EPA Region 8 Emergency Preparedness Newsletter
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Volume XII No. I First Quarter 2022 Newslette
Welcome to the EPA Region 8 Preparedness Newsletter.
Feel free to page through the entire newsletter or click on the links
to the stories you want to read first.
OSC Response-Lodge
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TRI Announcements
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Safety Announcement
Addressing PFAS
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Chemical Emergency
Preparedness and
Prevention Documents
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Page 2
OSC Response-Lodge Grass Drum Removal
Removal Actions can often be complex endeavors. The physical location and/or environment,
the types of contaminants present, the legal or regulatory challenges can all combine to make a
removal action more difficult. Such is the case with the action described below.
EPA's Region 8 Resource Conservation and Recovery Act (RCRA) Program initially became
aware of some abandoned 55-gallon drums in the summer of 2018 based upon a referral from
the Crow Tribe Environmental staff. The drums were located on a parcel of property in Big
Horn County, Montana and located just outside the town of Lodge Grass, on the 1-90 Frontage
Road, and is within the boundary of the Crow Reservation. The property is on the left
descending bank of the Little Bighorn River approximately 19 miles upstream of the water
intakes for the Crow Agency and Bureau of Indian Affairs (BIA) Drinking Water Treatment
Plants. Lodge Grass, population 428, is located within one mile of the property, and the
downstream drinking water treatment plants serve a population of approximately 1,800 people,
of which approximately 95% are Native Americans. The site is in a heavily wooded area and is
near two abandoned structures with difficult vehicle access. The primitive road nearest to the
abandoned drums was blocked by a fallen tree and a wire fence.
The property owner was aware of the
drums and said that they were left there
with permission. It was the owner's
perception that the drums contained used
motor oil. On July 10, 2018, EPA RCRA
staff conducted a site inspection to assess
the condition of the drums and containers
at the site. Twenty 55-gallon steel-top
drums were identified in a single group, all
appearing to contain liquids. The drums
and containers were on undeveloped
ground near one of the unoccupied
residential structures, approximately 500
feet from the banks of the Little Bighorn
River. Observations indicated the drums
were in various states of deterioration.
Rust was observed on most drums, and an
oily film and staining was present on the ground around the drums, indicating a release to the
environment.
EPA worked closely with the property owner and Tribal authorities to provide direction and
support for the removal, including a second site inspection in May of 2019. After over two
years of conversations and negotiations, it became clear that the disposition of the drums would
not change without stronger intervention. In July 2020, RCRA referred the Site to EPA's
Superfund Response program. EPA corresponded with the property owner on numerous
occasions in efforts to receive access to the property between August 2020 to October 2020. No
apparent disposal efforts by the property owner had been made by February 2021. EPA issued
an order requesting access to the property to perform the waste removal under the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). The
property owner ultimately granted EPA access following the issue of the order.
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Page 3
OSC Response-Lodge Grass Drum Removal
On the morning of February 23, 2021, Region 8 On-Scene Coordinator (OSC) C. Myers joined
START (Superfund Technical Assessment and Response Team) and ERRS (Emergency and
Rapid Response) contractors to further assess the site. ERRS crews immediately began to
assist in moving the fallen timber, fencing and brush overgrowth allowing the OSC and
contractors gain vehicle access and to sample and characterize the drums. In addition to the 20
closed top steel drums inventoried in the original RCRA inspections, two small metal
containers and a large pile of used tires were documented as being present at the scene. ERRS
staff secured the immediate area using caution tape and fence posts. Air monitoring and
radiation surveying near the drums indicated no elevated readings above background levels.
Fluid samples were taken from the
drums to characterize the waste streams
and to ensure proper disposal. On-site
sampling, as well as fixed laboratory
analysis done later revealed a complex
soup of contaminants, ranging from
petroleum-based oils and fuels as well
as anti-freeze and other coolants,
volatile solvents, perfluoro compounds,
and halogenated hydrocarbons. Several
drums were frozen in the ground, and
various means to extract them were
employed, including using the
excavator-mounted drum hoist.
Leaking containers were placed in new
overpack drums and bungs were
replaced on any drums that had
damaged/missing bungs mitigating any
further release of drum contents. The
contents of partially full drums were consolidated in other competent drums with similar waste
on site or were transferred and bulked into new steel drums. All waste was transported to the
Montana Department of Transportation (MDOT) lot to be secured while awaiting final
disposal.
Over the next two days, a roll-off dumpster was delivered to the site, and 151 tires were
collected and loaded. The dumpster was transported to the City of Billings landfill. Finally,
ERRS contractors removed approximately six cubic yards of soil (4.5 inches) from an area
measuring approximately 35 feet long by 12 feet wide in the former vicinity of the drums.
Contaminated soil was loaded into six lined Clean Pak cubic yard boxes for transport to the
MDOT yard.
In April 2021, the hazardous soil and the non-hazardous solids and liquids were transported to
a Clear Harbor site in Colorado, and the hazardous non-flammable and flammable liquids were
incinerated at a Clear Harbor site in Nebraska.
This action illustrates that not only does an OSC need to be an adept technical resource and
project manager, but sometimes they can also be pulled into the role of diplomat and educator
in order to successfully compete a project.
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Page 4
New Region 8 Administrator
Kathleen (KC) Becker has been appointed as EPA's Regional Administrator for Region 8.
Becker will lead the implementation of the Biden-Harris environmental agenda in Colorado,
Montana, North Dakota, South Dakota, Utah, Wyoming and with 28 Tribal Nations.
"With her background on critical climate change and environmental justice issues, KC is an
excellent choice to lead our Region 8 team. She is experienced in stakeholder engagement and
will ensure voices from throughout the region are heard on key issues," said EPA Administrator
Michael S. Regan.
"I am so honored to have the opportunity to serve the Biden Administration as EPA Region 8
Administrator. The aggressive and critical agenda that President Biden and Administrator Regan
have announced to address climate change, repair aging water infrastructure, and drive down
methane emissions requires an 'all hands on deck' approach. I am ready to use my experience to
help states, Tribal governments, businesses, and communities in Region 8 implement these
important pieces of the Biden agenda," KC Becker said.
KC Becker recently completed four terms in the Colorado legislature, culminating as Speaker of
the House. Prior to serving in the Colorado legislature, she served four years on Boulder,
Colorado's city council. She worked for nearly seven years as an attorney-advisor in the
Solicitor's Office at the US Department of the Interior, practicing administrative and natural
resources law. While in the Colorado legislature, Becker led landmark legislation to reform
Colorado's oil and gas sector, created a first in the nation Office of Just Transition, and passed
nationally-leading legislation requiring the state of Colorado to put forward a plan to meet
carbon reduction goals. Becker lives in Boulder with her husband and two sons.
NASTTPO
The National Association of SARA Title III Program Officials (NASTTPO) has announced they
currently plan to move forward with hosting an in-person annual workshop scheduled to be held
in Covington, Kentucky, April 18-21, 2022. The agenda will highlight new trends in emergency
planning, showcase our most active and progressive LEPCS, and provide both regulatory and
programmatic updates.
For workshop details, room reservation information, and registration information, please consult
the NASTTPO website for more information.
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Page 5
Chemical Safety Advisory
In November 2021, a joint safety advisory was issued by EPA, the Occupational Safety and Health
Administration (OSHA) and the Cyber and Infrastructure Security Agency (CISA) for chemical
warehouses and distribution facilities. These companies must ensure that their chemicals are man-
aged safely, securely and in compliance with EPA, OSHA, and CISA programs to help prevent
chemical accidents and security incidents. The Joint Safety Advisory can be viewed on the
webpage and direct link to the PDF.
EPA's Office of Enforcement and Compliance Assistance (OECA) as a part of their National Com-
pliance Initiative also released an enforcement alert for Chemical Accident Risk Reduction titled
Risks of Improper Storage of Hazardous Chemicals at Chemical Warehouses and Distributi on Fa-
cilities, November 2021. This Enforcement alert is on the website and direct link to the PDF.
&EPA
United States
Environmental Protection
Agency
PHMSA Hazmat Roundtable
To help guide the complex nature of hazardous materials emergency response , the International
Association of Fire Chiefs (IAFC) has convened periodic Roundtable meetings for hazardous mate-
rials (hazmat) response technical specialists and subject matter experts. In these Roundtable meet-
ings, participants identify critical issues and suggest plans of action to strengthen hazmat prepared-
ness. In 2019, the U.S. Department of Transportation (DOT) Pipeline and Hazardous Materials
Safety Administration (PHMSA) and the U.S. Fire Administration (USFA) partnered with the
IAFC to reconvene the Roundtable process with a two-day meeting on February 5 and 6, 2019, at
the IAFC Headquarters in Chantilly, Virginia. A number of the major issues identified in that meet-
ing were then further examined by Roundtable member teams in three concurrent assessment ef-
forts in 2021. The three assessment efforts focused on developing possible action options (1) to im-
prove LEPC/TERC performance; (2) to improve risk-based response and preparedness; and (3) to
improve hazmat prevention and mitigation programs (the report of these three assessment efforts is
located in the appendix of this report). The analysis of hazmat issues initiated in 2019 was contin-
ued at the Roundtable meeting held on October 26 and 27, 2021.
To view the entire report, see the 2021 Hazardous Material Emergency Response Roundtable Re-
port link.
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Page 6
Western Regions Conference
EPA Regions 8, 9, and 10 partnered together to host virtual version of our annual Western State
Emergency Response Commissions (SERCs) and Tribal Emergency Response Commissions
(TERCs) meeting on January 25th and 26th. This annual meeting provides an opportunity for
SERC and TERC members to share ideas and problem solve with their peers and federal part-
ners.
Approximately 80 attendees were in attendance representing states from all three regions. Other
federal agency representatives including the Pipeline and Hazardous Materials Safety Admin-
istration, the Cybersecurity and Infrastructure Security Agency, Occupational Safety and Health
Administration, Federal Emergency Management Agency and the National Oceanic and Atmos-
pheric Administration also participated.
Agenda highlights included a discussion on upcoming activities in planning, training and exer-
cises and a panel discussion including topics on Butane hazards associated with the cannabis
industry, emergency planning and extreme weather events and environmental justice.
For more information, contact Bre Bockstahler at bockstahler.breann@epa.gov or visit re-
sponse. epa.gov/WesternSERCs2022.
RMP Guidance Update
EPA's Office of Emergency Management has updated two portions of the RMP Guidance,
Chapters 8 (Emergency Response) and 11 (Communication with the Public), to reflect recent
regulatory changes and are now posted. The updated chapters can be found here: https://
www.epa.gov/rmp/guidance-facilities-risk-management-programs-rmp#general.
Potential RMP Regulation Update
Under the current administration, EPA is reviewing the RMP rule in accordance with Executive
Order 13990: Protecting Public Health and the Environment and Restoring Science To Tackle
the Climate Crisis (EO 13990). The Agency is considering improvements to the RMP rule to
better address the impacts of climate change on facility safety and protect communities from
chemical accidents, especially vulnerable and overburdened communities living near RMP facil-
ities. In June and July 2021, EPA held two virtual public listening sessions, which gave approxi-
mately 770 interested people the opportunity to present information, comments or views pertain-
ing to the review of RMP regulation revisions completed since 2017.
EPA is working toward publishing a proposed rule by September 2022, as reflected in the 2021
Fall Regulatory Agenda, which can be found here.
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Page 7
LEPC/TEPC Handbook Now Final
EPA developed this national handbook as a resource for local and tribal emergency planning
committees (LEPCs and TEPCs) to strengthen community preparedness for accidental chemical
releases. It compiles and expands upon existing guidance materials for the Emergency Planning
and Community Right-to-Know Act (EPCRA) and its amendments under the America's Water
Infrastructure Act (AWIA) of 2018. This resource will be particularly helpful for new members
of tribal and local organizations responsible for implementing EPCRA and for communities that
may deal with chemical accidents.
This full handbook is organized into distinct chapters and sections online for ease of use.
Included within the handbook are a multitude of samples and examples of documents to assist
in running your LEPC/TEPC.
TRI Updates
Natural Gas Processing Facilities Added to TRI Reporting Requirements
This past fall, EPA finalized a rule requiring all natural gas processing facilities that meet TRI
reporting criteria to begin reporting in 2023 (for calendar year 2022 data). Natural gas
processing facilities that primarily recover sulfur from natural gas were already covered by TRI
reporting requirements. The Agency believes at least 321 U.S. natural gas processing facilities
will meet TRI reporting criteria.
First-Ever Use of EPCRA Discretionary Authority to Add Individual Facilities
For the first time in the TRI Program's history, EPA is using its EPCRA discretionary authority
to add 29 individual contract sterilization facilities that use ethylene oxide and/or ethylene
glycol to the scope of facilities subject to TRI reporting requirements. Under EPCRA, the EPA
Administrator may extend TRI reporting requirements to specific facilities based on a
chemical's toxicity, the facility's proximity to other facilities that release the chemical or to
population centers, any history of chemical releases at the facility, or other factors the
Administrator deems appropriate.
RY 2021 TRI Reporting Season Opens
Industrial and federal facilities may now begin submitting TRI reporting forms for calendar year
2021 data using TRI-MEweb. These data, covering waste management and source reduction
activities that occurred at facilities during 2021, are due to EPA by July 1, 2022.
Have You Tried EPA's Most User-Friendly Tool for Finding and Visualizing TRI Data?
EPA has merged its "TRI Search" and "TRI Search Plus" tools and renamed them "TRI Toxics
Tracker." This tool is ideal for beginning users and for use on mobile devices. You can search
for TRI facilities near an address or location or by facility name and see summary-level TRI
data for the latest reporting year. Beyond TRI data, summaries include RSEI (Risk Screening
Environmental Indicators) modeling results of release data, facility compliance and enforcement
information, and surrounding community demographic information. TRI Toxics Tracker is
available in English and Spanish via the TRI homepage: www.epa.gov/tri.
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Page 8
Addressing PFAS
How is the Preparedness and Site Assessment Section addressing per- and polyfluoroalkyl
substances (PFAS)?
The Site Assessment Team within Region 8's Superfund and Emergency Management Division
has been addressing issues of PFAS in the region through a number of activities that provide
support to the Agency, States, Tribes, and local governments over the past couple years. PFAS
are a class of manmade chemicals that have been manufactured and used in a variety of
industries since the 1940s. These chemicals include PFOA, PFOS, GenX, and thousands of
others. They are found in a wide array of consumer and industrial products and are persistent
and bioaccumulative. Exposure can lead to adverse human health effects including reduced
response to vaccines, lower birth rate, delayed mammary gland development, thyroid disease,
increased cholesterol levels, liver damage, kidney cancer, and testicular cancer. Addressing
PFAS is a priority for the Administration and Administrator Regan has charged the agency with
building on our ongoing work to better understand and ultimately reduce the potential risks
caused by these chemicals. Information on national ongoing efforts can be found here.
The team finalized the Template PFAS SAPZOAPP (Sampling and Analysis Plan/Quality
Assurance Project Plan) in February of 2021. The purpose of developing this template was to
assist States, Tribes, and local governments with the time-consuming task of developing a new
SAP/QAPP each time they went into the field to sample for PFAS. The template is an Excel-
based tool with easy-to-understand user inputs that automatically populate a site-specific QAPP.
This template has already been used by the Montana DEQ, the State of Colorado, and the
Region 8 Drinking Water Division. In addition, the Confederated Salish and Kootenai Tribes in
Montana recently requested a presentation on the template and will be using it soon to sample
for PFAS on tribal land.
Next, the Regional Research Partnership Program (R2P2) PFAS Occurrence Mapping and
Diagnostic Project is a collaboration between the Site Assessment Team in Region 8 and the
EPA's Office of Research and Development (ORD) to develop their national GeoPFAS tool in a
more focused regional and local context. The goal of the project is to use ORD's GeoPFAS tool,
as well as PFAS sampling data already collected from State, Tribal, and local governments in
the region to predict unknown and emerging PFAS threats.
Finally, the Site Assessment Team worked with the Region 8 Science Council in 2021 to
develop the PFAS Interdisciplinary Resource Coordination Committee (PIRCC). The PIRCC
was formed to encourage regional communication, coordination, and support for PFAS
practitioners across programs. Specifically, the PIRCC has established a MS Teams site for
PFAS resources and to assist us in facilitating and coordinating regional support for addressing
the challenges associated with PFAS by leading the Community of Practice. Since its inception,
the PIRCC consists of staff members from across seven divisions and twelve branches in the
region.
If you're interested in knowing more about the Template
PFAS SAP/OAPP, the PFAS Occurrence Mapping and
Diagnostic Project, or the PIRCC, please feel free to
contact David Fronczak (fronczak.david@epa.gov) for
more information.
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Page 9
Outreach and subArea Contingency Planning
Outreach
EPA Region 8's Emergency Management Branch (EMB), which includes both the Response
Section and the Preparedness and Site Assessment Section, is actively working to plan and
coordinate outreach efforts throughout Region 8 this fiscal year. These outreach efforts
include compliance assistance workshops, targeted training events and exercises, technical
assistance to LEPCs/SERCs/TERCs, and contingency planning for environmental
emergencies. The objective of these efforts is to enhance partnerships with local emergency
management agencies and first responders, state environmental and emergency management
agencies, and tribes. These
outreach activities will also be
informed by environmental justice
and climate adaptation priorities.
If you're interested in having EPA
partnership in your environmental
or homeland security emergency
preparedness activities, please
contact Bre Bockstahler (303-312-
6034 or
bockstahler.breann@epa. gov)
for more information.
subArea Contingency Planning
The National Oil and Hazardous
Substances Pollution Contingency
Plan (NCP), outlined in 40 CFR
300, requires EPA to prepare for
the potential threats posed by worst
-case discharges of petroleum. For
planning purposes, EPA Region 8 has been subdivided into 10 sub Areas defined primarily by
large watersheds or adjacent hydrologic units, as shown. Within these sub-Areas, EPA teams
are working with local, state, and tribal partners to complete subArea Contingency Plans
(sACPs) for discharges into rivers and tributaries from bulk oil storage facilities, pipelines,
railroads, and bulk tanker truck shipments.
As these sACPs are developed, sensitive areas identified by EMB staff and the subArea
stakeholders will be displayed in TERA, EPA Region 8's GIS-based viewer along with
recommended response strategies. subArea Contingency Plans or Geographic Response Plans
have been used by several other EPA regions to accomplish this important purpose in the
inland zone. sACPs highlight potential oil discharge locations, define the sensitive natural,
cultural/historic, and economic resources that could be impacted, and develop effective
response strategies that could be implemented to contain, remove, and clean-up the spill.
EPA cannot and should not do this important planning work alone, and we invite all
stakeholders, including first responders, natural resource trustees, historic preservation
officers, water utilities, industry, and tribal, state, and local governments to participate in the
process.
If you're interested in participating in the sACP activities in your area, please contact Gina
Cristiano (303-312-6688 or cristiano.gina@epa.gov) for more information.
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EPA Covid Resources
Page 10
EPA is updating its coronavirus website to include new resources for state, local, and tribal
agencies and intergovernmental associations. These resources will help EPA and its partners
continue to provide the environmental protection the nation depends on without interruption
during the coronavirus public health emergency.
EPA's Coronavirus (COVID- l 9) Resources for State. Local and Tribal Agencies and Associa-
tions contains important information on grants, enforcement and compliance programs, water
infrastructure, and a host of other issues important to effective environmental program delivery.
The webpage will be updated regularly with new information.
EPA is also continuing to update resources on its website and add to the list of surface disin-
fectant products that are effective against SARS-CoV-2. To contact EPA about any coronavirus
(COVID-19) issue, you may do so here: https://www.epa.gov/coronavirus/forms/contact-us-
about-coronavirus-covid-19.
Chemical Emergency Preparedness and
Prevention Documents
EPCRA Requirements: http://www.epa.gov/epcra
NRT Hazardous Materials Emergency Planning Guidance:
https://www.nrt. org/Main/Resources.aspx?ResourceType=Hazards%20('Oil%20Chemic
al.%20 Radi ol ogi cal ,%20etc )& ResourceSecti on=2
Actions to Improve Chemical Facility Safety and Security - A Shared Commitment:
https://www.osha.gov/chemicalexecutiveorder/index.html
EPCRA On-Line Training: https://www.epa.gov/epcra/epcra-non-section-313-online-
training-states-tribes-lepcs-local-planners-and-responders
EPCRA Fact Sheets: https://www.epa.gov/epcra/epcra-fact-sheets
EPCRA Regional Contacts: https://www.epa.gov/epcra/epcra-regional-contacts
EPCRA, RMP & Oil Information Center: https://www.epa.gov/epcra/forms/contact-us-
about-emergencv-planning-and-communitv-right-know-act-epcra
TIER2 Submit: https://www.epa.gov/epcra/tier2-submit-software
LEPC/TEPC Handbook: https://www.epa.gOv/epcra/national-lepc-tepc-handbook#full
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Page 11
EPA Region 8 Preparedness Program
We will increase EPA Region 8 preparedness through:
• Planning, training, and developing outreach relations with federal agencies, states, tribes, local OUR
organizations, and the regulated community. MISSIC
• Assisting in the development of EPA Region 8 preparedness planning and response capabilities
through the RSC, IMT, RRT, OPA, and RMP.
• Working with facilities to reduce accidents and spills through education, inspections, and enforcement.
To contact a member of our Region 8 EPA Preparedness Unit team, review our programs or view our
organization chart, click this link.
Region 8 SERC Contact Information
Colorado
Montana
Utah
Ms. Amanda Hettinger, Co-Chair
Ms. Delila Bruno, Co-Chair
Ms. Kim Shelley , Co-Chair
Phone: 303-692-2000
Phone: 406-324-4777
Phone: 801-536-4404
amanda.hettinger@state.co.us
dbruno@mt.gov
kshelley@utah.gov
Ms. Lynn Bailey, Co-Chair
Mr. John Rasmann, Co-Chair
Mr. Jess Anderson Co-Chair
Phone: 720-852-6606
Phone: 406-444-5328
Phone: 801-965-4062
lynn.bailey@state.co.us
jrasmann2@mt.gov
jessanderson@utah.gov
North Dakota
South Dakota
Wyoming
Mr. Darin Hanson, Chair
Mr. Dustin Willett, Chair
Mr. Dale Heggem, Chair
Phone: 701-328-8100
Phone: 800-433-2288
Phone: 307-777-7321
nddes@nd.gov
Contact: Kelsey.Newling@state.sd.us
dale.heggem@wyo.gov
RMP Region 8 Reading Room: (303) 312-6345
RMP Reporting Center: The Reporting Center can answer questions about software or installation
problems. The RMP Reporting Center is available from 8:00 a.m. to 5:30 p.m., Monday - Fri-
day:(703) 227-7650 or email RMPRC@epacdx.net.
RMP: https://www.epa.gov/rmp EPCRA: https://www.epa.gov/epcra
Emergency Response: https://www.epa.gov/emergencv-response
Lists of Lists (Updated September 2021)
Questions? Call the Superfund, TRI, EPCRA, RMP, and Oil Information Center at (800) 424-9346 (Monday-
Thursday).
To report an oil or chemical spill, call the National Response
Center at (800) 424-8802.
U.S. EPA Region 8
1595 Wynkoop Street (8SEM-EM)
Denver, CO 80202-1129
800-227-8917
This newsletter provides information on the EPA Risk Management Program, EPCRA, SPCC/FRP (Facility Response Plan) ami other issues relating
to Accidental Release Prevention Requirements. The information should be used as a reference tool, not as a definitive source of compliance
information. Compliance regulations are published in 40 CFR Part 68 for CAA section 112(r) Risk Management Program, 40 CFR Part 355/3 70for
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