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Emergency Planning for LEPCs

Emergency Planning for LEPCs. Susan Parker DEQ Jim Breuker EMHSD October 2009.  SARA Title III  Emergency Planning & Community Right-to-Know. Emergency preparedness “tools” & resources available to LEPCs Planning information that facilities must provide to LEPCs LEPC planning process

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Emergency Planning for LEPCs

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  1. Emergency Planning for LEPCs Susan Parker DEQ Jim Breuker EMHSD October 2009

  2. SARA Title IIIEmergency Planning & Community Right-to-Know • Emergency preparedness “tools” & resources available to LEPCs • Planning information that facilities must provide to LEPCs • LEPC planning process • Information available from the online database • HMEP Funding

  3. Way cool, Dude. Updated in 2009! Available on the Internet!

  4. SARA Title III in Michigan • Federal Regulation • Enforced by EPA • Implemented under Executive Order from the Governor

  5. SARA Title III - Components • Emergency Planning • Sections 302 & 303 • Emergency Release Notification • Section 304 • Hazardous Chemical Inventory • Sections 311 & 312 • Toxic Chemical Release Inventory • Section 313

  6. SARA TITLE III - Components • Emergency Planning - 302 & 303 • Hazardous Chemical Inventory

  7. Emergency Planning – 303LEPC Requirements • LEPC writes HAZMAT Emergency Plans (Off-site response) • Containing information about facilities subject to Section 302 • Submit to MSP-EMHSD • Provide copies to Responders How does the LEPC get the information it needs?

  8. Emergency Planning - 302 Facility Requirements • Submit Emergency Planning Notification,aONE TIME REPORT • Within 60 days after the Threshold Planning Quantity (TPQ) for the Extremely Hazardous Substance(EHS)is reached • To Michigan SARA Title III Program and the LEPC

  9. Emergency Planning - 302Facility Requirements • Designate a facility emergency coordinatorand tell the LEPC • Provide informationrequested by the LEPC that it needs to fulfill its planning responsibilities • Inform the LEPC of any changes relevant to emergency planning

  10. Emergency Planning“302 List” How can the LEPC assure an accurate 302 List? • Chapter 6 “LEPC Role in Compliance” • Form letters • Handouts • DEQ has email and phone number of person reporting online

  11. Emergency Planning“302 List” How else can the LEPC assure an accurate 302 List? • EMHSD website “Instructions for LEPCs to add Farms to Tier II Manager” - Guidance for LEPCs to Manage Farms on the 302 List: add, delete, edit

  12. Emergency Planning- Farms • Subject to Emergency Planning for anhydrous ammonia and pesticides • Emergency Planning for the Farm– MSU Extension Bulletin (7/06) • Includes postcards for section 302 Notification to LEPC & SERC • Includes SARA planning requirements for LEPCs

  13. Emergency Planning in Part 5 Rules: Spillage of Oil & Polluting Materials • Provide notification to the LEPC that they have completed a Pollution Incident Prevention Plan (PIPP) or an Integrated Contingency Plan (ICP) containing the PIPP requirements • Provide a copy of the PIPP or ICP to the LEPCupon request

  14. Emergency Planning in Clean Air Act sect 112(r) If the facility has an emergency RESPONSE plan… • Coordinate the Risk Management Plan with LEPC HAZMATemergency plan • Provide information to the LEPC upon request for developing and implementing the LEPC HAZMAT emergency plan

  15. Emergency Planning in Clean Air Act sect 112(r) If the facility will NOT RESPOND to a release… • Assure that facility with toxic chemicals is included in the LEPC HAZMATemergency plan • Assure that facility with flammable substances has coordinated response actions with the local fire department

  16. Plans State & Local • Emergency Operations Plan (EOP) /Emergency Action Guidelines (EAG) • Hazard Mitigation Plan • MIOSHA Firefighter Right-to-Know Plan • MIOSHA HazWOper Plan • SARA Title III Offsite HazMat Response Plan

  17. Local Planning Requirements • Michigan has a two phased approach • County Emergency Operations Plan (EOP)/County Emergency Action Guidelines (EAG) • LEPC develops an Off-Site HazMat Response Plan

  18. Local Planning Requirements • LEPCs and Local Emergency Management must work hand in hand to be successful • LEPC Plans are not stand-alone plans, they must be coordinated with and incorporated into the EOP/EAG

  19. A copy of this sheet must be attached to each plan since this info is part of the plan

  20. Basic Information • Basic information on how to respond can be found in the most currentEmergency Response Guidebook and on the EPA website • Note: primarily for transportation incidents but useful tool for fixed sites if other information is not available • hazmat.dot.gov/pubs/erg/gydebook.htm

  21. http://www.epa.gov/emergencies/content/cameo/index.htm • CAMEO/ALOHA/MARPLOT • Lists of Lists • Chemical Hazards & Reactivity Worksheet • Chemical References • Factsheets • Calculating vulnerability zones • Training modules and much more • Visit it!

  22. Planning Guidance • Review the Guidance for Community HAZMAT Response Plans

  23. Plan Submission • Plan & Plan Submittal Sheet (for new plans only) • Send to MSP/EMHSD District Coordinator • District Coordinator will send to EMHSD • Plan Review List (for updated plans only) • Send directly to EMHSD

  24. SARA TITLE III - Components • Emergency Planning • Hazardous Chemical Inventory - 311 & 312

  25. Hazardous Chemical Inventory 311 & 312 • Hazardous Chemicals = all substances for which the OSHA Hazard Communication Standardrequiresthe facility to maintainMSDSs(Employee Right-to-Know). • There is NO LIST of these “OSHA” hazardous substances

  26. Hazardous Substances covered bySARA Title III OSHA: Tier Two (311 & 312) EHS: Emergency Plan (302) & Release Report CERCLA: Release Report OSHA Hazardous (MSDS required) EHS CERCLA RCRA hazardous waste EHS and CERCLA chemicals in List of Lists

  27. Hazardous Chemical Inventory 311 & 312 • Thresholds for reporting: • OSHA hazardous substances = 10,000 pounds • EHS = 500 poundsorTPQ (whichever is lower) • Requests by LEPC/Fire Dept = zeropounds

  28. Hazardous Chemical Inventory 311 • INITIAL REPORT within 3 months after threshold reached • Submit MSDSsor • List of hazardous substances and associated hazards to: • Michigan SARA Title III Program • LEPC • Fire Department

  29. Hazardous Chemical Inventory 312 • ANNUAL REPORT by March 1st • Submit Tier Two Emergency and Hazardous Chemical Inventory to: • Michigan SARA Title III Program • LEPC • Fire Department Report on PREVIOUS full calendar year

  30. Can LEPCs request that non-OSHA chemicals be reported? • 40 CFR 355.30(d)(2): Upon request of the [LEPC], the owner or operator of a facility subject to this section [302] shall promptly provide the committee any information necessary for development or implementation of the local emergency plan.

  31. Facilities go online to complete and submit Tier Two reports to the state and all LEPCs and fire departments in Ingham, Kent, Oakland, Ottawa,and Wayne counties Facilities print hard copies of reports to send to LEPCs and fire departments in remaining counties TIER TWOONLINE REPORTINGTIER II MANAGER™

  32. TIER TWOONLINE REPORTING Information available to LEPCs and fire departments • Excel Queries • CAMEO file • Tier Two reports • Maps

  33. TIER TWOONLINE REPORTING TIER II MANAGER™ 3 Modules • Submit - for facilities & LEPCs managing Farms • Planning/Response – for select LEPCs & Fire Departments, MSP-EMHSD (including District Coordinators), Fire Marshall • Administration – for DEQ and licensed LEPC Administrators

  34. www.michigan.gov/deqsara SARA Guidebook Access Submit module

  35. www.michigan.gov/emhsd

  36. HMEP Funding • Funding levels increased in the 2008-2009 grant year • Additional data for USDOT is needed • Every LEPC will be eligible for a $1,000 support grant • Spending limitations (no equipment, no software, etc.) remain as before • Allowable expenses include: Training for members, plan development and improvement/implementation, exercises, commodity flow studies, tech staff to support planning, assessment of local response capabilities, needs analysis for establishing regional response teams

  37. HMEP Funding • Other requirements will apply • LEPC must meet quarterly • LEPC officer/membership list must be updated annually • LEPC plans must be incorporated into the city/county EOP/EAG • LEPC must review the EOP/EAG annually to make sure it’s hazmat response section is current

  38. HMEP $1000 Support Grant Funds Use and Assurances 2008-2009 LEPC Name: _______________________________ Support Grant funds will be/were used this grant year in the following ways (put an “X” in front of each appropriate item and give explanation/est. cost): _____ Training for LEPC Members Est. Cost: $ __________ _____ Exercises Related to HazMat Transportation and/or SARA Title III Sites No. of Exercises: ____ Est. Cost: $ __________ _____ Commodity Flow Studies (See http://www.phmsa.dot.gov/hazmat/grants for more information) Est. Cost: $ __________ _____ Technical Staff to Support the Planning Effort Est. Cost: $ __________ _____ Assessment of Local Response Capabilities Est. Cost: $ __________ Total of All Categories must equal a minimum of $1,000. Examples of eligible costs include: Meeting room rental, Per Diem for LEPC members, public notices, printing costs, office administrative expenses, LEPC staff costs. Computer hardware and software are not allowable expenses. I certify that the LEPC has met at least quarterly, updated its membership list by providing the EMHSD with changes, provided copies of completed off-site response plans to the appropriate local emergency management program for inclusion in the EOP/EAG, and reviewed the local EOP/EAG to make sure its HazMat section(s) are current. _______________________________________________ Date: ______________ LEPC Chairperson/Emergency Management Coordinator Signature

  39. HMEP Funding • Other funding levels remain • The per plan reimbursement amount for new plans remains $160 (assuming funding is available) • The per plan reimbursement amount for updating existing plans remains at $25 (assuming funding is available) • Local match for all HMEP funds received remains at 20% (federally funded positions/ programs cannot be used for match) • Information on how HMEP funds were used and what was accomplished will likely be requested

  40. Michigan SARA Title III Program Staff Database Manager: Tonya Schelter TRI Reporting:Ruth Borgelt Reporting (except TRI):Susan Parker

  41. SARA Title III – ReportingQuestions? MICHIGAN SARA TITLE III PROGRAM 517-373-8481 deq-ead-sara@michigan.gov www.michigan.gov/deqsara

  42. SARA Title III – LEPC & Emergency Plan Questions? MICHIGAN STATE POLICE EMERGENCY MANAGEMENT & HOMELAND SECURITY DIV 517-333-7776 Jim Breuker: breukerj1@michigan.gov Thom Higinbotham: higinbot@michigan.gov www.michigan.gov/emhsd

  43. Environmental Program Questions? MDEQ ENVIRONMENTAL ASSISTANCE CENTER 800-662-9278 deq-ead-env-assist@michigan.gov www.michigan.gov/deq www.michigan.gov/deqworkshops

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