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

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

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

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

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

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

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

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

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10 Emergency Planning Facility Requirements Designate a facility emergency coordinator and tell the LEPC Designate a facility emergency coordinator and tell the LEPC Provide information requested by the LEPC that it needs to fulfill its planning responsibilities Provide information requested by the LEPC that it needs to fulfill its planning responsibilities Inform the LEPC of any changes relevant to emergency planning Inform the LEPC of any changes relevant to emergency planning Designate a facility emergency coordinator and tell the LEPC Designate a facility emergency coordinator and tell the LEPC Provide information requested by the LEPC that it needs to fulfill its planning responsibilities Provide information requested by the LEPC that it needs to fulfill its planning responsibilities Inform the LEPC of any changes relevant to emergency planning Inform the LEPC of any changes relevant to emergency planning

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

12 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 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 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 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

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

14 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 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 LEPC upon request Provide a copy of the PIPP or ICP to the LEPC upon request 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 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 LEPC upon request Provide a copy of the PIPP or ICP to the LEPC upon request

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

16 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 HAZMAT emergency plan Assure that facility with toxic chemicals is included in the LEPC HAZMAT emergency plan Assure that facility with flammable substances has coordinated response actions with the local fire department Assure that facility with flammable substances has coordinated response actions with the local fire department If the facility will NOT RESPOND to a release… Assure that facility with toxic chemicals is included in the LEPC HAZMAT emergency plan Assure that facility with toxic chemicals is included in the LEPC HAZMAT emergency plan Assure that facility with flammable substances has coordinated response actions with the local fire department Assure that facility with flammable substances has coordinated response actions with the local fire department

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

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

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

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

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

24 /content/cameo/index.htm /content/cameo/index.htm /content/cameo/index.htm /content/cameo/index.htm CAMEO/ALOHA/MARPLOT CAMEO/ALOHA/MARPLOT Lists of Lists Lists of Lists Chemical Hazards & Reactivity Worksheet Chemical Hazards & Reactivity Worksheet Chemical References Chemical References Factsheets Factsheets Calculating vulnerability zones Calculating vulnerability zones Training modules and much more Training modules and much more Visit it! Visit it!

25 Planning Guidance Review the Guidance for Community HAZMAT Response Plans Review the Guidance for Community HAZMAT Response Plans

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

27 SARA TITLE III - Components Emergency Planning Emergency Planning Hazardous Chemical Inventory & 312 Hazardous Chemical Inventory & 312 Emergency Planning Emergency Planning Hazardous Chemical Inventory & 312 Hazardous Chemical Inventory & 312

28 Hazardous Chemical Inventory 311 & 312 Hazardous Chemicals = all substances for which the OSHA Hazard Communication Standard requires the facility to maintain MSDSs (Employee Right-to-Know). Hazardous Chemicals = all substances for which the OSHA Hazard Communication Standard requires the facility to maintain MSDSs (Employee Right-to-Know). There is NO LIST of these OSHA hazardous substances There is NO LIST of these OSHA hazardous substances Hazardous Chemicals = all substances for which the OSHA Hazard Communication Standard requires the facility to maintain MSDSs (Employee Right-to-Know). Hazardous Chemicals = all substances for which the OSHA Hazard Communication Standard requires the facility to maintain MSDSs (Employee Right-to-Know). There is NO LIST of these OSHA hazardous substances There is NO LIST of these OSHA hazardous substances

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

30 Hazardous Chemical Inventory 311 & 312 Thresholds for reporting: Thresholds for reporting: OSHA hazardous substances = 10,000 pounds OSHA hazardous substances = 10,000 pounds EHS = 500 pounds or TPQ (whichever is lower) EHS = 500 pounds or TPQ (whichever is lower) Requests by LEPC/Fire Dept = zero pounds Requests by LEPC/Fire Dept = zero pounds Thresholds for reporting: Thresholds for reporting: OSHA hazardous substances = 10,000 pounds OSHA hazardous substances = 10,000 pounds EHS = 500 pounds or TPQ (whichever is lower) EHS = 500 pounds or TPQ (whichever is lower) Requests by LEPC/Fire Dept = zero pounds Requests by LEPC/Fire Dept = zero pounds

31 Hazardous Chemical Inventory 311 INITIAL REPORT within 3 months after threshold reached INITIAL REPORT within 3 months after threshold reached Submit MSDSs or Submit MSDSs or List of hazardous substances and associated hazards to: List of hazardous substances and associated hazards to: 1. Michigan SARA Title III Program 2. LEPC 3. Fire Department INITIAL REPORT within 3 months after threshold reached INITIAL REPORT within 3 months after threshold reached Submit MSDSs or Submit MSDSs or List of hazardous substances and associated hazards to: List of hazardous substances and associated hazards to: 1. Michigan SARA Title III Program 2. LEPC 3. Fire Department

32 Hazardous Chemical Inventory 312 ANNUAL REPORT by March 1 st ANNUAL REPORT by March 1 st Submit Tier Two Emergency and Hazardous Chemical Inventory to: Submit Tier Two Emergency and Hazardous Chemical Inventory to: 1. Michigan SARA Title III Program 2. LEPC 3. Fire Department Report on PREVIOUS full calendar year ANNUAL REPORT by March 1 st ANNUAL REPORT by March 1 st Submit Tier Two Emergency and Hazardous Chemical Inventory to: Submit Tier Two Emergency and Hazardous Chemical Inventory to: 1. Michigan SARA Title III Program 2. LEPC 3. Fire Department Report on PREVIOUS full calendar year

33 Can LEPCs request that non-OSHA chemicals be reported? 40 CFR (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. 40 CFR (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.

34 TIER TWO ONLINE REPORTING TIER II MANAGER 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 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 Facilities print hard copies of reports to send to LEPCs and fire departments in remaining counties 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 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 Facilities print hard copies of reports to send to LEPCs and fire departments in remaining counties

35 TIER TWO ONLINE REPORTING Excel Queries Excel Queries CAMEO file CAMEO file Tier Two reports Tier Two reports Maps Maps Excel Queries Excel Queries CAMEO file CAMEO file Tier Two reports Tier Two reports Maps Maps Information available to LEPCs and fire departments

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

37www.michigan.gov/deqsara SARA Guidebook Access Submit module

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39 HMEP Funding Funding levels increased in the grant year Funding levels increased in the grant year Additional data for USDOT is needed Additional data for USDOT is needed Every LEPC will be eligible for a $1,000 support grant Every LEPC will be eligible for a $1,000 support grant Spending limitations (no equipment, no software, etc.) remain as before 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 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

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

41 HMEP $1000 Support Grant Funds Use and Assurances 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 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

42 HMEP Funding Other funding levels remain Other funding levels remain The per plan reimbursement amount for new plans remains $160 (assuming funding is available) 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) 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) 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 Information on how HMEP funds were used and what was accomplished will likely be requested

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

SARA Title III – Reporting Questions? MICHIGAN SARA TITLE III PROGRAM

SARA Title III – LEPC & Emergency Plan Questions? MICHIGAN STATE POLICE EMERGENCY MANAGEMENT & HOMELAND SECURITY DIV Jim Breuker: Thom Higinbotham: MICHIGAN STATE POLICE EMERGENCY MANAGEMENT & HOMELAND SECURITY DIV Jim Breuker: Thom Higinbotham:

Environmental Program Questions? MDEQ ENVIRONMENTAL ASSISTANCE CENTER