroleum cis.
154.1047 Group V petroleum oBs.
154.1050 Training _- —
154.1055 Drite ____
154.1057 lnspectkx> aid inairtenanee of response resources
154.1060 Submission and approval procedures.
154.1065 Plan revision and amendment procedures .
154.1070 Deficiencies.
154.1075 Appeal Process. •
Appendix C—Guidelines for determining and evaluating requved response resources for tacdity
response plans.
Appendix D—Training elements for oil spin response plans .
UL5.
dl.5.
OL6.
nmp).
1115.
DOT/RSPA FRP (49 CFR Part 194)
194.101 Operators required to submit plans.
194.103 Significant and substantial harm: operator's statement
194.105 Worst case discharge
194.107 General response plan requirements:
(a) Resource planning requirements
(b) Language requirements.
(c) Consistency with NCP and ACPfe) :
(d) Each response plan must include:
(1) Core Plan Contents;.
(!) An information summary as required in 194.113 _.
194.113(a) Core plan Information summary:
(1) Name and address of operator
(2) Description of each response zi
oe
(b) Response zone appendix information summary:
(1) Core plan information summary
(2) Name*O»S*A*A-O Submission and approval procerj
194.121 Response plan review and update procedures
ires.
•Aperxta«S*A-Aecommended gufeines for the preparation of response plans.
Section 1—Information cur
ny.
Section 2—Notification procedures
Section 3—Spill detection and en-scene so* mitigation procedures.
Section 4—Response activities ______________
Section S-List of contacts
Section 6—Training procedures . ..
Section 7—Drill procedures _________________
Section 8-Aesponse plan teview and update procedures -
Section 9—Response zone appendfces _
IILB.
IIL3.d
IIL3.d(3); III*
L4; (ILL
1.4.0; l.4.d.
MJC.
1.4; IIL1.
III.6.
L2.
L4SX-. \\2JX U2AUI&.
ILi;
UI5.
1115.
HLS.
U.2.D; (13: III.1A-C. (UJ3.
OSHA Emergency Action Plans (29 CFR 1910.36(8)) and Process Safety (29 CFR 1910.119)
l9l(L38(a) Emergency action plan:
(1) Scope and applicability __
(2) Elements:
(i) Emergency escape p
EJUT6S And 6fH6fQ6nC]f CSCflpfi IOUt6
sigr
(D) Procedures to be followed fay employees who remain to operate critical plant oper-
etions before they evacuate*
(B) Procedures to account far al employees after emergency evacuation has been
{UwnpIeterJL
fiv) Rescue and medical duties for those employees who are to perform them
(v) The preferred means ot reporting fires and other emergencies
(vi) Names or regular Job tides of persons or departments who can be contacted for
further information or explanation of duties under the plan.
(3) Alarm system1* .
(4) Evacuation
(5) Training
1910.119 Process safety management of highly I
(e)(3)(ii) Investigation of previous incidents
rdo
CTN
(e)(3)(E) Process hazard analysis requirements .
(g)(1)(i) Employee training in process/operating pi
(j)(4) Inspectionftesting of process equipment _
01(5) Equipment repair
(I) Management of cnange(s).
(m) incident investigation —
112: IL2x: HI3Jb.(3); IIL3X.
I.4J; UJLa: OL3JL(2); III Jjbj(4).
\\2jx, nujc.(3): ni jA(3).
n24 III JJM3): iHJ.c(3V. 111
111.4; UlAJb.
HL3
HL&
UI5.
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Federal Register f Vol. 61. No. 109 / Wednesday. June 5. 1996 / Notices
28661
ATTACHMENT 3: REGULATORY CROSS-COMPARISON MATRICES—Continued
(n) Emergency planning and respi
™ -F -» -"*—»--
wS*Mh?sSeMrflrfc!section to handle anticipated emergences pnor to the com-
an emergentr action plan complying with section 1910 J8(a) ol tos part.
(2) Elements ol an emergency response plan: ^^
(i) Pre-emergency planning and coordination with outside parties.
(ii) Personnel rotes, bnes of authority, and cornmuneawn.
(iii) Emergency recognition and prevention
fw) Safe distances and places of refuge
(v) Site security and control
IIL3je.<6).
LI.
|V| 911V 0«%^*«**J •••*• ^w—»- .
(vi) Evacuation routes and procedures
(vii) Decontamination procedures rr^T^T
(viiQ Emergency medical beatment and response procedures
(ix) Emergency alerting and response procedures
(x) Critique of response and fottow*p r
(xi) PPE and emergency equjpmenl . •—
j.
MA U2Jt>; IH2* "12-c: III .3Jb.(4):
.
Il2jd; III JJxO)
«*•*
(3) Procedures (or handing emergency incidents:
«*-».-«-:OTSS&--*"
(B)
'reining incidents to local, state, and federal government
(u) The^rgtrey lesponse pbn Shan be a separate seAon of the S*> Safety and
(iiOHT?IBhe'rrSgency response plan shall be corrg^e withthe disaster, fire, and/or
^ency resp^r^c^^t^and^^encjes
(tv) The emergency response plan shall be tetvearseo reraxany as fan ot «« «YCI«I
essary. be amended to keep It current with new or«
III.1JC.
II24; IH2.
to MUf/erAployees of an emergency
to lower background-noise to order to speed
kitorma6on.*vailable at time of «w «"«8«^.«'
«« hcideiit and the site response capaWties and proceed with *e
appropriate -steps to implement the site emergency response plan,
1910.120{P)(8) Emergency r
|^. •^W|f/\'Wf ^^.™~w— —f g -» "*TF
(i) Emergency response plan.
(D) Elements of an emergency response plan:.
(A) Pre-emergency planning and coordination with outs
^^
panes,
(B) Personnel totes. Enes of aUrtorBy. and <
(C) fsmergency reoogntfion and prevention
ricatirj
l%4f Hll«i|fm.wj ••••• " - - — — ^-^-——
(D) Safe distances and places ot refuge
(E) Site security and control
^CJ, 0(10 VO%M*I»J «•••«• »»-™». •^•HMO^K
(F) Evacuation routes and procedures
(G) Decontamination procedures,
\ » ^ ..i iilC»rtl tv^«lMAA«^
LI
II2JD: UI2Jb;
IH.3.b.(4):
IL1:HL7
(H) Emergency medical treatment and response procedu
(I) Emergency aJeding and response procedures
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1
Federal Register / Vol. 61. No. 109 / Wednesday. June 5. 1996 / Notices
" ATTACHMENT 3; REGULATORY CROSS-COMPARISON MATRiCEfr-Continued
I 'irr
ICP Citations)
(J) Critique of response and MMH* .
(K) PPE and emergency eqwpment —
fii) Training _ '•• ...__-——.
CMPrc^dureslortanrJingeinBrgjmcylrciderts:
(A) Additional elements of emergency response plans:
* WSiU.topoa^.bvoutandpre^nj.weaker
condttons
aSSreSW^* ~ -^ .^government
IIIJ.e.(6); IIIAM3): IHJ4(2); IIU.e.(6);
10.1(3).
1115.
II2« 1115-
IllJ-e.
shan evaluate the Incident and the site response eapaaniiesju»
appropriate steps to implement the site emergency response plan
I9i0.i20(q) Emergency response to hazardous substance releases: •
(1) Emergency response plan """
—
(2) Elements ot an emergency response ptorc fcMaM1«I.
(i)Pre-emergency planning and coordination with outside parties
(ii) Personnel roles. Enes ot amhorty. Vaining. and <
(iii) Emergency recognilion and prevention „.___——~
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Federal Register / Vol. 61. No. 1O9 / Wednesday. June 5. 1996 / Notices
28663
ATTACHMENT 3: REGULATORY CROSS-COMPARISON MATRICES—Continued
ICP
(x) When deemed necessary tor meeting the tasks at hand, approved ******&**
eomorassed air breathino apparatus may be used with approved cylinders irom
omTSSoved SScoZSWressed * breathir,, apparatus provided that
such cylinders are of the same capacity and pressure rating.
(4) Skilled support personnel
(5) Specialist employees.
(6) Trebling
(7) Trainers.
(B) Refresher training.
(9) Medical surveillance and consultation.
(10) Chemical protective dotting.
(11) Post-emergency response operations.
1115.
EPA's Risk Management Program (40 CFR Part 68)
6820-36 Offstte consequence analysis ,
68.42 Five-year accident history
Hazard review
Incident investigation
Process hazards analysis
Incident investigation
6650
68.60
66.67
OOiOl MIWWIM MI»«H»»»Jf•••""• •"""" " ™~~
68.95(a) Elements o» an emergency response program:
0) Elements of an emergency response ptaw •
(i) Procedures for inlonring the putXc and emergency response agencies about aco-
dental releases.
(ii) Documentation of prepsr first-aid and emergency medical treatment necessary to
treat accidental human exposures.
(Hi) Procedures and measures for emergency response alter an accidental release 01
a regulated substance.
(2) Procedures for the use of emergency response equipment and for its inspection, test-
ing, and maintenance.
(3) Training for all employees in relevant procedures
(4) Procedures to review and update the emergency response plan
68.9S(b) Compliance with other federal contingency plan regulations.
68.95(c) Coordination with the community emergency response plan.
III.4.D.
lli.3.d.(l).
111.4.3
lll.3.d.(1)
Hl.4.8
\\2a; \\\2.
ll.i: 115; II J: iw: Hi JA-C.
«L3.e.(6).
111.6.
Notes to Attachment 3
the federalreqremenls listed. Thus, in
I cases state requirements may not track this matrix.
' Facilities snouio oe aware inai most siaies mm uevi o«un«ii«J by^PA to implement RCRA
the federal requi/emenjs listed. Thus, in many eases slate requirements may not track ttw matra.
states to ensure an tCP complies whh slate RCRA requiremeits. .
• Section 26456 is incorporated by reference at §26452{a).
»Incorporates by reference § 264.37. ._,,-..
•Section 265.56 is incorporated by reference at §265.52(8).
'Incorporates by reference §26547. .,..,-««
•Secton 27952(b)(6) is incorporated by reference at §27952(b)(2)(i).
JJlSSSWpSS!^^ K. ,n, «hm,,CP
" H a fac.% is rMuieflIto^develop a st/ww oil sin contingency P&" «"»der tNs section, the requirement can be met »«ugh »« CP.
"The appendix Srther descrbesthe reqiwed elements In I20^0(h). II contains regulatory requirements as well as recommendations.
BS3L"SBW^^
'• Section 1910J8(a)(3) incorporates 29 CfR 1910.165 by reference.
-------
Federal Register / Vol. 61. No. 109 / Wednesday. lune S. 1996 / Notices
Dated: April IS. 1996.
Elliott P. Law*.
Assistant Adminittrator. Office of Solid Watte
and Emergency Retporae. VS.
Environmental Protection Agency-
Dated: April 22.1996.
Rear Admiral fane* CCerd.
Chief. Marine Safety end Enviwuneiifa/
Protection Directorate. US. Coo* Cwud.
Dated: April IB. 1996.
RkhanlB.FeUer.
Associate Administrator for Pipeline Safety.
Research ond Special Program*
Administration. U.S. Department of
Transportation.
Dated: April IB. 1996.
John B. Moran.
Director of Policy. Occupational Safety and
Health Administration. Department of labor.
Dated: April 18.1996.
ThoraesGernhofer.
Associate Director. Offshore Minerals
Management. Minerals Management Service.
Department of the Interior.
|FR Doe. 96-13712 Filed 6-1-96:8:45 «ml
BILLING COOC BMO-60-*
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[Code of Federal Regulations]
[Title 40, Volume 8, Parts 63 to 71]
[Revised as of July 1, 1997]
From the U.S. Government Printing Office via GPO Access
[CITE: 40CFR68]
[Page 1149-1154]
TITLE 40—PROTECTION OF ENVIRONMENT
CHAPTER I—ENVIRONMENTAL PROTECTION AGENCY
PART 68--CHEMICAL ACCIDENT PREVENTION PROVISIONS—Table of Contents
Subpart A—General
Sec. 68.1 Scope.
This part sets forth the list of regulated substances and
thresholds, the petition process for adding or deleting substances to
the list of regulated substances, the requirements for owners or
operators of stationary sources concerning the prevention of accidental
releases, and the State accidental release prevention programs approved
under section 112(r). The list of substances, threshold quantities, and
accident prevention regulations promulgated under this part do not limit
in any way the general duty provisions under section 112(r)(l).
Sec. 68.2 Stayed provisions.
(a) Notwithstanding any other provision of this part, the
effectiveness of the following provisions is stayed from March 2, 1994
to December 22, 1997.
(1) In Sec. 68.3, the definition of *'stationary source,11 to the
extent that such definition includes naturally occurring hydrocarbon
reservoirs or transportation subject to oversight or regulation under a
state natural gas or hazardous liquid program for which the state has in
effect a certification to DOT under 49 U.S.C. 60105;
(2) Section 68.11S(b){2) of this part, to the extent that such
provision requires an owner or operator to treat as a regulated
flammable substance:
(i) Gasoline, when in distribution or related storage for use as
fuel for internal combustion engines;
(ii) Naturally occurring hydrocarbon mixtures prior to entry into a
petroleum refining process unit or a natural gas processing plant.
Naturally occurring hydrocarbon mixtures include any of the following:
condensate, crude oil,
[[Page 1150]]
field gas, and produced water, each as defined in paragraph (b) of this
section;
(iii) Other mixtures that contain a regulated flammable substance
and that do not have a National Fire Protection Association flammability
hazard rating of 4, the definition of which is in the NFPA 704, Standard
System for the Identification of the Fire Hazards of Materials, National
Fire Protection Association, Quincy, MA, 1990, available from the
National Fire Protection Association, 1 Batterymarch Park, Quincy, MA
02269-9101; and
(3) Section 68.130(a).
(b) From March 2, 1994 to December 22, 1997, the following
definitions shall apply to the stayed provisions described in paragraph
(a) of this section:
Condensate means hydrocarbon liquid separated from natural gas that
condenses because of changes in temperature, pressure, or both, and
remains liquid at standard conditions.
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oere a process that has a regulated substance
present in more than a threshold quantity as determined under
SCC' Designated agency means the state, local, "Federal agency
designated by the state under the provisions of Sec. 68. 215 (d) .
DOT means the United States Department of Tran*P"t^"";al or state
Environmental receptor means natural areas such as national or state
narks, forests, or monuments; officially designated wildlife
SancluaSes, preserves, refuges, or areas; and Fede"1^ld«'J°« *"«'
that could be exposed at any time to toxic concentrations, radiant heat,
or overpressure greater than or equal to the endpoints Provided in
Sec 68:22 (a) , as a result of an accidental release and that can be
identified on local U. S. Geological Survey maps.
Hot work means work involving electric or gas welding, cutting,
brazing, or similar flame or spark-producing operations. ...
implementing agency means the state or local agency that obtains
delegation for an accidental release prevention program under subpart E,
40 CFR part 63. The implementing agency may, but is not required to, be
the state or local air permitting agency. If no state or local agency is
granted delegation, EPA will be the implementing agency for that state.
Iniury means any effect on a human that results either from direct
exposure to toxic concentrations; radiant heat; or overpressures from
accidental releases or from the direct consequences of a vapor cloud
explosion (such as flying glass, debris, and other projectiles) from an
accidental release and that requires medical treatment or
hospitalization.
Major change means introduction of a new process, process equipment,
or regulated substance, an alteration of process chemistry that results
in any change to safe operating limits, or other alteration that
introduces a new hazard.
Mechanical integrity means the process of ensuring that process
equipment is fabricated from the proper materials of construction and is
properly installed, maintained, and replaced to prevent failures and
accidental releases.
Medical treatment means treatment, other than first aid,
administered by a physician or registered professional personnel under
standing orders from a physician.
Mitigation or mitigation system means specific activities,
technologies, or equipment designed or deployed to capture or control
substances upon loss of containment to minimize exposure of the public
or the environment. Passive mitigation means equipment, devices, or
technologies that function without human, mechanical, or other energy
input. Active mitigation means equipment, devices, or technologies that
need human, mechanical, or other energy input to function.
NFPA means the National Fire Protection Association.
Offsite means areas beyond the property boundary of the stationary
source, and areas within the property boundary to which the public has
routine and unrestricted access during or outside business hours.
OSHA means the U.S. Occupational Safety and Health Administration.
Owner or operator means any person who owns, leases, operates, controls,
or supervises a stationary source.
Population means the public.
Process means any activity involving a regulated substance including
any use, storage, manufacturing, handling, or on-site movement of such
substances, or combination of these activities. For the purposes of this
definition, any group of vessels that are interconnected, or separate
vessels that are located such that a regulated substance could be
involved in a potential release, shall be considered a single process.
Public means any person except employees or contractors at the
stationary source.
Public receptor means off site residences, institutions (e.g.,
schools, hospitals), industrial, commercial, and office buildings,
parks, or recreational
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WAIS Document Rctnew! v ^
(iii) Response or restoration activities for an exposure of an
environmental receptor;
(2) The distance to a toxic or flammable endpoint for a worst-case
release assessment conducted under Subpart B and Sec. 68.25 is less than
the distance to any public receptor, as defined in Sec. 68.30; and
(3) Emergency response procedures have been coordinated between the
stationary source and local emergency planning and response
organizations.
[[Page 1153]]
(c) Program 2 eligibility requirements. A covered process is subject
to Program 2 requirements if it does not meet the eligibility
requirements of either paragraph (b) or paragraph (d) of this «c"°n;
(d) Program 3 eligibility requirements. A covered process is subject
to Program 3 if the process does not meet the requirements of paragraph
(b) of this section, and if either of the following conditions is met:
°1) The process is in SIC code 2611, 2812, 2819, 2821, 2865, 2869,
'(2) The process'is subject to the OSHA process safety management
standard, 29 CFR 1910.119. .n,,4MHt-ir
(e) If at any time a covered process no longer meets the eligibility
criteria of its Program level, the owner or operator shall comply with
the requirements of the new Program level that applies to the process
and update the RMP as provided in Sec. 68.190.
[61 FR 31717, June 20, 1996]
Sec. 68.12 General requirements.
(a) General requirements. The owner or operator of a stationary
source subject to this part shall submit a single RMP, as provided in
Sees. 68.150 to 68.185. The RMP shall include a registration that
reflects all covered processes.
(b) Program 1 requirements. In addition to meeting the requirements
of paragraph (a) of this section, the owner or operator of a stationary
source with a process eligible for Program 1, as provided in
Sec. 68.10(b), shall:
(1) Analyze the worst-case release scenario for the process(es), as
provided in Sec. 68.25; document that the nearest public receptor is
beyond the distance to a toxic or flammable endpoint defined in
Sec. 68.22(a); and submit in the RMP the worst-case release scenario as
provided in Sec. 68.165;
(2) Complete the five-year accident history for the process as
provided in Sec. 68.42 of this part and submit it in the RMP as provided
in Sec. 68.168; _,.._, ,
(3) Ensure that response actions have been coordinated with local
emergency planning and response agencies; and
(4) Certify in the RMP the following: "Based on the criteria in 40
CFR 68.10, the distance to the specified endpoint for the worst-case
accidental release scenario for the following process(es) is less than
the distance to the nearest public receptor: [list process(es)). Within
the past five years, the process(es) has (have) had no accidental
release that caused offsite impacts provided in the risk management
program rule (40 CFR 68.10(b)(1)). No additional measures are necessary
to prevent offsite impacts from accidental releases. In the event of
fire, explosion, or a release of a regulated substance from the
process(es), entry within the distance to the specified endpoints may
pose a danger to public emergency responders. Therefore, public
emergency responders should not enter this area except as arranged with
the emergency contact indicated in the RMP. The undersigned certifies
that, to the best of my knowledge, information, and belief, formed after
reasonable inquiry, the information submitted is true, accurate, and
complete. [Signature, title, date signed]."
(c) Program 2 requirements. In addition to meeting the requirements
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of paragraph (a) of this section, the owner or operator of a stationary
source with a process subject to Program 2, as provided in
Sec. 68.10(c), shall: .
(1) Develop and implement a management system as provided in
(2)"conduct a hazard assessment as provided in Sees. 68.20 through
is, Implement the Program 2 prevention steps provided in Sees. 68.48
through 68.60 or implement the Program 3 prevention steps provided in
Sees. 68.65 through 68.87;
(4) Develop and implement an emergency response program as provided
in Sees. 68.90 to 68.95; and
(5) Submit as part of the RMP the data on prevention program
elements for Program 2 processes as provided in Sec. 68.170.
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WAIS Document Retrieval v °
[Code of Federal Regulations]
[Title 40, Volume 8, Parts 63 to 71)
[Revised as of July 1, 1997)
From the U.S. Government Printing Office via GPO Access
[CITE: 40CFR68]
[Page 1154-1158]
TITLE 40—PROTECTION OF ENVIRONMENT
CHAPTER I—ENVIRONMENTAL PROTECTION AGENCY
PART 68--CHEMICAL ACCIDENT PREVENTION PROVISIONS—Table of Contents
Subpart B—Hazard Assessment
Source: 61 FR 31718, June 20, 1996, unless otherwise noted.
Sec. 68.20 Applicability.
The owner or operator of a stationary source subject to this part
shall prepare a worst-case release scenario analysis as provided in
Sec. 68.25 of this part and complete the five-year accident history as
provided in Sec. 68.42. The owner or operator of a Program 2 and 3
process must comply with all sections in this subpart for these
processes.
Sec. 68.22 Offsite consequence analysis parameters.
(a) Endpoints. For analyses of offsite consequences, the following
endpoints shall be used:
(1) Toxics. The toxic endpoints provided in appendix A of this part.
(2) Flammables. The endpoints for flammables vary according to the
scenarios studied:
(i) Explosion. An overpressure of 1 psi.
(ii) Radiant heat/exposure time. A radiant heat of 5 kw/
m2 for 40 seconds.
(iii) Lower flammability limit. A lower flammability limit as
provided in NFPA documents or other generally recognized sources.
(b) Wind speed/atmospheric stability class. For the worst-case
release analysis, the owner or operator shall use a wind speed of 1.5
meters per second and F atmospheric stability class. If the owner or
operator can demonstrate that local meteorological data applicable to
the stationary source show a higher minimum wind speed or less stable
atmosphere at all times during the previous three years, these minimums
may be used. For analysis of alternative scenarios, the owner or
operator may use the typical meteorological conditions for the
stationary source.
(c) Ambient temperature/humidity. For worst-case release analysis of
a regulated toxic substance, the owner or operator shall use the highest
daily maximum temperature in the previous three years and average
humidity for the site, based on temperature/humidity data gathered at
the stationary source or at a local meteorological station; an owner or
operator using the RMP Offsite Consequence Analysis Guidance may use
25 deg.C and 50 percent humidity as values for these variables. For
analysis of alternative scenarios, the owner or operator may use typical
temperature/humidity data gathered at the stationary source or at a
local meteorological station.
(d) Height of release. The worst-case release of a regulated toxic
substance shall be analyzed assuming a ground level (0 feet) release.
For an alternative scenario analysis of a regulated toxic substance,
release height may be determined by the release scenario.
(e) Surface roughness. The owner or operator shall use either urban
or rural topography, as appropriate. Urban means that there are many
obstacles in the immediate area; obstacles include buildings or trees.
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Rural means there are no buildings in the immediate area
[(Page 1155]]
and the terrain is generally flat and unobstructed. ..
(f) Dense or neutrally buoyant gases. The owner or operator shall
ensure that tables or models used for dispersion analysis of regulated
toxic substances appropriately account for gas density.
(g) Temperature of released substance. For worst case, liquids other
than gases liquified by refrigeration only shall be considered to be
released at the highest daily maximum temperature, based on data for the
previous three years appropriate for the stationary source, or at
process temperature, whichever is higher. For alternative scenarios,
substances may be considered to be released at a process or ambient
temperature that is appropriate for the scenario.
Sec. 68.25 Worst-case release scenario analysis.
(a) The owner or operator shall analyze and report in the RMP:
(!) For Program 1 processes, one worst-case release scenario for
each Program 1 process;
(2) For Program 2 and 3 processes:
(i) One worst-case release scenario that is estimated to create the
greatest distance in any direction to an endpoint provided in appendix A
of this part resulting from an accidental release of regulated toxic
substances from covered processes under worst-case conditions defined in
(ii) One worst-case release scenario that is estimated to create the
greatest distance in any direction to an endpoint defined in
Sec 68.22(a) resulting from an accidental release of regulated
flammable substances from covered processes under worst-case conditions
defined in Sec. 68.22; and
(ill) Additional worst-case release scenarios for a hazard class ir
a worst-case release from another covered process at the stationary
source potentially affects public receptors different from those
potentially affected by the worst-case release scenario developed under
paragraphs (a) (2) (i) or (a) (2) (n) of this section.
(b) Determination of worst-case release quantity. The worst-case
release quantity shall be the greater of the following:
(1) For substances in a vessel, the greatest amount held in a single
vessel, taking into account administrative controls that limit the
maximum quantity; or ...
(2) For substances in pipes, the greatest amount in a pipe, taking
into account administrative controls that limit the maximum quantity.
(c) Worst-case release scenario—toxic gases. (1) For regulated
toxic substances that are normally gases at ambient temperature and
handled as a gas or as a liquid under pressure, the owner or operator
shall assume that the quantity in the vessel or pipe, as determined
under paragraph (b) of this section, is released as a gas over 10
minutes. The release rate shall be assumed to be the total quantity
divided by 10 unless passive mitigation systems are in place.
(2) For gases handled as refrigerated liquids at ambient pressure:
(i) If the released substance is not contained by passive mitigation
systems or if the contained pool would have a depth of 1 cm or less, the
owner or operator shall assume that the.substance is released as a gas
in 10 minutes;
(ii) If the released substance is contained by passive mitigation
systems in a pool with a depth greater than 1 cm, the owner or operator
may assume that the quantity in the vessel or pipe, as determined under
paragraph (b) of this section, is spilled instantaneously to form a
liquid pool. The volatilization rate (release rate) shall be calculated
at the boiling point of the substance and at the conditions specified in
paragraph (d) of this section.
(d) Worst-case release scenario—toxic liquids. (1) For regulated
toxic substances that are normally liquids at ambient temperature, the
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ovmer or operator shall assume that the quantity in the vessel or pipe,
as determined under paragraph (b) of this section, is spilled
instantaneously to form a liquid pool.
(i) The surface area of the pool shall be determined by assuming
that the liquid spreads to 1 centimeter deep unless passive mitigation
systems are in place that serve to contain the spill and limit the
surface area. Where passive mitigation is in place, the surface
[[Page 1156]]
area of the contained liquid shall be used to calculate the
volatilization rate.
(ii) If the release would occur onto a surface that is not paved or
smooth, the ovmer or operator may take into account the actual surface
characteristics. • .....
(2) The volatilization rate shall account for the highest daily
maximum temperature occurring in the past three years, the temperature
of the substance in the vessel, and the concentration of the substance
if the liquid spilled is a mixture or solution.
(3) The rate of release to air shall be determined from the
volatilization rate of the liquid pool. The owner or operator may use
the methodology in the RMP Offsite Consequence Analysis Guidance or any
other publicly available techniques that account for the modeling
conditions and are recognized by industry as applicable as part of
current practices. Proprietary models that account for the modeling
conditions may be used provided the owner or operator allows the
implementing agency access to the model and describes model features and
differences from publicly available models to local emergency planners
upon request.
(e) Worst-case release scenario—flammables. The owner or operator
shall assume that the quantity of the substance, as determined under
paragraph (b) of this section, vaporizes resulting in a vapor cloud
explosion. A yield factor of 10 percent of the available energy released
in the explosion shall be used to determine the distance to the
explosion endpoint if the model used is baseo on TNT-equivalent methods.
(f) Parameters to be applied. The owner or operator shall use the
parameters defined in Sec. 68.22 to determine distance to the endpoints.
The owner or operator may use the methodology provided in the RMP
Offsite Consequence Analysis Guidance or any commercially or publicly
available air dispersion modeling techniques, provided the techniques
account for the modeling conditions and are recognized by industry as
applicable as part of current practices. Proprietary models that account
for the modeling conditions may be used provided the owner or operator
allows the implementing agency access to the model and describes model
features and differences from publicly available models to local
emergency planners upon request.
(g) Consideration of passive mitigation. Passive mitigation systems
may be considered for the analysis of worst case provided that the
mitigation system is capable of withstanding the release event
triggering the scenario and would still function as intended.
(h) Factors in selecting a worst-case scenario. Notwithstanding the
provisions of paragraph (b) of this section, the owner or operator shall
select as the worst case for flammable regulated substances or the worst
case for regulated toxic substances, a scenario based on the following
factors if such a scenario would result in a greater distance to an
endpoint defined in Sec. 68.22(a) beyond the stationary source boundary
than the scenario provided under paragraph (b) of this section:
(1) Smaller quantities handled at higher process temperature or
pressure; and
(2) Proximity to the boundary of the stationary source.
Sec. 68.28 Alternative release scenario analysis.
(a) The number of scenarios. The owner or operator shall identify
and analyze at least one alternative release scenario for each regulated
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toxic substance held in a covered process(es) and at least one
alternative release scenario to represent all flammable substances held
cena. (1, For each scenario required under
paragraph
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information provided on local U.S. Geological Survey maps or on any data
source containing U.S.6.S. data to identify environmental receptors.
68.36 Review and update.
(a) The owner or operator shall review and update the offsite
consequence analyses at least once every five years.
(b) If changes in processes, quantities stored or handled, or any
other aspect of the stationary source might reasonably be expected to
increase or decrease the distance to the endpoint by a factor of two or
more, the owner or'operator shall complete a revised analysis within six
months of the change and submit a revised risk management plan as
provided in Sec. 68.190.
Sec. 68.39 Documentation.
The owner or operator shall maintain the following records on the
offsite consequence analyses:
(a) For worst-case scenarios, a description of the vessel or
pipeline and substance selected as worst case, assumptions and
parameters used, and the rationale for selection; assumptions shall
include use of any administrative controls and any passive mitigation
that were assumed to limit the quantity that could be released.
Documentation shall include the anticipated effect of the controls and
mitigation on the release quantity and rate.
[[Page 1158]]
(b) For alternative release scenarios, a description of the
scenarios identified, assumptions and parameters used, and the rationale
for the selection of specific scenarios; assumptions shall include use
of any administrative controls and any mitigation that were assumed to
limit the quantity that could be released. Documentation shall include
the effect of the controls and mitigation on the release quantity and
rate.
(c) Documentation of estimated quantity released, release rate, and
duration of release.
(d) Methodology used to determine distance to endpoints.
(e) Data used to estimate population and environmental receptors
potentially affected.
Sec. 68.42 Five-year accident history.
(a) The owner or operator shall include in the five-year accident
history all accidental releases from covered processes that resulted in
deaths, injuries, or significant property damage on site, or known
offsite deaths, injuries, evacuations, sheltering in place, property
damage, or environmental damage.
(b) Data required. For each accidental release included, the owner
or operator shall report the following information:
(1) Date, time, and approximate duration of the release;
(2) Chemical(s) released;
(3) Estimated quantity released in pounds;
(4) The type of release event and its source;
(5) Weather conditions, if known;
(6) On-site impacts;
(7) Known offsite impacts;
(8) Initiating event and contributing factors if known;
(9) Whether offsite responders were notified if known; and
(10) Operational or process changes that resulted from investigation
of the release.
(c) Level of accuracy. Numerical estimates may be provided to two
significant digits.
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[Code of Federal Regulations]
(Title 40, Volume 8, Parts 63 to 71]
[Revised as of July 1, 1997]
From the U.S. Government Printing Office via GPO Access
[CITE: 40CFR68]
[Page 1158-1160]
TITLE 40--PROTECTION OF ENVIRONMENT
CHAPTER I—ENVIRONMENTAL PROTECTION AGENCY
PART 68--CHEMICAL ACCIDENT PREVENTION PROVISIONS—Table of Contents
Subpart C—Program 2 Prevention Program
Source: 61 FR 31721, June 20, 1S>96, unless otherwise noted.
Sec. 68.48 Safety information.
(a) The owner or operator shall compile and maintain the following
up-to-date safety information related to the regulated substances,
processes, and equipment:
(1) Material Safety Data Sheets that meet the requirements of 29 CFR
1910.1200(g);
(2) Maximum intended inventory of equipment in which the regulated
substances are stored or processed;
(3) Safe upper and lower temperatures, pressures, flows, and
compositions;
(4) Equipment specifications; and
(S) Codes and standards ustd to design, buiJd, and operate the
process.
(b) The owner or operator shall ensure that the process is designed
in compliance with recognized and generally accepted good engineering
practices. Compliance with Federal or state regulations that address
industry-specific safe design or with industry-specific design codes and
standards may be used to demonstrate compliance with this paragraph.
(c) The owner or operator shall update the safety information if a
major change occurs that makes the information inaccurate.
Sec. 68.50 Hazard review.
(a) The owner or operator shall conduct a review of the hazards
associated with the regulated substances, process, and procedures. The
review shall identify the following:
(1) The hazards associated with the process and regulated
substances;
(2) Opportunities for equipment malfunctions or human errors that
could cause an accidental release;
(3) The safeguards used or needed to control the hazards or prevent
equipment malfunction or human error; and
(4) Any steps used or needed to detect or monitor releases.
[[Page 1159]]
(b) The owner or operator may use checklists developed by persons or
organizations knowledgeable about the process and equipment as a guide
to conducting the review. For processes designed to meet industry
standards or Federal or state design rules, the hazard review shall, by
inspecting all equipment, determine whether the process is designed,
fabricated, and operated in accordance with the applicable standards or
rules.
(c) The owner or operator shall document the results of the review
and ensure that problems identified are resolved in a timely manner.
(d) The review shall be updated at least once every five years. The
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owner or operator shall also conduct reviews whenever a major change in
t£ procesToccurs; all issues identified in the review shall be
resolved before startup of the changed process.
Sec. 68.52 Operating procedures.
The owner or operator shall prepare written operating procedures
^^
or or«niza1ioJs knowledgeable about the process and equipment may be
SseS Is "SIS for a stationary source's operating procedures.
(S) The procedures shall address the following:
(1) Initial startup;
(2) Normal operations;
(3) Temporary operations;
(4) Emergency shutdown and operations;
\l\ s"™upSfollow?ng a normal or emergency shutdown or a major
change that requires a hazard review; ,.„..„„,.* nr
(7) Consequences of deviations and steps required to correct or
avoid deviations; and
SfST. ir5SS--h.il ensure that the operating procedures
are updated, if necessary, whenever a ma3or change occurs and prior to
startup of the changed process.
Sec. 68.54 Training.
(a) The owner or operator shall ensure that each employee presently
operating a process, and each employee newly assigned to a covered
process have been trained or tested competent in the operating
procedures provided in Sec. 68.52 that pertain to their duties For
thH. employees already operating a process on June 21, 1S99 the owner
or operator may certify in writing that the employee has the required
knowledge, skills, and abilities to safely carry out the duties and
responsibilities as provided in the operating procedures.
(b) Refresher training. Refresher training shall be provided at
least every three years, and more often if necessary, to each employee
operating a process to ensure that the employee understands and adheres
to the current operating procedures of the process. The owner or
operator, in consultation with the employees operating the process,
shall determine the appropriate frequency of refresher Draining
(c) The owner or operator may use training conducted under Federal
or state regulations or under industry-specific standards or codes or
training conducted by covered process equipment vendors to demonstrate
compliance with this section to the extent that the training meets the
requirements of this section.
(d) The owner or operator shall ensure that operators are trained -in
any updated or new procedures prior to startup of a process after a
major change.
Sec. 68.56 Maintenance.
(a) The owner or operator shall prepare and implement prpcedures to
maintain the on-going mechanical integrity of the P""".^"1*™6");- ™®
owner or operator may use procedures or instructions provided by covered
process equipment vendors or procedures in Federal or state regulations
or industry codes as the basis for stationary source maintenance
Pr° (b) The owner or operator shall train or cause to be trained each
employee involved in maintaining the on-going mechanical integrity of
the process. To ensure that the employee can perform the job tasfcs in a
safe manner, each
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[[Page 1160]]
such employee shall be trained in the hazards of the process, in how to
avoid or correct unsafe conditions, and in the procedures applicable to
the employee's ]ob tasks.
(c)' Any maintenance contractor shall ensure that each contract
maintenance employee is trained to perform the maintenance procedures
developed under paragraph (a) of this section.
(d) The owner or operator shall perform or cause to be performed
inspections and tests on process equipment. Inspection and testing
procedures shall follow recognized and generally accepted good
engineering practices. The frequency of inspections and tests of process
equipment shall be consistent with applicable manufacturers'
recommendations, industry standards or codes, good engineering
practices, and prior operating experience.
Sec. 68.58 Compliance audits.
(a) The owner or operator shall certify that they have evaluated
compliance with the provisions of this subpart at least every three
years to verify that the procedures and practices developed under the
rule are adequate and are being followed.
(b) The compliance audit shall be conducted by at least one person
knowledgeable in the process.
(c) The owner or operator shall develop a report of the audit
findings.
(d) The owner or operator shall promptly determine and document an
appropriate response to each of the findings of the compliance audit and
document that deficiencies have been corrected.
(e) The owner or operator shall retain the two (2) most recent
compliance audit reports. This requirement does not apply to any
compliance audit report that is more than five years old.
Sec. 68.60 Incident investigation.
(a) The owner or operator shall investigate each incident which
resulted in, or could reasonably have resulted in a catastrophic
release.
(b) An incident investigation shall be initiated as promptly as
possible, but not later than 48 hours following the incident.
(c) A summary shall be prepared at the conclusion of the
investigation which includes at a minimum:
(1) Date of incident;
(2) Date investigation began;
(3) A description of the incident;
(4) The factors that contributed to the incident; and,
(5) Any recommendations resulting from the investigation.
(d) The owner or operator shall promptly address and resolve the
investigation findings and recommendations. Resolutions and corrective
actions shall be documented.
(e) The findings shall be reviewed with all affected personnel whose
job tasks are affected by the findings.
(f) Investigation summaries shall be retained for five years.
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[Code of Federal Regulations]
[Title 40, Volume 8, Parts 63 to 71)
[Revised as of July I/ 1997]
From the U.S. Government Printing Office via GPO Access
[CITE: 40CFR68)
[Page 1160-1166]
TITLE 40—PROTECTION OF ENVIRONMENT
CHAPTER I—ENVIRONMENTAL PROTECTION AGENCY
PART 68—CHEMICAL ACCIDENT PREVENTION PROVISIONS—Table of Contents
t
subpart D—Program 3 Prevention Program
Source: 61 FR 31722, June 20, 1996, unless otherwise noted.
Sec. 68.65 Process safety information.
(a) In accordance with the schedule set forth in Sec. 68.67, the
owner or operator shall complete a compilation of written process safety
information before conducting any process hazard analysis required by
the rule. The compilation of written process safety information is to
enable the owner or operator and the employees involved in operating the
process to identify and understand the hazards posed by those processes
involving regulated substances. This process safety information shall
include information pertaining to the hazards of the regulated
substances used or produced by the process, information pertaining to
the technology of the process, and information pertaining to the
equipment in the process.
(b) Information pertaining to the hazards of the regulated
substances in the process. This information shall consist of at least
the following:
(1) Toxicity information;
(2) Permissible exposure limits;
(3) Physical data;
(4) Reactivity data:
(5) Corrosivity data;
(6) Thermal and chemical stability data; and
[[Page 1161]]
(7) Hazardous effects of inadvertent mixing of different materials
that could foreseeably occur.
Note to paragraph (b): Material Safety Data Sheets meeting the
requirements of 29 CFR 1910.1200(g) may be used to comply with this
requirement to the extent they contain the information required by this
subparagraph.
(c) Information pertaining to the technology of the process.
(1) Information concerning the technology of the process shall
include at least the following:
(i) A block flow diagram or simplified process flow diagram;
(ii) Process chemistry;
(iii) Maximum intended inventory;
(iv) Safe upper and lower limits for such items as temperatures,
pressures, flows or compositions; and,
(v) An evaluation of the consequences of deviations.
(2) Where the original technical information no longer exists, such
information may be developed in conjunction with the process hazard
analysis in sufficient detail to support the analysis.
(d) Information pertaining to the equipment in the process.
(1) Information pertaining to the equipment in the process shall
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include at least one employee who has experience «' J""^^
to the orocess being evaluated. Also, one member of the team must oe
Inow5ed?eaMe in the specific process hazard analysis methodology being
(e) The owner or operator shall establish a system to promptly
address the team's findings and recommendations; assure that the
anl "her employees whose work assignments are in the process and who
may be affected by the recommendations or actions.
y (f) At least every five (5) years after the completion of the
initial process hazard analysis, the process hazard analysis shall be
uSdited Snd "validated by a team meeting the requirements in paragraph
u
(d) of this section, to assure that the process hazard analysis is
cons«teni with the current process. Updated and "validated process
Hazard analyses completed to comply with 29 CFR 1910.119
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he owner or operator shall develop and implement safe work
practices to provide for the control of hazards during operations such
aTlockout/tagout; confined space entry; opening process equipment or
piping; and control over entrance into a stationary source by
maintenance, contractor,
([Page 1163]]
laboratory, or other support personnel. These safe work practices shall
apply to employees and contractor employees.
Sec. 68.71 Training.
(a) Initial training. (1) Each employee presently involved in
operating a process, and each employee before being involved in
opting a Eewly assigned process, shall be trained in an overview of
the process and in the operating procedures as specified in Sec. 68.69.
The training shall include emphasis on the specific safety and health
hazards, emergency operations including shutdown, and safe work
practices applicable to the employee's }ob tasks.
(2) In lieu of initial training for those employees already involved
in operating a process on June 21, 1999 an owner or operator may certify
in writing that the employee has the required knowledge, skills, and
abilities to safely carry out the duties and responsibilities as
specified in the operating procedures.
(b) Refresher training. Refresher training shall be provided at
least every three years, and more often if necessary, to each employee
involved in operating a process to assure that the employee understands
and adheres to the current operating procedures of the process. The
owner or operator, in ccns.uH.at.ion witn the employees involved in
operating the process, shall determine the appropriate frequency of
refresher training.
(c) Training documentation. The owner or operator shall ascertain
that each employee involved in operating a process has received and
understood the training required by this paragraph. The owner or
operator shall prepare a record which contains the identity of the
employee, the date of training, and the means used to verify that the
employee understood the training.
Sec. 68.73 Mechanical integrity.
(a) Application. Paragraphs (b) through (f) of this section apply to
the following process equipment:
(1) Pressure vessels and storage tanks;
(2) Piping systems (including piping components such as valves);
(3) Relief and vent systems and devices;
(4) Emergency shutdown systems;
(5) Controls (including monitoring devices and sensors, alarms, and
interlocks) and,
(6) Pumps.
(b) Written procedures. The owner or operator shall establish and
implement written procedures to maintain the on-going integrity of
process equipment.
(c) Training for process maintenance activities. The owner or
operator shall train each employee involved in maintaining the on-going
integrity of process equipment in an overview of that process and its
hazards and in the procedures applicable to the employee's job tasks to
assure that the employee can perform the ]ob tasks in a safe manner.
(d) Inspection and testing. (1) Inspections and tests shall be
performed on process equipment.
(2) Inspection and testing procedures shall follow recognized and
generally accepted good engineering practices.
(3) The frequency of inspections and tests of process equipment
shall be consistent with applicable manufacturers' recommendations and
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good engineering practices, and more frequently if determined to be
neCei;tr^yoPWneroropera;ore:Ph:neSCocument each inspects and test
that has been performed on process equipment. The documentation shall
Sentify Se dSte or the inspection or test, the name of the person who
p«iomedSe inspection or test, the serial number or other identifier
oltnTequipment on which the inspection or test was P«formed a
description of the inspection or test performed, and the results of the
^'^IquJpmenfdeficiencies. The.owner or operator shall correct •
deficiencies in equipment that are outside acceptable limits (defined by
Se process safety information in Sec. 68.65) before further use or in a
safe anS timely manner when necessary means are taken to assure safe
°Pe"n°Quality assurance. (1) In the construction of new plants and
equipment, the owner or operator shall assure that
[(Page 1164]]
equipment as it is fabricated is suitable for the process application
f°r U^ppr^rrate "neckband inspections shall be performed to assure
that equipment is installed properly and consistent with design
specifications and the manufacturer's instructions.
(3) The owner or operator shall assure that maintenance materials,
spare parts and equipment are suitable for the process application for
which they will be used.
Sec. 68.75 Management of change.
(a) The owner or operator shall establish and implement written
procedures to manage changes (except for replacements in kind ) to
process chemicals, technology, equipment, and procedures; and, changes
to stationary sources that affect a covered process.
(b) The procedures shall assure that the following considerations
are addressed prior to any change:
(1) The technical basis for the proposed change;
(2) Impact of change on safety and health;
(3) Modifications to operating procedures;
(4) Necessary time period for the change; and,
(5) Authorization requirements for the proposed change.
(c) Employees involved in operating a process and maintenance and
contract employees whose ]ob tasks will be affected by a change in the
process shall be informed ol. and trained in, the change prior to start-
up of the process or affected part of the process.
(d) If a change covered by this paragraph results in a change in the
process safety information required by Sec. €8.65 of this part, such
information shall be updated accordingly.
(e) If a change covered by this paragraph results in a change in the
operating procedures or practices required by sec. 68.69, such
procedures or practices shall be updated accordingly.
Sec. 68.77 Pre-startup review.
(a) The owner or operator shall perform a pre-startup safety review
for new stationary sources and for modified stationary sources when the
modification is significant enough to require a change in the process
•safety information.
(b) The pre-startup safety review shall confirm that prior to tne
introduction of regulated substances to a process:
(1) Construction and equipment is in accordance with design
specifications;
(2) Safety, operating, maintenance, and emergency procedures are in
place and are adequate;
(3) For new stationary sources, a process hazard analysis has been
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performed and recommendations have been resolved or implemented before
startup; and modified stationary sources meet the requirements contained
in management of change, Sec. 68.75.
(4) Training of each employee involved in operating a process has
been completed.
Sec. 68.79 Compliance audits.
(a) The owner or operator shall certify that they have evaluated
compliance with the provisions of this section at least every three
years to verify that the procedures and practices developed under the
standard are adequate and are being followed.
(b) The compliance audit shall be conducted by at least one person
knowledgeable in the process.
(c) A report of the findings of the audit shall be developed.
(d) The owner or operator shall promptly determine and document an
appropriate response to each of the findings of the compliance audit,
and document that deficiencies have been corrected.
(e) The owner or operator shall retain the two (2) most recent
compliance audit reports.
Sec. 68.81 Incident investigation.
(a) The owner or operator shall investigate each incident which
resulted in, or could reasonably have resulted in a catastrophic release
of a regulated substance.
(b) An incident investigation shall be initiated as promptly as
possible, but not later than 48 hours following the incident.
(c) An incident investigation team shall be established and consist
of at least one person knowledgeable in the
[[Page 1165]]
process involved, including a contract employee if the incident involved
work of the contractor, and other persons with appropriate knowledge and
experience to thoroughly investigate and analyze the incident.
(d) A report shall be prepared at the conclusion of the
investigation which includes at a minimum:
(1) Date of incident;
(2) Date investigation began;
(3) A description of the incident;
(4) The factors that contributed to the incident; and,
(5) Any recommendations resulting from the investigation.
(e) The owner or operator shall establish a system to promptly
address and resolve the incident report findings and recommendations.
Resolutions and corrective actions shall be documented.
(f) The report shall be reviewed with all affected personnel whose
job tasks are relevant to the incident findings including contract
employees where applicable.
(g) Incident investigation reports shall be retained for five years.
Sec. 68.83 Employee participation.
(a) The owner or operator shall develop a written plan of action
regarding the implementation of the employee participation required by
this section.
(b) The owner or operator shall consult with employees and their
representatives on the conduct and development of process hazards
analyses and on the development of the other elements of process safety
management in this rule.
(c) The owner or operator shall provide to employees and their
representatives access to process hazard analyses and to all other
information required to be developed under this rule.
Sec. 68.85 Hot work permit.
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(a) The owner or operator shall issue a hot work permit for hot work
operations conducted on or near a covered process.
(b) The permit shall document that the fire prevention and
protection requirements in 29 CFB 1910.2S2
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WAIS Document Retneval r r
[Code of Federal Regulations]
(Title 40, Volume 8, Parts 63 to 71)
[Revised as of July 1, 1997]
From the U.S. Government Printing Office via GPO Access
[CITE: 40CFR68)
[Page 1166]
TITLE 40--PROTECT1ON OF ENVIRONMENT
CHAPTER I--ENVIRONMENTAL PROTECTION AGENCY
PART 68—CHEMICAL ACCIDENT PREVENTION PROVISIONS—Table of Contents
Subpart E—Emergency Response
Source: 61 FR 31725, June 20, 1996, unless otherwise noted.
Sec. 68.90 Applicability.
(a) Except as provided in paragraph (b) of this section, the owner
or operator of a stationary source with Program 2 and Program 3
processes shall comply with the requirements of Sec. 68.95.
(b) The owner or operator of stationary source whose employees will
not respond to accidental releases of regulated substances need not
comply with Sec. 68.95 of th:s part provided that they meet the
following: . . . .
(1) For stationary sources with any regulated toxic substance held
in a process above the threshold quantity, the stationary source is
included in the community emergency response plan developed under 42
(2) For stationary sources with only regulated flammable substances
held in a process above the threshold quantity, the owner or operator
has coordinated response actions with the local fire department; and
(3) Appropriate mechanisms are in place to notify emergency
responders when there is a need for a response.
Sec. 68.95 Emergency response program.
(a) The owner or operator shall develop and implement an emergency
response program for the purpose of protecting public health and the
environment. Such program shall include the following elements:
(1) An emergency response plan, which shall be maintained at the
stationary source and contain at least the following elements:
(i) Procedures for informing the public and local emergency response
agencies about accidental releases;
(ii) Documentation of proper first-aid and emergency medical
treatment necessary to treat accidental human exposures; and
(iii) Procedures and measures for emergency response after an
accidental release of a regulated substance;
(2) Procedures for the use of emergency response equipment and for
its inspection, testing, and maintenance;
(3) Training for all employees in relevant procedures; and
(4) Procedures to review and update, as appropriate, the emergency
response plan to reflect changes at the stationary source and ensure
that employees are informed of changes.
(b) A written plan that complies with other Federal contingency plan
regulations or is consistent with the approach in the National Response
Team's Integrated Contingency Plan Guidance ("One Plan") and that,
among other matters, includes the elements provided in paragraph (a) of
this section, shall satisfy the requirements of this section if the
owner or operator also complies with paragraph (c) of this section.
(c) The emergency response plan developed under paragraph (a) (1) of
this section shall be coordinated with the community emergency response
plan developed under 42 U.S.C. 11003. Upon request of the local
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emergency planning committee or emergency response officials, the owner
or operator shall promptly provide to the local emergency response
officials information necessary for developing and implementing the
community emergency response plan.
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[Code of Federal Regulations]
[Title 40, Volume 8, Parts 63 to 71]
[Revised as of July 1, 1997]
From the U.S. Government Printing Office via GPO Access
[CITE: 40CFR68)
(Page 1166-1174]
TITLE 40—PROTECTION OF ENVIRONMENT
CHAPTER I—ENVIRONMENTAL PROTECTION AGENCY
PART 68--CHEMICAL ACCIDENT PREVENTION PROVISIONS—Table of Contents
Subpart F—Regulated Substances for Accidental Release Prevention
Source: 59 FR 4493, Jan. 31, 1994, unless otherwise noted.
Redesignated at 61 FR 31717, June 20, 1996.
[[Page 1167]]
Sec. 68.100 Purpose.
This subpart designates substances to be listed under section
112(r)(3), (4), and (5) of the Clean Air Act, as amended, identifies
their threshold quantities, and establishes the requirements for
petitioning to add or delete substances from the list.
Sec. 68.115 Threshold determination.
(a) A threshold quantity of a regulated substance listed in
Sec. 68.130 is present at a stationary source if the total quantity of
the regulated substance contained in a process exceeds the threshold.
(b) For the purposes of determining whether more than a threshold
quantity of a regulated substance is present at the stationary source,
the following exemptions apply:
(1) Concentrations of a regulated toxic substance in a mixture. If a
regulated substance is present in a mixture and the concentration of the
substance is below one percent by weight of the mixture, the amount of
the substance in the mixture need not be considered when determining
whether more than a threshold quantity is present at the stationary
source. Except for oleum, toluene 2,4-dnsocyanate, toluene 2,6-
diisocyanate, and toluene diisocyanate (unspecified isomer), if the
concentration of the regulated substance in the mixture is one percent
or greater by weight, but the owner or operator can demonstrate that the
partial pressure of the regulated substance in the mixture (solution)
under handling or storage conditions in any portion of the process is
less than 10 millimeters of mercury (mm Kg), the amount of the substance
in the mixture in that portion of the process need not be considered
when determining whether more than a threshold quantity is present at
the stationary source. The owner or operator shall document this partial
pressure measurement or estimate.
(2) Concentrations of a regulated flammable substance in a mixture.
If a regulated substance is present in a mixture and the concentration
of the substance is below one percent by weight of the mixture, the
mixture need not be considered when determining whether more than a
threshold quantity of the regulated substance is present at the
stationary source. If the concentration of the regulated substance in
the mixture is one percent or greater by weight, then, for purposes of
determining whether more than a threshold quantity is present at the
stationary source, the entire weight of the mixture shall be treated as
the regulated substance unless the owner or operator can demonstrate
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that the mixture itself does not meet the criteria for flammability of
flash point below 73 deg.F (22.8 deg.C) and boiling point below
100 deg.F (37.8 deg.C). The owner or operator shall document these flash
ooint and boiling point measurements or estimates.
P ^Concentrations of a regulated explosive substance in a mixture.
Mixtures of Division 1.1 explosives listed in 49 CFR 172.101 (Hazardous
Materials Table) and other explosives need not be included when
determining whether a threshold quantity is present in a process, when
the mixture^ is intended to be used on-site in a non-accidental release
in a manner consistent with applicable BATF regulations. Other mixtures
o? division 1.1 explosives listed in 49 CFR 172.101 and other explosives
shall be included in determining whether more than a threshold quantity
is present in a process if such mixtures would be treated as Division
1.1 explosives under 49 CFR parts 172 and 173.
(4) Articles. Regulated substances contained in articles need not be
considered when determining whether more than a threshold quantity is
present at the stationary source. .
(5) Uses. Regulated substances, when in use for the following
purposes, need not be included in determining whether more than a
threshold quantity is present at the stationary source:
(i) Use as a structural component of the stationary source;
(li) Use of products for routine janitorial maintenance;
(ni) Use by employees of foods, drugs, cosmetics, or other personal
items containing the regulated substance; and
(iv) Use of regulated substances present in process water or non-
contact cooling water as drawn from the environment or municipal
sources, or use of regulated substances present in air used either as
compressed air or as part of combustion.
[[Page 1168]]
(6) Activities in laboratories. If a regulated substance is
manufactured, processed, or used in a laboratory at a stationary source
under the supervision of a technically qualified individual as defined
in Sec. 720.3(ee) of this chapter, the quantity of the substance need
not be considered in determining whether a threshold quantity is
present. This exemption does not apply to:
(i) Specialty chemical production;
(11) Manufacture, processing, or use of substances in pilot plant
scale operations; and
(lii) Activities conducted outside the laboratory.
Sec. 68.120 Petition process.
(a) Any person may petition the Administrator to modify, by addition
or deletion, the list of regulated substances identified in Sec. 68.130.
Based on the information presented by the petitioner, the Administrator
may grant or deny a petition.
(b) A substance may be added to the list if, in the case of an
accidental release, it is known to cause or may be reasonably
anticipated to cause death, injury, or serious adverse effects to human
health or the environment.
(c) A substance may be deleted from the list if adequate data on the
health and environmental effects of the substance are available to
determine that the substance, in the case of an accidental release, is
not known to cause and may not be reasonably anticipated to cause death,
injury, or serious adverse effects to human health or the environment.
(d) No substance for which a national primary ambient air quality
standard has been established shall be added to the list. No substance
regulated under title VI of the Clean Air Act, as amended, shall be
added to the list.
(e) The burden of proof is on the petitioner to demonstrate that the
criteria for addition and deletion are met. A petition will be denied if
this demonstration is not made.
(f) The Administrator will not accept additional petitions on the
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Environmental Protection Agency
(68.125 Exemptions.
Agricultural nutrients. Ammonia used
as an agricultural nutrient, when held
by farmers, is exempt from all provl-
gions of this part.
(68.130 LUtofsubataneea.
(a) Explosives listed by DOT as Divi-
sion 1.1 in 49 CPR 172.101 are covered
under section 112(r) of the Clean Air
Act. The threshold quantity for explo-
sives is 5.000 pounds.
(b) Regulated toxic and flammable
substances under section 112(D of the
Clean Air Act are the substances listed
in Tables 1. 2. 3, and 4. Threshold quan-
tities for listed toxic and flammable
substances are specified in the tables.
(c) The basis for placing toxic and
flammable substances on the list of
regulated substances are explained in
the notes to the list.
TABLE 1 TO §68.130.—LIST OF REGULATED
Toxic SUBSTANCES AND THRESHOLD QUAN-
TITIES FOR ACCIDENTAL RELEASE PREVENTION
(Alphabetical Order-77 Substance*)
§68.130
TABLE i TO §68.130.—LIST OF REGULATED
Toxic SUBSTANCES AND THRESHOLD QUAN-
TITIES FOR ACCIDENTAL RELEASE
pREVENTON-Continued
[Alphabetical Order—77 Substances]
O-CflUCfl- fttflM
AeroWnp-
i^— •— ««i
propenaq.
taykmitnlep-
Propenomviiai.
p^ioponoyi
J^^MMtel
craonoDj.
AMDcoholp-
Propen+oq.
ftopen 1 Bmne|.
Mnmone (anhy-
drous).
Ammona (cone
20% or greater).
Anenoustt-
f^^_
Boron trcnonde
P«fane.
Boron tnSuonde
Iflmajij
IBorane.
tttuonH
Boron trOuorUe
compound tridi
Mtfhyl eoiflf
(1:1) (Boron.
MhiOfO (oxytu
pwtwwl^t T*4*
Carton duuffide
CHorhe _____
Qtorino Joilde
PMnenHe
wan.
CAS No.
107-02-6
107-13-1
814-68-6
107-18-61
107-11-9
7664-41-7
7664-41-7
7784-34-1
7784-42-1
10294-34-6
763747-2
353-42-4
7726-05-6
75-15-0
7782-60-6
10049-04-1
^SSrW,*1
5.000
20.000
5.000
15.000
10.000
10.000
20.000
15.000
1.000
5.000
5X00
15.000
10.000
20.000
iSOO
ijooo
Basis tor
bting
t
i
b
b
b
a.b
a.b
b
b
b
b
b
a.b
b
a.b
c
Chemical name
CNorotorm (Meth-
ane. tacNonH.
CNoremethyl
ether (Methane.
o*ybis(chlon>].
Chtofornefhyt
methyl ethef
(Methane.
CnMonaUehyde
P-Butenaq.
(EHZ-Butenal.
(EH-
Cyanogen cNo-
nde.
[Cydoheiana-
mlfle].
0&oren6 ...._...-..
tilane (Stone.
»H.
1.1-
DiffltSthyttiydrft*
tme (Hydra-
tine. 1.1-OV
rnemyH.
[Ourane,
(chhxofnetttylH*
EthylonodiBninM
n>
EtnAWOAfTttAi)]
(AamSne)
Ethytenecude
(Omrane].
Fluorine __
FormaUehyde
(solutkxi).
Furan __..___.
Hydrame
Hydrochloric add
(cone 30* or
greater).
Hydrocyanic acid
(anhydrou*)
(HydrocNonC
add].
UtMtWtM^M 4*lllM_
nywUU
-------
§68.130
TABLE i TO §68.130.—LIST OF REGULATED
Toxic SUBSTANCES AND THRESHOLD QUAN-
TITIES FOR ACCIDENTAL RELEASE
PREVENTION—Continued
(Alphabetical Order—77 Substances)
Iron. ^^^^
(Fe(CO)5).(TB-
Isobulyfonttrito
IDiinneman li !•
(PropanenMa.
2-methyH.
Isopropyl
(kcaod. 1-
methylethyl
ester)
Methacrytontnie
(2-
Propenenitnle.
2-methyl-)
Methyl chlonde
(Methane.
chkxo-)
Methyl
chtoroformate
die aod.
melhylester].
Mfithyl hyViUlftS
(Hydraiine.
methyl-).
Methyl isocyanate
(Methane.
Bocyanato-1
Methyl mercaptan
(Methanetruol).
Methyl
thiocyanate
[Thiocyanc
BOd, methyl
ester)
Methyltnchlorosil-
ane(Silane.
tnchlorornethyl-|.
Nickel carbonyl ...
Mine aod (cone
80% or greater)
Nitre oude (Nitro-
gen o»de (NO)]
Oleum (Fuming
Sullurcaod)
(SuHuncaod.
mixture with
suthir tnoude)'.
Peracebcaod
[Ethaneperoioi-
caod).
PCfChlOfORtttlnyf*
mercaptan
[Metfianewfleri.
yl cNondc,
r>r£££eW
ride)
Phosplkna
CAS No.
13463-40-6
78-82-0
108-23-6
126-98-7
74-67-3
79-22-1
60-34-1
624-83-9
74-93-1
556-64-9
75-79-6
13463-39-3
7697-37-2
10102-43-9
8014-95-7
79-21-0
594-42-3
75-14-5
7803-51-2
Threshold
ouanuy
(KB)
2.500
20.000
15.000
10.000
10.000
5,000
15,000
10.000
10,000
20.000
5.000
1.000
15.000
10.000
10.000
10.000
10.000
500
5.000
Basis tor
b
b
b
b
a
b
b
a.0
b
b
b
b
b
b
e
b
b
a.b
b
40 CFR Ch. I (7-1-97 Edition)
TABLE 1 TO §68.130.—LIST OF REGULATED
Toxic SUBSTANCES AND THRESHOLD QUAN-
TITIES FOR ACCIDENTAL RELEASE
PREVENTION—Continued
(Alphabetical Order-77 Substances)
Phosphorus
oiychlondo
i liliniilal
wvonocj.
Phosphorus tn-
phoroustri-
P,perioino 1
Pfop40/htiue
(rropai MI >u ue j
Propyi
(CarbonocHon-
Jeaod.
propyleslerj
Propyicno innno
(Azinolne. 2-
methyl-).
Propytene onto
(Oiirane. meltv
y-i-
Sulfur deude
(anhydrous).
Sullur tetra-
ttuoride (Surtur
fluonde (SF4).
a-4»-i.
Sullur tnonde
TetramemyDead
(Plumoane.
letramethyl-).
Tetranttro-
ane. tetranftro-).
Tilanum tetra-
chloride (Tita-
nufn cnlonoo
(TiCM) (T^)-].
Toluene 2.4-
diisocyanate
(Benzene. 2,4-
diisocyanat>l-
methyl-p.
Toluene 2.6-
dusocyanate
(Benzene. 1 J-
dn$ocyanatO'2B
methyl-)'.
Toluene
djtsocyanate
(unspeofied
isomer) fBen-
tene. 1>
*• ena(Silane.
CAS No.
10025-67-3
7719-12-2
110-89-4
107-12-0
109-61-5
75-55-6
75-56-9
7446-09-6
7763-60-0
7446-11-9
75-74-1
509-14-6
7550-45-0
50*1 01 3
91-08-7
"
26471-«2-5
Threshold
quantity
Pbs)
5.000
15.000
15.000
10.000
15.000
10.000
10.000
5.000
2.500
10.000
10.000
10.000
2.500
10.000
10.000
10.000
Id AM
1U.IWU
Basis tor
fatmg
b
b _
b
b
b
b
b
a.b
b
a.b
b
b
b
a
a
•
•*
Environmental Prc
TABLE i TO §68.13
Toxic SUBSTANCES
TITIES FOR ACCIDEK
PREVENTION—Conti
(Alphabetical Or.
Vinyl acetate
monomer (Aoe-
fc aod ethenyl
ester).
CAS
IOC
•The mixture eiempbon In
the subslanee.
TABLE 2 TO §68.130.-
CASNo.
75-56-9
75-74-1
75-77-4
75-78-5 _
75-79-6.
78-82-0
79-21-O
79-22-1
91-08-7
106-69-6
107-02-«
107-11-9
107-12-0
107-13-1
107-15-3
107-18-6
107-30-2
108-05-4
108-23-6
108-41-8
109-61-5
110-004
110-69-4
123-734
126-98-7
151-58-4
302-01-3.
353-42-4.
508-77-4.
509-14-6.
542-66-1.
556-64-9.
594-42-4.
624-63-9.
814-68-6.
4170-30-3.
7446-09-5.
fQttt
1.1-C
Men
Crto
Carb
25!
Phn
Ptopj
Tttc
Trirrw
One-
Perae
Meth>
Tobe
EpieK
Acryto
Ethyte
CMorc
Vinyl i
Isopro
Crdor
Propyi
:uran
Pipe*
Cnxor
Ethyle
lofon
Mb
Cym
CNoro
tethyl
Toluer
1170
-------
JST OF REGULATED
THRESHOLD GUAM-'
RELEASE
j _
1 '
Environmental Protection Agency
TABLE 1 TO §68.130.-UST OF REGULATED
TOXIC SUBSTANCES AND THRESHOLD QUAN-
TITIES FOR ACCIDENTAL RELEASE
PREVENTION—Continued
i^phabetkal Order-77 Substaneetl
Chemical name
monomer |Ace-
tfcaoMeihenyi
CAS No.
108-05-4
Threshold
15.000
§68.130
' NOTE: Basis to UftoV
a Mandated tor isbng by Congress.
b On EHStel vapor pressure 10 mmHg or greater.
c Tovcoas.
d Tontatyolhydrogenchloride. polanUItorelease hydro-
oeneNonde. and hstory d aocUerts.
• TwUrti ol wnur trionde and suHune acid, potentd to
reteaseT.3S tnowde. and hstory ri accident*.
Bads tor
•Tha mtature eumption ki 868.1i5(b)(i) does not apply to
010 substmov.
REGULATED TOXIC SUBSTANCES AND THRESHOLD QUANTITIES FOR
TABLE2TO§68.130.-USTOF
ACCIDENTAL RELEASE PREVENTION
(CAS Number Order-77 Substances]
CAS No.
50-00-0 — ~
57-14-7 .......
60-34-4
74^7-3
74-45-1 ••• -
7^1 £4
7S-21^ -.—....—«-
75-44-6
«r-A4-A «
75-66-9
75-74-1 —
75—77—4
75—78—5 ...1 '
T5 T9 6 --
7842-0 —
79-214 -
79-22-1 —
106-89-8 — -
107-02-8 --
107-11-9
107-12-0 ____-—.
107-13-1
107-15-3
107-16-6
107-30-2
100 CT fi
1Q9-61-5 __„-_
110-00-9
110-89-4
123-73-9
1CT OT T
302-01-2 _
805-77-t
falll ftl fl
594-42-3
071 03 9
814-68-6
417040-3 —
7446494
Chemical name
Formaldehyde (solution) rTTr;7 —
1>r>methylhydraw>e [Hydranne. 1.1-dmethyt-)
Methyl hydranne (Hydranne. rneHiyv-J
Chloroform (Methane. IneNoro-l
Methyl cMonde (Methane, ehkxc-1
Hydrocyarkc and — ....—•- _._._...-.———————•
Methyl mercaptan (Methanelhieq
Parhrjn driUlMe ..... — - — ™ ™ ~~ — — — —
Elhytene onde (Owene)
Phosgene (Canonc dnregnde)
Piopylenelmine (Aztndine. 2-methyH
Propyiene oiude (Onrane. mettiyH
TetramelhyUead (Pkimbane. tetramethyH .~~
MemyttncNorosilane ISdane. WeWwomemyi-i
dobulyronrtnle (Propanenitnle. 2-methyi-| ...__.— — _*..—...
Methyl chtorotormate (CaiUOHflcreonoic too. roCT1»"'°"°^' -""."'
Toluene 2.6-oTisoeyanate (Benzene. l^eSisccyanato-2-metriyl-J1
EtAJtoohrdrin (Odrane. (chteromelhylH
Acroteinp-Propenal) .
Mlylamine p-Propen-1-aminel -— -
Acrytonrlnle p-PropenenitnleJ __._ — - - -
ARyl atoohol p-Propen-1-olJ r •™-v
CNoromethyl methyl ether (Methane. cMorometixwiH —
Vinyl acetate monomer (AoeOc acid ethenyl ester) — •
baprapyl chtarolormate (Carbonechloricle aod. 1-melhyietnyi eswq
CyeJohexylamine Pydoneianainlnej ____-. , — — — —
Pr^yl ehteolormate fCaitwrMehtenrJe add. propytester)
Furan
Crotonakkriyde. (E|- p-Butenal. (EH — 77—— ~~
MefliaerytonMe p-PropenenWe. Mnethyl-1 — •
Baron MHuorlde eompound with methyl ether (1:1) poron.
Wfluoro(OJrfbii(rne1hBneD-. T-4-.
Cyanogen cnkxioe ••— ' '
Methyl BMcyanate [TNocyanic add. mettiyi esttf) —....., ^ ^ ^
P»a*ircrnelhylmercaplan (Methanesullenyl chtonde. tnchtore-)
AcfyVehtoo^p-Propenoylchlorldal .,
CratcflaUehydep-Buienaq — —
SuHurtfoiide (anhydrous) —
1171
Threshold
quantity
15.000
15.000
15.000
20.000
10.000
2.500
10.000
20.000
10.000
500
10.000
10.000
10.000
10.000
5.000
5:000
20X100
10.000
S.OOO
10XXK)
20.000
5.000
10.000
10.000
20.000
20.000
15.000
5.000
15.000
15.000
15.000
15.000
5.000
15.000
20.000
10.000
10X00
15.000
ISjOOO
10X100
10.000
1,000
20.000
10.001
10.001
10.001
s.oa
20.001
sxxx
Basis for
hstmg
b
b
b
a
8.0
b
b
a.b
a.b
b
b
b
b
b
b
b
b
b
a
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
c
b
b
b
a
b
a.b
b
b
a.b
-------
§68.130
TABLE 2
CAS No
40 CFRCh. I <7-l-*7 Edition)
(CAS Number Order— 77 Substances)
10.000a. b
2.5001 b
7446-11-4
7550-454
Boron Wluonde (Borane. Mhio«H ..
7617-07-2
7647-01-0
7647-01-0
Ammonia (anhydrous)
Ammonujjeonc 20% or greater)
N*ie acid (cone 60% or greater)
766«-*1-7
7664-41-7
7697-47-2
7719-12-2
772645-6
7762-41-4
7782-50-5
7763-06-t
7783-07-5
776)404
Phosphorus trlehtonde (Phosphorous tncWondeJ
10.0001 a. b
1.000 b
ArsenomtncNoiide
Arsme
7764-34-1
778*-42-1
7603-51-2
6014-95-7
10025-67-3
10049-04-1
10102-434
10294-34-5
13463-39-3
is^^
Boron MNonde [Borane, tncNoro-]
13463-40-6
19287-45-7
26471-«2-S
'The mixture eiempMn h «66.115]
—:ji>^.
i»ji ,
Ounethylamine (Methanamlne. NHnetti|i i •.
IT^n _.,k.J. ..»...«. IRmnilu 5» jflMttllll 1 "-
2.2-umethylpropane [nopane. ^^^PIIKUIII i —
Ethane — — - — ———————
Ethyl acetylene [1-Bulyne]
Ethylamine (Ethanamne] __._—»
—""""*"""
CAS No.
75-07-0
74-66-2
598-73-2
10649-0
10647-6
106464
10741-7
2516747-3
590-18-1
624444
463-56-1
7791-21-1
557-08-2
590-214
460-194
75-19-4
4109464
75474
124-404
46342-
74444
107404
75-04-7
rveshotd
ouantity
(ibs)
10.000
10.000
10.000
10.000
10.000
10.000
10.000
10.000
10.000
10.000
10.000
10.000
10.000
10.000
10.000
10.000
10.000
10.000
10.000
10.000
10.000
10.000
10.000
Basis tor
taung
.^^•.^^v
1
1
g
i
Environmental Prolecl
TABLE3TO§68.130.-U!
FOI
Ethyl cNonde (Ethane. eWore-1 ._
Elhylene (Elhenel
Ethyl ether (Ethane. 1.r-o»yt»-l
Ethyl mercaptan (Ethanethnll ._
Ethyl r*nte (Nitrous Kid. ethyl e»t
Hydrogen
Isobutane (Propane, 2-methyq _
bopenune (Butane. 2-methyl-l _
Isoprene [1>Butacinene. 2-meth
Isopopytamine (24>ropanaflMie)
Isopropyl Monde (Propane. 2Pentadinene
Penlane
1-Pentene .- ———
2-Pentene. (E)-
2-Pentene. (Z)-
Propadiene (l.2-Propad«nel _
Propane .
Propytene (i-Propenel
Propyne (l-PropyneJ
Tetrafluoioethylene ikinene. tetr
TetramethyHilane (Silane. tetrair
Tnchlorosilane (Saane. tnehtonX
Tnnuoroehloroethylene (Ethene.
Tmnethylamine [Methanamine. r
Vinyl aeerylene (l-8olen*»ne)
Vmyl chloride (Ethene. cNoro-1 .
Vinyl ethyl ether (Ethene. ethoi>
Vmyl luonde (Etnene. Ouoro-) -
Vinylidene cNonde (Elhene. 1.1-
Vnylidene Huonde (Elhene. 1.1-
Vmyl methyl ether (Elhene. mett
NOTE Basil tor listing:
a Mandated tor tatmg by Co
I Flammable gas.
g Volatile flammable fcquA
TABLE 4 TO §68.130.—
CAS NO.
74-
7449-7.
7540-3.
79-01-4.
75-02-6.
7544-7.
75-07-0.
7546-1
Ethyl I
Methe
Ethan
Ethyte
Aoetyl
Met*
Ptopa
Ethyl i
Vmyl i
Vmyl i
Ethyli
Aorta
Ethyl
1172
-------
(7-1-97 Edition)
u> QUANTITIES FOR
Environmental Protection Agency
§68.130
Threshold
quantity
(*»)
10.000
2.500
5.000
1S.OOO
5.000
1.000
10JOOO
20.000
15.000
15.000
10000
1.000
iSOO
10.000
500
2.500
15.000
1.000
5.000
10.000
5400
1.000
10.000
5.000
1.000
2.500
2.500
10.000
Basis tor
isting
a.b
)
b
d
a
a.b
a.b
a.b
b
b
,b
qESHOio QUANTITIES
0
2
2
0
4
9
7
3
1
-6
•1
-1
•2
4
-5
4
•0
4
-3
.1
-0
•4
-;
Threshold
10400
10.000
10400
10.000
10.000
10.000
10.000
10.000
10.000
10400
10400
10400
10400
10400
10400
10400
10400
10400
10400
10400
10400
10400
10400
Basis tor
fcbng
I
TABLE 3 TO 668.130.-UST OF REGULATED FLAMMABLE SUBSTANCES AND THRESHOLD QUANTITIES
FOR ACCIDENTAL RELEASE PREVENTION-ContmuCd
(Alphabetical Order-63 Substances)
Chemcal name
Elh« cnwfitw (ttnane. awyu-| ...-...-.— —»- • »•— —
hylene [ttncnej „«.»»»—-....—.-..-»«——
toy* Bihar [EUm. 1.1 -Om^US-) »-——————
EOqfl mercaptan (bttwclMII __-...- -• - -—-•
^ituyn11 ___.—.—.-..— ...-..—...——— -—-——•
bobutana (Propane. 2-melhyl]
(sopertana (Butane. 2-methyH — —
boprane (1.3-Buurinene. 2niielriyH —...———
•opnvylvnra p-ft«jaAiiim«] . —
boprapyl cnonoe (nopai*. f.-w"*-i .—
Methane
Methylamine fMethanamine]
Methyl ether (Methane. oiyt»-| -
Methyl formate (Forme aod. methyl ester| - - -
2-Pentene.
-------
§68.150
40 CFR Ch. I (7-1-97 Edition)
TABLE 4 TO §68.130.—LIST OF REGULATED FLAMMABLE SUBSTANCES AND THRESHOLD QUANTITIES
FOR ACCIDENTAL RELEASE PREVENTION—Continued
(CAS Number Order-63 Substances)
CAfi MA
75-19-4
75-29-5
T}_J1_0
'S-H-*
TW-4
75-M-7
7WQ-9
T5_T£_3
78-76-4
76-79-5
79-38-9
106-97-8
106-98-9
196-49-0
107-00-6
107-01-7
107-25-5 .
109-66-0 _
109-67-1
109-92-2
115-07-1 .
115-10-6
115-11-7
116-14-3
124-40-3
460-19-5
463-49-0
463-56-1
463-82-1
504-60-9 ...
557-98-2
563-45-1
563-46-2
590-16-1 -
590-21-6
598-73-2
624-64-6
627-20-3
646-04-6 .
689-97-4
1333-74-0
4109-96-0
7791-21-1 ._
7803-62-5
10025-78-2
25167-67-3
C«*?Fflpll"ff
Vmyfadene cNonde (Etnene 1 Kftfrioro-j
DifluOfQetflktne [EVUflQ 1 IsWhlOfO-l
Vmybdene ftuonda (Ethane 1 Kftfluoro-)
Isopentane [Bultne 2-flietnyH
l$oprene|1. 3 -Butadiene 2-methyl-)
Butane - .
1-Butene ...
1 >Bu!atf ene ««.«.- «:. « . ..
Ethyl acetylene |1-Butyne]
?4fcjtftn*
Vinyl nielhyl ether [Ethene. niethoiy*] .»................*—>............
Pentane _
Vinyl ethyl ether JEthene. eihcnH "! "" " ! "~ ...!.".! .....
Ethyl nrtnle (Nitrous aod. ethyl ester)
Methyl ether (Melhane. wytiiil'ZZlZ"!"!""!. 'ZZ'..
Tetrafluoreelhylene (Ethene. lelraDuoro-)
Cyanogen (Ethanedinitnle]
Carbon oiysutfide (Carbon onto suffide (COS)J™"!."1"".!
2.2-Oimethylpropane [Propane. 2.2-Amethyt-)
1 3-Pontarjirno
24Mnyi.1Aut«n> ,..,
1-CMoropropylene [1-Propene. Khtoro-) _...
2-Butene-trans |2-Butene. |E|) .
2-PenteM. p). ,. -,-,„„..,.... .........„.,„. ,
2-Pentene. (E)- _ .
Vinyl acetylene [l-Buten-3-yne]
Dichlorosilane I&lane. dichloro-)
CHonne monoude [Chtonna onde)
Sdane
Tnchlorosilane [Stine.lnchloro-] _
Butene _
£AS MA
75-19-4
75-28-5
75-41-0
75-35-4
75-37-6
75-38-7
7C_KA_^
75-76-3
76-78-4
78-79-5
79-38-9
106-97-8
106-98-9
106-99-0
107-00-6
10741-7
107-25-5
109-66-0
109-67-1
109-92-2
109-95-5
115-07-1
115-10-6
116-14-3
124-40-3
460-19-5
461-49-0
463-56-1
463-62-1
VlA-fiA-Q
563-45-1
563-46-2
590-18-1
590-21-6
624-64-6
627-20-3
646-04-6
689-97-4
1333-74-0
410946-0
77Q.1-91-1
7803-62-5
10025-78-2
25167-67-3
Threshold
(bs)
10.000
10000
10000
10000
10000
10000
inoflo
10000
10000
10000
10000
10000
10000
10000
10.000
10000
10.000
10000
10.000
10.000
10000
10.000
10.000
10.000
10000
10000
10.000
10.000
10.000
moon
10000
10000
10000
10000
10000
10000
10000
10000
10.000
10000
10000
10.000
Basis tar
(sting
9
g
0
1
0
Note: Bans tor Uung: a Mandated tor kshng by Congress. I Flammable gas. g Volatile flammable kqud.
Subport G-Risk Management
Plan
SOURCE: 61 FR 31726. June 20. 1996. unless
otherwise noted.
{68.150 Submission.
(a) The owner or operator shall sub-
mit a single RMP that Includes the in-
formation required by §§68.155 through
68.185 for all covered processes. The
RMP shall be submitted In a method
and format to a central point as speci-
fied by EPA prior to June 21.1999.
. (b) The owner or operator shall sub-
"rfint the first RMP no later than the
latest of the following dates:
(1) June 21.1999;
(2) Three years after the date on
which a regulated substance is first
listed under §68.130; or
Environmental Prole
(3) The date on <
substance Is first
threshold quantity ii
(c) Subsequent But
shall be in accordant
(d) Notwlthstandin
§§68.155 to 68.190. tl
elude classified infer
appropriate procedui
information from
classified data or Inf
from the RMP may
In a classified annex
view by Federal and
tives who have rec
priate security clean
168.155 Executives*.
The owner or oper
in the RMP an execut
Includes a brief desc
lowing elements:
(a) The accidental i
and emergency respo:
stationary source;
(b) The stationary
lated substances hand
(c) The worst-case i
and the alternative r-
Including adminlatra
mitigation measures
tances for each report
(d) The general a
prevention program i
clfic prevention steps;
(e) The five-year ace
(0 The emergency r
and
(g) Planned changes
ty.
§68.160 Registration.
(a) The owner or op
Plete a single registra
elude It in the RMP
cover all regulated su
la covered processes.
(b) The registration
following data:
(1) Stationary sour
city, county, state, zi
and longitude;
(2) The stationary
Bradstreet number;
(3) Name and Dun
number of the corpor
Pany;
1174
174-141 0-97 38
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[Code of Federal Regulations]
[Title 40, Volume 8, Parts 63 to 71]
[Revised as of July 1, 1997]
From the U.S. Government Printing Office via GPO Access
[CITE: 40CFR68]
[Page 1174-1178]
TITLE 40--PROTECT10N OF ENVIRONMENT
CHAPTER I—ENVIRONMENTAL PROTECTION AGENCY
PART 68--CHEMICAL ACCIDENT PREVENTION PROVISIONS—Table of Contents
Subpart O—Risk Management Plan
Source: 61 FR 31726, June 20, 1996, unless otherwise noted.
Sec. 68.150 Submission.
(a) The owner or operator shall submit a single RMP that includes
the information required by Sees. 68.155 through 68.185 for all covered
processes. The RMP shall be submitted in a method and format to a
central point as specified by EPA prior to June 21, 1999.
(b) The owner or operator shall submit the first RMP no later than
the latest of the following dates:
(1) June 21, 1959;
(2) Three years after the date on which a regulated substance is
first listed under Sec. 68.130; or
[[Page 1175]]
(3) The date on which a regulated substance is first present above a
threshold quantity in a process.
(c) Subsequent submissions of RMPs shall be in accordance with
Sec. 68.190.
(d) Notwithstanding the provisions of Sees. 68.155 to 68.190, the
RMP shall exclude classified information. Sub]ect to appropriate
procedures to protect such information from public disclosure,
classified data or information excluded from the RMP may be made
available in a classified annex to the RMP for review by Federal and
state representatives who have received the appropriate security
clearances.
Sec. 68.155 Executive summary.
The owner or operator shall provide in the RMP an executive summary
that includes a brief description of the following elements:
(a) The accidental release prevention and emergency response
policies at the stationary source;
(b) The stationary source and regulated substances handled;
(c) The worst-case release scenario(s) and the alternative release
scenario(s), including administrative controls and mitigation measures
to limit the distances for each reported scenario;
(d) The general accidental release prevention program and chemical-
specific prevention steps;
(e) The five-year accident history;
(f) The emergency response program; and
(g) Planned changes to improve safety.
Sec. 68.160 Registration.
(a) The owner or operator shall complete a single registration form
and include it in the RMP. The form shall cover all regulated substances
handled in covered processes.
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WAIS Document Retrieval
(b) The registration shall include the following data:
ill stationary source name, street, city, county, state, zip code,
latitude, and longitude;
12) The stationary source Dun and Bradstreet number;
!!! Jame and Dun ind Bradstreet number of the corporate parent
e name, telephone number, and mailing address of the owner or
e name and title of the person or position with overall
resnansibilitv for RMP elements and implementation;
P°S) The name? title, telephone number, and 24-hour telephone number
°f tS»TE9S2 covert'' process, the name and CAS number of each
regulated substance held above the threshold quantity in the process,
thTmaximum quantity of each regulated substance or mixture in the
proc«s (in pounds) to two significant digits, the SIC code, and the
Program level of the process;
(8) The stationary source EPA identifier;
(9) The number of full-time employees «fc *he ""HS"?™ SJ^U-
(10) Whether the stationary source is subject to 29 CFR I9"-!".
(11) Whether the stationary source is subject to 40 CFR part 355,
(12) Whether the stationary source has a CAA Title V operating
date of the last safety inspection of the stationary source
by a Federal, state, or local government agency and the identity of the
inspecting entity.
Sec. 68.165 Offsite consequence analysis.
(a) The owner or operator shall submit in the RMP information:
(1) One worst-case release scenario for each Program 1 process; and
(2) For Program 2 and 3 processes, one worst-case release scenario
to represent all regulated toxic substances held above the threshold
quantity and one worst-case release scenario to represent all regulated
flammable substances held above the threshold quantity. If additional
worst-case scenarios for toxics or flammables are required by
Sec. 68.25U) (2) (iii), the owner or operator shall submit the same
information on the additional scenario (s). The owner or operator of
Program 2 and 3 processes shall also submit information on one
alternative release scenario for each regulated toxic substance held
above the threshold quantity and one
[[Page 1176]]
alternative release scenario to represent all regulated flammable
substances held above the threshold quantity.
' (b) The owner or operator shall submit the following data:
(1) Chemical name;
(2) Physical state (toxics only);
(3) Basis of results (give model name if used);
(4) Scenario (explosion, fire, toxic gas release, or liquid spill
and vaporization) ;
(5) Quantity released in pounds;
(6) Release rate;
(7) Release duration;
(8) Wind speed and atmospheric stability class (toxics only);
(9) Topography (toxics only);
(10) Distance to endpoint;
(11) Public and environmental receptors within the distance;
(12) Passive mitigation considered; and
(13) Active mitigation considered (alternative releases only);
Sec. 68.168 Five-year accident history.
The owner or operator shall submit in the RMP the information
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WAIS Document Retneval * °
(6) Changes since the last PHA.
(f) The date of the most recent review or revision of operating
procedures^ ^^ ^ ^ ^^ recent review or revision of training
programs^ ^^ ^ training provided-classroom, classroom plus on the
job, on the job; and
(2) The type of competency testing used.
h The date of the most recent review or revision of maintenance
procedures and the date of the most recent equipment inspection or test
and the equipment inspected or tested.
(i) The date of the most recent change that triggered management of
change procedures and the date of the most recent review or revision of
management of change procedures.
(j) The date of the most recent pre-startup review.
(k) The date of the most recent compliance audit and the expected
date of completion of any changes resulting from the compliance audit;
(1) The date of the most recent incident investigation and the
expected date of completion of any changes resulting from the
investigation; ,„.,„«,
(m) The date of the most recent review or revision of employee
participation plans;
(n) The date of the most recent review or revision of hot work
permit procedures; .. ..-•.«..
(o) The date of the most recent review or revision of contractor
safety procedures; and
(p) The date of the most recent evaluation of contractor safety
performance.
Sec. 68.180 Emergency response program.
(a) The owner or operator shall provide in the RMP the following
information:
(1) Do you have a written emergency response plan?
(2) Does the plan include specific actions to be taken in response
to an accidental releases of a regulated substance?
(3) Does the plan include procedures for informing the public and
local agencies responsible for responding to accidental releases?
(4) Does the plan include information on emergency health care?
(5) The date of the most recent review or update of the emergency
response plan;
(6) The date of the most recent emergency response training for
employees.
(b) The owner or operator shall provide the name and telephone
number of the local agency with which the plan is coordinated.
(c) The owner or operator shall list other Federal or state
emergency plan requirements to which the stationary source is subject.
Sec. 68.185 Certification.
(a) For Program 1 processes, the owner or operator shall submit in
the RMP the certification statement provided in Sec. 68.12(b)(4).
(b) For all other covered processes, the owner or operator shall
submit in the RMP a single certification that, to the best of the
signer's knowledge, information, and belief formed after reasonable
inquiry, the information submitted is true, accurate, and complete.
Sec. 68.190 Updates.
(a) The owner or operator shall review and update the RMP as
specified in paragraph (b) of this section and submit it in a method and
format to a central point specified by EPA prior to June 21, 1999.
(b) The owner or operator of a stationary source shall revise and
update the RMP submitted under Sec. 68.150 as follows:
(1) Within five years of its initial submission or most recent
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WA1S Document Retrieval r
update required by paragraphs (b)(2) through «b)(7) of this section,
whichever^later.,^ ^^ ^^ ^^ ^ ncwiy regulated substance is
""^"So'laS/than the date on which a new regulated substance is
first present in an already covered process above a threshold quantity;
(4) No later than the date on which a regulated substance is first
present above a threshold quantity in a new process;
[[Page 1178]]
(5) Within six months of a change that requires a revised PHA or
hazard^review^ ^ months of a change that requires a revised offsite
consequence analysis as provided in Sec. 68.36; and
(7) Within six months of a change that alters the Program level that
applied to any covered process.
(c) If a stationary source is no longer subject to this part, the
owner or operator shall submit a revised registration to EPA within six
months indicating that the stationary source is no longer covered.
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[Code of Federal Regulations]
[Title 40, Volume 8, Parts 63 to 71]
[Revised as of July 1, 1997]
From the U.S. Government Printing Office via GPO Access
[CITE: 40CFR68J
[Page 1178-1183]
TITLE 40--PROTECTION OF ENVIRONMENT
CHAPTER I—ENVIRONMENTAL PROTECTION AGENCY
PART 68—CHEMICAL ACCIDENT PREVENTION PROVISIONS—Table of Contents
Subpart H—Other Requirements
Source: 61 FR 31728, June 20, 1996, unless otherwise noted.
Sec. 68.200 Recordkeeping.
The owner or operator shall maintain records supporting the
implementation of this part for five years unless otherwise provided in
subpart D of this part.
Sec. 68.210 Availability of information to the public.
(a) The RMP required under subpart G of this part shall be available
to the public under 42 U.S.C. 7414(c).
(b) The disclosure of classified information by the Department of
Defense or other Federal agencies or contractors of such agencies shall
be controlled by applicable laws, regulations, or executive orders
concerning the release of classified information.
Sec. 68.215 Permit content and air permitting authority or designated
agency requirements.
(a) These requirements apply to any stationary source subject to
this part 68 and parts 70 or 71 of this chaptee. The 40 CFR part 70 or
part 71 permit for the stationary source shall contain:
(1) A statement listing this part as an applicable requirement;
(2) Conditions that require the source owner or operator to submit:
(i) A compliance schedule for meeting the requirements of this part
by the date provided in Sec. 68.10(a) or;
(ii) As part of the compliance certification submitted under 40 CFR
70.6(c)(5), a certification statement that the source is in compliance
with all requirements of this part, including the registration and
submission of the RMP.
(b) The owner or operator shall submit any additional relevant
information requested by the air permitting authority or designated
agency.
(c) For 40 CFR part 70 or part 71 permits issued prior .to the
deadline for registering and submitting the RMP and which do not contain
permit conditions described in paragraph (a) of this section, the owner
or operator or air permitting authority shall initiate permit revision
or reopening according to the procedures of 40 CFR 70.7 or 71.7 to
incorporate the terms and conditions consistent with paragraph (a) of
this section.
(d) The state may delegate the authority to implement and enforce
the requirements of paragraph (e) of this section to a state or local
agency or agencies other than the air permitting authority. An up-to-
date copy of any delegation instrument shall be maintained by the air
permitting authority. The state may enter a written agreement with the
Administrator under which EPA will implement and enforce the
requirements of paragraph (ei of this section.
(e) The air permitting authority or the agency designated by
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written response being due and upon written request from the owner or
operator, the implementing agency may provide in writing additional time
for the response to be received.
(g) After providing the owner or operator an opportunity to respond
under paragraph (f) of this section, the implementing agency may issue
the owner or operator a written final determination of necessary
revisions to the stationary source's RMP. The final determination may
adopt or modify the revisions contained in the preliminary determination
under paragraph (e) of this section or may adopt or modify the
substitute revisions provided in the response under paragraph (f) of
this section. A final determination that adopts a revision rejected by
the owner or operator shall include an explanation of the basis for the
revision. A final determination that fails to adopt a substitute
revision provided under paragraph (f) of this section shall include an
explanation of the basis for finding such substitute revision
unreasonable.
(h) Thirty days after completion of the actions detailed in the
implementation schedule set in the final determination under paragraph
(g) of this section, the owner or operator shall be in violation of
subpart G of this part and this section unless the owner or operator
revises the RMP prepared
[[Page 1180]]
under subpart G of this part as required by the final determination, and
submits the revised RMP as required under Sec. 63.150.
(i) The public shall have access to the preliminary determinations,
responses, and final determinations under this section in a manner
consistent with Sec. 68.210.
(3) Nothing in this section shall preclude, limit, or interfere in
any way with the authority of EPA or the state to exercise its
enforcement, investigatory, and information gathering authorities
concerning this part under the Act.
[[Page 1181]]
Pt. 68, App. A
Appendix A to Part 68~Table of Toxic Endpoints
[As defined in Sec. 68.22 of this part]
CAS No. Chemical name
107-02-8 ' Acrolein [2-Propenal]
107-13-1 Acrylonitrile [2-Propenenitrile]
814-68-6 Acrylyl chloride [2-Propenoyl chlorid
107-18-6 : Allyl alcohol [2-Propen-l-ol]
107-11-9 Allylamine [2-Propen-l-amine]
7664-41-7 Ammonia (anhydrous)
7664-41-7 Ammonia (cone 20% or greater)
7784-34-1 Arsenous trichloride
7784-42-1 Arsine • •
10294-34-5 Boron trichloride [Borane, tnchloro-
7637-07-2 Boron trifluoride [Borane, trifluoro-
353-42-4 Boron trifluoride compound with methy
[Boron, trifluoro[oxybis[methane]]-,
7726-95-6 Bromine
75-15-0 Carbon disulfide
7782-50-5 Chlorine
10049-04-4 Chlorine dioxide [Chlorine oxide (CIO
67-66-3 Chloroform [Methane, trichloro-J
542-88-1 Chloromethyl ether [Methane, oxybis [c
107-30-2 Chloromethyl methyl ether [Methane, c
3 of 5
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»; V •*. •>« • i
APPENDIX A TO PART 68—TABLE OF Toxic ENDPOINTS
|Ai defined bi |6U2 d this pert)
CAS No.
107424 .....
107-1»-1 ...
614-66-6
107-16-6 -
107-11-4
7664-41-7 ,
7684-41-7
776444-1
7764-42-1
10294-344
7637-47-2
353-42-4 ...
7726-6S-6
75-15-0
7781-60-6
10Q49-Q4-4
67-66-3
542-66-1
107-30-2 ..-
4170-30-3
12»-73-6
606-77-4
106-01-4
19287-45-7
75-764
(7-14-7
10649-6
107-15-3
151-*9-»
75-81-4
7762-41-4
50-00-0 -
110-094
302-01-2
7647414
74404
7647414
7664494 „ .
7763474
776346-1 ., .
13443-404 ~
76424
106-234
Chemical name
*•
AeroWn p-Propenal]
Aoytoritrllep-PrapenenlMel
Aery* chloride p-Propenoyl chloride)
Alyl alcohol p-Propen-1-oq
AIMamlna p-Propen-l-amlne|
Ammonia (anhydrous)
Ammonia (cone 20% or greater) _—_—_——
Arsenout MeHorido
Anfew
Boron McNorMa (Borane. Hchtoro-] — — "•
9oran Mduerida (Bonne. Wfluoro-J
Boron MfluorUa compound *8h methyl ether (1 :1) (Boron. Wfluorojoiytblmethanel]-. T-4
Carbon dsutfWe ——. •— — — — -
Chtorlna —
CMorine dortla (Chtorlna oiUa (CK»)]
CMorotorm (Melhan*. McNonH — . — ••
CMorometnyl ether (Methane. oiytts(cMoro-| — — •
ChtoromeUiyl methyl ether (Methane, chtaomettwy) f—
CratonaUehyitop-Butenaq *<
Cretonakiehyde. (EK p-Sutenal. (EH 1
Cy^*xyatrtr»(Crek)rwxarwrtn«]
1.1-DlmeOi>lhyilrazlne (Hydrailne. 1.1-dmeHiyH ^__ ~— — . •—
EpfcNororiydHnpnlrane. (eWoromethyM
Ethylenadlamlne di-Etheneoianilnel
EBiyleneimine (ArtWne) ______————
Emytene mMe (Qiriranel
Fluorine
Formaldehyde (solution)
Furan . —
Hydraitna ^^.w^^......— .«..«.—...—>.— -^— ••—"••"•-•"-•••-•— ••"•"••••— "••"••"•"•—•"•••""•••
Hydrochloric add (eone 30* or greater)
Hydrogen chloride (anhydroui) "
-------
APPENDIX A TO PART 68—TABLE OF Toxic ENOPOinrs-Continued
(As deHned h J, 68.22 ol this parti
M
g
CAS No.
12*48-7
74-07-3 _„„„...
79-22-1
60-34-4 _
624-63-0
74-OT-1 ,
556-64-0 .
75-70-6 -.
1340J-30-9
7697-37-2 .
10102-43-9
8014-64-7
79-21-0 .
594-42-3 -1
75-14-5 If
7803-51-9
10029-67-4 _
7719-12-2
110-89-4 _
107-12-0
101HI1-5
75-55-6
75-58-4 . — -
7445-09-5
7763-40-0
7446-11-0 -
75-74-1 .
509-14-8
7750-45-0
584-84-0
81-08-7 _
20471-62-5 -
75-77-4
MMhaoytonlHa p-PropenenllrBe. 2-methyH
Methyl chloride [Methane. cNoro-t
Methyl ehtorotomwte (CarbonoeNorldfc add. malhylMter]
Methyl hydraztne (Hydrazlne. melhyH
Methyl bocyanata (Methane, beeytntle-)
Methyl mercaptan (MethaneUM)
Methyl thtocyanate (TNocyanle add. maihyl ester)
MethyRrlcNorosnane [SHane. McNoromethyH — — ••
NUielcarbonyl ~
NMe add (eene 80* or greater)
NRric oikto (Nitrogen oiWe (NO)] — .«....-. ^•-...^.•....•.^-...-^- «..«.««.„•.... .
Oleum (Fuming Srilurlc aod) ISultune add. mhlure with tullur trtoikJe)
Peracetlc add (EDianeperaioic add)
PercNoromethylniereaptan ptothanetullenyl ehtotde. MeNOfoH
Phosgene (Carbonic oTcMoride) „_
PhospNne •......—.-*.».—"———••—— • .——.-«"•.*""-*— —•-""—-"•"- —
PhoiphonnoKycMocUe (Phosphoryt chloride]
Phosphorus MeNoride (Phosphorous trichloride)
Proplonttffle IPropenenltrlle) _._...„.....—.—-.
Propyl cNorotonnale (CarbonocNorlde add. propytoster) -
Propylenebnlne (AjWdlne. 2-methy»-|
Propylene oiUe (Oxliane, methyH
SutTu> doiMe (anhydrous) .__—- — -..-— ____........—.—— .-.—.-.........— -....~-.....~.— •— — — ,,..-—
Sulfur lelranuorWe (SuHur fluoride (SF4). (T-«H
Suflur trtoxkJe
Tetramethyflead IPIumbane. tatramathyH
TatranHrornettiane (Methane, tetranlfro-)
TRarium tetracrigrlde (Titanium eNorkto {TCM) (T+H
Toluene 2.4-d»ioeysnaloniethyl-)
TrhrwthykNorosilana (SUane, cMoroMmelhyH __— — .
Tejde^
andpolnl
(moA)
OXK87
0.82
0.0019
OJ0094
0.0012
OM9
0.085
OA18
OM067
0.028
0.031
0.010
OM45
OJ007B
0.00081
0.0035
0.0030
0.028
0X122
0.0037
0.010
0.12
0.59
01X178
0.0092
0.010
QB040
0.0040
0.020
0.0070
OM70
ojoon
0.050
09*
l\
BS
<*
3 I
I
£ 5* II
|g«ii
-------
APPENDIX K
Compilation of Recommendations
-------
Compilation of Recommendations
5.5.1 Finding:
The Basic Plan clearly states its purpose to achieve effective governmental and private
sector preparedness for prompt, fully coordinated, flexible response and assistance when
natural, human-caused disaster or acts of war threaten or occur anywhere in the County of
Hawai'i. As reflected in this statement and throughout the plan, little recognition or
attention to "chemical" or "industrial" issues occurs. Annex M, the Oil and Hazardous
Substances Response Plan, is underdeveloped considering the island's continuing
economic growth.
Recommendation:
The County Department of Civil Defense should review and revise the Hawai'i Emergency
Operations Plan to update and replace the 1989 Plan They should update the Plan in
cooperation with all County agencies, local code enforcement and emergency response
departments and other interested parties The basic Oil and Hazardous Substances
Response Plan, as described in Annex M, is not a plan for field operations The Plan
should describe the relationship between Federal, State and local response plans for
hazardous materials This document should contain three parts basic plan, local
jurisdiction information, and pertinent source material
Part I- the basic Oil and Hazardous Substances Response Plan (Annex M) should provide
the framework to bring together, in one place, information describing the elements of
hazardous materials incident planning and response in the County of Hawai'i including
a Establishing roles and responsibilities for government agency actions required to
protect life, the environment and property from the effects of any hazardous materials
release or threatened release that impacts any part of the County of Hawai'i,
b Identifying procedures Hawai'i County will use to coordinate the management of
hazardous materials emergency response,
c. Meeting the requirements for the County that also carry out the requirements for the
State of Hawai'i;
d. Substantially addressing each element listed in the SARA Title III and in the Hazardous
Materials Emergency Planning Guide (NRT-1) issued by the National Emergency
Response Team. Objectives include the following:
1 Providing guidance to those required to provide services in case of a hazardous
materials incident;
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2 Describing pre-emergency preparations, concept of operations, organization, incident
command, protective actions, and supporting systems required to carry out the plan;
3. Defining responsibilities and functions of each participating organization, public or
private; and
4. Establishing lines of authority and coordination.
Part II- Each lead agency with planning and response roles should provide local
jurisdiction information. Local jurisdictions should provide information for the following:
a. An information sheet with contacts;
b A narrative report describing local capabilities and resources, and
c Supplemental information showing assigned responsibilities
Part III- Appendices should include, at a minimum, references to all source documents
that provide the foundation for the basic Oil and Hazardous Substances Response Plan
(Annex M) including-
a County and Operational Plan,
b Local Police and Fire Service,
c County Central Fire Protection District Hazardous Materials Operations Guide, and
d PGV Emergency Response Plan
5.5.2 Finding:
While the Basic Plan mentions 'private sector1 assistance, this is not well defined for the
role of facilities that may experience hazardous materials accidents Many organizational
graphics (see Annex D-l) do not include assistance from the private sector.
Recommendation:
Planners should address and define the role of facility personnel if facility chemical
emergencies are to be coordinated with the county plan. They should also specify how,
when, and under what conditions facility (private sector) personnel would interface with
other authorities. Concerning the Oil and Hazardous Substances Response Plan (Annex
M), EPCRA laws require the designation of a community emergency coordinator and
facility emergency coordinators who will make determinations necessary to implement the
plan
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5.5.3 Finding:
Annex C, Section III, Civil Defense Siren Signals and Appendix 4, Hazards with Warning
Time are inconsistent based on discussions with Mr Harry Kim While the Emergency
Siren System described in Section III provides warnings throughout the county, Appendix
4 says they will notify the 'community' at risk.
Recommendation:
Emergency managers have found many ways to alert and notify the community when a
human-made disaster affects only the area local to the source Below are some ways that
Hawai'i County working with PGV could improve their alerting and notifying.
• Both Hawai'i County and PGV should explore the technical and economic feasibility of
upgrading the system The upgrade should include the capability to provide alerts within a
single community (such as Pahoa or Hilo) without unnecessarily alerting the entire island
This would allow them to use the system as Annex C, Appendix 4 intends — the
notification of a specific community at risk;
• Install tone-alert radios that a Radio Broadcast Data System (RBDS) signal could
activate in the homes surrounding PGV or where sensitive population centers exist (e g,
schools, hospitals, day care centers),
• Use a telephone call-down system, which can make many telephone calls
simultaneously, to get emergency information to the community,
• When sirens are sounded, in response to an accidental release of a hazardous material,
use the existing connections with the television and radio stations to notify the public what
is occurring and protective actions they should to take, and
• Educate the public on how to "shelter-in-place" and turn on their radios or televisions to
receive instructions on the appropriate protective action, when a they hear a siren With
some -nodifications to the Hawai'i County systems, they could provide an excellent means
of alerting and notifying the community surrounding the PGV facility The County could
also instruct the public about what actions they should take during an emergency.
5.5.4 Finding:
Some hazards will occur with almost no warning time Appendix 3 to Annex C lists local
tsunami, flash floods, water spout tornado, and earthquake as such hazards Notably, the
list of hazards also includes human-induced events that could be catastrophic to the
community. Any of these hazards could result in a sudden unexpected effect with little
time for official warning: explosions, fires, and transportation or industrial accidents In
an urgent local tsunami warning, the Central Police Dispatch (County Warning Point) in
Hilo has the authority to sound the Attention/Alert signal immediately Appendix C does
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not specify whether the County has extended an urgent alerting authority to the Central
Police Dispatch for other hazards that may occur with little warning
Recommendation:
The Plan should include a procedure allowing the Pahoa Substation of the Hawai'i County
Fire Department to make emergency decisions, such as sounding sirens The Pahoa
Substation could then manage the emergency until personnel from Hawai'i County Civil
Defense have time to arrive and take command. This could shorten the time needed to
alert and notify the public after a release.
Hawai'i County Civil Defense, the Pahoa Substation, PGV, and representatives of the
community should work together and determine how they will manage an accidental
release. This could include setting up different levels of incidents. This group could also
determine the appropriate response for each level of incident and when to notify Civil
Defense, the Pahoa Substation, and the community.
5.5.5 Finding:
Annex M, Section I "Overview" does not address public or environmental threats caused
by a serious release of hazardous substances from a facility The appendix listing
hazardous materials for individual facilities is also missing
Recommendation:
Puna Geothermal Venture and other facilities in Hawai'i County that handle hazardous
materials should submit information on all hazardous substances as required by EPCRA
In addition, each facility should prepare a hazards analysis including a worst-case scenario
and off-site consequence analysis If the hazards analysis shows a serious threat to the
public and the environment, the County should list it in Annex B, Hazards Analysis,
Section HI - Vulnerability. The County also should address it in Annex M "Oil and
Hazardous Substances Response Plan "
In September 1998, Hawai'i County Civil Defense Agency informed EPA that each
individual facility appendix is available on the Hawai'i County Fire Department computer
A paper copy is also located at the Civil Defense emergency operations center, but it
should be updated. These appendices are commonly referred to as the "individual facility
profiles for SARA Title HI."
5.5.6 Finding:
Annex M, Section III, Concept of Operations (Step C) states that "the Chief of the
Hawai'i Fire Department, or his designee, assumes the role of Incident Commander until
relieved by the Hawai'i County Civil Defense Agency upon activation of County of
Hawai'i Emergency Operations Plan " However, the emergency response plans for Puna
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Geothermal Venture designate facility personnel to fill the role of incident commander
Thus, the county and facility plans are inconsistent.
Recommendation:
PGV and County personnel should jointly assess the emergency and the necessary
response activities. PGV personnel will better understand the response level required
within the plant boundaries However, the County agencies should also assess the
emergency, as PGV may call them to provide backup for personnel rescue, medical
assistance and fire fighting within the plant boundaries Additionally, the County agencies
should decide the need for offsite evacuations Refer to the recommendations in Section
42.4.
5.5.7 Finding:
In Annex M, Section VJ1, Warning and Evacuation, the County determines the evacuation
area based on information from the computer program CAMEO (Computer Aided
Management of Emergency Operations) They do not define the parties responsible for
modeling in the procedure Additionally, they do not define procedures for obtaining
necessary input variables to run the computer program Variables include industrial
process and meteorological information that should be available quickly
For planning purposes, PGV has prepared advanced modeling of anticipated worst case
release scenarios for H2S and effects from pentane fires This information is presented in
the Plan The models show no life threatening effects at the nearest residential location,
which is approximately 2,000 feet However, the public is concerned about model
accuracy One local resident stated that during a blowout, concentrations of 30 parts per
million (ppm) were present at the resident's home, but the PGV models predicted only 1 1
ppm The EPA has not confirmed the PGV model accuracy or the resident's statement
Recommendation:
a Identify a responder responsible for CAMEO modeling and identify where to obtain
meteorological input data Identify a PGV source to provide release information This
procedural information may be better placed in the Hawai'i County Fire Department plan
for Emergency Response to Puna Geothermal Venture The County Emergency
Operations Plan is more general in nature.
b. Hawai'i County (with support from EPA) should confirm PGV model accuracy,
determining if PGV s input is appropriate and if the model results are reasonable
Additionally, Hawai'i County and PGV should evaluate other hazard scenarios One
example of a hazard scenario is the failure of caustic injection at the Emergency Steam
Release Facility when this facility experiences maximum flow Another example is the
effect of discharges from pressure relief valves on the pentane, steam, and process sides of
the operation The "process" at PGV, as defined by Process Safety Management (29 CFR
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1910.119), includes the pentane, steam, and condensate systems, as they are all
interconnected by pipeline
5.5.8 Finding:
Annex M, Section VII, Warning and Evacuation says that each facility appendix lists
individual evacuation plans. The Review Team did not see a facility appendix for PGV
Additionally, the public has raised several concerns related to evacuation:
a They do not know where to evacuate.
b They do not know how the County will notify them of an evacuation.
c Residents southwest of PGV are concerned that their only evacuation route is toward
the facility, and that electric power transmission lines run along this road For example,
the power lines could fall onto the road during a major earthquake, and this same
earthquake could also cause a major accidental release from PGV If the release required
an evacuation, and the only evacuation route was impassable, residents would be at risk of
injury.
d They are concerned about housing for evacuees
e They state that too few (only two) buses are available for evacuating children from
school in Pahoa They do not know how the County will notify the school of an
evacuation
e They are concerned about the County Civil Defense's ability to notify the residents in
the adjacent housing if they need to evacuate quickly
Recommendation:
a Initially, the local responders and PGV should resolve all coordination issues identified
previously in these findings and recommendations
b. After Hawai'i County, with EPA support, confirms release scenario models, local
responders should define public evacuation routes and safe congregation areas. Although
maps show releases as circles concentric to the release point, the actual release will take
the shape of a plume. Consequently, local responders should define alternate evacuation
routes considering different wind directions
c. A plan to evacuate the schools at the Pahoa K-12 complex should be in place. If too
few buses are available, perhaps the County should consider using private vehicles Local
responders should also work with the schools to develop an emergency plan which
includes shelter-in-place procedures
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d Local responders should develop a plan to ensure the public follows proper evacuation
routes and that they reduce traffic congestion.
e. The County should publish additional information in the individual facility appendix of
Annex M addressing - (1) indoor protection and (2) the evacuation procedures detailed in
Function 9, Page 56 of the NRT-1 guidance. Evacuation procedures should address
housing for evacuees.
f. The local responders should review the evacuation plan with the public and consider
public participation to the plan.
5.5.9 Finding:
Annex M, Section X -Training provides little information beyond the County's intent to
provide training
Recommendation:
Annex M, Section X -The County should develop training for hazardous materials
response to include both frequency of delivery (a schedule) and emphasis on joint activities
with private sector facility personnel Joint training is vital for addressing and exercising
the interface mechanisms (cited above) which avoid confusion in real-world events
5.5.10 Finding
The State Department of Civil Defense prepared the Hawai'i County Emergency
Operations Plan for the County of Hawai'i. On March 8, 1990, the Mayor of the County
(who is also the State Deputy Director of Civil Defense) and the Director of Hawai'i State
Civil Defense signed the Plan The document as signed was incomplete However, they
have made no revisions to the Plan since the date of acceptance The Emergency Planning
and Community Right-to-Know Act, 42 U S C §11003(1995), states that each local
emergency planning committee (LEPC) "shall review such olan once a year, or more
frequently as changed circumstances in the community or at any facility may require."
Recommendation:
Hawai'i County should review, update, and complete the Plan, including SOPs. The
Review Team suggests that the County refer to the Hazardous Materials Emergency
Planning Guide, document NRT-1, and the Criteria for Review of Hazardous Materials
Emergency Plans, document NRT-1 A The National Response Team prepared both
documents as guides for reviewing and updating emergency response plans
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6.2 Employee Emergency Plans and Fire Prevention Plans — 29 CFR 1910.38
6.2.1 Finding:
Under 1910.38(a)(2)(ii), the plan is required to include, "Procedures to be followed by
employees who remain to operate critical plant operations before they evacuate" PGV
notes equipment removal activities in case of a natural hazard in Table 5-1 of the ERP.
Due to time constraints, the Review Team scanned the procedures in the emergency
response documents The Operations and Maintenance Manual table of contents did not
state clearly whether emergency shutdown procedures do exist.
Recommendation:
PGV should have emergency shutdown procedures If these procedures exist already,
PGV should cross-reference the procedures for an emergency shutdown with its
emergency response procedures [Please note: the Review Team was not given the
opportunity to review the PGV Operations Manual, and EPA did not receive a copy for
review. HIOSH informed EPA during a teleconference November 3, 1999, that HIOSH is
satisfied with the written emergency shut down procedure* in PGV's emergency response
plan.]
6.2.2 Finding:
Under 1910 38(a)(2)(iv), the plan is required to include, "Rescue and medical duties for
those employees who are to perform them" The ERP states that at least three people
with first aid training will work on every shift At the time of the review, it was not clear
in any emergency response document how the facility identified individuals with first aid
training during an emergency or what their role was on the response team. PGV has since
indicated to EPA that all PGV employees are certified for first aid and cardiopulmonary
resuscitation or CPR.
Recommendation:
The emergency response procedures should clarify the role of first aid responders to
ensure they are available to administer first aid when required.
6.3 Hazardous Waste Operations and Emergency Response — 29 CFR 1910.120
6.3.1 Finding:
Under 29 CFR 1910 120(q)(2)(I), the emergency response plan is required to address,
"pre-emergency planning and coordination with outside parties " From discussions with
County Civil Defense and local responders, the Review Team found that coordination with
outside parties is practically nonexistent The emergency response plans do not address
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responders' roles or coordination of response activities with local responders. At the time
of this review, PGV's stated position was that it will handle all incidents internally in its
facility, except fire incidents Insufficient coordination with outside parties is the primary
cause of concern over PGV's need to improve its emergency response capability Some
of the specific concerns are described below, in paragraphs 6.3 2 through 6.3.6
Recommendation:
PGV should improve its emergency response capability by ~
1 Clarifying in writing the local responder responsibilities and
2 Communicating with outside parties during pre-emergency planning
PGV responders may need backup from the Hawai'i County Fire Department and its
HAZMAT, hazardous materials, or EMT, emergency medical technician, teams A facility
emergency could include a fire, explosion, hazardous substance release, or all three at the
same time, in which case PGV could become overwhelmed Given a very serious
emergency, local responders may need to rescue PGV responders
6.3.2 Finding:
The Hawai'i County Fire Department and its HAZMAT team members said they were
uncertain what their role would be in an emergency response at PGV. The assistant fire
chief also stated that he would not send County responders beyond the plant boundary
without understanding the facility and the County's role in the response. PGV personnel
noted that they do not expect the fire department to respond to releases of hazardous
substances in their facility However. PGV would call Hawai'i County Fire Department
for assistance if it had a fire in its facility For example, if the pentane cycle or any
component of the entirely closed cycle caught fire, PGV would call the fire department
Recommendation:
PGV should work with the Hawai'i County Fire Department to refine the Fire
Department's procedure entitled, "Emergency Response to Puna Geothermal Venture "
The Fire Department should incorporate the response of its newly formed HAZMAT
team. Also, PGV should work with the Fire Department to clearly define the possible
response scenarios, both inside and outside the plant boundaries. Some of these scenarios
involve hydrogen sulfide, caustic soda, diesel fuel, pentane, brine and steam If other
hazardous chemicals are present in the steam from geothermal wells, the Emergency
Response Plan should include them as well. Defining these scenarios and the anticipated
level of backup from the Fire Department and the HAZMAT team will require PGV
participation
PGV should work with Hawai'i County Civil Defense Agency and Fire Department,
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Pahoa Substation, to establish how and whom PGV will notify during an incident. For
example, a situation could arise in which PGV personnel are injured during an emergency
response, and PGV would need to call County Fire for rescue or backup. PGV and the
County should address emergencies involving both hazardous materials and fire in the
facility.
6.3.3 Finding:
Version 6.3 of the Emergency Response Plan states that the County "Civil Defense
Agency has the responsibility of providing the warning to, and to effect the
implementation of, the evacuation of any residents or other members of the public from
the appropriate hazard area surrounding the site, as necessary " However, this plan does
not clearly state the order in which PGV personnel should notify County responders The
lack of clarity may cause a delay in County response, such as evacuation, that could have
serious consequences. PGV does not address pre-emergency response planning activities
with outside parties, e g. the community, in any planning document
Version 6 3 of PGV's Plan states that "PGV anticipates no project-created situation which
would not provide sufficient time for the Civil Defense Agency to warn or evacuate the
public, as appropriate." PGV's release history does not support this statement In the
past, incidents have occurred quickly and without sufficient warning to notify or evacuate
the public before they were exposed to hazardous substances According to the County
Civil Defense Administrator, incidents also have occurred in which neighbors to PGV
phoned-in complaints of H2S releases, and PGV did not report these same releases.
Copies of letters between EPA and PGV regarding one such release in January, 2000 are
appended to the final report
Recommendation:
With PGV's assistance, Hawai'i County Fire Department personnel should evaluate and
determine if release or fire situations require outside response The State of Hawai'i has
adopted the 1988 edition of the Uniform Fire Code by reference into its State Model Fire
Code The Uniform Fire Code section 10101 authorizes the County Fire Department to
direct an operation as necessary at the scene of a fire or other emergency involving the
protection of life or property. Section 10.101 also empowers the County Fire Department
to perform any rescue operation or take any other action necessary in the reasonable
performance of its duty. Both PGV and Hawai'i County Fire Department have emergency
response capabilities and responsibilities. PGV should improve its coordination with
outside parties and its outreach activities. PGV should involve both local responders and
the community in its pre-emergency planning.
6.3.4 Finding:
This finding pertains only to hazardous materials releases. By not incorporating the
ranking outside responder into the Incident Command System (1CS) for hazmat response,
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PGV is directly or indirectly making decisions that affect outside emergency response
personnel and the public. For example, PGV will define the severity of an accidental
release scenario or the potential severity of the release. Then the outside responders will
base their action on the PGV assessment
Recommendation:
PGV and Hawai'i County should modify the PGV Emergency Response Plan and the
Hawai'i County Emergency Operations Plan to coordinate a joint incident command
system. Both a PGV official and the ranking outside responder should share the
responsibility for incident command The PGV Emergency Response Plan should clarify
that the PGV control room operator will serve as the Incident Commander during every
shift, including off-hours, until relieved by the Operations and Maintenance Manager or
Site Manager
6.3.5 Finding:
The Review Team was not able to review and determine if PGV had conducted a
thorough process hazards analysis (PHA), such as a hazard and operability study, for the
entire PGV facility. As of August 1996, PGV had not reviewed \tsPHA on well blowouts
and pentane fires with outside responders Thus, they may not have identified
emergencies beyond well blowouts and pentane fires that could require outside emergency
response EPA takes notice of PGV's more recent efforts to work with response agencies
and its willingness to share process hazards analyses
Recommendation:
PGV should continue to review the results of its PHAs with outside responders to identify
the hazards that may require outside emergency response
6.3.6 Finding:
Under 1910.120(q)(2)(viii), the emergency response plan should address, "Emergency
medical treatment and first aid." The ERP discusses first aid but does not clarify the
coordination with outside responders to provide emergency medical treatment.
Recommendation:
PGV should address medical treatment beyond first aid, such as acute exposure to H2S
and severe burns. PGV also should identify offsite responders and the hospital in Hilo that
can handle such emergencies. EPA has discussed this issue with HIOSH and takes note
that PGV has made improvements since the Review Team's site visit in 1996.
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6.3.7 Finding:
Under 1910.120(q)(2)(iii), the emergency response plan is required to address,
"Emergency Recognition and Prevention." The ERP discusses recognition of an H2S
emergency. However, it does not discuss recognition of combustible gas leaks and fires in
any of the emergency response procedures The ERP references pentane leak rupture and
fire in the Operations and Maintenance Procedures, but PGV did not make these
procedures accessible to the Review Team. Thus, the Review Team cannot comment on
the content. The Operations Manager advised the Review Team that as of August 1996,
PGV was developing the emergency procedure for fire.
Recommendation:
If PGV addresses combustible gas leaks and fires somewhere, then it should either
incorporate them into the emergency response procedures or cross-reference them If
PGV has not addressed gas leaks and fires, it should incorporate them into the ERP or
LAP.
6.3.8 Finding:
Under 1910 120(q)(3)(I), "The senior emergency response official responding to an
emergency shall become the individual in charge of a site-specific Incident Command
System (ICS)"
Recommendation:
PGV and the local Fire Department's HAZMAT Team should consider the Joint Incident
Command System for a coordinated emergency response Both parties should formalize
the joint command structure so everyone will know who is responsible for all tasks
6.3.9 Finding:
Under 1910.120(q)(3)(v), "The individual in charge of the ICS shall limit the number of
emergency response personnel at the emergency site, in those areas of potential or actual
exposure to incident or site hazards, to those who are actively performing emergency
operations However, operations in hazardous areas shall be performed using the buddy
system in groups of two or more." HAZWOPER discusses control zones, but at the time
of this review in August 1996, none of the emergency response plans addressed control of
the number of personnel or use of the buddy system.
Recommendation:
In its ERP or EAP, PGV should include a discussion of using the buddy system and
controlling the number of response personnel. This should also be included in PGV's
Annual Safety Training Program which is in Section 6 of the ERP.
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6.3.10 Finding:
Under 1910.120(q)(3)(viii), "When activities are judged by the safety official to be an
Immediately Dangerous to Life and Health (IDLH) condition and/or involve an imminent
danger condition, the safety official shall have the authority to alter, suspend, or terminate
those activities." The PGV emergency response plan does not give this authority to the
safety officer.
Recommendation:
PGV should provide this authority to the safety officer or provide some type of check
support to the incident commander's authority. PGV should add a clear statement of
authority or check support to its ERP. The term "check support" means a system of
checks and balances on the authority of the incident commander
6.3.11 Finding:
Under 1910.120(q)(4), "temporary employees who are needed to perform work on an
emergency basis, such as operating cranes or earth moving equipment, are not required to
be trained in the emergency response plans, but should be briefed in the hazards, proper
Personal Protective Equipment (PPE) to be used and the duties to be performed " This
issue is not addressed in the emergency response plans
Recommendation:
PGV should amend the ERP to satisfy this requirement
6.3.12 Finding:
Under 1910.120(q)(10), "chemical protective clothing used for emergency response shall
meet the requirements of 1910 120(g)(3-5)" Personnel protective equipment (PPE) and
clothing available for emergency response are listed in HAZWOPER and \hcEAP. PGV's
plans do not discuss what type of clothing and PPE its personnel will use for different
types of emergency response.
Recommendation:
PGV should clarify what appropriate clothing and protective equipment its personnel will
use for different response activities.
7.2.1 Finding:
In 1991, the State of Hawai'i Department of Health (HDOH) identified levels of hydrogen
sulfide (H2S) that emergency managers could use for alert, warning, and emergency levels
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of H2S in the air. The alert level is 10 ppb H2S averaged over a 24-hour period, the
warning level is 100 ppb averaged over a one-hour period, and the emergency level is
1,000 ppb averaged over a one-hour period
Emergency managers at Hawai'i County and PGV also have identified H2S levels.
Hawai'i County has identified the 1,000 ppb level averaged over a one-hour period as an
evacuation trigger. In itsERP, PGV has listed a watch level of 25 ppb averaged over a
one-hour period and a warning level of 1,000 ppb averaged over a one-hour period.
The Review Team found that the stationary H2S air monitoring network around PGV's
perimeter is currently not set to measure ambient H2S levels greater than 500 ppb
HDOH and PGV operate stationary monitors around the PGV perimeter, which are set to
monitor from 0 to 500 ppb1 The monitors are capable of measuring different ranges, up
to 20 ppm or 20,000 ppb, if recalibrated Because the monitors are currently set to
measure from 0 to 500 ppb, the stationary H2S air monitoring network around PGV
cannot adequately measure the data necessary to make evacuation decisions if ambient
H2S concentrations exceed 500 ppb2.
Recommendation:
The Review Team recommends that stationary air monitors around the facility perimeter
should measure continuously the higher H2S concentrations, greater than 500 ppb This is
to ensure that local authorities can alert, warn, or evacuate the public quickly. PGV
should share its real-time air monitoring data with the Pahoa Substation, so the local
responders will know exactly what is occurring at PGV during an emergency
The Review Team also recommends that the County form a technical work group to
evaluate evacuation needs, resources, and procedures The technical work group could
begin by reviewing H2S trigger levels, types of incidents, and the air monitoring network
around PGV The technical work group also may want to consider if stationary monitors
should have alarms set to notify the County Civil Defense Agency and Fire Department
automatically when H2S concentrations reach the alert, warning, or emergency levels
Technical work group members should include representatives from the County Civil
Defense Agency and Fire Department, HDOH, the University of Hawai'i, and EPA.
Work group members should confer with PGV technical staff on the details of facility
operations. Technical issues under evaluation are extremely important and will require a
1 The monitors are currently set to a range of 0 to 500 ppb to ensure that the H3S ambient requirements in the
HDOH air operating permit can be adequately enforced However, monitors with a wider dynamic range, from five to
1000 ppb, are now available, and monitoring equipment is fundable under EPA's Clean Air Act Section 105 grant to
HDOH
2 The Review Team recognizes that PGV and HDOH currently have portable monitors that are available to
measure ambient H:S levels greater than 500 ppb
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great deal of thought, research, and professional judgement.
Public participation should be included when setting new evacuation trigger levels Based
on comments EPA received regarding the draft report, EPA suggests that at least one
member of the technical workgroup could represent the community-at-large.
7.2.2 Finding:
The perimeter H2S air monitors are on an interruptible power supply. Circumstances
causing power disruptions also may cause accidental H2S releases from the PGV facility
PGV personnel can monitor ambient conditions with hand-held H2S monitors.
Recommendation:
The Review Team suggests that PGV and HDOH install, for their respective monitors, an
adequate backup power source for the stationary H2S monitors HDOH and PGV should
maintain stationary H2S monitoring during power disruptions
7.2.3 Finding:
Hawai'i County Fire Department personnel noted that not all shifts from the Pahoa
Substation have received site tours to familiarize them with the PGV facility or training in
the hazards unique to PGV This was a discussion item during the combined meeting with
firefighters at the Pahoa Substation on August 8, 1996 The meeting included Hawai'i
County Fire Department personnel, the EPA Review Team, and members of PGV
management.
Recommendation:
The Review Team suggests that PGV provide site familiarization and training for all shifts
of fire and HAZMAT response personnel from the local fire department, including
1 Asi overview of plant operations and process hazards,
2 H2S and any other hazards unique to PGV,
3. Safe handling practices of H2S and any other hazards unique to PGV,
4. Facility procedures, information, and personnel responsibilities for emergency
response, this should include the locations of all water hydrants, hydrocarbon
monitors, and point source monitors for H2S.
EPA notes that for the purposes of the PGV plan the hydrogen sulfide (H2S) monitors
should measure air quality in the "breathing zone" of approximately six feet There are
no federal regulations which prescribe the requirements of siting hydrogen sulfide
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monitors. EPA monitoring regulations [40 CFR Part 58] address the monitoring of
"criteria" pollutants, i.e ozone, paniculate matter, carbon monoxide (CO), sulfur
dioxide (S02), nitrogen dioxide (N02), and lead. In general, EPA, State and local
agencies collect data on these pollutants for use in regulatory programs mandated by
the Clean Air Act. EPA monitoring regulations contain specific siting criteria for
monitors that measure these pollutants In order for the data collected to be valid for
regulatory use, the criteria pollutant monitors must meet all relevant siting criteria,
including probe height. However, since H2S is not a criteria pollutant, these
regulations can be used as simply a guide to siting the samplers, not a requirement.
Minimum probe heights for collecting ozone, CO, S02 and N02 data are three meters
(about 10 feet). For paniculate matter and lead monitoring, the minimum probe height
is two meters (about 6 5 feet) The reason the minimum probe heights are set where
they are is to obtain the most representative sample of ambient air in order to measure
concentrations of a particular air criteria pollutant If the probe is too close to the
ground, the air sampled may be influenced by the effect of ground turbulence or near
ground sources (e g automobile exhaust)
Since the object of the monitoring of H2S is to provide information to the community on
H2S levels they are exposed to, not to implement a regulatory program mandated by the
Clean Air Act, it is absolutely appropriate to site the monitor probes at the breathing
height level (six feet) The data collected will be used to indicate whether certain actions
in the emergency response plan should be triggered If there are concerns about where the
H2S is coming from (i e PGV, natural vents, automobiles, etc.) then supplementary
monitors can be set up at different heights to try to assess contributions from different
sources The primary purpose of the H2S monitoring is to protect the health of the
community, therefore, the monitoring sites operated by the Hawai'i DOH should sample
air at breathing height (six feet)
5. Where the outside agencies will meet, including alternate locations, when an incident
occurs, and
6 The interface between the agencies and the facility and the different responsibilities of
each, this should include coordinated drills for rescuing injured PGV employees.
Subsequent to the Review Team's visit, PGV stated that it has provided increased site
familiarization for all shifts of fire and HAZMAT response personnel in Pahoa and Hilo.
7.2.4 Finding:
PGV's Emergency Response Plan (ERP) addresses magma intrusion. The ERP seems to
imply that this event is controllable, but does not discuss the severity or likelihood of this
event.
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Recommendation:
Knowledge of this type of occurrence is outside the expertise of the review team PGV
should evaluate the likelihood of occurrence and the severity of a magma intrusion PGV
could draw upon the expertise of the University of Hawai'i, Center for the Study of Active
Volcanoes and the U.S. Geological Survey's Hawai'ian Volcano Observatory PGV
should share the results of the evaluation with the public.
7.2.5 Finding:
The effects of an earthquake of magnitude seven or greater on the PGV facility, including
pentane piping and tanks and underground well casings, are unknown to the emergency
response agencies Seismic activity and its effects on structures are outside the expertise
of the Review Team
Recommendation:
PGV should consult with a qualified and respected engineering firm to review and
comment on the structural integrity of the facility, existing geothermal wells, and any new
wells yet to be drilled This engineering review should address whether the PGV facility
would likely withstand earthquakes of magnitude seven or greater in the Puna locality
7.2.6 Finding:
In Hawai'i, the Emergency Planning and Community Right-to-Know (EPCRA) Tier Two
filing fees currently go directly to the State's Superfund environmental response revolving
fiind and not to the Local Emergency Planning Committees (LEPCs) The Review Team
finds that these funds are not returning to local agencies for emergency responder training
A lack of funds may compromise the training of local response personnel
In 1998, the Hawai'i County LEPC nominated two PGV employees to serve on its
reactivated committee The Hawai'i State Emergency Response Commission (SERC)
confirmed their membership in August 1998
Recommendation:
a. The LEPC should evaluate the training for local responders to decide if it is adequate
and evaluate ways to improve training where appropriate.
b. The Review Team encourages participation of industry on the Hawai'i County LEPC
This will greatly improve communication between responders and facilities and help to
improve the quality of individual emergency response plans.
c. The State of Hawai'i should channel some Tier Two filing fees to LEPCs for use in the
training of HAZMAT response personnel.
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7.2.7 Finding:
Hawai'i County has not recently conducted an exercise for hazardous materials response,
and PGV has never participated in one. The last time the EPA co-sponsored a HAZMAT
exercise for Hawai'i County was 1993. Then, the exercise planning team mentioned PGV
as a possible focus of the exercise However, the hazardous materials exercise scenario
selected by the planning team was the Port of Hilo in an industrial part of the city.
On October 4, 1996, PGV had a release of H2S that exceeded the limit under the state's
air permit. The County and PGV should conduct a joint hazardous materials response
exercise to prepare for this type of release FEMA's guidance for training exercises
suggests a progression, from less difficult to more difficult exercises First a jurisdiction
should conduct a tabletop exercise, then a functional exercise, and finally a full-field
exercise
Recommendation:
The Review Team recommends that local and state agencies and PGV plan and conduct a
multiple jurisdictional hazmat response exercise Participants should include Hawai'i
County Civil Defense, Hawai'i County Fire Department, Hawai'i County and Keeau
Police Departments, Hawai'i Department of Health and other agencies Before
conducting an exercise, participants should resolve many coordination issues and update
their emergency response plans
Hawai'i County should conduct the complete series of exercises - tabletop, functional and
full-field, as recommended by FEMA Additionally, exercise evaluators should critique
each exercise and make this information available to the public
PGV should initiate and actively participate in at least one of these exercises with Hawai'i
County A tabletop or functional exercise between PGV and Hawai'i County should have
a target completion date no later than two years after the release of this report
7.2.8 Finding:
Under 29 CFR 1910.120(q)(2)(I) and (ix), the emergency response plan should address
"pre-emergency planning and coordination with outside parties" as well as "emergency
alerting and response procedures " At the time of the review, the EAP did address
internal alerting but did not clearly define the alerting of offsite emergency responders.
Recommendation:
In cooperation with the County of Hawai'i Civil Defense, both the Pahoa Substation and
PGV should develop local emergency alert, warning and response procedures. Hawai'i
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County also should educate the public near the PGV facility regarding appropriate action
that may be necessary.
Hawai'i County and/or PGV should equip the Pahoa Substation with a combustible gas
monitor, H2S detector, and UV/IR flame detector. PGV should work with the County to
identify the appropriate equipment, train the Pahoa Substation personnel, and help
maintain the equipment. PGV's EAP or ERP should describe what actions operators will
take when they hear a high alarm from one of the point source monitors for hydrogen
sulfide and hydrocarbons. This information should be communicated to the Pahoa
Substation for the use of its first responders.
7.2.9 Finding:
The Review Team found that public communications and access to chemical emergency
planning information from PGV could improve This is based on the EPA's experiences
with community requests-for information, such as requests under the Freedom of
Information Act. Community residents also raised comments about the availability of
information during the August 1996 public meetings Public comments are summarized in
Table 2 at the end of Section 1.
Recommendation:
The Review Team strongly recommends that PGV improve and expand a program for
proactive community outreach One objective is to increase the flow of information for
chemical emergency planning Another important objective is to further improve the
working relationship between the community and PGV 3
The Review Team recommends that Hawai'i County agencies ensure that EPCRA Tier
Two information from all applicable facilities is readily available for emergency planning
and response
In closing, the review team must emphasize that an emergency response plan alone does
not directly protect the public and the environment The plan is only a detailed blueprint
of an emergency response program designed for a facility or community, with the purpose
of protecting the environment and the public Emergency response programs are the
3 PGV has recently provided updated information to EPA regarding its public outreach program. PGV reports
that an average of one hundred visitors per month have toured the plant In addition, PGV personnel have participated
as guest lecturers at local schools and business organizations PGV is maintaining published telephone lines which
allow the general public to speak to plant personnel, ask questions, obtain information on plant activity, and file
complaints Through the Hawai'i Department of Health, PGV provides 24-hour-a-day hydrogen sulfide tables and
charts from each of its air monitoring stations. PGV is constructing an Internet web page to allow electronic interaction
with the community. Completion of the web page is expected by the end of the first quarter of 1999 PGV also reports
that it provides other services and contributions to the community For example, during the recent drought, PGV
provided fire fighting equipment and water to assist the local fire department respond to a fire in the nearby Leilam
Subdivision
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comprehensive approach to protecting the public.
In addition to complete, updated and coordinated emergency response plans, jurisdictions
and industries must have the required resources, equipment and trained personnel, to be
fully prepared to implement the plans and respond to accidents resulting from man-made
hazards as well as natural disasters. Finally, the authorities responsible for the emergency
response programs must be assured at all times that the programs are workable. They
need feedback through the results of scheduled periodic exercises.
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APPENDIX L
Letter to U.S. Senator Daniel Inouye from
Felicia Marcus, EPA Regional Administrator
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REG.ON IX
75 Hawthorne Street
San Francisco. CA 94105-3901
1 * IQQfi OFFICE OF THE
I 0 I99U REGIONAL ADMINISTRATOR
Honorable Daniel K. Inouye
U.S. Senate
Suite 722, Hart Senate Office
Washington, DC 20510
Dear Senator Inouye:
Thank you for your letter of October 11, 1996 regarding EPA's regulatory oversight of
the Puna Geothermal Venture (PGV) on the Island of Hawaii. EPA Administrator Carol
Browner has asked me to respond to your letter. This letter provides background information
explaining EPA's regulatory involvement at PGV and responds to the issues you have raised.
EPA decided to evaluate PGV's safety and compliance status after PGV experienced
two serious blowouts in 1991 while geothermal wells were being drilled. The blowouts
resulted in releases of hydrogen sulfide (H2S), which impacted the neighboring residential
area and heightened community concerns about the plant's safety. We received numerous
letters and telephone calls from community members - primarily residents of the Puna District
- requesting EPA to evaluate PGV's compliance with environmental laws and safety. In 1992,
me Pele Defense Fund and other community groups sent a formal petition to EPA requesting
that we conduct a comprehensive evaluation of PGV. In particular, the community groups
asked EPA to (1) evaluate PGV's compliance with various environmental laws, including the
Safe Drinking Water Act, the Clean Air Act and the Resource Conservation and Recovery
Act; (2) conduct a preliminary assessment and site investigation under the Comprehensive
Environmental Response, Compensation and Recovery Act ("CERCLA" commonly known as
Superfund) to evaluate the impact of past releases of H2S on human health and the
environment; and (3) assess the facility's safety and potential for future incidents. The
community also raised serious concerns about the apparent lack of public involvement in the
permitting of PGV.
In 1993. in response to the Pele Defense Fund's petition, EPA staff performed a
preliminary assessment, pursuant to Section 105(d) of CERCLA, to determine whether the
facility qualified for listing on the National Priorities List (NPL). Although we determined
that PGV was theoretically eligible for NPL listing, the EPA staff recommended that the
facility not be added to the NPL, because PGV's problems appeared to be primarily
Pnnitd on Recycled Paptr
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operational in nature resulting from intermittent air emissions rather than residual
contamination requiring a Superfund-type cleanup.
During a trip I.made to Hawaii in 1994, community members approached me and
asked that EPA address their continuing concerns about PGV's safety. They subsequently
followed up with written material. On a subsequent trip to Hilo to give a speech, I took the
time to meet with the Geothermal Alliance, including a member of your staff, State
employees responsible for geothermal oversight, and community members to hear various
points of view. I also took a tour of the facility. Upon my return to the regional office, and
after reviewing the State of Hawaii and EPA's regulatory oversight of PGV's operations, I
decided to form an EPA team comprised of staff from several EPA programs including
Underground Injection Control, Air Quality, Superrund and Chemical Emergency
Preparedness and Prevention to evaluate PGV's safety and potential impact on the
environment.
I asked Keith Takata, then Deputy Director of the Hazardous Waste Management
Division in Region 9, to serve as the team leader because as the Superrund Program Manager
in Region 9, he was and is responsible for CERCLA Section 105(d) petition assessments and
for overseeing hazardous material emergency planning and response throughout the Region.
Mr. Takata, having just completed the CERCLA preliminary assessment in 1993, was also
very familiar with PGV's H2S releases and related safety problems. Other Region 9 senior
managers have also been involved with PGV to the extent their regulatory responsibilities are
affected. Alexis Strauss, Acting Director of the Water Division, has the lead for all
compliance and permitting issues pertaining to the Underground Injection Control (U1C)
program.
The first step - in what has become known as the "fact finding" mission - EPA staff
visited the PGV plant, and met with community members, state and local officials. Attached
is a trip repon summarizing our meetings. This report also lists all of the State and local
officials we met with during the "fact finding" trip.
In February of 1995, after the EPA team returned to the office, we developed a
strateg). which included the following activities:
• determine whether the facility is in compliance and take corrective action as
needed;
review the adequacy of PGV's emergency response plan and coordination with
Hawaii County's hazardous material response plan;
ensure that the residents and interested community members are kept apprised
of our activities and have an opportunity to be involved;
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perfoim a technical evaluation of the mechanical integrity of the injection wells
and closure of several wells on PGV's site.
In April of 1995, we described this strategy in a letter to the Hawaii Department of
Health (DOH) and requested their comments. We asked DOH to discuss our proposed
strategy with the Department of Land and Natural Resources (DLNR) and the Department of
Business and Economic Development, and Tourism (DBEDT). We also sent copies of our
draft strategy and trip report to elected officials, the County of Hawaii, PGV and members of
the community. Since that time, we have been carrying out this strategy.
Compliance Status
We conducted a multi-media compliance inspection in February 1995. As a result of
this inspection, EPA determined there were no major violations. However, the Compliance
Inspection Report noted some violations and recommended several operational improvements
(copy attached). EPA's review of the air permit showed compliance problems including the
absence of some sampling and monitoring data, failure to submit certain reports and records,
and failure to have certain equipment in place. In reviewing the UIC permit, the report
identified several monitoring problems. The final report was not issued until March 1996
because PGV made extensive confidential business information (CBI) claims. After EPA
discussed these claims with PGV, the company agreed to remove most documents from its
list of those claimed as CBI. EPA issued the PGV report, redacting portions for which a
CBI claim was still outstanding. EPA's determination on the remaining documents claimed as
CBI should be issued soon.
The Compliance Inspection Report also recommended several operational
improvements. Two recommendations included in the air portion of the report were to: (1)
implement recommendations from previous investigations regarding drilling plans and the
Emergency Steam Relief Facility (ESRF); and (2) explore the possibility of combining Hawaii
DOH and PGV monitoring data into one program. Suggestions for improving the UIC permit
include modifying sampling and reporting procedures, and re-examining the permit to
determine which chemical parameters should be sampled. The report also recommended that
PGV document the basis for assumptions of flows entering the ESRF pond and assess the
sufficiency of the current bond for plugging and abandoning wells.
Notwithstanding the importance of PGVs compliance with the Clean Air Act and the
state-issued air permit, the UIC permit program is EPA's direct responsibility and a key
component of our strategy to ensure PGV's operational safety. Although Hawaii has issued,
under its own regulations, a state UIC permit to PGV, EPA has not delegated the UIC
program to Hawaii. Hawaii submitted its application for UIC primacy to EPA in--I984;
however, EPA was not able to delegate the program because the State did not meet the
minimum requirements. EPA's May 17, 1991 review of DOH's UIC regulations is enclosed.
As part of its new UIC primacy application to EPA, the State is currently rewriting their
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-4-
regulations to make them as stringent as the Federal regulations, and EPA will be reviewing
them shortly.
In April of this year, the'Hawaii DOH asked EPA via letter to "... proceed with the
issuance of the federal UIC permit for... PGV, and other major facilities in the State of
Hawaii that may be of concern." Further, the State's letter cited the large number of
regulated facilities in Hawaii (478 permits and 635 facilities), the limited resources available
at the State level, and EPA's legal obligation for regulating geothermal reinjection wells in
Hawaii as reasons for requesting EPA to assume direct responsibility for these permits. EPA
is now working with PGV to obtain the remaining pieces of information needed for the
application prior to proceeding with final analysis and issuance of a draft Federal UIC permit.
We expect to hold a public hearing in the Spring of 1997 and anticipate issuing the permit
within 90 days of this hearing.
Emergency Response Plan
Under the Emergency Planning and Community Right to Know Act and Section
112(r) of the Clean Air Act, EPA also has responsibility for working with communities and
facilities to prevent chemical accidents and improve emergency response capabilities. Given
the intermittent H2S emissions and related community and county agency concerns, EPA
agreed to conduct an independent review of PGV's Emergency Response Plan and Hawaii
County's Emergency Operations Plan. The purpose of our review was to evaluate the
adequacy of the facility's plan, and in particular, coordination of PGV's plan with the County
Plan. Hawaii County agencies responsible for hazardous material planning and preparedness,
including Fire, Police and Civil Defense, indicated to us that they strongly supported this
effort.
We formed a review team comprised of three outside technical experts, and EPA staff
with experience in hazardous material response planning and chemical safety audits. The
review team evaluated the PGV Emergency Response Plan, Hawaii County Emergency
Operations Plan (all hazards plan) and the Hawaii County Fire Department plan for
responding to emergencies at the PGV facility. In August 1996, the review team visited the
PGV facility and held two public meetings to allow the public an opportunity to ask questions
and make comments on these plans. The emergency response review team also met with
local officials, including the Director of Hawaii County Civil Defense, Deputy Chief of the
Hawaii County Fire Department, the Director of the County Planning Department, the Safety
Coordinator for the County Division of Industrial Safety, and local police and fire agencies.
The emergency response review team briefed these county officials on EPA's initial findings
and solicited suggestions for improving the interaction of the PGV and County plans. We
expect to issue a draft report of our findings and recommendations in early 1997, and a final
report shortly thereafter.
Community Involvement
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We have met with community groups, as well as State and local officials, during each
phase of this project to share information and solicit comments on PGV. In February of 1995
we held several public meetings to hear the concerns of community members. Last April, we
met with PGV, DOH, DLNR and DBEBT to modify PGV's mechanical integrity testing
(MIT) program. Afterwards, we and DOH met with representatives of Puna Malama Pono to
answer questions on the MIT program. During that trip, we also met representatives of
Hawaii Island Geothermal Alliance. In August of 1996, during the emergency response plan
review, the review team held two public meetings to hear community concerns and questions
about both plans.
We recognize that not everyone agrees with the amount of attention we have paid to
PGV. However, for reasons which I firmly support, we have paid more attention recently to
PGV than to other, similar facilities in California. First, many community members continue
to express their concerns to us about the safety and environmental compliance of PGV. The
recent H2S emissions exceeding permit limitations have heightened community concerns.
Moreover, air emissions and noise problems take on greater significance when there are
nearby residents - as is the case at PGV, where some residents live within a quarter mile of
the facility. In California, geothermal power plants are usually located a significant distance
from residential areas. Second, the geothermaJ industry in Hawaii is relatively new as
compared to similar facilities in California. In the past, EPA was more active in California as
its geothermal industry developed. During the 1980s, EPA conducted extensive UIC
inspections in California geothermal fields. Currently, EPA has a Memorandum of
Understanding (MOU) with the California Division of Oil and Gas and Geothermal Energy
Resources regarding the regulation of reinjection wells. Within California, the state agencies
that regulate geothermal energy production have a written agreement delineating
responsibilities. Third, there are significant differences between California and Hawaii in
geology, ground water quality and beneficial uses in the vicinity of geothermal power plants
that warrant greater regulatory oversight in Hawaii. In Hawaii, adjacent geothermal
exploration wells can produce very different power regimes. Therefore, conditions
encountered during exploration and production drilling are far more unpredictable than they
are in most California geothermal fields. In addition to this, PGV is located in a subdivision
unlike the geothermal power plants in California. Regarding ground water, PGV is located
over an Underground Source of Drinking Water (USDW) whereas most geothermal fields in
California do not have USDWs.
As part of EPA's efforts to respond to the issues raised in your letter to Administrator
Browner, EPA staff held a telephone conference call with George Steuer of your Honolulu
office on November 7. Mr. Steuer inquired about EPA's geothermal regulations in other
states. Nevada, Oregon, and Utah have delegated UIC programs, so we provide oversight, but
do not directly regulate geothermal injection wells in those states. A situation similar to
Hawaii':, exists in Alasl.a. There, EPA Region 10 has direct responsibility for geothermal
injection wells. EPA did not have to issue a UIC permit for this facility because the State of
Alaska incorporated Federal UIC permit conditions into its permit. We had been working on
this approach with DOH. However, DOH believes that a Federal UIC permit would be the
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-6-
most effective way in which EPA's concerns would be satisfactorily addressed and
expeditiously accomplished, as stated in their April 25, 1996 letter (enclosed).
We have also been criticized for not coordinating with Hawaii County. When EPA
first visited Puna in 1995, we offered to meet with any County Office or Agency concerned
with PGV. Although the Mayor was unable to meet with us during our "fact finding" trip in
February of 1995, we did meet with representatives of the Fire Department, Hawaii County
Civil Defense, and William Davis, Managing Director of Hawaii County. We also met with
the County's geothermal compliance coordinator. In subsequent trips, we have met with
Harry Kim, Director of Hawaii County Civil Defense, Edward Bumatay Deputy Chief of
Hawaii County Fire Department, Virginia Goldstein, Director of Hawaii County Planning
Department, and representatives of local fire and police departments. We plan to write a
letter to Mayor Yamashiro conveying the status of the project. Additionally, we will offer to
meet with him when we go to Hawaii for the UIC permit public meeting.
You have asked us to calculate EPA's costs to date for the various activities I have
described in this letter pertaining to PGV. EPA tracks the costs of each regulatory program;
however, with the exception of Superfund cleanup projects, we do not routinely charge
individual project accounts. Therefore, we cannot provide you complete and accurate cost
information for PGV. In addition, trips to PGV are often combined with other EPA business
to reduce travel costs. However, I understand the concerns you are raising and have asked
my staff to begin tracking their time, travel and other expenses associated with PGV to a
project-specific account. To date, we have spent approximately $25,000 in travel expenses
associated with PGV - this includes the travel costs incurred by outside experts during our
review of PGV's Emergency Response Plan.
During our November call, Mr. Steuer asked about the status of $4 million in Federal
funds appropriated for an Environmental Impact Study (EIS) of geothermal power in Hawaii
County. !n response to Mr. Steuer's inquiry, my staff investigated the status of the EIS, and
determined that the $4 million was appropriated to the U.S. Department of Energy (DOE) to
conduct the EIS. DOE subsequently published a withdrawal notice for the EIS project in the
Federal Register (May 17, 1994). EPA did not receive any of these funds, nor did EPA
review the EIS since DOE never completed it.
I believe that at the heart of the controversy surrounding PGV is a community,
especially the residents who live in close proximity to the facility, who, in the past, have felt
excluded from issues directly affecting their health and safety. EPA has listened to their
concerns as well as other community interests promoting geothermal power as a means to
achieve energy self sufficiency. We are sympathetic to the concerns raised by both groups
and hope that our involvement will resolve many of the issues surrounding PGV. However,
we also recognize that, in the long run, EPA cannot substitute its broad regulatory authority
and responsibility for local implementation. Ultimately, PGV, the community and local
agencies will decide how they can work together to improve the environment, public safety
and communication.
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I hope this letter provides you the information you have requested. Enclosed is
additional background information on PGV. My staff and I would be happy to meet with you
or your staff at any time to discuss EPA's involvement at the PGV facility or other
environmental issues affecting Hawaii. If we can be further assistance please call my
Congressional Liaison Officer, Sunny Nelson, at (415) 744-1562.
Yours,
Felicia Marcus
Regional Administrator
Enclosures
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LIST OF ENCLOSURES
Petition from Pele Defense Fund to EPA, August 20, 1992
EPA Letter & Trip Report to Hawaii Department of Health, April 7, 1995
EPA Report: Pnna Geothermal Venture Compliance Investigation. March 1996
Letter from U.S. Representative Patsy Mink to EPA, April 8, 1996
Letter from Hawaii Department of Health to EPA, April 25, 1996
EPA Fact Sheet: "Compliance Inspection Report Released for Puna Geothermal Venture",
May 1996
EPA Fact Sheet: "EPA toHold Community Meetings On Puna Emergency Response Plans"
July 1996
Letter from State Senator Andrew Levin to EPA Region 9, September 6, 1996
Letter from Hawaii County Planning Department, October 8, 1996
EPA Letter to Hawaii Department of Health, May 17, 1991, regarding EPA's review of the
State's UIC regulations
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APPENDIX M
Correspondence on January 2000 Release.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, CA 94105-3901
MAR 10 2000
Mr. Barry Mizuno
Owner's Representative
Puna Geothermal Venture
P.O. Box 30
Pahoa, HI 96778
Dear Mr. Mizuno:
As we are finalizing our report reviewing the emergency response plans for the Puna
Geothermal Venture (PGV) facility and the Hawaii County Emergency Operations Plan Hazmat
Annex, it has come to our attention that there was a loud steam release caused by a broken pipe
at PGV on Monday afternoon, January 31,2000.
As you know from our draft review report, there are a number of recommendations for
the PGV facility as well as for Hawaii County. The incident on January 31 and the response to it
indicates there is a need to improve PGV's means of emergency notification to emergency
response agencies. Verbal reports to EPA in February and a newspaper account in the Hawaii
Island Tribune Herald on February 2, seem to indicate that public calls to the Hawaii County fire
and police departments and the Hawaii County Civil Defense Agency occurred almost
instantaneously to the' jet-like noise" from PGV's broken pipe and the vibrating ground beneath
some nearby homes. PGV may want to consider emergency notification procedures that
immediately notify the county's emergency response agencies when there are upset conditions of
the type that would alert nearby neighbors by visual, auditory, olfactory and/or vibrational senses.
This emergency notification to the response agencies may be above and beyond the required
notifications under various permits or federal, state and local regulations. However, it would be
advantageous for the emergency response agencies to receive initial incident information from
the facility rather than from nearby neighbors. This would help alleviate any possible
misinformation to the emergency responders and the nearby residents inquiring about the
incident. This would also provide the emergency response agencies with direct and current
situation reports from the facility.
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It is EPA's understanding that during the broken pipe incident on January 31, the PGV
command post telephone line was quite busy. The emergency response agencies were not able to
make calls into PGV for first-hand reports of the incident. Based upon EPA's questions, Harry
Kim of the Hawaii County Civil Defense Agency reports he was able to make contact after about
four attempts. PGV may want to consider whether a dedicated, direct telephone line for the
response agencies (outgoing and incoming) or another means of immediate emergency
communication with the response agencies will help alleviate this barrier to immediate and
current information.
Thank you for your efforts to review PGV's emergency notification procedures to the
emergency response agencies and PGV's look at ways to make improvements.
Sincerely,
Keith Takata, Director
Superfund Division
cc: Hawaii Department of Health, Gary Gill
Hawaii County Civil Defense Agency, Harry Kim
Hawaii County Fire Department, Edward Bumatay
Hawaii County Police Department, Wayne Carvalho
U.S. EPA, Shannon FitzGerald
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„ ™* D ,rt
L2£Cv K n*, PH GEOTHERMALVENrUJRE
14-3860 Kapoho Pahoa Rd.
Pahoa. Hawaii 96778
Telephone (808) 965-6233
Facsimile (808) 965-7254
A -in -mnn HAWAII
April 12,2000
Mr. Keith Takata
Director Superfund Division
USEPA Region K
75 Hawthorne Street
San Francisco, CA 94105-3901
Dear Mr. Takata:
Thank you for your letter of March 10,2000. Your thoughts regarding possible improvements in
communicating with our neighbors are shared by PGV.
For your information, on February 18, Harry Kim of the County Civil Defense Agency graciously
accepted our invitation to visit our site to discuss the issue of improving communication of any
incidences of potential public concern. Our mission was solely to brainstorm ideas. Several
ideas resulted, which we are reviewing at this time. We fully realize that improved and timely
communication with the community will go a long way to alleviate any anxiety and fear when we
have an incident that could cause public concern.
PGV has taken a proactive posture in sharing information with our neighbors. We regularly meet
with community associations and other community groups to share information and to assist with
community projects. We also provide a quarterly newsletter to all neighbors, by mail or hand
delivery, to share timely information on our activities. Our latest edition is enclosed for your
reading enjoyment.
Our relationship with the community has improved and we constantly look for ways to make
things better. Likewise, we hope to have an open line of communication with your organization.
While we realize it may be easier to rely upon newspaper accounts, please feel free to call me at
any time to discuss my perspective.
Very truly yours,
Owner's
ref0412epa
A Hawaii Partnership
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APPENDIX N
Comment Letters to Draft Report
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Index of Comment Letters on the Draft Puna Emergency Response Report
Author
1. Bator, Bonnie
2. Carvalho, Wayne
3. Dean, Jack
4. Folena, Joyce & Gregory Smith
5. Folena, Joyce & Gregory Smith
6 Gertzweig, Gary'Dov'
7. Gill, Gary
8 Hedtke, Jane
9. Hyson, Michael & Adrian Barber
10 Jacobson, Julie
11 Melemai, Anakura
12 Olson, Jon
13 Peanut, Athena
14 Siracu&a, Rene
15 Stephens,Shelley
16 Stewart, Patricia
17. Szvetecz, Annie
18 Thomas, Donald
19. Zeissler, Rv. D.
Affiliation
Kurtistown, HI resident
Hawai'i County Police
Puna Geothermal Venture
Puna residents
Puna residents
The Earth Harmony Foundation
State of Hawai'i Department of
Health
Pahoa resident
Pahoa resident
Hawai'i County Council Member
Kea'au
Kingdom of Hawai'i
Pahoa resident
Friends of the
Red Road
Puna Outdoor Circle
Pahoa resident
Exodus Foundation
Hilo resident
Hilo resident
Leilani resident
The following letter arrived after the end of the public comment period.
20. Lopez-Mau, Lehua Hilo resident
Date
5/23/99
3/24/99
5/31/99
4/8/99
(21trs)
4/8/99
3/1/99
3/4/99
4/15/99
5/30/99
5/23/99
4/28/99
5/28/99
5/27/99
5/31/99
5/28/99
5/28/99
5/7/99
5/31/99
5/31/99
5/28/99
6/14/99
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23 May 1999
Mi. Michael Ardito
U.S. Environmental Protection Agency (EPA)
75 Hawthorne Street (SFD-1-2)
San Fransciso, California 94105
Re: Draft Puna Emergency Response Plan
Dear Sir:
Thank you, for the opportunity to respond to the Draft Puna Emergency Response Plan.
Regarding page 4 of the Draft Puna Emergency Response Plan Please obtain a copy of the
report paid for by the County of Hawaii that was unrevealed by then Mayor Inouye as a source of
information. Please contact Dr. Wilson Goddard, 6870 Frontage Rd., Lucerne, CA 95458-8504.
This report analyzes the Geothermal Blow Out of June 12-13, 1991. The Draft Puna
Emergency Response Plan referred to the Thomas, Whiting, Moore, and Milner Report. Dr. Goddard
is a strong supporter of geothermal energy and gives an excellent overview of Hawaii's geothermal
resource — which is much hotter, more corrosive, and also more toxic than other geothermal
resources. Thank you, for insuring that the Final Puna Emergency Response Plan includes Dr.
Goddard's report.
Under a. Facility Description, on page 17, the Draft Puna Emergency Response Plan does not
address the other chemical components of geothermal fluids/gases. The effect of the combined
chemicals of hydrogen sulfide, cadmium, mercury, radon, and etc. are a Molotov Cocktail of toxins
that continue to affect the health and safety of Puna's populous. The Final Emergency Response Plan,
in all fairness should address the other toxic chemicals besides hydrogen sulfide and investigate the
combination of these poisonous chemicals.
On page 49 of the Draft Puna Emergency Response Plan, recommendations do not adequately
address the need for rightful monitoring of geothermal hazards, especially the main component of
geothermal gases — hydrogen sulfide. The fact that hydrogen sulfide is heavier than air, the more
sensible goal, would be to locate monitors at ground level to have a true and accurate reading —
thereby assuring protection of the health of residents in the many surrounding subdivisions.
Please modify the Draft Puna Emergency Response Plan to insure the health and well-being of
the residents whom reside in the geothermal resource zone by mandating that the hydrogen sulfide
monitors are located at ground level.
Lastly, on page 38,5.5.10 of the Draft Puna Emergency Response Plan, it finds that The State
Civil Defense Director, as well as the current Mayor of Hawaii, has overstepped the County of Hawaii
Civil Defense Director Mr. Harry Kim a sincere and truthful man whom honestly cares
about the health and welfare of the people of Puna. Mr. Kim is a just and honorable man whose
opinion on safety should be valued at the utmost!
Thank you, again for the occasion to comment oKthe Draft Puna Emergency Response Plan.
Sincerely, <
V^e-Ywo
Bonnie Bator
-------
Wayne G. Carvalho
Mice CM
. Correa
(ttnunig 0f plafo
POLICE DEPARTMENT
349 Kapiolani Street • Kilo, Hawaii 96720-3998
(808)935-3311 • Fax (80S> 961-2702
March 24, 1999
Mr. Mike Ardito
Project Manager
U.S. EPA
75 Hawthorne Street
San Francisco, CA 94105
Dear Mr. Ardito:
Thank you for the opportunity to comment on the Hawai'i County
Emergency Operations Plan. We agree that it needs to be
revised to address the shortcomings you mentioned, as well as
to include specific joint assessment and reaction response
plans for the necessary responding agencies to include their
activities.
We recommend that these plans include mandatory annual table
top exercises to insure interagency coordination and
preparedness.
Finally, we agree that PGV should clarify what appropriate
clothing and protective equipment its personnel, as well as
outside responding agencies such as police, will use for
different response activities.
Should you require further information, please contact Major
David Kawauchi of our East Hawaii Field Operations Bureau at
(808)961-2345.
Sincerely,
WAYNE G. CARVALHO
POLICE CHIEF
DAK:Ik
-------
Post Office Box 30 GrCFriERVAL VLMTJRE
14-3860 Kapoho Pahoa Rd.
Pahoa. Hawaii 96778
Telephone (808) 965-6233
Facsimile (808) 965-7254
May 31,1999
Mr. Michael Aidito
Hawaii State Project Officer, Superfund Programs
United States Environmental Protection Agency
75 Hawthorne Street
San Francisco, CA 94105-3901
Dear Mr. Ardito:
Enclosed please find comments from Puna Geothermal Venture ("PGV") regarding the 2/10/99
draft copy of the Environmental Protection Agency's ("EPA's") Report on the Reviw of
Hawai 'i County Emergency Operations Plan and Puna Geothermal Venture Emergency.
Response Plan ("Report"). Many of these comments have been discussed with EPA in the past.
Please include these previous comments, as may be pertinent, as part of this response.
If there are any questions or a need for clarification, then please do not hesitate to call.
Best Regards,
r
}
Jack A. Dean
Vice President and General Manager
cc: Jim Willey
Bruce Davis
Peggy Stover-Catha
Barry Mizuno
Mike Kaleikini
r>jadicones.out
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Mi.MikeArdito
5/31/99
Page: 2
PGV's comments are as follows:
General Comments:
1. The stated overall objective of the task team was to review the emergency response plans,
with the longer-term objective of preventing chemical accidents and improve emergency
response capabilities. With regard to PGV, it should be clear that the emergency
prevention and response measures for the facility are contained in several facility plans,
systems and procedures. PGV personnel advised the task team that the ERP was
developed to meet the objectives and requirements of the County Geothermal Resource
Permit and that other related plans or procedures that may be required by applicable
regulations (OSHA for example), may not be incorporated in the ERP. No such
incorporation is starutorily required.
2. The task team was also advised that PGV has always been willing to participate in
County local emergency response committee (LEPC) efforts, which state law requires
counties to coordinate. This is true during geotherma] plant operations, as well as during
drilling activities (drilling and exploration). PGV remains willing and able to participate
and is currently active with the County LEPC and Big Island Safety Association.
3. The Report's statement that "the PGV Emergency Response Plan does not address any.
coordination issues..." [bold & underline added] is simply not true.
4. The Report states that a "major release of hydrogen sulfide from the facility is the
principal threat to the community". Yet, the Report fails to describe what a "major
release" is and the likelihood, if any, of it occurring at PGV.
5.. The Report mis-characterizes PGV's historical attempts to reach out to, and communicate
with, the facilities neighbors and area residents. As was explained to the EPA team,
these efforts were largely successful in educating the public. In a small portion of the
public, however, these efforts were met with bodily threats, verbal abuse, and extensive
frivolous lawsuits against PGV. PGV determined that no amount of communication was
likely to persuade these small groups about the benefits PGV brings to the Big Island or
PGV's ability to handle emergency events. Nonetheless, PGV continues with its efforts
to communicate with residents on the Big Island.
t.\jad\corres out\epa\990531 .wpd
-------
Mr. Mike Ardito
5/31/99
Page: 3
PGV has a 24-hour telephone line for citizen involvement, inquiries and comments. PGV
has a local member in the community who regularly speaks with the local citizens on
PGV activities and responds, on behalf of PGV to the 24-hour call comments or inquiries.
PGV operators in the control room take calls from local neighbors to answer questions on
plant activities and PGV personnel advise citizens of certain activities by the newspaper
and in many cases in person. Additionally, PGV conducts regular tours of the facility and
many Hawaii citizens have visited the site; 1,200 visitors toured PGV in 1998.
To state that PGV has an historical, and continuing, reluctance to communicate and
cooperate with its neighbors is simply not true.
Comments on Specific Report Sections
A. 1-3 Community Concerns:
The focus of an emergency response plan is to address emergency events that may occur
at a given facility. This paragraph which includes reference to chronic health impacts due
to hazardous substances is not relevant to the task team's stated scope in section 1.2. The
task team should focus report elements on those concerns and issues solely related to
emergency level events.
B. Section 1.S Background:
The last sentence of the first paragraph implies that there was a release of hydrogen
sulfide, at sufficiently high concentration levels, that posed an immediate danger to the
facility employees, the public, and the environment. This is an incorrect implication.
The entire second paragraph is highly misleading and deliberately implies that PGV has
inadequate control of its process, especially with statements such as, "the quantities have
been measurable and have occurred throughout the years since 1991." PGV has had
unanticipated release events on certain occasions and those have been reported based on
permit requirements and, when required, under SARA Title ni and CERCLA. PGV also
notifies agencies, as a courtesy, not a requirement, when there is a momentary release
which might be sensed/smelled. This notification enables agencies to address phone
inquiries, if any, from members of the community.
The first sentence of the third paragraph is incorrect.
t:\jad\cones.oui\epa\990531 .wpd
J
-------
Mr. Mike Ardiio
5/31/99
Page 4
Tabltli
How does this table relate to the scope of the independent review? This table is not
relative to that scope.
D. Tahle 2«
This table summarizes a litany of public comments that are wholly unrelated to any
review of the emergency response plans for PGV or Hawaii County. Indeed, EPA's
Diana Young, at the public meetings in Pahoa and Hilo, specifically noted that comments
unrelated to the emergency response would not be considered by EPA in connection with
the ERP review. Accordingly, listing comments unrelated to the emergency response
plans is irrelevant, goes beyond the stated objectives of the EPA plan, and only serves to
unnecessarily focus attention on matters unrelated to emergency response.
In particular PGV believes the following questions and comments should be deleted from
Table 2:
Chemical Hazards - 2,3,4,5,6,7,8, and 11
Public Health-1,2,4,5,6,7, 8,14,15,16,17,18, and 19
Facility Design and Safety - 1,7,9, and 11
Process and Environmental Monitoring - 1 and 4 •
Alert and Notification Procedures - 11
Evacuation Plans - 7
Fiscal Concerns -1,2, and 3
Other Concerns - 1,3,4,5,6,7, and 8
E. Section 6.1 - General;
(i) The first sentence in the first paragraph is incomplete and misleading. For
completeness, the sentence should read, "The PGV Emergency Response
Plan and other facility documents describe all appropriate types of
incidents and who will be contacted during an incident.*'
(ii) PGV has designated an individual on every shift who is responsible for
notifying agencies. Operations personnel on every shift are fully
qualified to take initial immediate action to minimize plant operation
events and are responsible for immediate reporting in accordance with
permits and regulatory requirements. Additionally, the operations
environmental and safety coordinator assists with incident command as
specified in the responsibility section of the ERP Table 3-2.
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Mr. Mike Ardito
5/31/99
Page: 5
(Hi) The elements alleged to be missing, regarding OSHA requirements, are
addressed. PGV suggests that EPA discuss the results of its letter to
HIOSH and then remove the last paragraph of this section.
F. Sfptinn fi.2.1
Procedures for key personnel to operate or shut down critical equipment are
addressed in the facility Operations and Maintenance procedures section 7.0.
Additionally, section 6.4 of the ERP references these procedures and provides that
personnel will be trained in these and other relevant and associated procedures.
This is cross-referenced in the ERP and personnel are fully trained in the relevant
procedures and refresher training is ongoing.
PGV suggests that EPA discuss the results of its letter to HIOSH and then remove
this section.
G. Section 6.2.2:
The facility ERP refers to at least three people being trained on first aid. In
addition to this, PGV has qualified all operations (O&M) personnel in CPR and
first aid and all are required to respond, as needed, to provide first aid level
response and/or CPR. Medical assistance will be sought from the County
ambulance service. First aid response and rescue is addressed in the safety
training and rescue plans. Additionally, training records exist to demonstrate such
is conducted.
Such training is referenced in the ERP on page 38 after item 6.4.
PGV suggests that EPA discuss the results of its letter to HIOSH and then remove
this section.
H. Section 6.3.1;
Again, it should be pointed out that the Hazardous Waste Operations and
Emergency Response program is fully the responsibility of each "employer" to
protect its employees if they conduct certain functions covered by the standard. If
no response, as defined by the standard is required by outside panics, then this
standard, is not relevant to the comments made. PGV's program does-address the
responded s roles.
i.\jad\cones.out\epa\990531 .wpd
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Mr. Mike Aidito
5/31/99
Page: 6
PGV takes full responsibility and is the incident command for all emergency level
release responses under the Hazwoper standard since its PGV personnel who will
respond to the release and, therefore, are subject to the standard. At times, PGV
may seek the assistance of certain outside contractors who will first go through a
contractor orientation program that is included in the safety manual. If a medical
evacuation is necessary, PGV will rely on the outside medical team and/or
ambulance service. .
The fire department's response to a fire situation for employee protection falls
with the County. PGV has and will continue to make information available to the
county and the fire department and the local emergency planning committee
regarding chemicals on site, so appropriate planning and protection of its
employees may be addressed.
1) With regard to the lack of clarity to local responder responsibility, PGV
will work with the local fire department and ambulance service to assure
roles are clear. This is always a relevant suggestion.
I. ftprfinn 6.3.3:
The EAP, which is used by PGV personnel, identifies when calls to various
agencies will occur for chemical releases based on reponable quantity level
requirements. Table 3-1 in the ERP indicates reportable quantity release levels
and includes notification telephone numbers and contacts. Personnel are trained
on release scenarios included in the plan, participate in drills, understand the
facility permits requiring reporting if a permit level is exceeded, and as stated
above, PGV has an internal communication requirement (company imposed, not
regulatory) to advise the County Civil Defense, State DOH, etc. of release events
detected at an hourly average of 5 ppb on external alarms. PGV operations
personnel are also professional and understand the interest in protecting the
community. PGV would always notify the agencies if a significant event were to
occur.
Additionally the ERP addresses scenarios that could occur (see Appendix H,
Attachment 1, Attachment 2, Attachment 3, section 8 and the Hazwoper
document). It should be noted that the percent of hydrogen sulfide gas in the
geothermal fluids/steam has decreased well below those used for the model. PGV
will however, continue with use of the original PPM number since drilling of new
wells may find hydrogen sulfide gas levels similar to the model's numbers.
t AjadVeorres out\epa\990531 .wpd
-------
Mr. Mike Ardito
5/31/99
Pagr: 7
With regard to sufficient time for community notifications, none of the incidents,
except for KS-8 in June 1992, resulted in public evacuation. The limited public
evacuation (only immediate area) was determined using a very low H2S criteria,
far less than the established OSHA levels. EPA's team should refer to the report
conducted by the State lexicologist Barbara Brooks, review the models prepared
by an outside consultant for PGV, and then determine if most of the events, in
fact, presented an evacuation scenario. The task team should not unnecessarily
alarm the public by indicating that any exposure is a hazard when, in fact, such is
not the case. There must be appropriate professional judgement by the qualified
personnel as to when the public should be evacuated, if there is an emergency
level release of any chemical from any industrial facility. Facilities across the
United States do not just evacuate people any time there is some level of a release.
The second sentence of the second paragraph is incorrect. Please explain why
"PGV's release history does not support this statement."
The last sentence of the second paragraph is hearsay and has nothing to do with
the topic of the paragraph.
J. Section 6.3.S:
PGV has conducted a thorough process hazards analysis for the facility. PGV has
identified all emergency scenarios that could occur at the facility. During drilling
activities, staff conducted "white board" "what if brainstorming discussion on
drilling activities to develop plans, procedures and control systems. Interviews
with drilling personnel would have revealed such information. Additionally, after
completion of a well, members of the drill team and 'construction team conducted
additional hazop/"what-if type discussions. Such activities translated into
wellhead construction enhancements and the need for standby equipment, etc.
Additionally, hazard analysisfwhat if analysis was conducted prior to facility
startup.
The statements in 6.3.5 should be deleted or rewritten. A thorough process
hazards analysis for the entire facility ("what if and prevention actions) have
been addressed. Additionally, many of the systems and procedures have been
reviewed by outside agency personnel. The pentane event is covered in the ERP
and this has been provided to the Fire Department. Note the fire section
discussion in Section 8 of PGV's ERP.
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-------
Mr. Mike Ardito
5/31/99
Page: 8
Potential scenarios have been determined for the entire site and controls and plans
have been implemented.
PGV will do a follow-up review of its PHA with outside responders.
K. S«»rf inn 6.3.6;
This finding is in error. PGV emergency response plan notes that all employees
on site in the O&M group will be trained as first aid responders and in CPR and
they will be re-trained annually. Note Section 6 of the ERP, page 38. PGV
expects all personnel to be responders for First Aid/CPR. Note general response
in Section 6, of the ERP, page 51. Note 1910.120 addresses employer
responsibility to protect its personnel from potential exposures during certain
response activities. PGV has fully met this OSHA condition. This OSHA
standard does not require PGV or any other like entity to coordinate with outside
medical services if such services are not asked to enter an area of concern. PGV's
site personnel are trained to be the responders: we have a rescue team and trained
first aiders. The OSHA standard referenced has been fully met. The standard
referenced is not appropriate to the suggestion desired and should be deleted.
All potential exposure issues for PGV responders are fully addressed in PGV's
many programs. PGV suggests that EPA discuss the results of its letter to HIOSH
and then remove this section.
Finally, PGV provides chemical data each year to the County agencies for local
coordination and their planning to protect it responding medical, fire or other
personnel. PGV is always willing to provide more information, as requested.
Also, Section 4.1 of the ERP, lists the hospital facility.
L. Section 6.3.9;
PGV suggests that EPA discuss the results of its letter to HIOSH and then remove
this section.
M. Section 6.3.10;
The PGV facility operates with a true "safety culture" Every employee on the site
has the authority and right to stop a job or task if such is deemed unsafe. PGV
does not rely solely on the safety officer. Additionally, internal alarms provide
early warning throughout the site to reduce the chance of any employee entering a
f\jad\corres out\epa\99053 1 .wpd
e
-------
Mr. Mike Ardito
5/31/99
Page: 9
potential IDLH area. During a "response event" for which the standard reference
is applicable, monitoring equipment is used to assure the level of the hazardous
material is evaluated. However, personnel entering the area wear appropriate
equipment when conducting a "response" to release events until the area is
deemed safe. The safety manual references the safety person's role,
responsibilities and authority and is cross-referenced in the Hazwoper program.
The recommendation is not applicable since the authority issue is addressed.
N. Serf inn fi.3.13;
All temporary employees at PGV are H2S trained, briefed on hazards and PPE, as
well as the duties each is to perform. The recommendation is not necessary since
this is addressed by reference in the Hazwoper program, (i.e., reference to the
safety manual).
O. Serf inn fi.3.12:
The requirement of OSHA under 1910.120(q)(10) is being fully met by PGV.
This recommendation should be dropped. The team did not evaluate all of the
programs to fully understand the detail and depth of its programs. PGV has a
written personal protection equipment program that is included in the safety
manual. PGV also trains on response events and the PPE for personnel to wear.
The safety manual is cross-referenced in the Hazwoper program and the ERP.
The effectiveness of such is also evaluated after a response activity.
P. Section 7:
Section 1.1 states the purpose of the EPA project "was to provide an independent
evaluation of emergency response plans...." Some of Section 7 addresses issues
beyond the review of the emergency response plans.
t.\jad\corrcs oui\epa\990531 .wpd
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Joyce Alberta Jolena
Gregory Toad Smith
fcefer:
v,aptain ~ale lergerstrom
Kona Ploice Lepartment
74-5221 Queen Kaahuinanu Hwy
Kailua Kona, Hi 96740
phone 808.J26 4211
Mike Ardito
Project Manager ~,¥L> 1 t
Environmental Protection *aency
75 Hawthorne street
^an Fransisco, California 94105
phone 415 744 2528
jiear Hike Ardito,
Please contact uaptdXn i/ale ^-ergerstiom at the aboVe phone number as v.e
are very concerned with tne past and exittin^, tiaifice safety proD~ems
associated with evacuation v,f Puna Makai, seaside, and middle Puna areas
in the event of a .blow Out abain at PGV.
Captain Fergerstron. was in Puna Police at the time oi the 1991 biow out
and uould be able to inli^hten eveiyone aoout the difiici.ltits he and
his. men experienced in attemptir,0 to contact everyone in the area
the moining aftei the blowout began. "TH^i C,OUA~&
-------
Joyce Alberta i-olena
Gregory lodti i—ith
Kike Aral to
iroject Manager £>FI> 1 2
Environmental irotection Agency,
75 Hawthorne street
.An Iraasisco California 94105
lear Kike Ardito:
Thank you'-for your continueing efforts and assistances to us in the
Puna District.
•*e are uow requesting froa: your Office a series of Meetings including^
Public Meeting with the Inited states Geological survey Team Kembers
at Volcanos J.aiional Park in older to furtner the information
and comaunication vith ti.e coiununity concerning the Volcanic and oeismic
conditions heie in the Lilauea East nift Zone in the vicinity of PGV.
Ion ^.wanson, scientist in charge at Vojicanos Park expressed a<>interest
in- svcl. E meeting with the coaai.ui.ity. of course, such otfte and County
Department and Agency people sn.-uld also be present in aciition to PGV staff.
It is of uUost concern to us Jiere as a coiuuunity at large and as
indiviiial itbicentE, th«+ ve be lold of the leality of -re interractior.
of the Geologic C'oj:d:tio;.b that are now piesent in the
iilauea iast i\ift Zone and surroujCiu^, treas now peopled by Vrriou: and n.3ny
subdivisions.
fee ttlieve thes>e public Keetings aust be recorded foi futu_e leference by
Community Ke^bers and appreciate your pion.pt attention to our reuuests ET.
j.ters.
ar.d
fce alto state we n< ed ioie public Keetines witn yovt Lffic6/
Inviionraental Protection Aeency in order to effectively address the ^
approppriate coaiments aiade by you in >our iuna 2nertency Kesponse Plans
Iraft Report.
Thank you foi your many assistance to us and we aie coj tinvein. to be , c:
concerned for our safety and well being in ielation to PGV»s activity.
Saletjr
Peace love and
Joyce Albezta foleua
iiregory Xodc ^...
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03/01/99 12:45:35 AM
To: ardito.michael
cc:
Subject: < no subject >
Dear Puna Project Manager Mike Ardito and EPA.
I am writing in response to your invitation for public comment regarding the
Puna-Geothermal investigation
As a part-time resident of the area, and long time advocate of sustainable
resources, I urge you and your staff to consider the shut-down of the
geothermal plant. The fact that you are considering emergency
operations for an energy producing plant is clear evidence that a
larger perspective needs to be seen when in fact, alternative energy
sources such as Solar, Wind. Free energy (perpetual motion), and even tidal
energies are far safer, less costly, and non-dispruptive to the environment.
The Geothermal plant emits toxic chemicals and changes the dynamics of a
very sensitive ecological area no company has a right to dig 4,000 feet
into a delicate volcano and force pressure and airborn chemicals into a
closed natural chamber!!!!!
On the other hand. Solar energy is abundant, available and to be
encouraged....
.-
I learned through EPA sources that a Wind Energy System that was built on
the big island was shut down to create a demand for energy and the
introduction of dangerous geothermal plants.
As I understand geothermal is not dangerous and effective in
areas where there is no volcanic activity! II •
Many miles of electric wire and unneccesary wooden poles were introduced to
carry this energy to hotels, disrupting the ecosystem. when the hotels
on the other side of the island could implement solar'and some are begining
this process.
PLEASE, PLEASE Think of the children in the area who at times breath
the released gasses....and the wildlife, and the danger to fire, the runnoff
going to the Puna Pu'ala 'a pools where people come from miles to relax and
become healthy in the ancient Hawaiian tradition the sounds of
the released gases in the night, the effect on every water catchment
tank...when Hydrogen sufide rains In the bathwater, in the
dishes We bought our house because we wanted to drink water from the
rain, but now no one the precious water from the rains..because it may
-------
contain chemicals from the geotherma!
Please, Please. Shannon Fitzgerald has lists of complaints from families of
the area The time is now for solar etc.
Your resources could be better used in assisting companies through tax
benfits and other incentives to invest in Solar and implementing a phase out
of the Puna Geothermal project
Thank you for this opportunity to express myself. I have sent these
comments to the U.S. Department of Energy and received a comment that told
me a second plant was closed down..but could not give me the reasons...It
would be interesting why this other plant was closed down
Mike,I am a founder of an Environmental Organization: The Earth Harmony
Foundation...and if I can be of any help in assisting in creating
alternative sources for energy, please contact me.
Mahalo,
Gary 'Dov' Gertzweig
Vice President. The Earth Harmony Foundation
-att1.htm
-------
03/04/99 04:31:51 AM
To: ardito.michael
cc:
Subject:
Dear Puna Project Manager Mike Ardito and EPA....
I am writing in response to your invitation for public comment regarding the
Puna-Geothermal investigation
As a part-time resident of the area, and long time advocate of sustainable
resources, I urge you and your staff to consider the shut-down of the
geothermal plant. The fact that you are considering emergency
operations for an energy producing plant is clear evidence that a
larger perspective needs to be seen when in fact, alternative energy
sources such as Solar, Wind, Free energy (perpetual motion), and even tidal
energies are far safer, less costly, and non-dispruptive to the environment.
The Geothermal plant emits toxic chemicals and changes the dynamics of a
very sensitive ecological area no company has a right to dig 4,000 feet
into a delicate volcano and force pressure and airborn chemicals into a
closed natural chamber!!!!!
On the other hand. Solar energy is abundant, available and to be
encouraged....
*•
I learned through EPA sources that a Wind Energy System that was built on
the big island was shut down to create a demand for energy and the
introduction of dangerous geothermal plants.
As I understand geothermal is not dangerous and effective in
areas where there is no volcanic activity!!!
Many miles of electric wire and unneccesary wooden poles were introduced to
carry this energy to hotels, disrupting the ecosystem when the hotels
on the other side of the island could implement solar and some are begining
this process.
PLEASE, PLEASE .Think of the children in the area who at times breath
the released gasses....and the wildlife, and the danger to fire, the runnoff
going to the Puna Pu'ala 'a pools where people come from miles to relax and
become healthy in the ancient Hawaiian tradition the sounds of
the released gases in the night, the effect on every water catchment
tank...when Hydrogen sufide rains.......ln the bathwater, in the
dishes We bought our house because we wanted to drink water from the
-------
rain, but now no one the precious water from the rains..because it may
contain chemicals from the geothermal
Please. Please, Shannon Fitzgerald has lists of complaints from families of
the area..... The time is now for solar etc.
Your resources could be better used in assisting companies through tax
benfits and other incentives to invest in Solar and implementing a phase out
of the Puna Geothermal project
Thank you for this opportunity to express myself. I have sent these
comments to the U.S. Department of Energy and received a comment that told
me a second plant was closed down..but could not give me the reasons...It
would be interesting why this other plant was closed down
Mike,I am a founder of an Environmental Organization: The Earth Harmony
Foundation...and if I can be of any help in assisting in creating
alternative sources for energy, please contact me.
Mahalo,
Gary 'Dov' Gertzweig
Vice President. The Earth Harmony Foundation
-att1.htm
-------
BENJAMIN J CAVETANO
GOVERNOR OF HAWAII
STATE OF HAWAII
DEPARTMENT OF HEALTH
P.O. BOX 3378
HONOLULU. HAWAII 96801
April 15, 1999
BRUCE 6 ANDERSON. Pti D. M.PH
DIRECTOR OF HEA.TH
In reply ptonc refer to
File
99-033/epo
Mr. Mike Ardito (SFD-1-2)
U. S. Environmental Protection
Agency, Region 9
75 Hawthorne Street
San Francisco, California 94105
Dear Mr.
Subject:
Draft Report for Puna Emergency Response Plans
Thank you for allowing us to review and comment on the subject
Plan. We do not have any comments to offer at this time.
Sincerely,
ELL
Deputy Director for
Environmental Health
-------
ICCZi ON IH/I1J 6Z:8T NOR 66/TC/SO
May 30,
£F£rtS2S*-l Protection A9«ncy
7 5 Jjft*" t"**^^™ ••*• •* _ _ _
T am writing my testimony at the last
x OM WAAI-A»»«J »»j . |.j,~ library* *** ••• *•«"•"—•—
I did not review the P1" »*1™BJ1 £ take my.testimony and
any specific points. I had PJa^° ;°stions J had posed to see
try to find answers to all of tne ques apologizing
ifythey had been jf^"?dfarfll^g/school work, health and family
for not^doing it l^^™1^!.! Day, a Federal holiday.
>: attentive to
ongoing ISUenSSonVfforts in the future.
I attend . Hawaii cm.tyL~.lk "^^"^plln^1""
field hazard exQrcises. Hawaii County must strongly ask for
funds to do HASMAT excercises. My concern that the County and
State agencies cannot or will not budget enough money for
implementation of the plan recommendations, w^ich will become
piecemeal. I left the meeting convinced that pie County and
State are not financially committed to be ready for the next
geothermal accident. The granting of the GRP was based on a
criteria (12-6), one of which stated that the. proposed activities
"would not unreasonably burden public agencies to provide
...police and fire protection." Obviously, this has not been
the case, and mitigation of the unreasonable effects are out
of reach financially. The solution would be to require the
permittee to bear the costs.
I am very thankful to the EPA and the State and County
individuals who worked on this document. I'm pure many, many
hours were spent on development. It was a very worthwhile project
from a health and safety standpoint, for all stakeholders. It
is sure to be an improvement over what we had, provided the
plan's recommendations are funded.
The true test will be when there is a seriousj accident.
Respectfully submitted;
Hedtke
-------
May 31, 1999
FAX COVERPAGE
TO: Michael Ardito ••
US. Environmental Protection Agency'
75 Hawethorne st. •
San Francisco, CA. ;94105
RE: Emergency Response Plan for the Puna Geothermal Venture
Testimony on Draft plan.
Page 1 of 2.
FROM: Jane Hedtke
OS/31/99 MON 16:27 [TA/RX NO 7232J
-------
Michael T. Hyson, Ph.D.
tt^u fal*
May 23,1999
Mr. Michael Ardito
Region 9
United States Environmental Protection Agency
75 Hawthorne Street
San Francisco, California 94105-3901
Dear Mr. Ardito:
In response to the Emergency response Plan Review Team's Review, as submitted per
your good self, it is our observation, and respectfully request that the community be
involved at all levels inclusive of conception, planning and implementation, or any other
aspects of Emergency Response Plan procedures outlined or contemplated in the
Emergency Response Plan Review Team Report, now, and in the future.
Please respond in writing forthwith to:
a) Receipt of this demand
b) Further developments in regard to these matters.
On a personal note, please be assured of our continued mahalos and our aloha
Ours sincerely in the Spirit of Aloha,
Michael T. Hyson, Ph.D.
Adrian-Barber
{p.p. M. Hyson)
-------
YiTT TC lArvMJcma ^fiPat vi:>^ PHONE: 961-8263
JULIE JACOBSON /Lftfc&l FAX: 961-8912
Council Member
COUNTY COUNCIL
County of Hawaii
Hawaii County Building
25 Aupuai Street
Htlo. Hawaii 96720
April 28,1999
Mr. Mike Ardito
U.S. Environmental Protection Agency
Region IX
75 Hawthorne Street (SFD-1-2)
San Francisco, CA 94105
Dear Mr. Ardito:
Thank you for the opportunity to comment on your draft report on the Puna
Emergency Response Plans. I applaud your objective point of view in examining
the issues and players that are central to your report. I feel that your
recommendations are valid. Given the unique factors we have in Hawai'i County,
a timetable for specific formulation and compliance to health and safety rules
must be addressed. As your own report clearly demonstrates, the current
administration led by Mayor Yamashiro does not have any demonstrable will to
formulate, implement or enforce basic safety rules concerning geothermal
development At one time the Mayor was legal counsel for PGV. He is also
administrator of the county's civil defense program. Meanwhile, residents are
denied basic health and safety protections. In hopes of honoring my constituents'
needs, I offer the following suggestions to modify and focus your
recommendations. I have related them to the pagination and organization of your
February 10,1999, draft report
Page 4
You cite the Richard Thomas, Dick Whiting, James Moore and Duey Milner
Report to Mayor Inouye as a source of information. I suggest that you look at the
report paid for by our county and suppressed by then-Mayor Inouye for a more
realistic and substantive analysis of events surrounding the June 12-13, 1991,
uncontrolled release of toxic well substances. Dr. Wilson Goddard prepared this
report and it is available from him at 6870 Frontage Road, Lucerne, California,
9S4S8-8504 (or if this is not possible, call me and I will try to acquire a copy).
His work is nationally recognized. He is a great believer in the potential of
geothermal energy, and he works in the geothermal industry, so his findings
District 6 - Upper Puna. Ka'u & South Kona
-------
EPA HAWAI'I
April 28.1999. COUNTY COUNCIL
Page Two
would be creditable. You will find that he states our resource is hotter and dirtier than
anywhere on the planet He also indicates that earthquakes, humidity and saltwater
corrosion all play a part in geothermal management *
Page 17
The full descriptive nature of the chemical components (such as cadmium, mercury,
radon etc.) is lacking under (a.) Facility Description. A full analysis of chemicals
released by PGV could be found in materials that were supplied by them at the time of
their request for more injection wells to the EPA. Ironically, the EPA granted permits for
more wells than Puna Geothermal Venture asked for.
Page 29, Section 5.3.5 Annex M
This section should be complete and up to date with information supplied by independent
authorities unrelated to and financially independent from PGV's or the Mayor's
influence. Without such factual information untempered by financial or political
influences, any emergency plan will be useless. The omission of this data is not an
innocent oversight.
Page 37, Recommendation (b)
Current monitoring plans and devices do not adequately measure H2S (hydrogen sulfide)
concentrations at ground level. This gas is heavier than air. To obtain dangerous
readings at the-height of these monitors (ten feet or so), ground levels must approach
toxic dose levels. All non-condensable gases and heavy metals must be monitored. The
levels are an indication of the relative danger surrounding residents face. They breathe
the air twenty-four hours a day. It is thought the H2S acts in a cumulative fashion to
trigger latent respiratory disorders such as asthma, bronchitis or emphysema.
Page 38, Section 5.5.10
As 5.5.10 Finding indicates, Hawai'i county civil defense director, Harry Kim, was
bypassed by the Mayor and the state civil defense director when it came time to approve
this inadequate plan. Harry Kim is an honorable man who refuses to cave in to politics.
Page 40-41,6.3 Hazardous Waste Operations and Emergency Response
Given the past failures of PGV to notify residents or civil defense officials, fire or police
agencies, or to properly manage releases of toxic materials into the surrounding
residential subdivision, PGV should be relieved of reporting responsibilities, and they
should pay for onsite monitoring and adequate responses to toxic releases. They have
proven themselves unwilling, unable and apathetic to taking care of emissions from their
facility. They must be held accountable to assist in the control of polluting events and the
subsequent cleanups that have yet to be done.
-------
EPA HAWAI'I
Apri. 28.1999 COUNTY COUNCIL
Page Three
Page 45,6.3.10 Finding
The need for emergency access to lands controlled by private contractors for public
safety has been restricted in contracts drafted by Mayor Yamashiro. For example, the
Waste Management Inc. contract for Hawaii's newest landfill does not allow access by
county agencies (police or fire) without prior written approval. Your recommendation is
sound.
Page 49
Your recommendations fail to clearly mandate the needed methodology for accurate
monitoring of all geothermal hazards. As stated under my response to Recommendation
(b) on Page 37, current monitoring plans and devices do not adequately measure H2S
concentrations at ground level.
Page 50,7.2.6 Finding
Two PGV employees on this team could easily lead to conflicts of interest. Employees
are always subject to pressures from their employers. Your recommendations could
include provisions to prevent such conflicts of interest.
Appendix H
This appendix contains further information which reveals a continuing secrecy. To this
date PGV has been unwilling to reveal anything of substance to public officials interested
in formulating viable Emergency Response Plans. PGV had three years to produce
information they said could be produced in "several weeks." The EPA must have full
access to PGV documents.
As an elected representative of the people of this island and a citizen who has followed
geothermal issues for over ten years, I applaud your work. I call on you to protect the
residents' health before trying to protect the fiscal well being of the Puna Geothermal
Venture. Our greatest resource of this country is a healthy, informed and empowered
citizenry. Please continue the good work you have begun. Thank you for your attention
to geothermal issues and, in particular, your insightful analysis and conclusions revealed
in the draft report on the Puna Emergency Response Plans. The opportunity to respond is
appreciated.
Sincerely,
JULIE JACOBSON
Council Member, District 6
-------
May 28.1999
Mike Ardito
U.S. EPA
75 Hawthorne St. (SFD-1-2)
San Francisco, CA 94105
Dear Mr. Ardito,
Mahalo nui loa (With much thanks) for being interested and concerned in the people's views, as I am one
who lives in Puna Moku (District) on the Big Island of Hawai'I and have been affected in this.region due
to hazardous, poisonous, chemical leaks from detrimental geo-thermal emissions.
On page 37 of the draft report for Puna Emergency Response Plans, there hasn't been sufficient, prolonged
analysis of how continued accumulation of hydrogen sulfide, heavy metals, non condensable gas
emissions from the PGV facility affects those who already have a medical condition such as bronchitis,
asthma, headaches, etc.
With reference to page 17, under small (a), facility description, chemicals as cadium, radon, rada, mercury.
etc, have they been tested, analyzed within the region they are affecting. That is to say, because we have a
humid climate the natural environment makes these emissions even more poisonous and hazardous.
As in my other testimonies regarding issues pertaining to this, The Kingdom of Hawai'I, I am writing to
REMIND YOU AND ALL OTHERS connected with this and all geothermal projects here in The Kingdom
of Hawai'I that you are presently operating in violation of Hawaiian Kingdom Law and in contravention of
Article VIII, Treaty of 1850, U.S. Statutes at Large, 43rd Congress, 1873-1875, p. 408, and the Petition for
Writ of Mandamu filed at The Supreme Court in Washington, D.C., August 7*. 1998, by David Keanu Sai,
appointed Regent serving in the capacity as Ambassador of The Hawaiian Kingdom to the United States of
America, against the Honorable William Jefferson Clinton, President of the United States. You will be
held ACCOUNTABLE for your actions from this day forward.
TRANSITION AND REINSTATEMENT OF THE CONSTITUTIONAL GOVERNMENT OF THE
HAWAIIAN KINGDOM IS IN PROGRESS!!
Irregardless, of what has been set into motion by those of you determining the PGV facility is necessary
and are taking safety measures and precautions for efficient management of this facility, it is the right thing
to ensure peoples safety, as it was the State of Hawai'i's undertaking to begin with. However, to remind
you, again, the State of Hawai'I is NOT the de jure government, therefore, your plans to do anything
without regards to the proper authorities being notified, considered, is IGNORING what is documented in
your congressional records, and the highest law of your land, your own U.S. Constitution, and Treaty of
1850 still in affect.
Aloha Na Akua,
Anakura Melemai
Cc: file
Pertinent Peoples
-------
en 05/29/99 01:18:OB AM
To- Michael Ardito/R9/USEPA/US® EPA
cc: Vicki Rosen/R9/USEPA/US®EPA
Subject: public comment puna e.r.p
MrMikeArdrtoMay27.1999
Project Manager (sfd-1 -2)
Ms Vicki Rosen (sfd-3)
Subject: Draft Report for Puna Emergency Plan
First I wish to commend the U.S Environmental Protection Agency Region 9 for their involvement in the
issues of my community in Puna.
The State of Hawaii and the County of Hawaii use of Puna as a social and environmental dumping ground
for more than three decades is well documented in the book land and power in Hawaii. This views of my
community process to this day and is manifest in the state and county refusal to enforce even the most
trivial regulation on the geothermal industry
E.P.A has done a more than creditable job of pointing out in detail what my community has said was true
from the begin about the impacts of the state supported geothermal.
The point was again made this month when the state begin the redrillmg of the H.G.P.A WELL for the
propose of abandonment. No new or updated emergency response plan was filed; the community was
again left in the dark. To date I am aware of no movement by any state or county agency to implement
E.P.A RECOMMMENDATION.
In closing I thank it is fair to point out that while the rest of the United States has been enjoying record low
cost energy Hawaii has seen record rate increases and has the highest electric rates in the country. While
at the same time one of the highest forced outage rates in the nation over the last ten years. The same
time fame as geothermal development on our island.
Jon Olson
II—l-attu
ID
htm
puna_poverty.rtf
-------
on 06/04/99 11:07:06 AM
To: Michael Ardito/R9/USEPA/US ® EPA
cc:
Subject: HELP Puna Draft
Dear Mike.
I really goofed when I E-mailed you my commentary on the PGV ERP on
Tuesday. June 1st. as you can see from the attached. I only picked up the
unable-to-defiver notice late yesterday. I hope you can except my
commentary inspite of my mistake. Mahalo for your time and consideration.
At one with the Earth.
Athena
Date: Tue. 1 Jun 1999 14:28:39 -1000 (HST)
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Date: Tue, 1 Jun 1999 1425:59 -1000
To: arditto.michael@epamail.epa.gov
From: Athena Peanut EW AM**1 toJ***^
Subject: Draft Puna Emergency Response Plam Commentary
May 31, 1999
Mike Arditto
US-EPA Region IX
75 Hawthorne Street (SFD 1-2)
San Francisco. California 94105-3901
Re: PGV Puna Emergency Response Plan. Version 6.3. Public Commentary
Dear Mike Arditto:
I have found the above-referenced Emergency Response plan inadequate in the
following eight areas
1. Definition of "Nearby Residents' • The Plan identifies nearby
residents within a few thousand feet radius of plant. This is incorrect.
and if deliberate, criminal. H2S a known lethal gas that travels many
miles in dense compact clouds and disperses very slowly.* Supporting
documentation of PGV's H2S impacts and the prevailing diurnal and nocturnal
wind patterns affecting residents in the lower Puna area for a radius up to
five miles and beyond during EPA cited PGV uncontrolled emissions (1991 and
1993) has been submitted to this agency many times before*. This limited
definition of nearby residents is inappropriate and incorrect, and needs to
be corrected to the ten-mile evacuation zone that mandated for toxic spills
of one ton of H2S or more.
2. Agency Responsible for Evacuating Nearby Residents • The Plan places
the responsibility for evacuating residents to the Hawai'i State Civil
Defense Agency and further states that PGV anticipates no project created
situation which would not provide sufficient time for the Civil Defense
Agency to warn and evacuate public.' Why not? There has already been two
EPA cited violations for which PGV was fined tor uncontrolled emissions and
very few, of the large number affected, were ever notified.
Furthermore, the area in which I live, the Kehena area on State Highway
137, commonly known as the Red Road, does not even have a nearby siren to
warn residents of impending disaster. The Mayor's office and the Civil
Defense Agency have been notified of this before by the Kalapana Seaview
Community Association* but the County and State continue to ignore a large
population at risk, immediately downwind and makai of the PGV plant.
-------
3. Evacuation Notification Procedures - The Plan proposes that PGV will
notify the Civil Defense Agency in the event of uncontrolled emissions.
Despite a notorious record of uncontrolled emissions, lack of aid to the „
community and denial of wrong doing, PGV HAS NEVER NOTIFIED ANY AGENCY OF
UPSET CONDITIONS BEFORE - IT IS ALWAYS THE COMMUNITY THAT NOTIFIES CIVIL
DEFENSE • so why are we asked to believe that PGV is going to do so in the
future? This is not acceptable without active community participation in
monitoring procedures..
4. Averaging Out of Peak Monitor Recordings to Distort Emission Impacts
on Residents 'Averaging of peak monitor recordings to distort data of H2S
emissions cannot continue over an hour cannot be permitted to continue. It
is simple to show that any lethal cloud of H2S could be released that could
prove fatal to those human beings In its path and yet data records would be
distorted to show no emission release because of the insane hourly
averaging method employed by PGV.
5. Disclosure of All Emission Toxins - PGV has to release the list of
toxic elements present in geothermal emissions. The community has demanded
this information for years. PGV has denied the information request for
years claiming 'proprietary secrets'. Under the provisions of the
Emergency Planning and Community Right-To-know Act this information must be
released to the public.
6. Adequacy of Monitoring Equipment - Upon PGV's disclosure of toxic
chemicals contained in geothermal emissions in Puna, the monitoring
control, by necessity must be updated to reflect presence of all toxins
emitted, e.x.. gas spectroscopic monitoring.
7. State of the Art Monitoring System To Be Located at Pahoa Schools - A
recent fire this year in Leilani proved once and forever that fumes and
debris from the area of the geothermal plant go directly to Pahoa* during
normal trade wind conditions when Pahoa was filled with smoke and ashes
from the fire in Leilani minutes after the blaze started. Furthermore, an
unprecedented 40%* of the Pahoa school children have behavior problems and
leaning disabilities This data strongly suggests heavy metal
intoxification. It is imperative that Pahoa school children are properly
protected by a state-of-the-art toxic gas monitoring system.
B. Community Involvement - The Plan presented does not include any
community representation. It is imperative that the playing field be
leveled and the community be granted equal representation and participation
in environmental decision making with developers and state regulators
governing and monitoring PGV operations under the provisions of the
Emergency Planning and Community Right-To-Know Act.
Thank you and your staff for the time and attention devoted to these very
important issues in Puna, Hawai'i and the opportunity to present these
comments.
At one with the Earth, Athena Peanut
•T<pk*^ AW-U- <3u4cV
* Note: Upon request, documentation will be provided for items with asterisk.
-------
Friends of the Red Road
'E^.i Itfrtnl' A/Ac/n'
http://vvvvw.planet-hawaii.corn/redroad/
Friends oi the Red Road
gir* • ACrf»-t-B /o^bcK^f
hnpy/www.planet-hawaii.conVredroaoV
-------
TO: Mike Ardito, U.S.E.P.A., Region IX
COMMENT LETTER ON VERSION 6.3, FEBRUARY 1, 1996
EMERGENCY RESPONSE PLAN OF
PUNA GEOTHERMAL VENTURE FACILITY
2.2 Definitions
The definition of the term "ambient level" in this document
fails to take into consideration the unusual circumstances present
in the Puna District, in which background emissions fluctuate
based on prevailing winds, volcanic emissions and quantities of
same, as well as current location of source of volcanic emissions,
which changes from time to time. It should be noted that these
circumstances are also ignored in PGV's GRP and the DOH's air
permits.
3.1 Notification Lists
I know from personal experience, as well as anecdotal, that
the so-called 24-hour information line does not always respond.
This appears to be the case especially during upset conditions,
when it is needed the most. The community is suspicious that this
is deliberate on the part of PGV. It is all very well for a list of
phone contacts, but quite meaningless if the numbers are not
dialed. It has consistently been the case that the first calls to -
agencies such as Civil Defense have ALWAYS come from the
neighboring residents, rather than from PGV. Unless there is a
P.O.BovlOBS * Palion * Hnwaii. 0677S
-------
tamper-proof computerized automated system in which Civil
Defense would be notified at the first moment of upset conditions,
any such list is not only meaningless but also misleading.
3.3 Notification to Public
PGV's consideration within the context of this condition that
applicable distances from the project are 3,500 feet from the
project boundary, as specified in the GRP, is self-serving: during
the 1991 blowout the effects and impacts were felt more than 5
miles away, and residents as far away as Orchidland were
awakened by the noise. For a worst-case scenario a 15-mile radius
from the plant has been identified by Hawaii County Civil Defense
(CDA), which would extend all the way to Kea'au. Evacuation
within a meaningful timeframe would be absolutely impossible.
Consideration #3 throws the entire burden of responsibility
for notification and evacuation of the public onto CDA. The
burden is increased astronomically for every minute that passes
prior to PGV's notification of CDA. Furthermore, CDA is based
in Hilo, more than 25 miles away, which further increases their
response time and reduces their effectiveness. The public could at
least get a headstart in preparing for evacuation if there were a
siren on site which would warn them in a more timely fashion.
4.1 Emergency Facilities Available Off-Site
Figure 4.1 shows the police stations in Pahoa and Kea'au.
The Pahoa facility is a sub-station and is not staffed on a regular
basis. Most of the time there is no one on the premises. The Kea'au
station is 15 miles from the project site. In the past, when police
were called to the site during H2S emissions, they were not
provided with breathing apparatus, and at least one officer had to
be hospitalized. Subsequently the captain notified PGV and the
general public that the police would no longer respond during
upset conditions unless they were adequately provided with
protective gear. To my knowledge this situation has not been
-------
rectified. Therefore, the public cannot be assured that their orderly
and safe evacuation would be police-assisted.
Figure 4.1 also shows the Fire Stations in Pahoa, Hawaiian
Beaches, Hawaiian Paradise Park and Kea'au. This is misleading,
since the HB and HPP stations are volunteer fire stations and are
not fully equipped. There is also a volunteer fire station in Wa'a
Wa'a. These do not carry oxygen, and have only 3 Scott
Air Packs aboard the engine for the use of the volunteers, in case
they have to enter a burning building. They carry no respiratory
supplies to serve the public. Indeed, there are not enough oxygen
tanks and respiration equipment available in the entire Puna
District in the event of a worst-case scenario. Furthermore, the
volunteers have not been specifically trained in the sort of
emergency medical procedures which may be required of them due
to a populace overcome by toxic fumes (not only H2S, either). It
must be remembered that the Puna public has been identified by
the DOH as having the highest incidence of respiratory problems
in the state. In Pahoa High School alone, more than 125 children
have been diagnosed with asthma. Because of the low property
values, many senior citizens on limited incomes have been
attracted to this area. They are another high risk segment of the
population. PGV's on-site safety equipment is for the use of their
workforce, who collect hazard pay for their CHOICE in taking
risks. The surrounding community has been given no choice, nor
pay, nor benefits; and obviously no access to sufficient oxygen and
respiration equipment to save their lives.
Table 4-1. Off-Site Emergency Facility Capabilities
There are some errors in this table: Pahoa police does not
have 2 officers on duty. That sub-station is not regularly staffed.
The officers stop in to fill out reports, but are more often in the
field. Those 2 officers may be as much as 30 miles away if they are
responding to an earlier call. Hilo is not 20 miles away, but 25 -
and Hilo Hospital is even farther. The fire station in Pahoa is not 3
-------
miles away, but 4.1 miles. While Table 4-2 lists on-site emergency
and safety equipment, such as first aid, fire extinguishers, eye
wash, airpacks and O2 kits, Table 4-1 does not inform us whether
such equipment is available, or in what quantities, at the local fire
and police stations for the general public.
5.1 Evacuation of Persons On-site
Employees being evacuated will leave the project site
through the gates on Pahba-Kapoho Road and/or Pahoa-Pohoiki
Road. What is omitted is that those are the two major routes by
which the lower Puna cul-de-sac residents will also be evacuating.
Both these roads meet at the project boundary and feed onto one
winding 2-line road. This will create a severe bottleneck, and PGV
staff will compound the problem by attempting to enter the flow of
traffic. Evacuating residents will be stressed and angry, and many
will blame PGV employees for the situation. If there are not
sufficient police on hand to direct the traffic flow, the situation
could lead to mob behavior. Yet the police will be required to help
notify adjacent communities, protect evacuated homes from
looters, etc. As it is, Puna Police are shorthanded. This is a recipe
for disaster.
5.2 Evacuation of Nearby Residents
Once again, in this section, PGV makes the mistake of
assuming that only residents within 3,500 feet will require
evacuation. That error makes it seem do-able. After the blowout in
1991, Police Captain Dale Fergerstrom stated that just to evacuate
nearby Nanawale Estates subdivision by driving up and down with
a bullhorn would take more than 3 hours. Leilani Estates is even
closer and more densely populated.! find it incredible that UPGV
anticipates no project-created situation which would not provide
sufficient time for the CDA to warn or evacuate the public9'. This
clearly runs counter to what we have already experienced in
-------
Once residents are finally (hours later) informed of the need
to evacuate, the next part of the nightmare ensues: lower Puna is
one large cul-de-sac; both Kapoho-PahoaRoad and Pohoiki-Pahoa
Road come together at the project boundary, and feed into a
narrow winding 2-way road, which eventually, at the outskirts of
Pahoa, feeds into a single highway. All traffic will slow down and
bottleneck. The bottleneck by the plant is the one of greatest
concern, as people will be trapped at the area of highest
concentrated emissions. A driver succumbing to emissions at this
point could tie up the entire line of evacuating cars, causing more
delay, which means the other drivers would be more likely to
succumb to the emissions as well. This could be a "snowball"
effect, which has not been considered in this document or by local
emergency personnel.
6.4 Power Plant Operation
This section states that "there are at least three (3) people
fully trained in handling hydrogen sulfide emergencies.".
However, there are other toxics which can be (and have been in the
past) emitted, such as sodium hydroxide. This deficiency must be
corrected in the plan.
8.1 Natural Hazards
This plan, as noted earlier, leaves it entirely up to CDA to
notify the public. The first problem with this is mat is assumes that
CDA will itself be notified in a timely fashion. The second
problem is that of informing all nearby residents of the hazard:
newspapers may be too slow and not everyone reads them, not
everyone may be tuned in to or have access to radio/TV
announcements. The Civil Defense sirens operate simultaneously
island-wide, and cannot be set to go off only in lower Puna. PGV
has an on-site siren to alert workers, but it is not set up to alert the
entire community. Driving up and down the subdivisions with a
bullhorn will take too long. Many residents on large agricultural
acreage have gates, which would prevent their notification. CDA
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has been given an impossible job, and PGV, by foisting
responsibility on that agency in this plan, makes it even more so.
As a result, it is the public that will suffer the worst impacts.
8.1.5 Lightning
"There is little potential for lightning to produce any facility
emergency situations which could threaten the health, safety, or
welfare of the public...".. There have been at least two (2) events
in the past in which lightning did indeed strike and give the lie to
the above statement.
Table 8-1 SITE RELEASES UNDER ROUTINE AND UPSET
CONDITIONS
This neglects to deal with computer failure in all or part of
the emergency programming. In the past, for example, the
computer failed to calculate the amount of sodium hydroxide
necessary to mitigate the amount of hydrogen sulfide. Sodium
hydroxide was "eyeballed" and added manually. This Mickey
Mouse procedure resulted in an excessive emission of sodium
hydroxide into the surrounding community, causing skin irritation,
burning eyes and upper respiratory distress.
8.2.1 Geothermal Steam and Fluid Releases: Nature of Hazard
This discussion would have one believe that participates are
only a hypothetical problem. Indeed, one of the particulates of
major concern is not even listed in this section nor in Appendix H,
namely cadmium. Nearby residents for many years have
experienced depositions of cadmium particulates on their roofs
(which feed into the home water catchment systems) and on the
leaves of their trees and plants. We know it is cadmium because
samples were collected by a visiting EPA team and tested by them
on the mainland. Cadmium ions are extremely poisonous; their
action is similar to those of mercury. Once in the body it does not
pass out through the urine or other mechanisms, but lodges in the
organs and accumulates. Between February and September, 1996,
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PRIOR to acceptance of this ERP, as the results may very well
yield data which should be considered in this document.
8.2.3 Noise Hazard: Nature of Hazard
• *
I live more than 5 miles away from PGV, with an intervening
forest which one would expect to buffer much of the noise from
PGV. Yet on the night of the 1991 blowout I was awakened by the
noise, which sounded like the repeated take-offs of jumbo jets
from a short distance away. Therefore, I believe that the formula
of 6 dBA drop for each doubling of the distance is inaccurate and
not based on reality. One interesting thing I have learned about
noise since living here is that topography is as important a factor as
distance. The formula does not consider this. Other factors are
high/low pitch of noise, direction of prevailing winds, background
noise (the country is quieter than the city and sounds travel farther;
noise is more evident at night than during the day, etc.), and the
discussion and formula do not consider these either. Therefore the
formula cannot help but be inaccurate and non-reflective of reality.
8.2.4 Spills and Leaks rNature of Hazard
"Pentane is not toxic... and is not hazardous outside of its
flammability characteristics91. But when pentane burns it releases
dioxins into the atmosphere, and these are toxic, hazardous and
carcinogenic. The plan does not discuss this, thereby downplaying
the hazard and obviating the perceived need to discuss mitigation.
Appendix B: Brief History of H2S Accidents
How convenient that none of the examples are chosen from
the history of PGV or its predecessors!
As regards the EPA Review Team recommendations: The
technical work group must also include members of the affected
community who have no conflict-of-interest ties with PGV. The
residents have been forced to conduct considerable research over
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for example, Thermochem reported an analysis of .102 mg/kg
cadmium in the type 1 injectate. It appears to be a miniscule
amount until one considers that it has been building up in residents'
bodies for many years. There is no question that it is present in
the resource. A worst-case scenario may release larger quantities of
this toxic participate, which may put some long-time residents
'over the edge".
Because HDOH allows PGV to calculate H2S emissions on
an hourly average, PGV could wait for the first hour to pass before
notifying CD A. This then extends the timelines and increases the
problems for CDA and other local agencies in their attempts to
assist and evacuate the public. OSHA standards for H2S are based
on what the normal healthy adult body can handle. The
surrounding community is composed of pregnant women, infants,
young children, people with a history of respiratory problems
(asthma, bronchitis, emphysema, etc) and seniors. They are
exposed for more than 8 hours a day, and many have been exposed
for many years at these low level doses. Many have become
sensitized, and this section does not discuss the phenomenon of
sensitization. I know of at least one person who can detect H2S at
1 ppb. I know of many who became sick and were even
hospitalized at less than 1,000 ppb.
Finally, in the last paragraph of this section, is a discussion of
the worst-case scenario modelling and its results. I cannot
emphasize this enough: a model is not reality; it is a compendium
of probabilities; life and nature are not required to conform to
computer-generated models. We should not put so much faith in
this methodology. The last sentence in this section states:
"However, PGV, under the review of HDOH, will be undertaking
a more detailed sampling and analysis program for these non-H2S
components during the first well flow test following acceptance of
this revision of the ERP." This program should be completed
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the years about geothermal technology as a matter of self-defense,
and many are probably more knowledgeable on the subject than
many agency personnel. The community must be represented on
this work group in order that it be in conformance with the
Emergency Planning and Community-Right-To-Know Act. Also,
because this community has for so many years been at the mercy
of closed door exclusionary meetings and been denied input and a
voice in life-threatening decisions, this must not be allowed to
continue.
Thank you for allowing me this opportunity to comment.
Rene' Siracusa
President
Puna Outdoor Circle
5/28/99
E-mail:
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Shelley Stephens
\j*'to*.Q3ZEVf\^
Po»HrFa*Note ' 767
bear fllchael Ardlto,
Aloha Croa Havai'll Thank you very much for the opportunity to review the
Emergency Response Plan •• such. 1 an very concerned that there are some serious
problem* with this draft a. Ui«r« are quits a tew very important things that have not
been properly and thoroughly addressed: and will warrant a revision/acid resubmltted for
public review/)
of the ditrlculty o£ Lli« obtaining the second part of the K.K.P.. namely
li. and the xeviav period mist be extended and copies of the missing Volume II
•use be luclud«d f«r public viewing and to concerned citizens who request it.
Voiu»e 11 was not «de available in Pahoa Public Library, where some of the greatest
•
concerns about H2S 6 Ceothenul Health related Issues are present in the community.
Ou« evident requested It tlitougli a .ccond Mlllng but when certain residents requested
It iro^che Ceotheraal riant It wa. not Bade available, according to that person's report
wl* Lli« it vent .
1 noticed chat Volime 11 was Biasing froa the «ail-out when 1 went to look for the
woc»t „.„« scenarios... the panes were BLAMK-there was atleact space for a listing of all
th* worst case acenariuH. 1 Intentionally wanted to review this report and Emergency
X>.L« because of its extreme iaportance to the actual relevance of the Implication of the
real £«*•*„„., lU.pun.e flan. Without review 0» this data, there is no way to know if
there i,. «u adequate plan for. emergency response. Since the EPA is mandated b/ lav to
allow public input into this utter. 1 respectfully request an axten.ion cf the
period and a «port done by tn. AXS1JK bMftd w ^ h^f
H28 iu properly ...... th. .u^t tu date cases.. . .with data that Oeotheraal i DOH must
05/28/90 FBI 21:21 [TX/RX NO 7227)
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submit. *»co if w« HUM I yet a court order to suplna (spelling?) the poundage amounts.
Tber« 1» wpvulflc probleas wltb the "Lightning" section In the vagueness of Che plan of
tiuLlficatlon ot residents and public facilities In csse of • lightning strike (as was the
caae vheo ch« litflilulnjf struck the control paanel and chere was emergency release of toxic
vlM«m.) We need co know exactly how chic will fee dona: which Is why the public is atill
requesting che Emergency notification be animated through an automated computerised phone
u«Lvurk that we have priced at spproxiametly $60.000.
There Is not specification of emergency back up generatora to power aircondltlonerc
Xui lung compromised children at the Public schools within the Ring Hap Areas... that ate
possible danger sonea. lula is ot great importance. since the age for permanent neuroglcal
damage is of greatest impact in school age children. The band rooms and other
designated areas must be equlpt with air conditioning units and back up generacors In case
«f the "Black-Out Scenario"; which Bust be included in the vorst case scenario llstingb-.
Also, chere is evidence ot water contamination of one of the largest aquifers in the
Puna area... at wells tested u*aib> tlits injection cites; levels of lead and other chemiccle the
are higher than naturally occuring In chat area. Comparisons of lead and other heavy nee all
amd toxins must be compared to what la naturally occuring in that area. Also. I need the
forenslcs of the EPA to come and take Che testimony of an X-wurker who saw the Geothermal
• v
illegally pumping toxic waste into a crack in the lava rock ground and knows who did it. etc.
which IB che Biasing piece co Che incident cbat Aurora reported having photos co.
I must reiterate that che Emergency Response Plan has been rejected by the Public and
mat be revised: based wu ewrw thorough Investigation of che facts for worst case scenario
and actual plan of action Cor nocltlestlon.
Thank you
PS Sorry .bout any spelling errors.
-W 1 *K*«1. «k.. .K. ISO
H* eudauKerment of Jfuna residents in srea through purposeful non-notification. etc. . .
1 have alot of additional Inf. on this... let a. know when you can come to record witnesses.
05/28/89 FRI 21:23 ITZ/RX NO 7228]
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Patricia Stewart
Exodus Foundation
Pahoa, Hawaii 96788
MAY 7, 1999
Environmental Protection Agency
Daniel Mcgovern, Regional Administrator, Region IX
attn. Michael Ardito
75 Hawthorne St.
San Francisco, CA 94105
Dear Sirs:
I am writing, in brief summary here by my 90-day response deadline to the content and summary of a
specially appointed team which I believe was assembled by the EPA (and not chosen by Hawaii State
government) in order to pass judgment on evidence regarding which agency should regulate certain
functions in Hawaii.
I believe that this special panel's function may be limited to providing evaluation of data and comment
on only questions of Toxic and Hazardous Waste management, regulation, and jurisdiction issues If the
committee's scope is more broad, I would likewise broaden my opinion and comments to include any or
all jurisdictional issues' Please let Hawaii's unique, pristine, and irreplaceable environments be afforded
the continued helps and protection we may receive from administration from your office, the E.P. A.,
please.
I have read the data pertinent to proposed rule changes, and have traveled on February 8,1999 to
an opportunity for public input offered by the Hawaii State Health Department, where I met with Hearing
officer Louis Erteschik, with April Katsuura and Grace Simmons from the Health Department.
They sent me the report of the Special committee. I am a 33 year resident of Hawaii, I do scientific
research on my own, as needed , on our environments conditions and needs, most specifically on
Hawaii Island, Hawaii: the Big Island, -where I currently live in Waa Waa, Kapoho 96788.
1 do not find the committee's report to be accurate in analysis of data which they have received, or
to be concluding with good judgment. Although I see adoption of the more stringent Federal
rules on toxic and hazardous waste to be applied to Hawaii's Environment, I do not see any good
effect of allowing the Hawaii State government to administer the rules.
The Coastal Zone Management Rules, for instance, are routinely ignored by the state of Hawaii. Locally,
the expert reports prepared at the governments request: a geological study by Goddard and Goddard, and a
health study by a Doctor Legator. from Texas, who studied the health effects of gepthermal industries
here and in Texas, finding the industries emissions to be similarly lethal here and in Texas... These
experts studies have been ignored, as our state Health agencies have gone along with industries that harm
residents health while providing business activity allowed and promoted by the State of Hawaii. Residents
testimony has been overwhelmingly ignored and ridiculed, as have our votes on a number of issues in this
state where there is effectively only one political party, where residents concerns have been ignored since
the illegal occupation and takeover of Hawaii by American troops and administrators years ago. We
need your help, as there is not much awareness here of the very value of the unique quality of our
relatively clean environment; a product not so much of our superior environmental practices, as claimed.
falsely, by Honolulu Mayor Jeremy Harris recently hosting a meeting of Pacific nations, but by virtue of
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our huge buffer of ocean space surrounding our most remote islands, where our pollution is allowed to
dissipate into the great expanses of air and sea surrounding us
Please consider taking a look at a more active role by the EPA in protecting and preserving our
environment: a World Treasure in flora fauna, and until very recently a place of clean air and good health
opportunities for growth of foods and people.
Please do not return administration to State of Hawaii.
Patricia L. Stewart
Po. Illy s;«5"S%i- Si$t<2.r, UnvJA J^l ~7£v); e^
/
/ed ;,. LA. April 4. Wy r*f*nh
T
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on 06/01/99 06:06:22 AM
To: Michael Ardito/R9/USEPA/US»EPA
cc:
Subject: Comments on Draft Report
Annie Szvetecz
Via e-mail:
May 31. 1999
Mike Ardito
U.S. EPA
75 Hawthorne St.
San Francisco. CA 94105
Re: Comments on Draft Report on the Review of Puna Emergency
Response
Dear Mike:
Thank you for this opportunity to comment on your draft review of
Pjna Emergency Response ("draft report*). As you know, over the past
eight years. Puna Geothermal Venture (*PGV) has caused adverse impacts to
Puna's health, environment, culture and economy. Both the fear of adverse
impacts and the history of actual acute exposure has been caused by
inaduquate emergency response planning. Your review provides a
comprehensive and constructive way to try and correct this serious
problem. It is truly refreshing to review such a useful document relating
to our ongoing problems with geothermal development in Hawafi.
I have a few comments on your draft report that I believe would result in
an additional improvement to both the Hawaii County and PGV's emergency
response plans. The overarching insufficiency in the draft report relates
to community involvement, especially since emergency response is one of
the most important aspects of facility regulation for the community to be
involved with.
COMMUNITY INVOLVEMENT
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The draft report addresses the need for improved communication to Puna
residents from the County and PGV, but It does not specifically suggest
that affected residents should be included in the process of improving
emergency response in Puna.
The draft report states that the reviewers focused on the 'longer-term
objective of preventing chemical accidents and improving emergency
response capabilities.' It is critical to involve the community in many
aspects of planning and regulation to accomplish this objective. It
should be clear from the history of releases and 'upset' events at PGV,
that the affected community needs to be involved with more than the
receiving end of information about the facility and the County's ability
to respond to chemical emergencies. '
I strongly suggest that you Include members of the affected community in
your list of representatives suggested in the technical work group
recommendation. Although you have suggested that this group focus on
technical details of emergency response planning, It is also clear from
your report that this group will gather information, and discuss
policy-related issues relevant to the "vulnerable community' such as "H2S
trigger levels, types of incidents, and the air monitoring network.' Draft
Report Appendix K. Including community representatives in this group is
consistent with the language and intent of SARA Title III ("EPCRA') as It
relates to membership of the Local Emergency Planning Committees ("LEPC").
see 42 U.S.C.A. 11001(0).
HAZARDS ANALYSIS AND ACCIDENTAL RELEASE PREVENTION
The recommendations in the draft report relating to Hazards Analysis is
not sufficiently clear or comprehensive. Firstly, there is no doubt that
an accurate and complete hazards analysis will show a serious threat to
the public and the environment. This type of chemical emergency has
already occured at PGV.
Consequently. PGV must fullfill the requirements of both EPCRA and the
Clean Air Act Prevention of Accidental Releases, and complete a hazards
analysis. The County is required to incorporate this information in its
Emergency Response Plan. PGV's hazards assessment, pursuant to the
Prevention of Accidental Release regulations, must include a Risk
Management Plan. 40 CFR 68.12 (a). As the draft report mentions,
worst-case scenario and off-she consequence analysis must be completed as
part of this process. Plume maps of hydrogen sulfide and pentane releases
are a critical component of emergency planning. It should be explicit in
the report that this mapping be published and encompass all hazardous and
harmful substances, including sodium hydroxide.
Also, the County should gather the approprate information and update Its
emergency response plan to include the following information about the
potential for chemical accidents at PGV.
1. hazards indentification
2. vulnerability analysis
3. risk analysis
The report should should be more explicit about the potential for a
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worse-case scenario to involve both a natural disaster and human-caused
chemical release. The draft report notes that Harry Kim is very concerned
about an accident at PGV due to a 6-7 magnitude earthquake. I urge you to
strengthen your recommendation regarding PGVs evaluation of earthquake
dangers by requesting that PGV include this type of scenario in their
hazards analysis.
FACILITY REPORTING AND ROLE OF LEPC
I was encouraged to read in the draft report's field notes that PGV
submitted their Tier II reports from 1995 to the State Department of
Health (SERC?). There was no mention of Toxic Release Inventory (TRI")
information from PGV on file with the SERC. Is this because PGV has not
submitted TRI data? Please clarify PGVs responsibilities regarding TRI
reporting. TRI data should be submitted to the EPA and the state SERC. 42
U.S.CA 11023.
I urge you to include a review of PGVs reporting requirements under EPCRA
in your final report. All chemical accident and storage inventory
information pursuant to EPCRA sections 304,311 and 312 is required to be
submitted by PGV to the SERC and Hawaii County LEPC.
The final report should include stronger reminders and recommendations
about the responsibility of the Hawaii County LEPC. These should include:
1. The Hawaii County LEPC is required by law to gather appropriate
information to develop and update an emergency response plan. PGV is
required by law to provide this information to the LEPC. 42 U.S.C.A.
11003.
2. Establish rules by which the LEPC functions that include provisions for
public access to committee activities and emergency response plan. The
LEPC is also required to establish procedures for receiving and processing
requests from the public for information. EPCRA 301.42 U.S.C.
11001(C). Emergency Plans, Chemical inventory reports, and emergency
notification reports shall be available to the public.
.•
3) Publish (as a legal notice in newspaper) annual notice of public
availability of EPCRA reporting information. EPCRA 324,42 U.S.C.
11044(b)
4) Request and obtain EPCRA information from a facility when a request of
such information is made by the public, see EPCRA 324,42 U.S.C.
11044(a) and EPCRA 312,42 U.S.C. 11022(b)
ENFORCEMENT
The draft report is not sufficiently clear about which recommendations are
suggestions and which are required by law. I suggest that the language be
changed when a recommendation is required by law. The verbs should be
changed to 'shall' or 'must' instead of 'should' and the legal citation
should follow. More importantly, the final report should remind PGV and
the County that EPCRA allows the EPA to order a facility to comply with
emergency planning provisions by a judicially enforceable order. The
maximum penalty in $25,000 per day. 42 U.S.CA 325.
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In addition to finalizing this report, the most Important thing that EPA
can do in conjuction with this emergency response review process, is to
disallow any new drilling operations at PGV until all of the
recommendations in the final report have been Implemented by PGV and
Hawaii County. Drilling activities provide the most likely potential for
an accidental release of hydrogen sulfide into the community. This has
been demonstrated at numerous times in the past. Without an effective
emergency response plan in place, EPA would be grossly negligent regarding
human health and safety in Puna.
Thank you again for this opportunity to comment. I look forward to seeing
a final report.
Sincerely,
Annie Szvetecz
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JD5/31/39 08:12:21 PM
To: Michael Ardito/R9/USE PA/US® EPA
cc:
Subject: Comments Re: Draft Report (or Puna Emergency Response Plans
Mr. Ardito:
I herewith submit my comments regarding the Draft Report for Puna
Emergency Response Plans. The text of my comments is pasted below and
are attached as a Microsoft Word file to this message.
Should you have any questions regarding my comments, please feel free to
contact me at the above address or at my home address listed in the
document.
Donald Thomas
Comments Re:
Draft Report for Puna Emergency Response Plans
Submitted By:
Donald M. Thomas
May. 31. 1999
I have reviewed the Draft Puna Emergency Response; Report on the Review
of Hawaii County Emergency Operations Plan and Puna Geotherrnal Venture
Emergency Response Plan dated February 10, 1999. Many of the statements
made in the report are ill informed, incorrect, and outright
inflammatory. There are so many objectionable aspects of this report
that it is difficult to respond to each one individually and so I will
make some general observations on the overall tenor of the report and
follow that with several specific comments on individual statements that
I find objectionable in the text.
Overall, I find that the exercise reported in this document to be a
highly prejudiced effort to pillory and harass a legitimate business
enterprise that has gone far beyond the minimum regulatory requirements
to produce a valuable, necessary, commodity while minimizing the
environmental impacts of its production. The justification given for
conducting the review, when analyzed in anything like a quantitative
way, borders on the ludicrous. Puna Geotherrnal Venturers infractions,
according to section 1.5 Background of the report, were to emit (once,
during nearly ten years of operations) 2,247 pounds of hydrogen sulfide
over a 31 hour steam venting episode, as well as to emit less than
reportable quantities of H2S at other times. It is implied that these
releases pose an unacceptable threat to both the environment and to the
health of a sparsely populated community. Yet, a fossil fuel power
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plant of similar electrical capacity, located within a far more densely
populated urban portion of Hilo. emits more than four times as much
sulfur dioxide every single day of the year and is not considered to be
worthy of mention. Likewise, the Pu«u Oo vent of Kilauea volcano,
located about 15 miles from the PGV facility, emits well over one
thousand times that quantity of sulfur dioxide every day and has done so
for the last sixteen years. From a quantitative standpoint, the
emissions of sulfur gases by PGV are less than the faintest trace of the
total anthropogenic and natural emissions that occur within the Big
Island community.
A dispassionate assessment of the risks posed by the geothermal
emissions from the PGV facility also suggest that the effort expended on
a detailed review of PGV cannot be justified. It is acknowledged that
the physiological impacts of hydrogen sulfide are different from those
of sulfur dioxide. There is substantial epidemiological data that
clearly indicates that long-term, chronic exposure to low levels of
sulfur dioxide poses a significant threat to respiratory health. By
contrast, if data exist to document that a similar threat is posed by
exposure to low concentrations of hydrogen sulfide, I have been unable
to find it. Moreover, my own experience in visiting geothermal power
facilities (as well as thermal health spas) worldwide, has clearly shown
me that low concentrations of hydrogen sulfide are not considered to be
a health risk by a wide array of regulatory agencies and health
professionals. One need only cite the construction of a health spa
immediately adjacent to a geothermal heat plant • that used no abatement
of H2S emissions • in Keflavik, Iceland; or the absence of concern
regarding ambient air H2S concentrations that routinely exceed 1000 ppb
in Rotorua, New Zealand.
I also have difficulty rationalizing the expenditure of the time and
effort spent in a detailed review of the emergency response plan of this
particular facility when the city of Hilo hosts industrial facilities
that:
1} contain tens of thousands of gallons of flammable petroleum products
(the Texaco fuel storage yard for one and the Chevron storage facility
for a second), within a tsunami inundation zone, located less than a
quarter mile from a densely populated subdivision;
2) store thousands of gallons of compressed liquefied propane gas
(Gasco), also within a tsunami inundation zone, also located within a
quarter mile of the same community;
3) stores substantial quantities of agricultural and industrial
chemicals • in a tsunami inundation zone, adjacent to a residential
community • that, according to the review committees comments on Annex
M of the County Emergency Response Plan, are clearly undocumented and
unknown to emergency response agencies.
•
It is quite clear from this document that the County of Hawaii Emergency
Response Plan was found to be deficient. Given the risks associated
with the above facilities, in the face of a deficient County plan, I
cannot understand how EPA can justify, in any rational sense, the
expenditure of the amount of time and funding that have been dedicated
to a detailed review of a facility that poses a much lower overall risk
to the community. In short, to have selectively burdened an individual
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facility operator • whose routine operations allow the local utility to
avoid the production of several tons-per-dsy of air pollutants - with
the costs associated with complying with the demands of such a review,
while ignoring facilities that pose a far higher risk is a misdirection
of public resources.
If EPA was truly Interested in reducing the risks to the community
associated with accidental release of chemicals, fuels, or other .
man-made products, this review should have focussed on the deficiencies
of the County Plan and then identified, and ranked, the relative risks
of all industrial facilities on the Island of Hawaii. Upon completion
of that review and ranking, an analysis of the risks posed by the
facilities or operations with the highest risks should have been
undertaken. Had this been done, I think it would be clear to everyone
that the risks posed by this geothermal operation are trivial in
comparison to those routinely posed by others, and that this facility is
far better prepared to deal with those risks than are other operators
within the County of Hawaii.
In summary, H is my opinion that this entire exercise is an effort to
pander to the demands of a small group of vocal activists who are
determined to halt the operation of this facility at any and all cost to
the larger community. Where previous efforts to accomplish this goal
have attempted, and failed, to justify its removal on environmental
grounds, the current effort is based on equally specious allegations
about health risks associated with its presence. For EPA to have
dignified the groundless allegations made by these activists, and to
treat this facility as though it poses a significant health threat to
the community, is scientifically insupportable and ethically
irresponsible.
Specific Comments
Section 1.5 Background: The authors of the report demonstrate a lack
of technical competence by adding to the existing state of confusion
regarding quantities and concentrations. In the second paragraph of
this section they state: 'Although most of these releases have been
small and below the reportable quantity of 25 ppb, the quantities have
been measurable*.* (italics added). 25 ppb is NOT a quantity • it is a
concentration. Neither is it an 'Emission Level* • see Table 1,
throughout. The repeated mis-use of terms to describe the presence of a
specific level (concentration) in the ambient air, or release of a
specified quantity (amount or mass • as in pounds or grams),
demonstrates an absence of competence at the most basic levels of the
concepts involved in the control or release of hydrogen sulfide.
I question the need or the justification for including Table 2 in this
report. Many of the statements made by the community activists are
deliberately inflammatory and. in my opinion, intentionally misleading.
If this is supposed to be *an independent evaluation of the emergency
response plans*, as stated in the Executive Summary, then such
self-serving, unsubstantiated, and frequently irrelevant ('kittens are
dying*?), statements have no place in this document. Inclusion of
these comments serves to further *muddy the waters* of perceived risk as
J
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opposed to actual risks posed by the facility. It is clear that EPA is
responding to a level of perceived risk (that has been diligently
cultivated by the activist faction) in the community. Incorporation of
these perceptions in a supposedly independent review serves only to
further perpetuate the confusion and to give those perceptions an
undeserved level of validation.
To the extent that the issues raised by the activists have relevance-to
the present exercise, the time and space expended compiling all these
comments could have been more productively spent simply summarizing the
concerns (e.g. •concerns were expressed regarding the potential health
impacts of H2S on the community*) and then conducting a review of
emissions and ambient air data in the context of known physiologic
response to H2S (and other possible emissions) to assess the legitimacy
of those concerns.
Section 2 Review Team: The general area of expertise of the members of
the review team is presented but there is no indication of their
specific fields of training. My concern relates to the presence of
members with training in toxicology, industrial hygiene, dispersion
modeling, and other similar fields, that can make a technically valid
assessment of the level of hazard and level of risk associated with
facility operations that exists within the community. The absence of
such an analysis, in my opinion, invalidates anything that can be
produced by such a review: if a technically competent assessment of the
level of risks cannot be made, how can one determine what the
appropriate response should be?
Section 5.3.2 Annex B: Hazards Analysis: **an industrial accident like
a release of H2S at Puna Geothermal Venture is a human caused emergency
when it seriously threatens the loss of life or damage to property* (my
italics). Tnis statement highlights a basic, and in my opinion fatal,
deficiency of this entire exercise. There is no scientifically
supported assessment of when or if a release of H2S from the PGV
facility could threaten the loss of life, damage to property, or even
seriously impair the health of, individuals within the community. The
presumption that underlies its absence, and that demonstrates the
prejudice of the intent of the review, is that such an incident can
occur. In the absence of anyone on the review team who can make such a
determination, the entire exercise is without a legitimate purpose.
Section 5.3.2 Annex B: Hazards Analysis: ~ because human-caused hazards
can occur more frequently and develop suddenly and unexpectedly.*
Whereas this statement may be true in a more benign geologic
environment, it does not necessarily hold for the Island of Hawaii.
Although not a major issue, It does highlight the level of ignorance of
the review team with respect to local conditions.
Section 5.4 Geothermal Incident Standard Operating Procedure: «The SOP
does not describe any response actions the County and local responders
would take in the PGV facility.* I question the basis for the
assumption that County or local responders should do anything within the
PGV facility. The purpose of the response plan is to protect the
general public from releases discharged from the facility. To empower,
or to condone the concept that independent action can be taken within
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the facility by individuals who are not intimately familiar with its
operations and conditions is an extremely dangerous precedent to
establish. The purpose of the emergency response plan is to protect the
public • outside of the facility perimeter. Any actions that would be
taken within the facility should be under the direct supervision of
individuals with the competence and understanding of the facility and
who will be able to distinguish between those actions that will
alleviate the emergency and those that will compound it or will endanger
themselves or others on the site.
Section 5.5.3 Finding: Recommendation: The presumption underlying this
entire section is that there is a significant probability for a release
of something (what is not specified) that will pose a life- or
health-threatening condition within the larger community at some
distance from the PGV property line. This presumption has not been
established in any technically defensible way. To suggest that it has
by recommending elaborate warning and notification systems only serves
to fuel the already high, and unjustified, level of paranoia in the
community regarding PGV*s operations.
Section 5.5.4 Finding: •The Plan should include a procedure allowing the
Pahoa Substation •. to make emergency decisions, such as sounding
sirens.* Sounding sirens where? What qualifications and training would
be required of whomever would be making that decision? Who would be
liable for any damages incurred if the decision was made
inappropriately? This recommendation appears to ignore the necessity
for maintaining a chain of command that requires that a decision, In an
emergency situation, be made by personnel having direct competence to
assess the conditions that may trigger an action.
Section 5.5.7 Finding: 'However, the public is concerned about model
accuracy. One local resident stated that during a blowout.
concentrations of 30 parts per million (ppm) were present at the
resident's home, but the PGV models predicted only 1.1 ppm. The EPA has
not confirmed the PGV model accuracy or the resident's statement.* If
that is the case, then why is this statement in this review. If EPA is
going to make regulatory decisions based on unfounded allegations, or
more accurately, the public's perception of risk instead of actual
risks, then they have no business being permitted to set environmental
policy in this country or anywhere else.
Section 5.5.8 Finding: This entire section is based, again, on the
presumption that release of something from PGV would result in off-site
conditions that are such a threat to life and health that they will
require immediate evacuation. This review has not established this fact
and the review committee apparently does not have the competence to
establish it independently. In my opinion, and in my experience dealing
with steam releases from the HGP-A facility, the likelihood of steam
discharge from this facility causing hydrogen sulfide concentrations
high enough to pose a health threat as far away as, for example, Pahoa
school, are vanishingly small. The treatment of these concerns as
though they had a significant probability, again, only serves to further
frighten a community that already has unjustifiably high levels of
concern about this facility.
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Section 6.2.1 Finding: and Recommendation: *PGV should have emergency
shutdown procedures. If these procedures exist already, PGV should
cross reference the procedures for an emergency shutdown with its
emergency response procedures.* This is plain silly. Is the review team
so ignorant of the operational practices of a power plant to not
recognize that every operator on duty would be trained in emergency
shutdown procedures? What possible function is served by
cross-referencing every single procedure that is required to deal with
an emergency?
Section B22 Finding: *The ERP states that at least three people with
first aid will work on every shift. • PGV has since indicated to EPA
that all PGV employees are certified for first aid and cardiopulmonary
resuscitation or CPR.*
Recommendation: *The emergency response procedures should clarify the
role of first aid respondent to ensure that they are available to
administer first aid when required.* This recommendation makes no sense
to me. After acknowledging that PGV meets and exceeds the minimum
requirements by having all of their staff trained to render first aid
and perform rescue duties, an objection is raised that those duties are
not restricted to a specified few individuals. This is complete
nonsense.
Section 6.3.2 Recommendation: *lf other hazardous chemicals are present
in the steam from geothermal wells, the Emergency Response Plan should
include them as well.* One wonders what is meant by this statement or
whether the author is so ignorant of chemical hazards as not to
recognize that specific conditions render a chemical hazardous rather
than their merest presence. It calls to mind the •Dihydrogen Monoxide*
prank that circulated through the internet a few years ago: a message
was circulated that cited the large number of deaths that result from
excessive ingestion of dihydrogen monoxide, and described all the
industrial activities that discharge dihydrogen monoxide to the
atmosphere. The reader of the text was then invited to contribute their
support for banning the use of dihydrogen monoxide. This discussion
generated a frighteningly large response from well-meaning but ignorant
members of the public who did not realize that dihydrogen monoxide is
nothing more than water. Would the recommended list include sodium
chloride? Potassium chloride? Hydrogen? Helium? Oihydrogen monoxide?
Section 6.3.3 Finding: This whole section is unfounded and
inappropriate. It, again, is based on a presumption that has not, and
cannot, be demonstrated by the review team or EPA. I take specific
exception to the statement •According to the County Civil Defense
Administrator, incidents also have occurred in which neighbors to PGV
phoned-in complaints of H2S releases, and PGV did not report these same
releases.* Of precisely what relevance is this statement to the issue at
hand? Did the alleged releases, in fact, occur? I have personal
knowledge of incidents (at the HGP-A facility) in which residents
(activists) called in complaints only when they thought a release was
going to occur • and when, in fact, the scheduled releases had been
postponed or completely eliminated. Further, were those releases that
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did occur, but were not reported, of such an extent that PGV was
required to report them? And finally, were they of such an extent that
the complainant's We or health were threatened? If not, how is this
statement relevant to the Emergency Response Plan?
Section 7.2.1 Finding: "The review team found that the stationary H2S
•• and Recommendation: »The review team recommends that stationary air
monitors around the facility should measure continuously the higher H2S
concentrations, greater than 500 ppb.» I can only wonder at the
ignorance of the review team (or report author) that this entire section
reflects. To begin with, the function of the H2S monitoring stations is
for compliance monitoring. The equipment used for compliance monitoring
cannot be calibrated to both provide accurate measurement of ambient air
H2S levels at the 5 ppb range (where ambient levels are for >»99% of
the time) and provide accurate measurements of H2S levels at the 1000
ppb range. To the best of my knowledge, instruments with this wide a
dynamic range are beyond the current state-of-the-art. Secondly, why
would an emergency response official rely on data from one, or a few,
fixed H2S monitoring stations when evacuation decisions will have to be
made on the basis of H2S concentrations present in the downwind plume;
concentrations that, because of variable wind conditions typical in
Puna, will have to be measured using a portable H2S monitor?
•The Review Team also recommends that the County form a technical work
group •» I certainly agree that such a review is needed. Any reviews of
the trigger levels should be scientifically justified rather than set to
appease community activists.
•Technical issues under evaluation are extremely important and will
require a great deal of thought, research, and professional judgement.
Public participation should be included when setting new evacuation
trigger levels.* The contradictory and self-negating effects of these
statements speak volumes about the absence of any true understanding of
the issues involved here. Again, there is the choice of making policy
decisions based on actual risks • by basing them on 'thought, research,
and proiessional judgement* • on based on perceived risk • in response
to the (frequently misinformed) perceptions of the public. The two
approaches are mutually exclusive: we either accept technically
supportable standards, or we accept standards based on who can shout the
loudest. If it is EPA*s desire to establish standards based on the
latter, it meets my definition of 'arbitrary and capricious* and yields
to mob rule.
Section 7.2.8 Recommendation: -Hawaii County and/or PGV should equip
the Pahoa Substation with a combustible gas monitor. H2S detector, and
UV/IR flame detector.* And following. Although the recommended
equipment might be an appropriate expenditure for the Geothermal Asset
Fund, it isn«t clear who will be trained to operate the various
detectors or whether these are the most appropriate uses of time for
emergency response personnel. It seems that the recommendation ignores
the level of probability that such training will be useful to the
emergency responders or whether their time might be more usefully be
spent on other training.
7
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Section 72.9 Finding: »The Review Team found that public communications
and access to chemical emsrgency planning information from PGV could
improve. •• This section again reflects the ignorance (willful or
otherwise) of EPA and/or the review team that the objective of the
community activists are to shut down this facility. The demands for
information are driven primarily by a desire to unnecessarily heighten
community fears about this facility and ultimately lead to its removal.
Having lived in Hawaii for more than 25 years, I know of no other.
industrial facility In the state that has expended more time and effort
to respond to legitimate public inquiries or provide information to
anyone who has a desire to understand what the production of geothermal
energy entails. I have personally arranged and participated in more
than a dozen tours, of students, professionals, and scientists at the
Puna facility. I have never made a request for a tour that was not
accommodated.
Conclusion and Summary
Overall. I find the report, as well as the review of the PGV operations
and ERP, to be technically flawed, rife with preconceived conclusions,
and extraordinarily biased. Where EPA and their review team could have
performed a valuable service to the Big Island community • by reviewing
and ranking all the industrial hazards that exist on the Big Island on
the basis of a technically competent analysis of real hazards and real
risks • they have chosen instead to arbitrarily target a single buisness
organization in an effort to pander to community activists. The flaws
inherent in the report render it of little use for any scientifically
analysis of the risks posed by PGV or for any regulatory or oversight
action by State or County agencies.
ID
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LAW OFFICES OF THOMAS E. LUEBBEN
211 12th Sintt N.W.
Albuquerque, Nev Mexico 87102
(SOS, U2-*ia . «* (SOS,
DATE: June 14, 1999
THIS FAX IS DIRECTED TO: Mike Ardito
FAX PHONE NUMBER: (415) 744-1916
ADDRESSEE: ETA - San Francisco
TOTAL NUMBER OF PAGES: Seven (7) pages
THIS FAX HAS BEEN SENT BY: Thell Thomas
RE: Lehua Lopez -Mau's Comments on
EPA '6 Draft Report for Puna
Emergency Response Flans
THIE ORIGINAL DOCUMENT BEING TRANSMITTED:
xx will not be sent Will be sent Fed. Express
Will toe sent regular nail Other;
TRANSMISSION PROBLEMS OR ERRORS
1. Problem with Transmission: If you did not receive all pages
or if you experience any other problems or errors, please call
505/842-6123.
2. This transmission ay be confidential attorney/client
information. If you have received this communication in
error* please: (a) contact us at 505/842-6123, (b) do not
distribute or copy, and (c) return the transmission to us at
the above address via U.S. Postal Service.
MESSAGE:
Dear Mr. Ardito:
Please accept this late Comment. Thank you and you all very much
fur your efforts.
Thell Thomas-
IPO
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OK YH/n) ZC:EI NOK 66/H/90
Lehua Lopez-Mau
COMMENTS ON
EPA'S DRAFT REPORT FOR
PUNA EMERGENCY RESPONSE PLANS1
I. INTRODUCTION
Ms. Lehua Lopez-Mau. as a land owner in Puna and a citizen of Hawai'i, hereby
submits the following comments:
The Puna Geotherroal Venture ("PGV) should be immediately shut down because its
operations pose an extreme threat to the public health that can not be mitigated by PGV's
Emergency Response Plan, or the County of Hawai'i's Emergency Operations Plan
PCV is a geothermal powered electric generating project. PGV currently consists of
production and injection wells and a power plant. PGV's industrial operations are unique
in their proximity to residences and farms in the area, which because of their nearness are
susceptible to exposure to toxic levels of hydrogen sulfide. Many people in the Puna
Community feel endangered by PGV. and consider PGV to be a nuisance. The U.S.
Environmental Protection Agency ("EPA"), and the Hawai'i Department Of Health
("HDOH") require that FGV have at least an adequate Emergency Response Plan to
protect the Puna Community, and the workers in the PGV facility from the releases of
toxic substances that threaten the safety of all people around PGV.
In February. 1999 EPA released a Draft Report on both PGV's Emergency Response
Plan, and the Hawai'i County Emergency Operations Plan.2 EPA conducted a study and
integrated the findings into a Draft Report ("the Report**). The long term goals stated
within the Report are: to prevent chemical accidents and improve emergency response
capabilities.1 EPA's Draft Report for Puna Emergency Response Plans is outstanding.
1 Drafted by Thell Tbomts far Mi. Lopec-Mau
' Environmental Protection Agency. Region 9, Punt Emcrtency Response Report. (February 10,1999)
' The Comprehensive Environmental Response, Compensation, and Liability Act, 42 U.S.C. f g 9601 -
9675 (1995). Sections 96M(b) ud 9604(e) authorize EPA 10 eater a facility and gather information when
illnesi or complaints of illness my be attributable to exposure to a hazardous substance. This is the legal
eir - 3OUJO im NaeSBTI fl:pl 6? 'f. '9!*
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urn os- M/xi) «:«T KOK es/n/eo
The Report is a sound step along the journey of protecting the public healtn. Many in the
i!l Smmunliy .gr~ with EPA', finding .nd «com»cod.tio». au.d the foll.wns
comments are designed as a supplement to EPA's findings and recommendations.
D THE EPA REPORT SHOULD EMPHASIZE THAT THE PEOPLE IN THE PUNA
COMMUNITY MUST BE
THE FOCUS OF ANY EMERGENCY RESPONSE PLAN
The next step for EPA is to require that POV and Hawai'i County include representatives
from the Puna Community in every aspect of accident prevention and emergency
response. The involvement of the community is mandatory because it is the health and
safety of the Community that is threatened by PGV. A local emergency response planing
committee must be established, to include members of the community, PGV emergency
response mangers, and Hawai'i County emergency response leaders. Community
involvement in toxic release prevention and emergency response planing is in accordance
with state and federal Emergency Planing and Community Right-to-Know laws.* EPA
bas repeatedly pointed out that PGV and the County of Hawai'i have failed to coordinate
their emergency response efforts.1 If PGV continues operations, the Puna Community
will continue to suffer from releases of hydrogen sulfide. Therefore, if PGV continues
operations, many in the community demand that Hawai'i County. PGV, and members of
the Puna Community work in partnership to protect everyone from the harms caused by
hydrogen sulfide releases.
Ill THE EPA REPORT SHOULD ACCOUNT FOR THE HARM CAUSED BY
HYDROGEN SULFIDE RELEASES
Under table 2. Summary of Public Comments, the EPA Repon sets out some of the
community concerns that the EPA gathered. But the EPA Repon does not succeed in
authority thai EPA uses ID enter private Btcilhies mat emit hazardous substances and seek information
regarding the ttf«y of the facility in question.
'See. The Emergency Planning and Cecanunhy-Right4o.Know Act (EPCRA), 42 U.S.C. §§ IJOOI-11050
(1995). EPCRA require* local emergency planing committee* (LEPCs) IB develop emergency response
plans to prepare for and respond to potential cbemical accidents. Sections 11001-11003 address emergency
response placing and require community and facility emergency coordinators, who make determinations
accessary to implement the plan. Section 11004 requires emergency release notification. Sections 11011-
11012 cover reporting requirements, and section 11013 specifies toxic chemical release reporting. EPA.is
the agency responsible for enforcing this law; tec, ebo. the 1994 Supplement to the Hawsi'i Revised
Statutes, Volume 3. Chapter USD Environmental Response Laws and Chapter 121E Hawai'i Emergency
Planing and Community Rights-Know Act. Paragraph 128E-5, that sets out thai at least one local
emergency response planing committee must he established in each county. The committee is subject to
both Chapter 12BE and acetic* 11003 of the Emergency Planning and Community Right-to-Know Act
described above.
'See. Environmental Protection Agency, Region 9, Puna Emergency Response Report. (February 10.
1999).
B3 BSi'ON 9T6t Wi Slt> • 331JJO Men N3S83.TI Et:gi
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OK in/in zc:ci KOK ee/n/eo
••I
and even death.*
LSs pSScnt toxic effects after chronic low level exposure. A ""P^ensjve
£mDiora7mdy was administered to residents of TWO communities exposed to chrome low
evToThy^geTsulfide, and possibly other chemicals. The results were compared to
c± f omVsimUar study administered to residents without exposure to hydrogen
["fide The TWO exposed groups were residents exposed to hydrogen sulf.de emissions
a EW^aTpTaai in AePuna District on the island of Hawai'i, and residents in
TnJ fan industrial facility where hydrogen sulfide was Elated due to
action in a waste water pond. In both of these populations, over 50% of those
.
ear nose and throat, respiratory, immune, cardiovascular, »feA« «* . *£ ™?
both of the hydrogen nilfide exposed populations, there was at least a doubling , m the
^ptoms, J compared to the non
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I em OK la/xil *C:BI NOR ee/r./eo
Puna
and safety standards study.
IV TOE EPA REPORT SHOULD HOLD PGV TO THEIR DUTY TO TAKE
IV. iHt "JESPONHBLITY FORTHEDANGERS POSED
BY RELEASES OF HYDROGEN SULFIDE
to locate an industrial facility that releases toxic chemicals close to a
PGV has a heightened duty to provide for the protection of that
nation, ruv must take responsibility for the external effects of their •*«*"»• *
„», context, PGV's duty to toxic release prevention, and emergency response is not
limited to the property line of their own facility.
should bold PGV accountable for any costs associated with toxic
PGV For example, PGV must provide Hawai'i County with more
and doctors who are specially trained to help people who suffer from
hydrogen sulfide toxicity.
County has not yet allocated the resources to properly protect the Puna
£D toxic releases caused by PGV. For example, the , Hft«f. County
perations Plan fails to address public or environmental threats caused by a
eoc^c-Thazardous substances from a facility such as PGV." The County PUjn
does not specify how to handle hydrogen sulfide releases, or Pcntane fires. Also, in the
5 5 1 FindinES and Recommendations section of the Report, the EPA menbons that.
»mhe plan Us] Unte recognition or attention to "chemical'** 'iindustnar issues.
/tnnex M £e Oil and H«ardous Substances Response Plan, is underdeveloped
Bering Se island', continuing economic growth.'"' EPA has pointed out that the
.dequacy of the Hawai'i County Emergency Operations Plan, is not sufficient because
the section of the Plan dealing with Oil and Hazardous Substance Response is not
currently up to the task of protecting the Community from the chemical hazards posed by
• T1»e Cle» Air Aei. Prevent of Accident,. R«««u«. 42 U.S.C. 1 74 12(r) ( WS). and « CFR P« 68
Ch«n!cd Accident Invention: Rejuteed Subsuae« for Aeeid.nt.1 Maaii htveDUon -^ J*
Muaccment PUn Requirementt. Undo the genertl duty clause in fi 7412(rXJ), e«h mdustntl owner or
%£%£ . ^eaoSduty .0 desiffi «d maiattla . »fe f.ci.iry, ***"*"* » "3K
preveni releue*. Tltey also hive • duty to minim in ihe conwqueoces of accident.! Rleues which do
preveni ree.
occur EPA is the agency rtsponsibk tor enforcing ihii Uw.
» Enviroflnental Ptottoion Agency. Region 9. Pm» Emergency Reroonit Report. « »4 (Febrwy 10.
1999)
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IBZU OK IH/I1) ZC:C1 NOR 66/H/BO
PCV. PGV has created the County's need for specialized toxic chemical emergency
response. BO PGV must finance oil »ueh toxic chemical emergency response efforts.
•
PGV should use local fire stations as emergency response centers that are responsible for
keeping all relevant communities informed. The local fire departments must be specially
trained to handle and monitor hazardous releases. Furthermore, the Puna Community
does noi have nearly enough firefighters to deal with the heightened dangers of fire and
catastrophic chemical release that PGV brings to the Puna Community. Thus, PGV has a
duty to provide the Puna Community with more firefighters who are specifically trained
to combat industrial disasters.
With respect to the adequacy of evacuation efforts, the EPA Report further points out in
the 5.5.9 Findings and Recommendations section that: "The County should develop
training for hazardous materials response to include... [an] emphasis on joint activities
with private sector facility personnel. Joint training is vital for addressing and exercising
the interface mechanisms which avoid confusion in real-world events."13
PGV poses heightened danger to the Puna Community because of the difficulty of
evacuating people from the area. There is only one road leading away from PGV and the
puna Community. As discussed below, the Puna area is very prone to natural disasters
such as volcanic eruption or earthquake. In such a disaster, PGV will likely release
catastrophic levels of hydrogen sulfide. There are at least three prcscbools and a public
school in the area that must be evacuated if there is a toxic release during the day.
Compounding this deadly combination is the fact that the sole exit will likely become
impassable, thus trapping people an the area.
Therefore, PGV must provide alternative evacuation routes such as a new road leading
away from PGV. Also PGV must provide some means to airlift the population away from
PGV in the event of a catastrophic hydrogen sulfide release coupled with road closure or
hazardous congestion. .-
As mentioned above, the Puna Community's has population of elderly persons. Some
members of the Puna Community are sick or disabled. Many of these people are not able
on their own to evacuate the Puna Community immediately in the event of a catastrophic
hydrogen sulfide release. PGV must provide an emergency evacuation team, with
vehicles for rapid evacuation and staff to be responsible for evacuating those who are
unable to do so themselves.
•
The EPA Report should invite PGV to spearhead the integration of all accident
prevention and emergency response efforts. Additionally, PGV must bear the costs
associated with integrating their emergency response efforts with those of the County, not
Hawai'i County.
"Environmental Protection Agency, Region 9, Puna Emergency Reraonie Kepon. at 31 (February 10,
1999)
BSi'ON 9T61
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OH XH'XD ZC'ST KOK 66/H/BO
V. THE EPA REPORT SHOULD CONSIDER THE MAGNITUDE OF DANGER
POSED BY THE GEOLOGY OF PGVS LOCATION
On page four of PGV's own Emergency Response Plan (version 6.3) PGV foresees
natural hazards, (such as lava flows, eanh quakes, and storms) but does not provide
adequate safety measures. PGV is not able to protect anyone from chemical releases
caused by such • natural disaster. Thus. PGV presents an extreme risk due to volcanic
and seismic activity in the area. According to the United States Geological Survey
C'USGS"), Hawaii County is located in Seismic Hazard Zone 4. Puna spans Volcanic
Hazard Zones 1-3. which are the most severe volcanic hazard zones on a scale of 1-9.
PGV itself is located in Kilauea Volcano's East Rift, which has been at 1 the most severe
volcanic hazard rating on the scale." Given the high potential for volcanic events, seismic
events and subsidence in the area that could cause multiple geothermal well blowouts
and open venting of wells, PGV's operation is inherently unsafe. No emergency response
plan could keep the Puna Community safe under these conditions. The emergency
response plans, both of the County of Hawai'i and PGV arc not adequate to protect the
residents of Puna should such a blowout or other emergency occur. A full formal seismic
and volcanic hazard risk assessment specific to PGV and the endangered communities
must be completed before any emergency response plan can viably be designed to protect
the Puna Community.
VI. CONCLUSION
PGV must be closed. No Emergency Response Plan can insure the health and safety of
ihe Puna Community. PGV never should have located within a populated area, especially
an area with so few evacuation routes, and an area that is so prone to natural disaster.
At the very minimum, PGV must immediately adopt and exceed all of the safety
requirements set out in these comments, and all EPA safety recommendations set out in
the EPA Report for Puna Emergency Response Plans. Furthermore, the general safety of
PGV must be continuously monitored by an independent regulating agency. PGV has
proven that it can not be trusted with the safety of the Puna Community. Therefore, it is
up to the EPA to continue on their journey to protect the health and safety of the Puna
Community. This EPA Draft Report is a step in the right direction.
0 InfonBBTion en seismic md volcanic huvd zones is liken from the USGS web-she it
bnp-//hve.wrtu»« r«"/K.»<.rdt/liv«ronet/ aad http://hvo WT.USES cov/carthQuakcs^izardi/ visited on
Friday. June 12, 1MB.
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APPENDIX O
EPA's Response to Comments
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Response to Public Comments on the
Draft Puna Emergency Response Report by
U. S. Environmental Protection Agency Region 9
How related: Public comments as they relate to the EPA Puna Emergency Response Report;
D = directly related, ID = indirectly related, N = not related
Categories: Categories of issues in the report -
1. Exercises
2. Evacuations
3. Revisions to and completion of Hawai'i County Emergency Operations Plan
4. Notifications
5. Chemical hazards
6. Air monitoring
7. Technical work group
8. Permit requirements
9. Seismic issues & natural hazards
10. PGV Emergency Response Plan
ll.RMP
12. Funding
13. Community involvement
Referrals: Organizations to whom EPA is sending referral letters highlighting specific public comments
County of Hawai'i Central Fire Department (Fire)
County of Hawai'i Central Police Department (Police)
County of Hawai'i Civil Defense Agency (County CD)
County of Hawai'i Local Emergency Planning Committee (LEPC)
County of Hawai'i Mayor's Office
County of Hawai'i Planning Department (County Planning)
Hawai'i State Emergency Response Commission (SERC)
Hilo Medical Center
Pahoa Elementary, Intermediate and High Schools (Pahoa Schools)
Puna Geothermal Venture (PGV)
State of Hawai'i Department of Civil Defense (State CD)
State of Hawai'i Department of Health (HDOH)
State of Hawai'i Department of Labor and Industrial Relations, Hawai'i Occupational Safety and Health
Division (HIOSH)
United States Department of Health and Human Services, Agency for Toxic Substances and Disease
Registry (ATSDR)
United States Geological Survey (USGS)
Page 1 • August, 2000
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Commenters and Comments
I Categor
y
Referrals
1.0 Bonnie Bator, Community Resident
1.1 Section 1.5, Table 1 - Obtain a copy of Dr. Wilson Goddard's report
on geothermal energy. EPA has obtained a copy of Dr. Goddard's
report (Part I) which was reviewed and filed as part of the EPA
public record.
ID-5
No referral
1.2 Section 3.1, Table 3 - under 'a. Facility Description' address the
other toxic chemicals besides hydrogen sulfide and combinations of
chemicals such as cadmium, mercury and radon. EPA quoted
verbatim the Geothermal Resources Permit Condition #26 to show
the requirements PGVfollowed In preparing its Emergency
Response Plan. The Review Team used EPA's chemical safety
audit guidelines and OSHA worker protection standards as a basis
for its review. Please refer to Section 4 of the final report for a
complete description of the legal authorities the Review Team used
during its review. EPA has referred your comment to the Hawai'i
County Planning Department which issued the geothermal
resources permit, so it can consider adding additional chemicals to
the permit.
ID-5
County
Planning
Page 2 • August, 2000
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1.3 Section 7.2.3 -- recommendations do not adequately address H2S
monitoring: monitors should be located at ground level.
EPA agrees that for the purposes of this plan the hydrogen sulfide
(HjS) monitors should measure air quality in the "breathing zone"
of approximately six feet There are no federal regulations which
prescribe the requirements of siting hydrogen sulfide monitors.
EPA monitoring regulations [40 CFR Part 58] address the
monitoring of "criteria"pollutants, Le. ozone, paniculate matter,
carbon monoxide (CO), sulfur dioxide (SO,), nitrogen dioxide
(NO,) and lead. In general, EPA, State and local agencies collect
data on these pollutants for use in regulatory programs mandated
by the Clean Air Act. EPA monitoring regulations contain specific
siting criteria for monitors that measure these pollutants. In order
for the data collected to be valid for regulatory use, the criteria
pollutant monitors must meet all relevant siting criteria, including
probe height. However, since HJ5 is not a criteria pollutant, these
regulations can be used as simply a guide to siting the samplers, not
a requirement.
Minimum probe heights for collecting ozone, CO, SO, and NO, data
are three meters (about 10 feet). For paniculate matter and lead
monitoring, the minimum probe height is two meters (about 6.5
feet). The reason the minimum probe heights are set where they are
is to obtain the most representative sample of ambient air in order to
measure concentrations of a particular air criteria pollutant. If the
probe is too close to the ground, the air sampled may be influenced
by the effect of ground turbulence or near ground sources (e.g.
automobile exhaust).
Since the object of the monitoring ofHJS is to provide information
to the community on HJS levels they are exposed to, not to
implement a regulatory program mandated by the Clean Air Act, it
is absolutely appropriate to site the monitor probes at the breathing
height level (six feet). The data collected will be used to indicate
whether certain actions in the emergency response plan should be
triggered. If there are concerns about where the HjS is coming
from (i.e. PGV, natural vents, automobiles, etc.) then supplementary
monitors can be set up at different heights to try to assess
contributions from different sources. The primary purpose of the
HfS monitoring is to protect the health of the community; therefore,
the four monitoring sites operated by the Hawaii DOH should
sample air at breathing height (six feet).
D-5&6
HDOH - Clean
Air Branch
Page 3 "August, 2000
-------
1.4 Finding 5.5.10 - The State Department of Civil Defense prepared the
Hawai'i County Emergency Operations Plan for the County of
Hawai'i. On March 8,1990, the Mayor of the County- (who is also
the State Deputy Director of Civil Defense) and the Director of
Hawai'i State Civil Defense signed the Plan. The document as signed
was incomplete. The State Civil Defense Director, as well as the
Mayor of Hawai'i, overstepped the County of Hawai'i Civil Defense
Director. EPA takes note of this comment and has referred your
letter to the Hawai'i SERC and Hawai'i County LEPC. Hawai'i
County is in the process of redrafting its Emergency Operations
Plan, Hazmat Annex, and EPA will make every effort to encourage
improvement.
D-3
SERC
LEPC
2.0 Wayne Carvalho, Police Chief, Hawai'i County Police
Department
2.1 Hawai'i County Emergency Operations Plan needs to include specific
joint assessment and reaction response plans for the necessary
responding agencies to include their activities. EPA has referred this
comment to the Hawai'i SERC, Hawai'i County LEPC, and State
and County Civil Defense Agencies.
D-3
SERC
LEPC
County CD
State CD
2.2 We recommend that these plans should include mandatory annual
table top exercises to insure interagency coordination and
preparedness. EPA concurs that annual exercises, a tabletop or
more complex, should be required to ensure interagency
coordination and preparedness. The National Response Team,
which includes EPA, recommends an annual review and exercise of
emergency response plans. EPA has referred this comment to the
Hawai'i SERC, Hawai'i County LEPC, and State and County Civil
Defense Agencies.
Hawai'i County conducted and successfully completed its first
tabletop hazardous materials exercise on June 22,1999. The
exercise was co-sponsored by the Hawai'i County Local Emergency
Planning Committee, and EPA noted that the Hawai'i County
Police Department was a major participant in both planning and
conducting the exercise. Several other emergency response agencies
from the county and state also participated in this training exercise.
D-l
SERC
LEPC
County CD
State CD
2.3 PGV should clarify what appropriate clothing and protective
equipment its personnel, as well as outside responding agencies will
use for different response activities. EPA has referred this comment
to PGV and the Hawai'i County Central Fire Department and
LEPC.
D-5&10
PGV
Fire
LEPC
Page4 "August,2000
-------
3.0 Jack Dean, Vice President & General Manager, Puna Geothermal
Venture
3.1 General comments - the report's statement that "the PGV Emergency
Response Plan does not address any coordination issues..." is simply
not true. EPA has revised the Executive Summary to state that at
the time of the review, PGV's Emergency Response Plan did not
fully address coordination issues.
D-13
PGV
IIDCH
Fire
Police
County CD
LEPC
3.2 Community concerns (section 1.3) - reference to chronic health
impacts is not relevant. EPA has clarified that the focus of the
Emergency Response Review was acute health effects resulting
from accidental releases. The Review Team did not look at chronic
effects.
ID-5
HDOH
3 3 Section 1.5, Background - disagrees with EPA's characterization of
the release history. The release history is based on direct quotes of
published reports on the release investigations.
D-5
No referral
3.4 Section 1.5, Table 1 - this table is not relevant to the scope of the
independent review. Table 1 is directly relevant to the scope of the
independent review. Accidental releases in the past prompted this
review of PGV. In general, the accident history of a facility directly
relates to emergency preparedness and accidental release
prevention, which is the reason facilities are required to include a
five-year accident history in their risk management programs under
40CFRPart68.
D-5
No referral
3.5 Section 1.5, Table 2 - listing public comments unrelated to the
emergency response plans is irrelevant. PGV believes that several,
specific questions and comments should be deleted. EPA has kept all
comments in the final report for a full record of public input.
D-13
No referral
3.6 Section 6.1, General - requests a rewrite of the first sentence; PGV
has designated personnel on every shift to take initial immediate
action and notify agencies; PGV believes it has addressed OSHA
requirements. Some of the Review Team's recommendations were
based on OSHA standards. In Hawai'i, OSHA requirements are
enforced by HIOSH, so EPA referred these findings and
recommendations to HIOSH. During a teleconference with HIOSH
11/3/99, EPA learned that a HIOSH inspection of PGV was opened
on 8/11/98. Citations were issued, including one on emergency
shutdown procedures. HIOSH determined that written shut down
procedures are in PGV's emergency response plan (although they
are not in the emergency action plan), and this is acceptable to
HIOSH. Final citations were withdrawn on 9/17/99.
D-10
HIOSH
PGV
Page5 "August,2000
-------
3.7 Section 6.2.1 - Operation and shut down of critical equipment are
addressed and cross-referenced in the ERP; personnel are trained in
the relevant procedures. The Review Team was not given the
opportunity to review the PGV Operations Manual, and EPA did not
receive a copy for review. HIOSH informed EPA (11/3/99
teleconference) that HIOSH is satisfied with the written emergency
shut down procedures in PGV's emergency response plan.
D-10
HIOSH
PGV
3.8 Section 6.2.2 - First aid and medical assistance personnel are trained
and required to provide first aid level response and/or CPR; training
records exist to demonstrate this. This comment is reflected in the
draft report, and it will stand as written unless PGV sends
documentation to verify this statement.
D-10
HIOSH
PGV
3.9 Section 6.3.1- HAZWOPER and response by outside parties: EPA
should read this comment carefully; PGV states that its program does
address the responders' roles. EPA takes notice of this clarification
and has revised the 'Report Disclaimer' to reflect that some of the
recommendations in the draft report have been adopted already.
D-10
HIOSH
Fire
Police
Hilo Medical
Center
3.10 Section 6.3.3 - Release reporting and emergency notification: the
EAP identifies when calls to various agencies will occur; personnel
are trained on release scenarios; PGV has an internal communication
requirement to notify agencies. "PGV would always notify the
agencies if a significant event were to occur." Determining a
"significant event" is a subjective judgment call, and release
notification has not always occurred in the past PGV should
consider emergency notification procedures that immediately notify
the county's emergency response agencies when upset conditions
occur that would alert nearby neighbors by vibration or visual,
auditory and/or olfactory senses. This emergency notification to
the response agencies may be above and beyond the notifications
required under various permits or federal, state and local
regulations. However, it would be advantageous for the emergency
response agencies to receive initial incident information from the
facility rather than from nearby neighbors. This notice would help
alleviate any possible misinformation to the emergency responders
and the nearby residents inquiring about the incident. This
notification would also provide the emergency response agencies
with direct and current situation reports from the facility.
D-10
Fire
Police
County CD
HDOH
3.11 Section 6.3.5 - Process hazards analysis: PGV has conducted a PHA
for the facility, identifying all emergency scenarios that could occur
at the facility. Staff conducted white board, what-if, hazop/what-if,
and hazard analysis/what-if for the entire facility. PGV will do a
follow-up review of its PHA with outside responders. EPA takes
notice of PGV's efforts to work with response agencies and its
willingness to share process hazards analyses.
D-5 & 10
Fire
Page 6 • August, 2000
-------
3.12
3.14
Section 6.3.6 -- PGV responders and coordination with community
response and medical personnel: the OSHA standard 1910.120 has
been met. PGV requests that EPA discuss the results of its letter to
HIOSH and then remove this section. EPA has discussed this issue
with HIOSH and takes note that PGV has made improvements.
3 13 Section 6.3.9 - Emergency response personnel and the buddy system:
requesting that EPA remove section 6.3.9. Section 6.3.9 remains as
written in the draft report because EPA received no updated
documentation showing that this recommendation was
implemented.
Section 6.3.10 -- PGV facility operates with a true "safety culture,"
the safety manual references roles and responsibilities and is cross-
referenced in the HAZWOPER program. This is required under
OSHA regulation. EPA has clarified that the term "check support"
means a system of checks and balances on the authority of the
incident commander. EPA has incorporated PGV's comment in the
final report.
D-10
HIOSH
D-10
D-10
HIOSH
HIOSH
3.15 Section 6.3.12--Training for temporary employees: H2S, hazards,
PPE and duties are covered. EPA was not given an opportunity to
review the HAZWOPER program.
D- 10
HIOSH
3.16 Section 6.3.12 - Personal protective equipment program is covered in
the safety manual and cross-referenced in the HAZWOPER program
and ERP; 1910.120(q)( 10) is met. EPA was not given an
opportunity to review the HAZWOPER program.
D-10
HIOSH
3.17 Section 7 -- Overarching Issues: issues beyond the review of
emergency response plans are included in section 7. EPA takes
notice of this comment and has revised Section 7.1 to clarify why
the overarching issues are included in Section 7 of the final report.
D- 10
HDOH
SERC
LEPC
4.0 Joyce Folena and Gregory T. Smith, Community Residents
4.1 Contact Captain Dale Fergerstrom, Kona Police Department, re:
traffic safety problems associated with evacuations. EPA takes
notice of this comment and has referred your letter to the Hawai'i
County Civil Defense Agency, Police Department and Local
Emergency Planning Committee (LEPC).
D-2
County CD
Police
LEPC
PGV
4.2 Discuss with Captain Fergerstrom the lack of alternate escape routes
out of the Lower Puna areas during an emergency. EPA takes notice
of this comment and has referred your letter to the Hawai'i County
Civil Defense Agency, Police Department and Local Emergency
Planning Committee (LEPC).
D-2
County CD
Police
LEPC
PGV
Page? "August,2000
-------
4.3
4.4
5.0
5.1
5.2
5.3
5.4
6.0
6.1
Include Captain Fergerstrom as a speaker in a series of public
meetings needed as a result of the Draft Report of Puna Emergency
Response Plans. EPA hus decided not to sponsor public meetings on
this report. EPA 's focus is on a written response to comments and
support to the State and County of Hawai'i for implementing the
report recommendations. EPA awarded a grant to the Hawai'i
SERC and Hawai'i County LEPC on October 25, 1999, for updating
and upgrading the Hawai'i County Emergency Operations Plan -
Hazardous Materials Annex. These revisions will include
information submitted to EPA under the Clean Air Act risk
management and accident prevention program, as well as
recommendations, public comments and response to comments from
this report
Formally record the community meetings to give the community
access to the minutes. Please refer to response 4.3 above.
Joyce Folena and Gregory T. Smith, Community Residents
Requested a senes of meetings including a public meeting with USGS
employees at Volcanoes National Park. Please refer to response 4.3
above.
Requested public meetings with EPA to address the comments in the
Draft Report. Please refer to response 4.3 above.
Record public meetings for future reference by community members
and appreciate prompt attention to their requests and needs. EPA
agrees that recording public meetings in a written format is
important for community involvement.
Requested further information and communication concerning
volcanic and seismic conditions in the Kilauea East Rift Zone in the
vicinity of PGV. Specifically mentioned Don Swanson, Scientist in
Charge at Volcanoes National Park, state and county departments and
agencies, and PGV staff as sources of information. This is an
excellent idea; EPA appreciates all of these comments and suggests
that the Hawai'i County LEPC is an appropriate forum for follow-
up. The LEPC is an open public forum, and its primary mission is
to work continually for improved emergency response planning and
preparedness at the local level EPA encourages active
participation by all community members who have an interest in
emergency response issues.
Gary 'Dov' Gertzweig, Vice President, The Earth Harmony
Foundation
Consider the shut-down of the geothermal plant.
ID-13
i
!
ID-13
ID-9
D-13
ID-13
ID-9
N
LEPC
SERC
LEPC
SERC
LEPC
USGS
LEPC
All referral
agencies
State CD
County CD
USGS
LEPC
No referral
PageS "August,2000
-------
6.2
6.3
6.4
6.5
7.0
7.1
8.0
8.1
8.2
Alternative energy sources are safer, less costly and non-disruptive to
the environment.
The geothermal plant emits toxic chemicals and changes the
dynamics of a very sensitive ecological area.
Concerned about children and wildlife who breathe released gases,
danger of fire, runoff going to the Puna Pu'ala'a pools, noise
pollution and the effect on water catchment tanks when H2S rains.
Shannon Fitzgerald has lists of complaints from families in the Puna
area.
EPA takes notice of these comments. Although they do not directly
relate to the emergency response review, EPA appreciates these
environmental concerns and is working with Hawai'i County and
PGy to prevent future accidental releases.
Gary Gill, Deputy Director for Environmental Health, HDOH
and Chair of the Hawai'i State Emergency Response Commission
We do not have any comments to offer at this time. EPA appreciates
HDOH's and the SERC's interest in this review process and referral
of the draft report to other LEPCs in the State ofHawai'L
Jane Hedtke, Community Resident
There needs to be adequate funding to provide equipment, training,
including hazmat exercises, and cover day to day expenses. EPA
encourages the State and County of Hawai'i to pursue on-going
funding sources for providing more hazmat response training and
planning opportunities, as well as providing for necessary hazmat
response equipment.
EPA awarded a $25,000 grant to the Hawai'i Department of Health
on October 25, 1999. HDOH then passed this grant to Hawai'i
County for updating and upgrading the hazmat portion of its
Emergency Operations Plan. The upgrade will also include
information from the risk management plans submitted by Hawai'i
County facilities (including Puna Geothermal Venture) to EPA in
June 1999.
Concerned that the County and State agencies cannot or will not
budget enough money for implementation of the plan
recommendations, which will become piecemeal. Convinced that the
County and State are not financially committed to be ready for the
next geothermal accident. Please refer to response 8.1 above.
N
i
ID-5
ID-5
ID -13
—
D-12
D-12
No referral
No referral
No referral
No referral
No referral
State CD
County CD
Fire
PGV
LEPC
State CD
County CD
County
Planning
LEPC
Page9 "August,2000
-------
8.3 Require the permittee to bear the costs of police and fire protection
associated with the proposed activities. Mitigation of these effects is
out of reach financially for local government agencies. The granting
of the GRP was based on criteria, one of which stated that the
proposed activities "would not unreasonably burden public agencies
to provide... police and fire protection." EPA encourages PGVto
review the criteria of its geothermal resource permit, that the facility
"would not unreasonably burden public agencies to provide...
police and fire protection..."
D-12
PGV
County
Planning
Police
Fire
State CD
County CD
HDOH
9.0 Michael Hyson and Adrian Barber, Community Residents
9.1 Respectfully requests that the community be involved in aU levels
inclusive of conception, planning and implementation, or any other
aspects of emergency response plan procedures outlined or
contemplated in the draft report, now and in the future. EPA
encourages community members to participate in emergency
planning efforts such as through LEPC meetings. The Hawai 'i
County LEPC is involved in updating the county's emergency
response plan, and community involvement is part of this planning
process. The LEPC may want to consider being the catalyst for
convening a task-oriented subcommittee to serve as the technical
workgroup described in EPA's recommendation 7.2.1. Based upon
comments received on this draft report, EPA suggests that at least
one member of the technical workgroup could represent the
community-at-large.
D-3,10
&13
LEPC
State CD
County CD
10.0 Julie Jacobson, Council Member, District 6, Hawai'i County
Council
10.1 Look at the Goddard report for a more realistic and substantive
analysis of events surrounding the release June 12-13, 1991. EPA
has obtained Part I of Dr. Goddard's report, and it is now part of
the EPA public record.
ID-5
No referral
10.2 Section 3.1, Table 3 — under (a) facility description, a full analysis of
chemicals could be found in materials supplied to EPA at the time of
PGV's request for more injection wells. PGV followed the
requirements in its Geothermal Resources Permit, Condition #26 to
prepare its emergency response plan. EPA has referred this
comment to the Hawai'i County Planning Agency which issued the
Geothermal Resources Permit.
The Review Team evaluated PGV's emergency response plan
following EPA chemical safety audit guidelines and OSHA
standards for process safety management and hazardous waste
operations. Please refer to Section 4 of the final report for a
complete description of the legal authorities the Review Team used
during its review.
D-5
County
Planning
Page 10 • August, 2000
-------
10.3 Section 5.3.5, Annex M -- this section should be complete and up to
date with information supplied by independent authorities. EPA has
recently awarded the LEPC a grant to update Annex M with
complete and up to date information.
D-3
LEPC
SERC
HDOII
County CD
10.4
Section 5.5.8, Recommendation (b) - current monitoring plans and
devices do not adequately measure H2S concentrations at ground
level. All non-condensable gases and heavy metals must be
monitored. According to the EPA Region 9 Air Division, the
California Air Resources Board has guidance and standard
operating procedures for monitoring non-condensable gases and
heavy metals. California uses paniculate matter monitors for
monitoring heavy metals on particulates. Regarding monitoring
at ground level - see response to comment 1.3 above.
D-6
HDOH - Clean
Air Branch
It is possible to monitor for heavy metals. Region 9 staff agree that
the steam from geothermal facilities can contain heavy metals.
Monitoring for ambient levels of heavy metals is performed using
high volume total suspended paniculate samplers. Paniculate
matter containing heavy metals is collected on a filter medium and
must be taken to a laboratory for analysis. Heavy metal monitoring
cannot be performed "real time". There will be a lag time between
when the sample is taken and when the results of the analysis are
known. For the purposes of providing information to the
community on what air contaminants are in the air they breathe we
agree that this type of monitoring could provide valuable
information to the community, however at this time there are no
ambient air quality standards set for heavy metals in the
atmosphere.
10.5 Section 5.5.10 -- Hawai'i County Civil Defense Director was
bypassed by the Mayor and State Civil Defense Director. EPA takes
notice of this comment and will continue to work with Hawai'i
County to upgrade the County Plan.
ID-3
SERC
LEPC
County CD
Mayor
10.6 Section 6.3.1 --... they (PGV) should pay for onsite monitoring and
adequate responses to toxic releases. They have proven themselves
unwilling, unable and apathetic to take care of emissions from their
facility. They must be held accountable. EPA takes notice of this
comment and has referred your letter to PGV management for
follow-up. PGV has the legal responsibility to notify local, state and
federal authorities of releases of regulated hazardous substances at
or above their reportable quantities. PGV monitors HJ5 emissions
at three locations and is required to notify the state and local
agencies if concentrations exceed stipulated levels.
ID - 6, 8
&10
PGV
HDOH
County
Planning
County CD
Page 11 • August, 2000
-------
10.7
10.8
10.9
10.10
10.11
Section 6.3.10, Finding - the need for emergency access to lands
controlled by private contractors for public safety has been restricted
in contracts drafted by Mayor Yamashiro. Although EPA recognizes
that land use decisions are locally controlled, emergency access is
critical for public safety. The Uniform Fire Code authorizes the
Fire Department to direct an operation as necessary at the scene of
afire or other emergency involving the protection of life or
property. Hawai'i County Fire Department is also empowered to
perform any rescue operation or take any other action necessary in
the reasonable performance of its duty.
Section 7.2.3 - recommendations fail to clearly mandate the needed
methodology for accurate monitoring of all geothermal hazards.
Please refer to EPA 's response to comment 1.3 above.
Section 7.2.6, Finding -- two PGV employees on this team could
easily lead to conflicts of interest. Recommendations could include
provisions to prevent such conflicts. Checks and balances are very
important, and active participation by members of the public is one
means of assuring that conflicts of interest will be prevented. Other
checks in the system, as required by the federal Emergency
Planning and Community Right-to-Know law, are state
confirmation of 'LEPC members, public notification ofLEPC
activities, and open public meetings that are announced throughout
the community. EPA is hopeful that a reactivated LEPC will be a
positive step toward increased community involvement.
Appendix H -- PGV has been unwilling to reveal anything of
substance to public officials interested in formulating viable
emergency response plans. EPA must have full access to PGV
documents. EPA agrees with your comment on the importance of
full access to documents related to the emergency response plan and
has referred this comment to PGV management for their follow-up.
Protect the residents' health before trying to protect the fiscal well
being of PGV. The purpose of EPA is to protect and enhance the
environment today and for future generations to the fullest extent
possible under the laws enacted by Congress. EPA 's legal authority
is to protect the environment and public health.
ID-3
D-6
ID-3&
13
D-10
ID -10
LEPC
County CD
Counrv FD
County
Planning
Mayor
HDOH - Clean
Air Branch
LEPC
SERC
PGV
No referral
Page 12 • August, 2000
-------
11.0
11.1
11.2
Anakura Melemai, Community Resident
Section 5.5.8 -- concerned about chronic effects of H2S, heavy metals,
non condensable gas emissions from the PGV facility and how they
affect those who already have a medical condition such as bronchitis,
asthma, headaches, etc.
The recommendations primarily address issues related to public
evacuations. Concerns about chronic effects of chemical releases
were not part of the Emergency Response Plan review. The Review
Team does not have expertise in chronic effects of chemical
releases.
Section 3.1, Table 3 - under (a) facility description, has anyone
tested and analyzed emissions for cadmium, radon, mercury, etc.?
Concerned that the humidity in HI makes these emissions more
hazardous. In Appendix H of the PGV Emergency Response Plan,
Version 6.3, PGV reports on the "Hazards Analysis of the Possible
Well - Related Uncontrolled Flow Event and Power Plant Emission
Scenarios Puna Geothermal Venture Project." Tables provide
summaries of modeled geothermal vapor phase emission and brine
aerosol impacts. PGV conducted this hazards analysis in
consultation with the Hawai'i Department of Health and its
consultants. A copy of this plan is in your community library.
For the 'facility description' on page 17, EPA quoted verbatim the
Geothermal Resources Permit Condition #26 to show the
requirements PGV followed in preparing its Emergency Response
Plan. The Review Team used EPA's chemical safety audit
guidelines and OSHA worker protection standards as a basis for its
review. Please refer to Section 4 of the final report for a complete
description of the legal authorities the Review Team used during its
review. EPA has referred this comment to the Hawai'i County
Planning Agency which issued the Geothermal Resources Permit.
D-5
D-5
HDOH
County
Planning
County
Planning
HDOH - Clean
Air Branch
11.3 Environmental justice concerns about this and all geothermal projects
in The Kingdom of Hawai'i, presently operating in violation of
Hawaiian Kingdom Law and in contravention of Article VIII, Treaty
of 1850. EPA notes this comment.
N
No referral
12.0 Jon Olson, Community Resident
12.1 Concerned about the State and County refusal to enforce even the
most trivial regulation on the geothermal industry. EPA has sent
your concerns to the Hawai'i County Planning Department and
Hawai'i Department of Health. State and County enforcement
issues were outside the scope of the emergency response plan
review.
ID-8
County
Planning
HDOH
Page 13 • August, 2000
-------
12.2
12.3
13-15
13.0
13.1
13.2
13.3
13.4
Concerned about the State's redrilling of the H.G.P.A. well for the
purpose of abandonment. No new or updated emergency response
plan was filed; the community was again left in the dark. These are
important issues, but the Review Team conducted a focused
assessment of emergency preparedness and response capabilities in
Hawai'i County and the PGV facility.
To date I am aware of no movement by any State or County agency to
implement EPA recommendations. EPA anticipates implementation
of the recommendations in the report once this final version is
released. In the meantime, the Hawai'i County Local Emergency
Planning Committee (LEPQ has started implementing some of the
recommendations pertaining to community planning. EPA awarded
a $25,000 grant for Hawai'i County to update its Emergency
Operations Plan, Haunat Annex. The LEPC has begun meeting on
a regular basis and has participated in a training exercise with
response agencies.
Athena Peanut, Rend Siracusa and Shelley Stephens
These three reviewers commented on the PGV plan, rather than
EPA 's draft report. Athena Peanut, Rene Siracusa and Shelley
Stephens make excellent points in their reviews of the PGV
Emergency Response Plan. EPA recognizes that the issues raised
are technical, economic, social/equity and political in nature, and
that they are local issues that need to be resolved locally. As such,
EPA has referred these comments to the Hawaii County LEPC for
further public discussion and resolution.
Based on these and other comments received, EPA has
recommended that the Hawaii County LEPC establish a technical
work group that could be formed as an ad hoc subcommittee to the
LEPC. EPA further suggests that at least one member of the
technical work group represent the public at large. EPA continues
to be very interested in emergency planning and public safety issues
in Hawaii and will remain involved through participation in LEPC
and SERC activities, awarding grant funds, and support for plan
updates, training and exercises.
Athena Peanut, Friends of the Red Road
Definition of "nearby residents" needs to be corrected.
Agency responsible for evacuating nearby residents - additional siren
needed.
Evacuation notification procedures - community participation
requested.
Averaging of peak monitor recordings - concerned about this method.
ID-8&
10
D-3
D-10
D-5 & 1 1
D-2
D - 2 & 4
D-6
County
Planning
LEPC
All referral
agencies
PGV
LEPC
SERC
HDOH
PGV
County CD
County
Planning
Police
Fire
County CD
PGV
County CD
HDOH
Page 14 • August, 2000
-------
13.5 Disclosure of all emission toxins.
1 3.6 Adequacy of monitoring equipment.
13.7 State of the art monitoring system to be located at Pahoa schools.
13.8 Community involvement requested.
13.9 Documentation offered; EPA requested and received documentation
for asterisked items.
14.0 Rene Siracusa, Puna Outdoor Circle
Please refer to response 13-15 above.
14.1 In Version 6.3 of PGV's Emergency Response Plan (2/1/96), clarify
definition of "ambient level" to take into account local conditions.
14.2 Notification lists - PGV's 24-hour information line does not always
respond. EPA notes that further discussions are needed between
PGV, Hawai'i County Civil Defense Agency and the LEPC. The
information line should be answered 24 hours per day if it is listed
as a 24-hour line.
14.3 Notification to public -- specific improvements are needed, including
a siren on site. For 14.3-1 6, please refer to response 13-15 above.
1 4.4 Emergency facilities available off-site ~ fire and police services are
not adequate.
1 4.5 Off-site emergency facility capabilities - Table 4- 1 needs revision.
14.6 Evacuation of persons on-site — evacuation routes not adequate and
Puna Police are shorthanded.
1 4.7 Evacuation of nearby residents - need to include residents beyond
3,500 feet from PGV's fence line.
14.8 Power plant operation - include sodium hydroxide in potential
emissions.
D-5
D-6
D-6
D-13
D-13
ID-3&
6
D-4
D-4
D-3
D-3
D-2
D-2
N
PGV
HDOH
PGV
HDOH
Pahoa Schools
HDOH
HDOH
LEPC
County
Planning
PGV
PGV
County CD
PGV
County CD
PGV
PGV
Fire
Police
PGV
County CD
PGV
Police
Fire
County CD
PGV
LEPC
County CD
'olice
Fire
*4o referral
Page IS "August,2000
-------
14.9 Natural hazards - emergency notification needs to be improved.
14.10 Lightning - correct statements about potential for lightning.
1 4. 1 1 Site releases under routine and upset conditions (Table 8- 1 ) -- address
computer failure.
14.12 Geothermal steam and fluid releases: nature of hazard — include
cadmium and its health effects, revisit H2S health effects and do not
put so much faith in modeling. Complete sampling and analysis
program for non-H2S components prior to acceptance of ERP.
14.13 Noise hazard: nature of hazard - revisit the formula for estimating
decibels.
1 4. 1 4 Spills and leaks: nature of hazard - when pentane burns it releases
dioxins. In response to your comment, EPA staff have researched
pentane reactions. The pentane on site at PGV is in a closed cycle
and is isolated from the geothermal steam. Pure pentane in a closed
cycle is a hydrocarbon that does not contain chlorine which would
be necessary to form dioxins. When pentane burns, it releases
carbon dioxide and water.
14.15 Brief history of H2S accidents (Appendix B) -- look at history of PGV
& predecessors.
14.16 EPA Review Team recommendations ~ include community members
in technical work group.
15.0 Shelley Stephens, Community Resident
Please refer to response 13-15 above.
15.1 The emergency response plan must be revised based on more
thorough investigation of the facts for worst case scenario and plan of
action for notification. The plan should be revised and resubmitted
for public review. The Review Team reviewed version 6.3 of the
plan.
1 5.2 Volume II was not made available in Pahoa Public Library, where
some of the greatest concerns about H2S & geothermal health related
issues are present in the community.
1 5.3 Worst case scenarios were missing from Volume II, and they are
necessary to determine adequacy of the ERP.
ID-9
ID -9
ID-10&
11
D-5
N
ID -'11
ID- 10 &
11
D-7&
13
D-5, 10
& 11
BD-10&
13
ro-5, to
&11
PGV
Count> CD
PGV
County CD
PGV
County CD
PGV
HDOH
PGV
County
Planning
PGV
HDOH
PGV
LEPC
PGV
HDOH
County
Planning
PGV
PGV
HDOH
Page 16 • August, 2000
-------
15.4
15.5
15.6
^
"Lightening" section of the plan is vague re: notification of residents
and public facilities
D-4.9&
10
^
Requested an automated, computerized phone network for emergency
notification, priced at approximately $60,000. EPA has funded Puna
MMamaPono to develop a work plan for this project Dr. WUson
Goddard developed a similar emergency alert system for Lake
County, CA, the site of a large geothermal facility, and the CA
project cost approximately $60,000. In the meantime, Hawai'i
County Civil Defense can override all signals of the eleven radio
stations on the Big Island when needed for an emergency alert
signal and broadcast.
"Black-Out Scenario" -- emergency backup generators needed for air
conditioners in public schools located within the 'ring map areas.'
State ofHawai'i Civil Defense has a very sound backup power
supply that could be used as one example for the public school
system. This issue would need further study and has been referred
to the organizations listed in the referral column.
ID-4
ID-13
PGV
County CD
County CD
Pahoa Schools
County CD
LEPC
HDOH
Page 17 "August,2000
-------
15.7 Evidence of water contamination of one of the largest aquifers in the
Puna area, at wells tested near the injection sites. Concerned about
lead, other heavy metals, chemicals and toxins. Requested that EPA
take the testimony of an ex-worker who saw the Geothermal (PGV)
illegally pumping toxic waste into a crack in the lava rock ground and
knows who did it.
Regarding concerns about lead, other heavy metals, chemicals and
toxins, PGV has provided the Hawai'i Department of Health with
over five years of analyses ofPGV's injectate. Parameters tested
include metals and volatile and semi-volatile organic compounds.
The injected fluid does contain metals, and three organic and
semi-volatile organic compounds have been detected at very low
levels. However, continuous and annual mechanical integrity
testing ofPGV's injection wells demonstrates that injected fluids
have only entered the injection zone. This zone is at a depth below
4,000 feet which is 2,000 feet below the base of the shallow aquifer.
Injection well KS-3 at one point had a leak in its liner but not its
casing, so injectate did not enter the shallow aquifer. KS-3 was shut
in until the liner was replaced.
PGV has also provided the Hawaii Department of Health with over
five years ofgroundwater monitoring information. The collection
ofgroundwater data began prior to injection, to provide a baseline
ofgroundwater quality. Review of the data indicates that the
chemical parameters in the groundwater have been fairly constant
since groundwater monitoring began.
Regarding possible impacts to groundwater from the blowout of
KS-8, a 1994 V. S. Geological Survey report entitled "Potential
Effects of the Hawaii Geothermal Project on Ground-Water
Resources on the Island of Hawai'i" noted that chloride
concentrations and chloride/magnesium ratios in monitoring well
MW2 increased in 1991 and 1992, as did temperature from June
1991 through 1992. Temperature continued to increase from
September 1992 through April 1993 according to a 1994 U.S.
Geological Survey report entitled "Chemistry of Spring and Well
Water on Kilauea Volcano, Hawaii and Vicinity." The former
USGS report states that "the timing of these changes at MW2 and
the proximity of this well to KS-8 indicate a possible relation
between the MW2 chemical changes and the blowout of KS-8 in
June 1991. Although the uncontrolled steam discharge at the KS-8
wellhead lasted for 31 hours, temperature measurements indicate
that steam continued to leak upward past the 13-inch casing shoe at
2,128 feet until the well was finally quenched and plugged several
months later."
In the future, if anyone sees dumping of hazardous materials,
please contact EPA immediately through the 24-hour spill phone
hotline: 415-744-2000.
ID-8
HDOH
USGS
Page 18 "August,2000
-------
16.0
16.1
16.2
Patricia Stewart, Exodus Foundation
Expert studies have been ignored; these include a geological study by
Goddard and Goddard and a health study by Dr. Legator from Texas.
EPA has obtained a copy of Dr. Goddard's report (Part I) which
was reviewed and filed as part of the EPA public record. The
Legator study has not been published, but EPA has been in contact
with Dr. Legator and will include his study in the public record as
soon as it is available.
N
No referral
Residents' testimony has been overwhelmingly ignored and ridiculed.
EPA takes all public comments seriously and will continue to work
with State and local agencies in Hawai'i to implement the report
recommendations.
16 3 Please consider EPA's taking a more active role; please do not return
administration to State of Hawai'i. EPA is the lead agency for
enforcing the underground injection control (UIC) permit and will
be monitoring compliance with the permit. Please read the response
to comments for the UIC permit, available in your public library,
which explains EPA's role in detail. EPA will continue to actively
participate in the Hawai'i SERC and LEPC activities as well. EPA
agrees with you about the importance of protecting and preserving
Hawai'i's environment.
N
•to referral
No referral
17.0 Annie Szvetecz, Community Resident
17.1 Community involvement -- involve affected residents in the process
of improving emergency response in Puna, including the technical
work group. As a new member of the LEPC, EPA hopes that your
active participation will help improve community involvement.
Based on these and other comments received, EPA has
recommended that the LEPC establish a technical work group that
could be formed as an ad hoc subcommittee to the LEPC. EPA
further suggests that at least one member of the technical work
group represent the public at large.
D-13
LEPC
17.2 Hazards analysis and accidental release prevention - PGV must
complete a hazards analysis, worst-case scenario (with natural
disaster + chemical release) and off-site consequence analysis and
include pentane, H2S and sodium hydroxide. County should include
in its plan: hazards identification, vulnerability analysis and risk
analysis. EPA has received information submitted by PGV from its
risk management plan (RMP) for pentane. The information is now
publicly available on the following website:
.
EPA has awarded the LEPC a grant for updating and upgrading the
Hawai'i County Emergency Operation Plan as it pertains to
hazardous materials (Annex M). Hazards identification and risk
information from all RMPs in the county can now be included in
the plan for a more complete hazards analysis.
D-ll
LEPC
HDOH
Page 19 "August,2000
-------
1 7.3 Facility reporting and role of LEPC - clarify TRI reporting
requirements and specific LEPC requirements. EPA has revised the
final report to Incorporate all of your suggestions on LEPC, TRI
andEPCRA reporting requirements.
17.4 Enforcement - clarify which recommendations are suggestions and
which are required by law. EPA should disallow any new drilling
operations at PGV until all recommendations in the final report have
been implemented by PGV and Hawai'i County.
The Review Team functioned in an advisory role. Although all
recommendations are based on laws, regulations or good
management practices, this report is not an enforcement document.
In the Underground Injection Control (UIC) permit, EPA did make
the drilling of new reinjection wells contingent on completion of
emergency response plans. PGV appealed the entire permit to the
Environmental Appeals Board (EAB) which noted that "it appears
to us that the determination of whether or not the emergency
response plan (ERP) is complete - which would be an indirect
means of compelling ERP revisions — is outside the scope of the
Region 's authority. " The EAB nevertheless required the Region, on
remand, to provide a sufficient underground source of drinking
water (USDW)-related rationale for this provision or to remove it
from the permit.
N
D3&10
No referral
i
County
Planning
Page20 "August,2000
-------
18.0
18.1
18.2
18.3
Donald Thomas, Community Resident
General comments -- unable to find data documenting health effects
of exposure to low concentrations of H2S. Critiqued EPA's
expenditure of resources on this review, citing relative risks of
industrial facilities in Hilo and deficiencies in Hawai'i County plan,
"an effort to pander to the demands of a small group of vocal
activists." Included in an appendix of the final report is a summary
of recent literature on HJS health effects, including exposures at
low concentrations. ATSDR has made an assessment of the threat
to public health posed by releases ofHJSfrom the Puna Geothermal
Venture facility. A TSDR 's report is included in Appendix I, Health
Information, of this EPA report
The plan review has resulted in improvements to both County and
PGV emergency response plans, an improved facility and County
planning process, and a reactivated LEPC. On October 25, 1999,
EPA awarded a grant to the SERC and LEPC to update and
upgrade the Hawai'i County Emergency Response Plan. The LEPC
will incorporate risk management program information on all
facilities in Hawai'i County that are required to submit risk
management plans (RMP). EPA expects that a number of
recommendations from the Review Team will be implemented
through this grant project.
EPA has conducted and reported several hundred chemical safety
reviews [audits], all with the objective of preventing chemical
accidents and improving emergency response capabilities. Included
in these reviews are assessments of chemical hazards, chemical
accident prevention, facility emergency preparedness and planning,
facility and community emergency response planning, and public
alert and notification procedures.
Typically, the reviews are conducted following these general topics
but may vary in specifics from one type of industry to another. The
scope of the review described in the EPA report (Section 1
Introduction, paragraph 1.3) can serve as a model for reviewing
emergency response plans of other facilities in the geothermal
power generation industry.
EPA selects facilities for audits based on specific criteria that have
been included in the Chemical Accident Prevention Provisions, 40
CFR 68.220. EPA chose to review PGV based on its accident
history and its location and proximity to the public and
environmental receptors.
Section 1.5, Background - make technical corrections on terms.
EPA has made the technical corrections you suggested. Please refer
to Section 1.5 of the final report.
Section 1.5, Table 2 -- Summarize community concerns. EPA has
kept all comments in the final report for a full record of public
input
D-5 HDOH
1
D-13
D-13
No referral
No referral
Page 21 • August, 2000
-------
18.4 Section 2, Review Team - clarify qualifications of team members.
EPA has clarified the qualifications of team members in Section 2
of the final report.
No referral
18.5 Section 5.3.2 Annex B, Hazards Analysis -- clarify health effects of
HjS. As stated above, EPA has included a summary of recent
literature on HJS health effects as an appendix of the final report.
D-5
LEPC
18.6 Section 5.4, Geothermal Incident Standard Operating Procedure -
questions that local responders should do anything within the PGV
facility. PGV has provided site familiarization training on fire
response to members of the Hawai'i County Fire Department.
Please refer to the legal authorities of the Fire Department in the
final report, Recommendation 6.3.3.
D-3
No referral
18.7 Section 5.5.3 Finding and Recommendation - questions the technical
basis for the presumption that a release could pose a life or health
threatening condition. Scientific studies and regulatory limits form
the technical basis for this finding and recommendation.
D-7
HDOH
LEPC
18.8 Section 5.5.4 Finding - questions that Pahoa Substation personnel
would have the competence to make emergency decisions, such as
sounding sirens. A public agency must make any emergency
notification to the public. EPA has suggested that a technical work
group be established to research and recommend evacuation trigger
levels to the public agencies.
D-2
County CD
Fire
18.9 Section 5.5.7 Finding -- EPA should make decisions based on actual
risks, rather than the public's perception of risk. EPA policy states
that risk decisions should have a strong scientific and technical
basis.
D-10&
11
No referral
18.10 Section 5.5.8 Finding -- the likelihood of steam discharge from this
facility causing H2S concentrations high enough to pose a health
threat as far away as Pahoa School is small. Although the likelihood
that an incident will occur may be small, the potential consequences
of such an incident could be great. Thus, public agencies need to
consider the worst case scenario for emergency planning in Hawai'i
County.
D-5
LEPC
HDOH
Pahoa Schools
Page 22 • August, 2000
-------
18.11
18.12
18.13
18.14
18.15
18.16
Section 6.2.1 Finding and Recommendation - disagrees with the
recommendation to cross reference the emergency shutdown
procedures with PGV's emergency response procedures. The Review
Team was not given the opportunity to review the Operations
Manual, and EPA did not receive a copy for review. HIOSH did
inform EPA that written emergency shut down procedures are
included in the ERP and that HIOSH is satisfied with PGV's
documentation. Even so, EPA suggests for expediency during an
emergency that PG V cross reference the emergency shutdown
procedures in its Operations Manual and Emergency Action Plan.
Section 6.2.2 Finding - PGV has indicated to EPA that all PGV
employees are certified for first aid and CPR. This comment is
reflected in the draft report, and it will stand as written unless PGV
sends documentation.
Section 6.3.2 Recommendation -- specific conditions render a
chemical hazardous rather than its mere presence. EPA agrees with
your technical comment and has revised the report to reflect it.
Section 6.3.3 Finding (release reporting) -- recounts personal
knowledge of incidents (at the HGP-A facility) in which residents
(activists) called in complaints only when they thought a release was
going to occur - and when, in fact, the scheduled releases had been
postponed or completely eliminated. This is a trust issue between
the community and facility operators. Public agencies are required
to be involved in the notification, verification and follow up of any
reported release.
Section 7.2.1 Finding -- The equipment used for compliance
monitoring cannot be calibrated to provide accurate measurement of
ambient air H2S levels at both the 5 ppb and 1000 ppb range . . .
instruments with this wide a dynamic range are beyond the current
state of the art. Because of the variable wind conditions typical in
Puna, H2S concentrations will have to be measured using a portable
monitor. According to the EPA Region 9 Air Division, this
equipment is now available, and monitoring equipment is a
fundable expense under the Clean Air Act §105 grant.
Chapter 7 (technical work group) - Any reviews of the trigger levels
should be scientifically justified rather than set to appease community
activists. EPA has referred this comment to the LEPC with a
recommendation to form a technical workgroup as a task force or
ad hoc subcommittee to the LEPC.
D-10
D-10
D.-5
N
D-6
D-6
HIOSH
PGV
No referral
No referral
No referral
HDOH - Clean
Air Branch
LEPC
Page23 "August,2000
-------
19.0 Rev. D. Zeissler, Community Resident
19.1 Concerned about inaccurate emergency phone numbers and stated
that the Dept. Of Health number (933-4552) is a local person's home
number. Thank you for your comments. EPA is referring these
corrections to the Hawai'i County planning and response agencies.
D-4
HDOH
Ccuinlv
Planning
County CD
Fire
Police
PGV
19.2 Concerned about care for disabled people, e.g. those who are wheel
chair bound, during an emergency. EPA is also concerned about
emergency planning for those with special needs and has recently
awarded a grant to the Hawai'i LEPC to update the county's
emergency plan and include response to all residents of the county.
D-2
County CD
Fire
Police
19.3 Drilling on the old well is very disturbing. Injection wells KS-3 and
KS-4 were successfully rehabilitated, and all maintenance has been
completed.
N
No referral
19.4 Concerned about air, water, privacy and safety. Concern for air,
water and safety issues is the reason EPA initiated the Emergency
Response Plan Review. It is EPA's intent to help improve
environmental and safety issues throughout Hawai'i County.
ID-5
HDOH
LEPC
20.0 Lehua Lopez-Mau, Community Resident - Comments prepared
by Thell Thomas and transmitted from the Law Offices of
Thomas E. Luebben
20.1 PGV should be shut down immediately because its operations pose an
extreme threat to the public health that cannot be mitigated by PGV's
or Hawai'i County's ER plans. EPA understood that this concern
existed and, as a result, sent a multi-media inspection team and an
emergency response review team to Hawai'i. EPA's intent in
sending these teams to Hawai'i was and is to prevent future
accidents and protect public health. To date, EPA has addressed
this concern to the full extent of the federal environmental laws.
For a full accounting of the activities, please refer to the attached
letter to Senator Inouyefrom EPA Regional Administrator Felicia
Marcus dated December 13,1996.
N
No referral
20.2 Community involvement -- EPA should require PGV and Hawai'i to
involve the community in every aspect of accident prevention and
emergency response; LEPC must be established, to include
community members. EPA agrees that the LEPC is the vehicle for
community involvement, under EPCRA. Hawai'i County's LEPC
was reactivated in August 1998, and a community member was
recently appointed. All LEPC activities are conducted in an open
public format, and EPA encourages community residents to
participate.
ID-13
LEPC
PGV
Page 24 • August, 2000
-------
20.3 Health effects of H2S - final report should clearly state the potential
health and safety threats; EPA should analyze all current medical
studies relating to chronic exposure to H2S to determine safe levels
for long term exposure. EPA should work closely with Dr. Marvin
Legator who has studied chronic low level exposure. PGV should not
be permitted to drill any new wells or expand existing operations
absent an in-depth health and safety standards study. The focus of
this review is emergency response, and EPA has examined
hydrogen sulflde effects from the perspective of emergency
planning. A TSDR has completed a health study on H£ health
effects, and a copy is attached to this report. As of the publication
of this final report, Dr. Legator's HJS health symptom study has not
been published. When the Legator study is published, EPA will
include a copy in its official public flies.
Prior to drilling any new re-injection wells, PGV will need to obtain
an Underground Injection Control permit from EPA, as well as
permits to construct and operate from the State.
D-5
ATSDR
20.4 General duty clause -- EPA should hold PGV to its duty to take
responsibility for the dangers posed by H2S releases, including
providing resources for health care, response, evacuation and
integration of response efforts with Hawai'i County. The General
Duty Clause of the Clean Air Act 112(r)(l) is a broad statement of
responsibility. Each facility owner and operator has a general duty
to design and maintain a safe facility, prevent chemical accidents
and minimize the consequences of any accidents that do occur. No
specific requirements address resources for emergency management
or response. EPA agrees that the integration of response efforts
throughout Hawai'i County is very important, and on October 25,
1999, EPA awarded a grant to update and improve the Hawai'i
County Emergency Response Plan.
ID-11
No referral
20.5 Natural disasters ~ PGV presents an extreme nsk due to volcanic and
seismic activity in the area. A full formal seismic and volcanic
hazard risk assessment specific to PGV and the endangered
communities must be completed before any emergency response plan
can be designed to protect the Puna community. EPA has identified
this comment as significant. Although EPA regulations do not
require a full formal seismic and volcanic hazard risk assessment,
EPA is referring your letter to Hawai'i State and County Civil
Defense Agencies, the U. S. Geological Survey and PGV for any
necessary follow up.
ID-9
State CD
County CD
USGS
PGV
20.6 PGV must be closed or (at a minimum) must adopt and exceed all
safety requirements. PGV must be continuously monitored by an
independent regulating agency. EPA requires facilities to comply
with federal environmental laws and regulations. State and local
agencies also require facilities to comply with state and local laws,
regulations and ordinances.
N
No referral
Page 25 • August, 2000
-------
APPENDIX P
Referral Letters
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, CA 94105
September 12, 2000
Mr. Barry Mizuno
Owner's Representative
Puna Geothermal Venture
P.O. Box 30
Pahoa, HI 96778
Dear Mr. Mizuno:
This letter is to inform you that issues or concerns were
expressed in comment letters to the U.S. Environmental Protection
Agency regarding the draft report reviewing the emergency
response plans for Hawai'i County and Puna Geothermal Venture.
While U.S. EPA has now provided written response to the comment
letters, certain issues or concerns should more appropriately be
addressed by the Puna Geothermal Venture (PGV) facility.
Those identified issues or concerns are listed in the
response to comments. Each comment letter is numbered,
alphabetically by author, with significant comment points
identified by a subset of numbers. It was attempted to identify
those significant points by category — one of 13 topics listed
on page one of the response to comments (in Appendix 0 of the
enclosed copy of the final, full review report) . Also, the
significant comment points are identified as to the degree the
comment is related to the review of the emergency response plans
(directly related, indirectly related, or not related) . For your
reference and context, the set of comment letters received by the
U.S. EPA is contained in Appendix N of the report enclosed.
Finally, the last column of the response to comments index
lists referrals. Those referrals are to the appropriate agencies
believed to be the best for addressing those issues. There are
numerous referrals to PGV as noted in the far right column of the
response to comments .
If you should have any questions for U.S. EPA about this
referral letter or this final, full report, please do not
hesitate to contact me by email ( ardi to . michael@epa . gov) or by
telephone at (415) 744-2328. Thank you for your time and effort
to help resolve emergency response and planning issues for the
Puna community.
Sincerely,
Michael Ardi to
Chemical Emergency Preparedness
Coordinator for Hawai'i
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco. CA 94105
September 12, 2000
Mr. John Bowen
Chair, Hawai'i County LEPC
P.O. Box 115
Hilo, HI 96721-1115
Dear Mr. Bowen:
This letter is to inform you that issues or concerns were
expressed in comment letters to the U.S. Environmental Protection
Agency regarding the draft report reviewing the emergency
response plans for Hawai'i County and Puna Geothermal Venture.
While U.S. EPA has now provided written response to the comment
letters, certain issues or concerns should more appropriately be
addressed by the Hawai'i County Local Emergency Planning
Committee (LEPC) .
Those identified issues or concerns are listed in the
response to comments. Each comment letter is numbered,
alphabetically by author, with significant comment points
identified by a subset of numbers. It was attempted to identify
those significant points by category — one of 13 topics listed
on page one of the response to comments (in Appendix O of the
enclosed copy of the final, full review report) . Also, the
significant comment points are identified as to the degree the
comment is related to the review of the emergency response plans
(directly related, indirectly related, or not related) . For your
reference and context, the set of comment letters received by the
U.S. EPA is contained in Appendix N of the report enclosed.
Finally, the last column of the response to comments index
lists referrals. Those referrals are to the appropriate agencies
believed to be the best for addressing those issues. There are
numerous referrals to the Hawai'i County LEPC as noted in the far
right column of the response to comments (Appendix O) .
If you should have any questions for U.S. EPA about this >
referral letter or this final, full report, please do not
hesitate to contact me by email f ardito . ndchael@epa . gov) or by
telephone at (415) 744-2328. Thank you for your time and effort
to help resolve emergency response and planning issues for the
Puna community.
Sincerely,
Michael Ardito
Chemical Emergency Preparedness
Coordinator for Hawai'i
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, CA 94105
September 12, 2000
Mr. William Davis, Administrator
Hawai'i County Civil Defense Agency
920 Ululani Street
Hilo, HI 96720
Dear Mr. Davis:
This letter is to inform you that issues or concerns were
expressed in comment letters to the U.S. Environmental Protection
Agency regarding the draft report reviewing the emergency
response plans for Hawai'i County and Puna Geothermal Venture.
While U.S. EPA has now provided written response to the comment
letters, certain issues or concerns should more appropriately be
addressed by the Hawai'i County Civil Defense Agency.
Those identified issues or concerns are listed in the
response to comments. Each comment letter is numbered,
alphabetically by author, with significant comment points
identified by a subset of numbers. It was attempted to identify
those significant points by category -- one of 13 topics listed
on page one of the response to comments (in Appendix O of the
enclosed copy of the final, full review report) . Also, the
significant comment points are identified as to the degree the
comment is related to the review of the emergency response plans
(directly related, indirectly related, or not related) . For your
reference and context, the set of comment letters received by the
U.S. EPA is contained in Appendix N of the report enclosed.
Finally, the last column of the response to comments index
lists referrals. Those referrals are to the appropriate agencies
believed to be the best for addressing those issues. There are
numerous referrals to the Hawai'i County Civil Defense Agency as
noted in the far right column of the response to comments
(Appendix 0) .
If you should have any questions for U.S. EPA about this
referral letter or this final, full report, please do not
hesitate to contact me by email (ardito . michaelQepa . oov) or by
telephone at (415) 744-2328. Thank you for your time and effort
to help resolve emergency response and planning issues for the
Puna community.
Sincerely,
Michael Ardito
Chemical Emergency Preparedness
Coordinator for Hawai'i
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, CA 94105
September 12, 2000
Mr. Edward T. Texiera
Vice Director of Civil Defense
State of Hawai'i Dept. of Defense
3949 Diamond Head Road
Honolulu, HI 96816-4495
Dear Mr. Texiera:
This letter is to inform you that issues or concerns were
expressed in comment letters to the U.S. Environmental Protection
Agency regarding the draft report reviewing the emergency
response plans for Hawai'i County and Puna Geothermal Venture.
While U.S. EPA has now provided written response to the comment
letters, certain issues or concerns should more appropriately be
addressed by the Hawai'i State Civil Defense Agency.
Those identified issues or concerns are listed in the
response to comments. Each comment letter is numbered,
alphabetically by author, with significant comment points
identified by a subset of numbers. It was attempted to identify
those significant points by category — one of 13 topics listed
on page one of the response to comments (in Appendix 0 of the
enclosed copy of the final, full review report) . Also, the
significant comment points are identified as to the degree the
comment is related to the review of the emergency response plans
(directly related, indirectly related, or not related) . For your
reference and context, the set of comment letters received by the
U.S. EPA is contained in Appendix N of the report enclosed.
Finally, the last column of the response to comments index
lists referrals. Those referrals are to the appropriate agencies
believed to be the best for addressing those issues. There are
numerous referrals to the Hawai'i State Civil Defense Agency as
noted in the far right column of the response to comments.
If you should have any questions for U.S. EPA about this
referral letter or this final, full report, please do not
hesitate to contact me by email ( ardito . michael@epa . oov) or by
telephone at (415) 744-2328. Thank you for your time and effort
to help resolve emergency response and planning issues for the
Puna community.
Sincerely,
Michael Ardito
Chemical Emergency Preparedness
Coordinator for Hawai'i
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, CA 94105
September 12, 2000
Fire Chief Edward Bumatay
County of Hawai'i Central Fire Dept.
777 Kilauea Ave., Mall Lane, Room 6
Hilo, HI 96720
Dear Fire Chief Bumatay:
This letter is to inform you that issues or concerns were
expressed in comment letters to the U.S. Environmental Protection
Agency regarding the draft report reviewing the emergency
response plans for Hawai'i County and Puna Geothermal Venture.
While U.S. EPA has now provided written response to the comment
letters, certain issues or concerns should more appropriately be
addressed by the Hawai'i County Fire Department.
Those identified issues or concerns are listed in the
response to comments. Each comment letter is numbered,
alphabetically by author, with significant comment points
identified by a subset of numbers. It was attempted to identify
those significant points by category — one of 13 topics listed
on page one of the response to comments (in Appendix O of the
enclosed copy of the final, full review report) . Also, the
significant comment points are identified as to the degree the
comment is related to the review of the emergency response plans
(directly related, indirectly related, or not related) . For your
reference and context, the set of comment letters received by the
U.S. EPA is contained in Appendix N of the report enclosed.
Finally, the last column of the response to comments index
lists referrals. Those referrals are to the appropriate agencies
believed to be the best for addressing those issues. There are
numerous referrals to the Hawai'i County Fire Department as noted
in the far right column of the response to comments (Appendix O) .
If you should have any questions for U.S. EPA about this
referral letter or this final, full report, please do not
hesitate to contact me by email (ardito . michael@epa . qov) or by
telephone at (415) 744-2328. Thank you for your time and effort
to help resolve emergency response and planning issues for the
Puna community.
Sincerely,
Michael Ardito
Chemical Emergency Preparedness
Coordinator for Hawai'i
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, CA 94105
September 12, 2000
Police Chief Wayne Carvalho
County of Hawai'i Central Police Dept.
349 Kapiolani Street
Hilo, HI 96720-3998
Dear Police Chief Carvalho:
This letter is to inform you that issues or concerns were
expressed in comment letters to the U.S. Environmental Protection
Agency regarding the draft report reviewing the emergency
response plans for Hawai'i County and Puna Geothermal Venture.
While U.S. EPA has now provided written response to the comment
letters, certain issues or concerns should more appropriately be
addressed by the Hawai'i County Police Department.
Those identified issues or concerns are listed in the
response to comments. Each comment letter is numbered,
alphabetically by author, with significant comment points
identified by a subset of numbers. It was attempted to identify
those significant points by category — one of 13 topics listed
on page one of the response to comments (in Appendix 0 of the
enclosed copy of the final, full review report) . Also, the
significant comment points are identified as to the degree the
comment is related to the review of the emergency response plans
(directly related, indirectly related, or not related) . For your
reference and context, the set of comment letters received by the
U.S. EPA is contained in Appendix N of the report enclosed.
Finally, the last column of the response to comments index
lists referrals. Those referrals are to the appropriate agencies
believed to be the best for addressing those issues. There are
numerous referrals to the Hawai'i County Police Department as
noted in the far right column of the response to comments
(Appendix 0) .
If you should have any questions for U.S. EPA about this
referral letter or this final, full report, please do not
hesitate to contact me by email ( ardi to .michaeieeoa . aov) or by
telephone at (415) 744-2328. Thank you for your time and effort
to help resolve emergency response and planning issues for the
Puna community.
Sincerely,
Michael Ardito
Chemical Emergency Preparedness
Coordinator for Hawai'i
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, CA 94105
September 12, 2000
Mayor Stephen Yamashiro
County of Hawai'i
25 Aupuni Street, Room 215
Hilo, HI 96720
Dear Mayor Yamashiro:
This letter is to inform you that issues or concerns were
expressed in comment letters to the U.S. Environmental Protection
Agency regarding the draft report reviewing the emergency
response plans for Hawai'i County and Puna Geothermal Venture.
While U.S. EPA has now provided written response to the comment
letters, certain issues or concerns should more appropriately be
addressed by you and your staff in Hawai'i County.
Those identified issues or concerns are listed in the
response to comments. Each comment letter is numbered,
alphabetically by author, with significant comment points
identified by a subset of numbers. It was attempted to identify
those significant points by category — one of 13 topics listed
on page one of the response to comments (in Appendix 0 of the
enclosed copy of the final, full review report) . Also, the
significant comment points are identified as to the degree the
comment is related to the review of the emergency response plans
(directly related, indirectly related, or not related) . For your
reference and context, the set of comment letters received by the
U.S. EPA is contained in Appendix N of the report enclosed.
Finally, the last column of the response to comments index
lists referrals. Those referrals are to the appropriate agencies
believed to be the best for addressing those issues. The
referrals to the Hawai'i County Mayor are 10.5 (page 11) and 10.7
(page 12) of the response to comments (Appendix 0).
If you should have any questions for U.S. EPA about this
referral letter or this final, full report, please do not
hesitate to contact me by email (ardito .michaelQepa .gov) or by
telephone at (415) 744-2328. Thank you for your time and effort
to help resolve emergency response and planning issues for the
Puna community.
Sincerely,
Michael Ardito
Chemical Emergency Preparedness
Coordinator for Hawai ' i
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, CA 94105
September 12, 2000
Ms. Virginia Goldstein, Director
Hawai'i County Planning Department
25 Aupuni Street, Room 109
Hilo, Hawai'i 96720-4252
Dear Ms. Goldstein:
This letter is to inform you that issues or concerns were
expressed in comment letters to the U.S. Environmental Protection
Agency regarding the draft report reviewing the emergency
response plans for Hawai'i County and Puna Geothermal Venture.
While U.S. EPA has now provided written response to the comment
letters, certain issues or concerns should more appropriately be
addressed by the Hawai'i County Planning Department.
Those identified issues or concerns are listed in the
response to comments. Each comment letter is numbered,
alphabetically by author, with significant comment points
identified by a subset of numbers. It was attempted to identify
those significant points by category — one of 13 topics listed
on page one of the response to comments (in Appendix 0 of the
enclosed copy of the final, full review report) . Also, the
significant comment points are identified as to the degree the
comment is related to the review of the emergency response plans
(directly related, indirectly related, or not related) . For your
reference and context, the set of comment letters received by the
U.S. EPA is contained in Appendix N of the report enclosed.
Finally, the last column of the response to comments index
lists referrals. Those referrals are to the appropriate agencies
believed to be the best for addressing those issues. There are
numerous referrals to the Hawai'i County Planning Department as
noted in the far right column of the response to comments.
If you should have any questions for U.S. EPA about this
referral letter or this final, full report, please do not
hesitate to contact me by email ( ardito .michaelQepa . crov) or by
telephone at (415) 744-2328. Thank you for your time and effort
to help resolve emergency response and planning issues for the
Puna community.
Sincerely,
Michael Ardito
Chemical Emergency Preparedness
Coordinator for Hawai ' i
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, CA 94105
September 12, 2000
Mr. Gary Gill
Chair, Hawai'i State Emergency Response Commission
Deputy Director, Environmental Health
Hawai'i Department of Health
P.O. Box 3378
Honolulu, HI 96801
Dear Mr. Gill:
This letter is to inform you that issues or concerns were
expressed in comment letters to the U.S. Environmental Protection
Agency regarding the draft report reviewing the emergency
response plans for Hawai'i County and Puna Geothermal Venture.
While U.S. EPA has now provided written response to the comment
letters, certain issues or concerns should more appropriately be
addressed by the Hawai'i Department of Health (HDOH) and the
Hawai'i State Emergency Response Commission (HSERC).
Those identified issues or concerns are listed in the
response to comments. Each comment letter is numbered,
alphabetically by author, with significant comment points
identified by a subset of numbers. It was attempted to identify
those significant points by category -- one of 13 topics listed
on page one of the response to comments (in Appendix 0 of the
enclosed copy of the final, full review report). Also, the
significant comment points are identified as to the degree the
comment is related to the review of the emergency response plans
(directly related, indirectly related, or not related). For your
reference and context, the set of comment letters received by the
U.S. EPA is contained in Appendix N of the report enclosed.
Finally, the last column of the response to comments index
lists referrals. Those referrals are to the appropriate agencies
believed to be the best for addressing those issues. There are
numerous referrals to the Clean Air Branch at HDOH as noted in
the far right column of the response to comments in Appendix 0:
Comment 1.3 (page 3)
Comment 10.4 (page 11)
Comment 10.8 (page 12)
Comment 11.1 (page 13)
Comment 11.2 (page 13)
Comment 13.6 (page 15)
Comment 14.12 (page 16)
Comment 18.15 (page 23)
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A referral letter regarding those comments has been sent to
Wilfred Nagamine, supervisor of the Clean Air Branch at HDOH.
For your information, there are other referrals to the HDOH
about other environmental matters beyond air issues.
Also, as chair of the HSERC, it is brought to your attention
that there are numerous referrals to the Hawai'i State Emergency
Response Commission as noted in the far right column of the
response to comments (Appendix 0) .
If you should have any questions for U.S. EPA about this
referral letter or this final, full report, please do not
hesitate to contact me by email (ardito .michael@epa . aov) or by
telephone at (415) 744-2328. Thank you for your time and effort
to help resolve emergency response and planning issues for the
Puna community.
Sincerely,
Michael Ardito
Chemical Emergency Preparedness
Coordinator for Hawai'i
-2-
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, CA 94105
September 12, 2000
Mr. Wilfred Nagamine
Supervisor, Clean Air Branch
Hawai'i Department of Health
919 Ala Moana Blvd., Room 203
Honolulu, HI 96814
Dear Mr. Nagamine:
This letter is to inform you that issues or concerns were
expressed in comment letters to the U.S. Environmental Protection
Agency regarding the draft report reviewing the emergency
response plans for Hawai'i County and Puna Geothermal Venture.
While U.S. EPA has now provided written response to the comment
letters, certain issues or concerns should more appropriately be
addressed by the Clean Air Branch of the Hawai'i Department of
Health (HDOH).
Those identified issues or concerns are listed in the
response to comments. Each comment letter is numbered,
alphabetically by author, with significant comment points
identified by a subset of numbers. It was attempted to identify
those significant points by category -- one of 13 topics listed
on page one of the response to comments (in Appendix 0 of the
enclosed copy of the final, full review report). Also, the
significant comment points are identified as to the degree the
comment is related to the review of the emergency response plans
(directly related, indirectly related, or not related). For your
reference and context, the set of comment letters received by the
U.S. EPA is contained in Appendix N of the report enclosed.
Finally, the last column of the response to comments index
lists referrals. Those referrals are to the appropriate agencies
believed to be the best for addressing those issues. There are
numerous referrals to the Clean Air Branch at HDOH as noted in
the far right column of the response to comments in Appendix O:
Comment 1.3 (page 3)
Comment 10.4 (page 11)
Comment 10.8 (page 12)
Comment 11.1 (page 13)
Comment 11.2 (page 13)
Comment 13.6 (page 15)
Comment 14.12 (page 16)
Comment 18.15 (page 23)
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If you should have any questions for U.S. EPA about this
referral letter or this final, full report, please do not
hesitate to contact me by email ( ardito . michaelQeoa . aov) or by
telephone at (415) 744-2328. Thank you for your time and effort
to help resolve emergency response and planning issues for the
Puna community.
Sincerely,
Michael Ardito
Chemical Emergency Preparedness
Coordinator for Hawai'i
-2-
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, CA 94105
September 12, 2000
Mr. Russell Charlton
Manager, Occupational Health Branch
State of Hawai'i Dept. of Labor & Industrial Relations
Division of Occupational Safety & Health (HIOSH)
830 Punchbowl Street
Honolulu, HI 96813
Dear Mr. Charlton:
This letter is to inform you that issues or concerns were
expressed in comment letters to the U.S. Environmental Protection
Agency regarding the draft report reviewing the emergency
response plans for Hawai'i County and Puna Geothermal Venture.
While U.S. EPA has now provided written response to the comment
letters, certain issues or concerns should more appropriately be
addressed by HIOSH.
Those identified issues or concerns are listed in the
response to comments. Each comment letter is numbered,
alphabetically by author, with significant comment points
identified by a subset of numbers. It was attempted to identify
those significant points by category — one of 13 topics listed
on page one of the response to comments (in Appendix 0 of the
enclosed copy of the final, full review report). Also, the
significant comment points are identified as to the degree the
comment is related to the review of the emergency response plans
(directly related, indirectly related, or not related). For your
reference and context, the set of comment letters received by the
U.S. EPA is contained in Appendix N of the report enclosed.
Finally, the last column of the response to comments index
lists referrals. Those referrals are to the appropriate agencies
believed to be the best for addressing those issues. The
referrals to HIOSH regard comments 3.6 through 3.9 (pages 5 and
6), comments 3.12 through 3.16 (page 7), and comment 18.11 (page
23) of the response to comments (Appendix 0).
-------
If you should have any questions for U.S. EPA about this
referral letter or this final, full report, please do not
hesitate to contact me by email (ardito . michaelQepa . qov) or by
telephone at (415) 744-2328. Thank you for your time and effort
to help resolve emergency response and planning issues for the
Puna community.
Sincerely,
Michael Ardito
Chemical Emergency Preparedness
Coordinator for Hawai'i
-2-
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, CA 94105
September 12, 2000
Ms. Maring Gacusana, Principal
Pahoa Intermediate and High Schools
15-3038 Puna Road
Pahoa, HI 96778
Dear Ms. Gacusana:
This letter is to inform you that issues or concerns were
expressed in comment letters to the U.S. Environmental Protection
Agency regarding the draft report reviewing the emergency
response plans for Hawai'i County and Puna Geothermal Venture.
While U.S. EPA has now provided written response to the comment
letters, certain issues or concerns should more appropriately be
addressed by you and the Pahoa schools.
Those identified issues or concerns are listed 'in the
response to comments. Each comment letter is numbered,
alphabetically by author, with significant comment points
identified by a subset of numbers. It was attempted to identify
those significant points by category — one of 13 topics listed
on page one of the response to comments (in Appendix 0 of the
enclosed copy of the final, full review report) . Also, the
significant comment points are identified as to the degree the
comment is related to the review of the emergency response plans
(directly related, indirectly related, or not related) . For your
reference and context, the set of comment letters received by the
U.S. EPA is contained in Appendix N of the report enclosed.
Finally, the last column of the response to comments index
lists referrals. Those referrals are to the appropriate agencies
believed to be the best for addressing those issues. The referral
for the Pahoa schools are: 13.7 (page 15 of Appendix 0), 15.6
(page 17), and 18.10 (page 22).
If you should have any questions for U.S. EPA about this
referral letter or this final, full report, please do not
hesitate to contact me by email (ardito.michael@eDa.aov) or by
telephone at (415) 744-2328. Thank you for your time and effort
to help resolve emergency response and planning issues for the
Puna community.
Sincerely,
Michael Ardito
Chemical Emergency Preparedness
Coordinator for Hawai'i
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, CA 94105
September 12, 2000
Ms. Michelle Ouellette, Principal
Pahoa Elementary School
15-3030 Puna Road
Pahoa, HI 96778
Dear Ms. Ouellette:
This letter is to inform you that issues or concerns were
expressed in comment letters to the U.S. Environmental Protection
Agency regarding the draft report reviewing the emergency
response plans for Hawai'i County and Puna Geothermal Venture.
While U.S. EPA has now provided written response to the comment
letters, certain issues or concerns should more appropriately be
addressed by you and the Pahoa schools.
Those identified issues or concerns are listed in the
response to comments. Each comment letter is numbered,
alphabetically by author, with significant comment points
identified by a subset of numbers. It was attempted to identify
those significant points by category — one of 13 topics listed
on page one of the response to comments (in Appendix 0 of the
enclosed copy of the final, full review report) . Also, the
significant comment points are identified as to the degree the
comment is related to the review of the emergency response plans
(directly related, indirectly related, or not related) . For your
reference and context, the set of comment letters received by the
U.S. EPA is contained in Appendix N of the report enclosed.
Finally, the last column of the response to comments index
lists referrals. Those referrals are to the appropriate agencies
believed to be the best for addressing those issues. The referral
for the Pahoa schools are: 13.7 (page 15 of Appendix 0), 15.6
(page 17), and 18.10 (page 22).
If you should have any questions for U.S. EPA about this
referral letter or this final, full report, please do not
hesitate to contact me by email ( ardito . michaelSepa . crov) or by
telephone at (415) 744-2328. Thank you for your time and effort
to help resolve emergency response and planning issues for the
Puna community.
Sincerely,
Michael Ardito
Chemical Emergency Preparedness
Coordinator for Hawai'i
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, C A 94105
September 12, 2000
Mr. Ronald Schurra, Administrator
Hilo Medical Center
1190 Waianuenue
Hilo, HI 96720
Dear Mr. Schurra:
This letter is to inform you that issues or concerns were
expressed in comment letters to the U.S. Environmental Protection
Agency regarding the draft report reviewing the emergency
response plans for Hawai'i County and Puna Geothermal Venture.
While U.S. EPA has now provided written response to the comment
letters, certain issues or concerns should more appropriately be
addressed by you and Hilo Medical Center.
Those identified issues or concerns are listed in the
response to comments. Each comment letter is numbered,
alphabetically by author, with significant comment points
identified by a subset of numbers. It was attempted to identify
those significant points by category — one of 13 topics listed
on page one of the response to comments (in Appendix 0 of the
enclosed copy of the final, full review report). Also, the
significant comment points are identified as to the degree the
comment is related to the review of the emergency response plans
(directly related, indirectly related, or not related) . For your
reference and context, the set of comment letters received by the
U.S. EPA is contained in Appendix N of the report enclosed.
Finally, the last column of the response to comments index
lists referrals. Those referrals are to the appropriate agencies
believed to be the best for addressing those issues. The referral
for Hilo Medical Center is comment 3.9 on page 6 of the response
to comments (Appendix O) .
If you should have any questions for U.S. EPA about this
referral letter or this final, full report, please do not
hesitate to contact me by email ( ardi t o . michaelQepa . aov) or by
'telephone at (415) 744-2328. Thank you for your time and effort
to help resolve emergency response and planning issues for the
Puna community.
Sincerely,
Michael Ardi to
Chemical Emergency Preparedness
Coordinator for Hawai'i
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, CA 94105
September 12, 2000
Mr. Don Swanson, Scientist-in-Charge
United States Geological Survey Team
Hawai'i Volcanos Observatory
P.O. Box 51
Hawai'i National Park, HI 96718
Dear Mr. Swanson:
This letter is to inform you that issues or concerns were
expressed in comment letters to the U.S. Environmental Protection
Agency regarding the draft report reviewing the emergency
response plans for Hawai'i County and Puna Geothermal Venture.
While U.S. EPA has now provided written response to the comment
letters, certain issues or concerns should more appropriately be
addressed by the U.S. Geological Survey Team.
Those identified issues or concerns are listed in the
response to comments. Each comment letter is numbered,
alphabetically by author, with significant comment points
identified by a subset of numbers. It was attempted to identify
those significant points by category — one of 13 topics listed
on page one of the response to comments (in Appendix 0 of the
enclosed copy of the final, full review report) . Also, the
significant comment points are identified as to the degree the
comment is related to the review of the emergency response plans
(directly related, indirectly related, or not related) . For your
reference and context, the set of comment letters received by the
U.S. EPA is contained in Appendix N of the report enclosed.
Finally, the last column of the response to comments index
lists referrals. Those referrals are to the appropriate agencies
believed to be the best for addressing those issues. The
referrals to USGS are 5.1 and 5.4 (page 8), 15.7 (page 18), and
20.5 (page 25) of the response to comments (Appendix 0).
If you should have any questions for U.S. EPA about this
referral letter or this final, full report, please do not
hesitate to contact me by email fardito.michael@epa.QQv) or by
telephone at (415) 744-2328. Thank you for your time and effort
to help resolve emergency response and planning issues for the
Puna community.
Sincerely,
Michael Ardito
Chemical Emergency Preparedness
Coordinator for Hawai'i
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, CA 94105
September 12, 2000
Mr. Dan Strausbaugh, Region 9 Representative
Agency for Toxic Substances and Disease Registry
75 Hawthorne Street, Suite 100
San Francisco, CA 94105-3901
Dear Mr. Strausbaugh:
This letter is to inform you that issues or concerns were
expressed in comment letters to the U.S. Environmental Protection
Agency regarding the draft report reviewing the emergency
response plans for Hawai'i County and Puna Geothermal Venture.
While U.S. EPA has now provided written response to the comment
letters, certain issues or concerns should more appropriately be
addressed by ATSDR.
Those identified issues or concerns are listed in the
response to comments. Each comment letter is numbered,
alphabetically by author, with significant comment points
identified by a subset of numbers. It was attempted to identify
those significant points by category -- one of 13 topics listed
on page one of the response to comments (in Appendix 0 of the
enclosed copy of the final, full review report) . Also, the
significant comment points are identified as to the degree the
comment is related to the review of the emergency response plans
(directly related, indirectly related, or not related) . For your
reference and context, the set of comment letters received by the
U.S. EPA is contained in Appendix N of the report enclosed.
Finally, the last column of the response to comments index
lists referrals. Those referrals are to the appropriate agencies
believed to be the best for addressing those issues. The referral
for ATSDR is comment 20.3 on page 25 of the response to comments
(Appendix 0) .
If you should have any questions for U.S. EPA about this
referral letter or this final, full report, please do not
hesitate to contact me by email (ardito .michael@epa . crov) or by
telephone at (415) 744-2328. Thank you for your time and effort
to help resolve emergency response and planning issues for the
Puna community.
Sincerely,
Michael Ardito
Chemical Emergency Preparedness
Coordinator for Hawai'i
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APPENDIX Q
Hydrogen Sulfide Literature Review
-------
Health Effects of Hydrogen Sulfide
Sandra L. Carroll
Section
Page
I. Title & Table of Contents ]
n. Abstract
9
ID. Introduction ~
IV. Review Methods 2
V. Results 3
VI. Discussion
VD. Literature Cited
16
17
Abstract
Objective- The primary objective is to determine the current status of the knowledge of
hydrogen sulfide (H2S) health effects
Design- This is a review of the literature, emphasizing the most recent studies (1987-2000)
Methods- A search of on-line data bases included Toxline, Chemical Abstracts, Pubmed, and
Advanced Medline, as well as sources within the University of Nevada system
Results- In the most recent clinical studies, health effects reported after exposure to H2S were
that stresses to the pulmonary system were consistently evident in both gross and microscopic
observations Case study findings were not as clear cut but did suggest that stresses to the
pulmonary system were the most common occurrence after exposure to H2S, even at very low
concentrations of 2.3 ug/m3 annual mean (Jaakkola et al 1991)
Findings and Implications- The latest findings suggest that H2S exposures above a low
threshold can result in stress to the respiratory system at both the cellular and systemic levels.
Health effects stemming from the stress include increased levels of acute respiratory infection,
respiratory disease, and cancers of the lung, bronchus, and trachea The relationship between
H2S exposure and reproductive health is an area of uncertainty that needs further study, results
of current research are contradictory.
8/29/00
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Introduction
Hydrogen sulfide (H2S) is a colorless gas heavier than air (d = 1.19) that has a distinctive,
acrid odor (Reiffenstein, et al., 1992). H2S is soluble in water and evaporates from aqueous
solutions (vapor pressure = 18.75 x 10s Pa); it is soluble in ethanol and diethyl ether, and it easily
penetrates biological membranes because of its lipid solubility (Reiffenstein, et al., 1992). H2S is
considered a broad-spectrum toxicant, though tissues most susceptible to H2S toxicity are those
with exposed mucous membranes or high oxygen demands (Reiffenstein, et al., 1992) The
conversion factor for H2S is 1 ppm = 1 4 mg/m? = 1400 ug/m3
Historically, research focused on acute exposures, and long term exposures to low
concentrations of H2S have not been well understood Health effects associated with long term
exposure to lower concentrations of HjS are a concern of some residents in communities located
in the vicinity of a geothermal area on the Big Island of Hawai'i The purpose of searching and
reviewing the most current literature on H;S health effects is to contribute to the understanding of
the question — how does H2S affect organisms in the long-term when they are exposed to lower
background levels with occasional peak exposures9
Review Methods
The focus of this review is the most current literature, from 1987 to 2000, on clinical and
epidemiological case studies. Search limits were the health effects of hydrogen sulfide inhalation
and included studies conducted and published worldwide Dr Richard Egami from Desert
Research Institute generously shared some of his experiences and references gained over several
years of research on hydrogen sulfide Data bases searched included Chemical Abstracts, Toxline.
National Library of Medicine' sPubmed and Advanced Medline, and Dissertation Abstracts
Online The search also included all current holdings and data bases in the University of Nevada
system, including medical school libraries
8/29/00
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Results
Clinical Studies of Animal Exposures - Key studies with references are summarized in Table 1
In recent clinical studies, researchers exposed laboratory animals to concentrations of hydrogen
sulfide ranging from 10 ppm to -1,600 ppm. The route of exposure was inhalation, and all
concentrations of H2S were administered in inhalation chambers. Duration of exposure ranged
from five minutes to more than one month, representing acute and chronic exposures Health
effects reported were that stresses to the pulmonary system were consistently evident in both
gross and microscopic observations Edema and congestion of the lungs and trachea on a gross
level were associated with decreased cell viability, perivascular edema, increases in protein
concentrations in the plasma, depressions in the activities of mitochondria! enzymes, and reduced
respiratory rates of macrophages.
Case Studies of Human Exposures — Key studies with references are summarized in Table 2
Human exposures to H2S were reported as the results of epidemiological studies, comparing
exposed populations with reference populations, or as accounts of single events in which
accidental exposures resulted in injury or death Concentrations and durations were much less
certain than those reported in controlled laboratory experiments, and ambient concentrations were
reported in a range of 0.1 to 840 ug/m3 ( = 06 ppm) Air monitoring after one fatal exposure
revealed H2S concentrations of 70 ppm Another characteristic of the case studies is that H2S is
commonly found in combination with other compounds, and the synergistic effects are not well
understood Some patterns do emerge, however, and the health effects associated with H2S
exposure include increased diseases of the respiratory system and elevated rates of nasal, trachea.
bronchus, and lung cancers Other effects reported are increased breathlessness, cough,
pharyngeal irritation, nasal symptoms, burning eyes and eye irritation, headaches or migraines,
nausea dizziness, imbalance, and disorientation Reproductive health effects have been
researched, but the results are not consistent (Morgan et al 1984, Xu et al. 1998), so further
study is needed
Clinical Studies of Human Exposures — Key studies and references are summarized in Table 3
Human exposures to H2S were controlled and administered to healthy adult volunteers in
concentrations ranging from 0.5 to 10 ppm during short time periods of less than one hour At
the lowest concentrations and durations, no significant health effects were reported. Exposures to
10 0 ppm H2S for 30 minutes did result in a significant decrease in oxygen uptake and enzyme
activity, a marker for aerobic metabolism, and an increase in blood lactate (Bhambhani, Y., et al.,
1997).
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Table 1. Clinical Studies of Animal Exposures to Hydrogen Sulfide
Concentrations of HZS,
Duration & Frequency of
Exposure
Species, Age,
Weight, & Number
Health Effects
References
200 & 300 ppm H2S;
Control = fresh air.
Duration of exposure =
4 hours.
Frequency of exposure = 2
consecutive days
Forty 10-week-old male Fisher
344 rats; weights not stated.
Exposure to 200 ppm H2S
significant increase in protein
and lactate dehydrogenase;
perivascular edema under
microscopic examination
Exposure to 300 ppm H2S
animals visibly stressed during
and after exposure; necropsy
revealed red atelectasis in
lungs, patchy edema with
substantial perivascular and
perihronchial edema; highly
significant increases in protein
concentration and lactate
dehydrogenase
Green, F.H.Y.,etal. (1991)
20, 50, & 75 ppm H2S;
Control = 0 H2S
Duration of exposure = not
stated.
Frequency of exposure = from
day 6 of gestation through day
21 postpart'um
Female Sprague-Dawley rats.
Dose dependent increase in
parturition time; viability of
pups decreased to 73% with
parturition > 200 minutes,
exposed pups developed with
subtle decrease in time of ear
detachment and hair
development
Hayden,L. J., etal. (1990)
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Concentrations or HjS,
Duration & Frequency of
Exposure
Varying concentrations
from I0to>500ppm
Duration = 4 hours
Frequency not stated
Species, Age,
Weight, & Number
Fischer-344 rats
Health Effects
H2S exposure at 50-400 ppm
marked and highly significant
depressions in the activities of
lung mitochondria! enzymes,
with marked recovery in
enzyme activity 24 & 48 hours
after exposure.
H2S exposure >500 ppm-
most severe enzyme inhibition.
Conclusion: such biochemical
impairment would lead to
functional hypoxia in the lung
tissues
References
Khan, A. A,etal. (1990)
H2S concentrations of 0, 50,
200, & 400 ppm.
Duration = 4 hours
Frequency not stated
Laboratory rats
Information on strain not given
H2S exposure at 200-400 ppm-
respiratory rates in pulmonary
alveolar macrophages
markedly reduced
H2S exposure at 400 ppnr
significant decrease in cell
viability.
Khan, A. A.,etal. (1991)
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Concentrations ofHjS,
Duration & Frequency of
Exposure
Species, ARC,
Weight, & Number
Henlth Effects
References
H2S concentrations of 0 &
16554±3909ppm.
NaHS concentrations of 0 &
30 mg kg'1
Duration = 5 minutes
Frequency = one time
Twenty male 6-month-old
Sprague-Dawley adult rats.
weighing 485 7 ± 50 I g
H2S exposure at
concentrations of 1655.4 ±
390 9 ppm. severe dyspnea
characterized by exaggerated
respiratory movements and
abnormal, easily audible
respiratory sounds; large
amounts of frothy fluids
pouring from the nose and
mouth; pulmonary edema
including foamy fluids in the
trachea and severe congestion
of the lungs, proteinaceous
fluid into the perivascular
spaces and alveoli, especially
into those of the subpleural
region
Lopez, A., etal. (1989)
H2S concentrations of 0 & 45
ppm. Durations = 2,4, and 6
hours prior to a 30-minute
challenge with a viable
staphylococcal aerosol.
Laboratory rats, H2S-exposed
and control, sacrificed 30
minutes, 3 and 6 hours post-
challenge
Rats exposed to H2S for 4 and
6 hours exhibited incomplete
inactivation of viable
staphylococci while a 2 hour
exposure to H2S had no effect.
The longer exposures
compromised the rats'
antibacterial defense systems
Rogers, R. E. (1982)
8/29/00
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Table 2. Case Studies of Human Exposures to Hydrogen Sulfide
Conversion factors for H2S - 1 ppm = I 4 mg/nv1 = 1,400 ng/m'
Compounds, Concentrations,
and Duration
Population Group
Health Effects
References
Petroleum emissions, H2S,
benzene
H2S emissions estimated up to
-65 metric tons for the year in
1992
Duration of exposure ranged
from 0 to >20 years
H2S and mercaptans
Concentrations and duration
not stated
Geothermal emissions, H2S
Concentrations not stated
Lifetime exposures
24 exposed workers in
petroleum plants & 35
unexposed controls
Residents of two towns -- the
more polluted town R and the
less polluted town B, based on
data from the Principle
Hydrological and Meteoro-
logical Administration
Residents of the Rotorua
geothermal area. New Zealand
compared with residents of the
rest of New Zealand, used
mortality data for the period
1981 to 1990
Increases in chromosome
aberrations and percent of aberrant
cells in exposed group, sister
chromatid exchanges were higher
for females. Both groups showed
increases due to smoking and the
winter season
Higher incidence of general
morbidity and allergic reactivity,
suggesting that the ambient air
pollution in town R is a health risk
factor
Elevated standardized mortality
ratios found for diseases of the
respiratory system, particularly in
Maori women Possibility of
confounding by ethnicity
Anderson, D., et al. (1996)
Basmadzhieva, K., et al.
(1987)
Bates, M. N., et al (1997)
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Compounds, Concentrations,
and Duration
Population Group
Health Effects
References
Geothermal emissions, HjS,
and mercury
Residents of the Rotorua
geothermal. New Zealand
compared with residents of the
rest of New Zealand, used
cancer registry and hospital
discharge morbidity data for
the period 1981 to 1990
Elevated rate of nasal, trachea,
bronchus, and lung cancers,
elevated standardized incidence
ratios of diseases of the nervous
system and the eye
Bates, M. N., etal. (1998)
H2S and in some cases other
compounds such as VOCs,
petrochemical distillates,
metals, and hot caustics
Five industrial workers
exposed to varying amounts of
H2S over periods of time
ranging from 30 minutes to 13
years
One worker exposed to 3%
( = 3 parts per hundred) H2S
Nausea, dizziness, emesis, severe
headaches, imbalance,
disorientation, ataxia, decreased
peripheral vision, sleep apnea
without hypoxia, reactive airway
disease, easy bruising, abdominal
cramps, diaphoresis, tremors,
sweating, shortness of breath,
nervousness, chest pain, startled by
noises, burning eyes, general
weakness.
Callender, T. J., et al.
(1993)
Toxic gases including H2S.
Exposed for -10 minutes when
overcome by gases.
Air tests post-incident showed
H2S at 70 ppm.
A 16-year-old worker who had
been in good health collapsed
and died Autopsy findings
consistent with inhalation of
toxic gas
Autopsy findings, emesis and
aspiration
Cowell,J., etal. (1994)
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Compounds, Concentrations,
and Duration
Population Group
Health Effects
References
H2S at 0 6 ppm ambient
concentration.
Exposed for ~ 1 year.
A 20-montli-old child exposed
to emissions From a colliery
where a burning tip had
emitted H2S for nearly 1 year
Deviation of the eyes, imbalance,
involuntary movements, ataxia,
choreoathetosis, dystonia
Gaitonde, U. B., et al.
(1987)
H2S at concentrations up to
135 ug/m3 for four hours, over
a period of two days
Reference period = two days -
four months later; H2S at
concentrations of 0.1 to 3.5
ug/m3 for four hours & no
odor sensed.
SO2 at concentrations of
~3 ug/m3 during both periods.
Mesityloxide recognized but
not measured in ambient air
44 adults [15 men+ 29
women; mean age 45 years]
and 16 children [9 boys + 7
girls, mean age 7 years] living
within ~ I km of the source of
exposure, a pulp mill
Breathlessness, depression,
anxiety, eye symptoms, cough or
pharyngeal irritation, nausea, and
headache Nasal symptoms
reported during reference period.
Authors concluded that the World
Health Organization guideline
value of 150 ug/m3 for H2S is
likely too high and does not
provide prevention from adverse
health effects
Haahtela, T., et al. (1992)
H2S ambient concentrations of
more than and less than 4.0
Mg/m3
Also exposed to SO2 and CS2
1,972 women in an industrial
area who had spontaneous
abortions or had given birth
during a four year period
Information on occupations,
places of work & residence
gathered on 89% of cases
Women residentially exposed to
more and less than 4 0 ug/m'
ambient concentrations of H2S had
miscarriage rates of 9.3 and 7 6,
respectively. Authors reported no
clear evidence of an increased risk
of spontaneous abortion associated
with exposure to air pollution
Hemminki, K., and M. L.
Niemi(1982)
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Compounds, Concentrations,
and Duration
Population Group
Health Effects
References
H2S up to 8.0 ug/m' mean
daily and 56 ng/m' four-hour
ambient concentrations.
Also exposed to SO2, methyl
mercaptan, and methyl sulfldes
from the source of exposure,
pulp mills.
Exposures were long-term, and
the duration of the study was a
12-month period.
488 residents from three
communities - 86 adults from a
nonpolluted reference
community, 204 adults from a
moderately polluted
community, and 198 adults
from a severely polluted
community All residents of
moderately and severely
polluted communities lived
within 4 km of a pulp mill
A consistent dose-response pattern
of increased cough, eye, and nasal
symptoms with exposures to
greater concentrations of H2S and
methyl mercaptan.
Jaakkola, J. JK., et al.
(1990)
H2S at 2.3 ug/m3 annual mean,
42.3 ng/m3 daily maximum,
and 177.0 ng/m3 half-hour
maximum ambient
concentrations.
Also exposed to SO2, methyl
mercaptan, other sulfur
compounds, particulates, and
NO, from pulp mills and a
heating plant.
Exposures were chronic, and
the duratioVi of the study was a
12-month period
Two age-groups of children in
three cities, one heavily
polluted city and two reference
cities with low concentrations
of pollutants due to lack of
sources The polluted city also
was divided into areas of more
and less pollution
The two groups comprised
679 infants 14 to 18 months
old and 759 children age 6
years
More upper respiratory infections
were reported in the polluted city.
Children in the more polluted area
of the polluted city had more
infections than children in the less
polluted area
Jaakkola, J. JK., et al.
(1991)
8/29/00
10
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Compounds, Concentrations,
and Duration
Population Group
Health Effects
References
H2S as a major component
(-67%) of total reduced sulfur
that was reported at
concentrations ranging from 2
to 82 ug/m3.
Also exposed to SO2, total
suspended participates, and
NOX from pulp mills; pollutants
were monitored continuously.
Duration of study was 15
months.
81 adults ranging in age from
21 to 73 years, with a mean
age of 48 years; all were
residents of an area that is I 5
km from a pulp mill, study area
was in an industrial city
Six surveys - two each carried
out after days of exposure to
low, medium, and high
concentrations of sulfur
compounds
A clear exposure-response pattern
of significantly greater eye, upper
and lower respiratory tract, and
headache symptoms during
medium and high exposures,
significantly higher occurrence of
nausea during high exposures.
Marttila, O., et al. (1995)
Emissions from an industrial
waste water treatment plant
that processed contaminated
water from a major oil
company.
No specific compounds or
concentrations reported.
Exposures reported with
reference to conception - any
time prior, four months prior,
three months after.
89 women ranging in age from
18 to 38 years, all wives of
workers in the waste water
treatment plant Number of
pregnancies ranged from 1 to
8, with a median of 2
Only verified miscarriages or
stillbirths were included in the
analysis.
Fetal loss rate of exposed
pregnancies was significantly
greater than the rate for the
unexposed Results of this study
were compatible with male
exposure producing defective
conceptus, resulting in
spontaneous abortion
Authors' note use extreme
caution in interpreting these
results, reasons were not stated
Morgan, R. W., et al
(1984)
8/29/00
II
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Compounds, Concentrations,
and Duration
Population Group
Health Effects
References
Petrochemical emissions,
including H2S, benzene, and
gasoline, from a large industrial
complex.
Concentrations and duration
not stated.
2,853 women who worked in a
petrochemical complex,
ranging in age from 20 to 44
years; all women reported at
least one pregnancy; 57%
reported occupational
exposure to petrochemicals
during first trimester of
pregnancy.
Significantly increased risk of
spontaneous abortion for women
who had frequent exposure to
petrochemicals compared with
those working in nonchemical
plants. Analyses of exposures to
specific chemicals - benzene,
gasoline, and H2S were significant.
Xu, X.,etal. (1998)
H2S as a major component (60
to 70%) of total reduced sulfur
that was reported at
concentrations ranging from 2
to 155 ug/m3 in an exposed
community.
Also exposed to SO: from a
pulp mill and sulfate mill;
pollutants were monitored
continuously.
Duration of study was 9
months in the exposed
community and 3 months in a
reference community.
336 adult men and women who
lived in a residential area ~ I
km from a sulfate mill, in a
town with a large pulp and
paper mill, mean age = 45 y
380 adult men and women who
lived in a reference community
with no emissions of total
reduced sulfur; mean age = 48.
Significant increases in headache
or migraine, eye and nasal
symptoms, cough, and acute
respiratory infections were
reported in the polluted
community, compared with the
reference community
Partti-Pellinen, K., et
(1996)
8/29/00
12
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Table 3. Clinical Studies of Human Exposures to Hydrogen Sulfide
Concentrations
Duration & Frequency of
Exposure
Number of Test Subjects,
Controls, & Length of
Experiment
Health Effects
References
Control = 0, 0.5, 2 0, and 5.0
ppm H2S on four separate
occasions
Duration short-term — test
subjects pedaled a cycle
ergometer and stopped when
they reached volitional fatigue
or did not increase oxygen
uptake with increasing power
output.
Sixteen healthy male subjects
who volunteered for the study,
ages were 25.2 ± 5 5 years
Control was a concentration of
H2S = 0
Short-term incremental test;
exact length of experiment not
stated, study designed to
examine acute effects of oral
H2S inhalation during exercise
Comparing H2S exposures
with control ~ no significant
differences in heart rate or
ventilation, blood lactate
concentrations increased,
oxygen uptake tended to
increase and CO2 output
decreased All test subjects
could exercise at their
maximum metabolic rates
while breathing 5.0 ppm H2S
during short-term incremental
tests.
Bhambhani, Y, and M. Singh
(1991)
8/29/00
13
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Concentrations of HjS,
Duration & Frequency of
Exposure
Number of Test Subjects,
Controls, & Length of
Experiment
Health Effects
References
Control = 0, and 5 0 ppm H2S
during three sessions over a
three-week period; duration of
control and experimental
exposures was 30 minutes
25 healthy subjects, 13 men
and 12 women, who
volunteered for the study, ages
were 24 7 ± 4 6 years for
males and 22 0 ± 2.1 years for
females Control medical air,
concentration of H2S = 0
Subjects completed two tests
on cycle ergometer at 50% of
their maximal aerobic power
while breathing medical air or
5 0 ppm H2S.
Comparing H2S exposures
with control — no significant
differences in oxygen uptake,
COa production, respiratory
exchange ratio, heart rate,
blood pressure, arterial blood
O2 and CO2 tensions or pH,
and perceptual responses in
either sex
Bhambhani, Y., etal. (1994)
Control = 0, and 5 0 ppm H2S
during three sessions over a
three-week period, duration of
control and experimental
exposures was 30 minutes.
Same as above, muscle
biopsies were taken at the end
of exercise to examine effects
of H2S on energy metabolism
Comparing H2S exposures
with control ~ only significant
finding was decrease in
concentration of citrate
synthetase enzyme in men
Bhambhani, Y., etal. (1996)
8/29/00
14
-------
Concentrations or H2S,
Duration & Frequency of
Exposure
Number of Test Subjects,
Controls, & Length or
Experiment
Health Effects
References
Control = 0, and 10 0 ppm H2S
during two sessions; duration
of control and experimental
exposures was 15 minutes.
19 healthy subjects, 9 men and
10 women, who volunteered
for the study Control =
medical air Subjects
completed two tests on cycle
ergometer at 50% of their
maximal aerobic power while
breathing medical air, then
IOOppmH2S
Comparing H2S exposures
with control -- no significant
effects on the acute pulmonary
function responses or any
unusual symptoms
Bhambhani, Y.,etal. (1996)
Control = 0, and 10 0 ppm H2S
during three sessions; duration
of control and experimental
exposures was 30 minutes
28 healthy subjects, 15 men
and 13 women, who
volunteered for the study
Control = medical air Subjects
completed two tests on cycle
ergometer at 50% of their
maximal aerobic power while
breathing medical air or 10 0
ppm H2S
Significant decrease in oxygen
uptake and increase in blood
lactate, tendency for decrease
in citrate synthase activity, a
marker for aerobic metabolism
Bhambhani, Y., etal. (1997)
8/29/00
15
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Discussion
Results of current research in the laboratory and in the field suggest that humans and
laboratory animals can tolerate H2S in low concentrations and durations, but that marked health
effects result when H2S exposure is either chronic or elevated. At lower levels of exposure, H2S
is an irritant that stresses the respiratory system, decreases oxygen uptake, and causes discomfort
to the head, especially the eyes. As presented in the tables above, symptoms have been reported
at very low H2S levels. Higher levels of exposure have resulted in stress to the respiratory system
at both the cellular and systemic levels These results suggest that irritation and edema of the
lungs and trachea over a long period of time could account for increased rates of acute upper
respiratory infections, respiratory disease, and cancers of the trachea, bronchus, lung, and nasal
passages.
8/29/00 16
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