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A Step Ahead

Developing effective environmental emergency prevention, control and countermeasure

By Valcar Bowman, REM, CEA May 1, 2002

The control of toxic and hazardous substances that may pose unreasonable risks to health and the environment is the basic purpose of all environmental and product safety legislation. However, the Clean Water Act (CWA), Resources Conservation and Recovery Act (RCRA), Oil Pollution Act (OPA) of 1990, Clean Air Act (CAA), the Superfund Amendments and Reauthorization Act (SARA), otherwise known as the Emergency Planning and Community Right-To-Know Act (EPCRA) and ISO-14000 standards require plans to be developed by affected facilities and communities to minimize the risk and impact of non-permitted releases of toxic and hazardous substances.

Getting Started
Affected and other concerned facilities should have -- at a minimum -- completed the following steps toward compliance with environmental emergency prevention, preparedness and response plan requirements.

• Designated an Emergency Coordinator;
• Assessed the site's chemical inventory with respect to threshold planning quantities of hazardous substances;
• Initiated chemical safety and emergency response training programs;
• Developed, acquired and submitted material safety data sheets;
• Notified U.S. EPA, the state emergency response commission (SERC), the local emergency planning committee (LEPC), local fire department and other relevant agencies and institutions;
• Prepared a true, accurate and complete hazardous substance mass balances;
• Submitted relevant plans, chemical inventories and toxic chemical release reporting forms to EPA, SERC, LEPC and other concerned and affected community organizations; and
• Developed risk prediction, health and environmental impact models and "what if" scenarios.

Typical requirements of environmental emergency prevention, control and countermeasure laws include:

• Material safety data sheets (MSDSs), inventory and locations of toxic and hazardous substances which could be spilled or released at the facility.
• Description of the manner in which such substances are stored and used, and also preventative maintenance programs.
• Procedures and provisions for prevention and control of accidental spills and releases.
• Training and management practices.
• Periodic inspections and audits.
• Probable nature, causes and routes of any sudden or unexpected spills or releases of such substances including a profile of the area and proximity to the public.
• Response procedures to be followed at the facility such as response actions, on-site alarm systems and evacuation plans.
• Notification procedures to regulatory and emergency responses agencies including LEPC, police, fire departments and hospitals.
• List of names, addresses and phone numbers of appropriate plant personnel qualified to act as the facility's emergency coordinator.
• List of emergency equipment, on-site and off-site resources.

A Blueprint for a Successful Plan
To demonstrate that a facility recognizes the importance of preventing releases of contaminants into the environment, facilities should develop and implement a comprehensive environmental emergency prevention, control and countermeasures (EEPCC) plan. The plan must be designed to provide procedures and controls used to prevent toxic and hazardous atmospheric emissions; oil and hazardous substances spills to the land and water; and harmful releases of hazardous substances to the subsurface environment. It must stress the immediate coordination of all activities to minimize any harmful health and environmental effects; and include notifications to appropriate government agencies and affected communities.

For the purpose of handling release of contaminants appropriately, the plan must also provide descriptions of the duties to be performed by facility personnel, procedures to be followed, available equipment, available outside resources and training. Training exercises and drills are also essential aspects of a facility?s environmental emergency preparedness and response program.

Developing your facility EEPCC plan based on the following outline is suggested:

General Facility Information Facility description

• Storage tanks and process vessels
• Hazardous waste storage
• Loading and unloading facilities
• Piping
• Site security
• Lighting

Prevention Programs

• Relief value inspection and maintenance program
• Preventative maintenance program
• Corrosion protection program
• Tank integrity, inspection and leak detection programs
• Process safety management programs
• Emission and discharge monitoring program
• Drum control program
• Personnel training

Atmospheric Release Control and Countermeasures

• Air pollution abatement systems inspection and maintenance program
• Preventative measures and equipment
• Special precautions against uncontrolled releases
• Containment measures and alarms systems

Release and Hazardous Waste Control

• Release potential, and control
• Containment and diversionary structures
• Commitment of manpower and equipment
• Facility drainage
• Hazardous waste storage
• Personnel handling hazardous waste
• High-level alarms
• Special precautions
• Inspections
• Spill history

Emergency Control and Response Plan

• Emergency response procedures
• Emergency notification list
• Responsibilities and actions
• Release and emergency response equipment
• Evacuation plan
• Arrangement with local authorities
• Plan amendment

Approval and Certifications

• Management approval and commitment
• Professional certifications

Release Reporting Requirements

• Federal
• State
• Local

Forms and Tables

• Storage tank inspection form
• Drum area inspection form
• Environmental agency contact form
• Environmental incident report form
• Environmental inspection report form
• Toxic chemical release inventory form
• Chemical inventory form
• Air pollution abatement equipment maintenance log
• Facility layout and area map
• Job title and descriptions
• Spill prevention control and countermeasures (SPCC), hazardous substances and waste management training program schedule
• Release response equipment list
• Emergency equipment list
• Emergency notification list
• Outside emergency contacts
• Medical emergency information
• Waste analysis plan
• Material safety data sheets
• Release decision trees
• Hazard assessment and worse case scenarios

A comprehensive, correctly constructed and implemented plan can also serve as a SPCC plan, RCRA contingency plan, OPA facility response plan, CAA risk management plan and should meet the requirements of current state level release prevention, control and countermeasures laws.

Enhance Your Environmental Performance
Attend the National Registry of Environmental Professional's Registered Environmental Manager (REM) and Certified Environmental Auditor (CEA) workshops May 22-23, Dallas, Texas; June 5-6, Chicago, Ill.; and June 19-20, Denver, Colo. Visit www.nrep-bowman.org or call 770.486.9253 for more dates and locations.

About the author

Valcar Bowman, REM, CEA
Dr. Valcar Bowman, REM, CEA has over thirty years of environmental management experience and is a former U.S. EPA advisory committee member. Dr. Bowman currently conducts an environmental management and auditing workshop for the National Registry of Environmental Professional. For more information on Dr. Bowman's workshops, schedule and publications.

You can visit the company Web site at www.nrep-bowman.org.