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8010
Appendix T2 Emergency
Planning and Community
Right-to-Know |
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1.0
Introduction
The Emergency Planning and Community Right-to-Know
Act of 1986 (EPCRA), among other things, requires that localities have chemical
emergency preparedness programs and that businesses, such as Jefferson Lab,
notify and inform federal, state, and local emergency planning and response
agencies of the following:
· the amounts of the hazardous chemicals (HCs) that the facility has on-site, routinely releases, or spills above the chemical’s threshold quantity;
·
special
or unusual chemical hazards at the facility; and
·
other information necessary to facilitate the emergency
response actions of our local support groups.
This appendix provides the rationale for EPCRA and
how Jefferson Lab interacts with this regulation.
Work at Jefferson Lab requires the use and storage of
a wide variety of chemicals. EPCRA
consists of a variety of programs, but only five require action on a regular
basis by Jefferson Lab, as coordinated by Environmental, Safety, Health, and
Quality (ESH&Q) Reporting, to ensure compliance.
Jefferson Lab has provided notification under EPCRA
for hydrogen fluoride (as hydrofluoric acid), nitric acid, and bromine.
For general emergency response and reporting
information refer to:
·
ES&H Manual Chapter 3510 Appendix T1 Building Evacuation Procedures
ES&H
Manual Chapter 8010 Environmental Protection Program
contains descriptions of relevant laws, regulations, standards, terms, and
agencies that are fundamental to the environmental protection (EP) program.
2.0
Responsibilities
ES&H
Manual Chapter 8010 Environmental Protection Program
summarizes staff EP responsibilities.
The following responsibilities apply specifically to the EPCRA program’s
goals and objectives.
Line Management
Emergency Manager (EM)
MSDS
Coordinator
ESH&Q Reporting Manager
3.0
Program Requirements
Compliance with
EPCRA, also known as Title III of Superfund Amendments and Reauthorization Act
(SARA), is also required under Executive Order 13148.
The EPCRA programs
that apply to Jefferson Lab are:
Each program imposes
different requirements and covers one or more of four, sometimes overlapping,
groups of chemicals. All information is
transmitted as identified to the EPGs by ESH&Q Reporting.
The emergency
response agencies to which Jefferson Lab reports are the Peninsula Local
Emergency Planning Committee (PLEPC) located in Newport News, the Virginia
Emergency Response Council (VERC) in Richmond, and the main Newport News Fire
Department (NNFD) at City Hall.
For site information, contact ESH&Q Reporting at extension
7308. To obtain information about other
facilities, the general public may contact or submit a written request to the
VERC or view toxic release
information on the EPA website at www.epa.gov/tri.
Planning for
Emergency Response (Section 302)
Section 302 requires facilities with an inventory of any extremely
hazardous substance (EHS) at or above its Threshold Planning
Quantity (TPQ) to provide written notification to designated EPGs. It also requires that a facility meeting this
criterion become designated as an Emergency Planning Facility and assign an
individual to assist the Peninsula
Local Emergency Planning Committee (PLEPC) in its emergency planning activities.
Under Section 302 Jefferson Lab has notified the EPGs for
hydrofluoric acid, nitric acid, and bromine.
As well, the Emergency Manager (EM) has been assigned as the facility
contact for providing emergency planning support and additional information
upon request by the EPGs.
Jefferson Lab shall notify the EPGs within sixty days if another
listed EHS
reaches inventories ≥ the TPQ for that
substance, or the site contact person changes.
Emergency Release
Notification (Section 304)
Under Section 304, Jefferson Lab is required to make the correct
and timely emergency release
notification to the applicable EPG or response organizations whenever an EHS (EPCRA
substance, listed in 40 CFR 355) or hazardous
substances (HS) (CERCLA
substance, listed in 40 CFR 302) is released to
the environment and meets the criteria shown in the box at left.
To date, only one instance of a release with
the potential of meeting the identified criteria has occurred, a buffered
chemical polish spill in 1992.
Appropriate actions and internal notifications were made, including
notification of the Facility Manager, who, in conjunction with the Department
of Energy (DOE) Site Office, determined that area response agencies did not
need to be notified.
Reportable
quantities (RQs) for chemicals can be as small as 1 pound for mercury, but
generally range from 100 to 5,000 pounds.
For more information see Appendix EPS
50-R1 Chemical/Material List of EHMs for a list of the materials we have on-site that have potential
reporting requirements.
If you observe a spill or release,
RESPOND and MAKE IMMEDIATE NOTIFICATIONS PER YOUR TRAINING
·
Call 9-911 if off site assistance needed
·
Call the guard at x5822 for on-site support [the guard
will call 911 at your request]
·
See Appendix
EPS 50-T1 Spill and Release Reporting Requirements
The framework for establishing a response management structure at the federal, state and local levels has been provided through a structure known as the National Response System. Releases of oil and HS across the United States are handled through this system. Notification of the National Response Center (NRC) for CERCLA and certain EPCRA releases activates this network which includes federal response teams, governments, and participating federal agencies, such as the DOE. For additional information on this program, contact the ESH&Q Reporting Manager at ext 7007.
Hazardous Chemical
Inventory
Community Right-to-Know Reporting
(Sections 311 and 312)
The purpose of these sections is to have facility operators
provide general hazard information to the EPGs on the HCs present
on-site. ESH&Q Reporting is
responsible for providing timely information to the EPGs. Jefferson Lab is subject to EPCRA Sections
311 and 312 because it follows Occupational Safety and Health Administration’s
(OSHA’s) Hazard Communication Standard regarding the availability of MSDSs.
Section 311 MSDS Information
Section 311 requires
that Jefferson Lab annually provide the EPGs with a MSDS or a
list of MSDS
chemicals grouped by health and physical hazard categories for HCs at the Lab
that meet or exceed their specified TPQ.
The MSDS
Coordinator ensures that MSDSs are
available for all chemical products used on-site. The master MSDS library
is kept in the Safety Lab (Bldg. 35), and a MSDS web site
to serve the lab community is available at http://msdsweb.jlab.org/msds/.
The MSDS Coordinator
also maintains the site’s chemical inventory.
Annually, the MSDS
Coordinator compiles a list of chemicals on-site, including quantities and
locations that could present more than minimal hazards, and provides a copy to
ESH&Q Reporting and the EM.
ESH&Q Reporting works with the MSDS Coordinator to review the chemicals for EPCRA applicability and to make any necessary notifications. The EM provides the information to the NNFD, who may request an MSDS for any of the listed materials if there could be special concerns to firefighters. The EM provides the list and the MSDSs on a “for information only” basis.
Additionally, Jefferson Lab must notify the EPGs within ninety
days if:
·
additional HCs become
present above the threshold levels, or
·
significant new information about a previously reported chemical is determined.
Section 312 Emergency and Hazardous Chemical Inventory Forms
Section 312 requires Jefferson Lab to provide the EPGs with an
annual emergency and hazardous chemical inventory for substances that meet
reporting thresholds. The Tier II
inventory form includes information on the locations, storage conditions,
quantities of HCs,
and associated risks which could assist EPG planning efforts. Tier II
information is available to the general public through the VERC.
ESH&Q Reporting and the MSDS
Coordinator prepare the Tier II report
by March 1. Substances included on
recent Tier II
forms include hydrogen fluoride, nitric acid, lead, bromine, argon, helium,
nitrogen, and hydraulic oil.
Use of the Tier II form
precludes special EPG notification if significant new information on the
reported chemicals is discovered, unless it is specifically requested by the
PLEPC or NNFD.
NOTE: One of the objectives of Jefferson Lab’s
overall chemical management policy is to minimize our on-hand inventory of hazardous
materials. Tier II is but
one of the factors to consider when procuring chemicals.
Toxic Chemical
Release Inventory Reporting (Section 313)
Section 313 requires facilities to inform the EPA and the EPGs
about the use, manufacture, treatment, transport, and releases of toxic
chemicals to the environment.
Under Executive Order 13148, DOE’s facilities are required to
report annually to the EPA and the VERC on activities involving toxic
chemicals if they meet the reporting criteria noted to the left.
The EPA uses Form R (a report that must be filed if toxic material
quantities exceed thresholds)
information to assess the impacts of toxics on the environment. The EPA works with citizens and businesses to
evaluate the information and places it in a publicly accessible database.
Form R considerations are handled by ESH&Q Reporting, with support from the Jefferson Lab Industrial Hygienist. No Form R reports have been required through 2005; however, upon request, Jefferson Lab provides the DOE information on HSs and EHSs released to the environment. If conditions change, Form R will be submitted by July 1st.
4.0
References
LAWS and EXECUTIVE ORDERS |
|
CERCLA/Superfund/SARA, as amended |
42 U.S.C. 9601 et.
seq. |
SARA Title III
(EPCRA) |
42 U.S.C. 11001-11050 |
Pollution
Prevention Act of 1990 |
42 U.S.C. 13101 et.
seq. |
Greening the Government through Leadership in Environmental
Management |
Executive Order
12856 |
Virginia Hazardous
Materials Emergency Response Act |
Code Of Virginia §44-146.4 |
REGULATIONS and PLANS |
|
Oil Pollution
Prevention |
42 CFR 112 |
Designation of
Hazardous Substances |
40 CFR 116 |
Determination of
Reportable Quantities for Hazardous Substances |
40 CFR 117 |
National Oil and
Hazardous Substances Pollution Contingency Plan |
40 CFR 300 |
Designation,
Reportable Quantities, and Notification HS List Table 302.4 |
40 CFR 302 |
EPCRA EHS and TPQ
List Appendices A and B |
40 CFR 355 |
Toxic Chemical
Release Reporting Thresholds for Reporting |
40 CFR 372 and
372.25 |
Hazardous Waste
Operations and Emergency Response |
29 CFR 1910.120 |
Virginia Emergency
Management Operation Plan |
|
Related ESH&Q Manual Chapters:
ES&H Manual Chapter 3510
Emergency Response Activities and appendices
ES&H Manual Chapter 5300
Occurrence Reporting to Department of Energy (DOE) and appendices
ES&H Manual Chapter 6610
Chemical Hygiene Program and appendices
ES&H Manual Chapter 8050
Environmentally Harmful Materials and appendices
Web sites:
EPA www.epa.gov
CFR www.access.gpo.gov/nara/cfr/index.html
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ISSUING
AUTHORITY |
TECHNICAL POINT-OF-CONTACT |
APPROVAL
DATE |
REVIEW
REQUIRED DATE |
REV. |
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ESH&Q Division |
08/01/03 |
08/01/06 |
0 |
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