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HomeMy WebLinkAboutMINUTES - 08171993 - IO.1 TO ""BOARD OF SUPERVISORS Centra 1 =r: •.; FRC 6' INTERNAL OPERATIONS COMMITTEE �y Costa C ll x� : .-.-• ,40¢ County . August o 9, 1993 DATE: T�coi N SUBJECT: REPORT ON HAZARDOUS MATERIALS PROGRAMS AND UPDATE ON GENERAL CHEMICAL COMPANY HAZARDOUS MATERIAL INCIDENT .OF JULY 26, 1993. SPECIFIC REQUEST(S)OR RECOMMENDATION(S)&BACKGROUND AND JUSTIFICATION RECOMMENDATIONS: 1 . ACCEPT the report from the Health Services Director dated July 21, 1993 providing the Department' s first quarterly report on the status of the County' s Hazardous Materials Programs . 2 . DIRECT the Health Services Director to provide his second quarterly. report on Hazardous Materials Programs to the Internal Operations Committee on October 25, .1993 . 3 . EXPRESS the Board' s congratulations for the excellent manner in which the Health Services Department and all involved employees responded to the General Chemical Company hazardous materials incident on July 26, 1993 and EXPRESS the Board' s support for the public health decisions which were made as a part of that response, including the "shelter-in-place" decision, which was clearly the correct and only practical response to the incident under the circumstances which existed at the time. 4 . At- the time he makes his second quarterly report to the Internal Operations Committee on October 25, 1993, REQUEST the Health Services Director to update the Committee on activities which have taken place in the interim regarding follow-up to and investigation of the General Chemical Company hazardous materials incident. of July 26, 1993, along with whatever recommendations he has for further action which should be considered by the Board of Supervisors . CONTINUED ON ATTACHMENT: YES SIGNATURE: RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE APPROVE OTHER SIGNATURE(S): ACTION OF BOARD 01 t 17 i 9 9 3 APPROVED AS RECOMMENDED OTHER i 1 VOTE OF SUPERVISORS I HEREBY CERTIFY THAT THIS IS A TRUE _XUNANIMOUS(ABSENT ) AND CORRECT COPY OF AN ACTION TAKEN. AYES: NOES: AND ENTERED ON THE MINUTES OF THE BOARD ABSENT: ABSTAIN: OF SUPERVISORS ON TH ATE SHOWN. ATTESTED_ / f3 i Contact: PHIL BATCHELOR, ERK OF THE BOARD OF CC: ,,See Page 3 SUPERVISORS AN COUNTY ADMINISTRATOR i i BY ;DEPUTY - I r BACKGROUND: On April 20, 1993, the Board of Supervisors directed the Health Services Director to provide quarterly reports to our Committee for one year to insure that appropriate progress was being made on all of the issues addressed in our Committee' s report resulting from our April 8, 1993 meeting with the Health Services Director, County Administrator and members of the 1992-93 Grand Jury. The presentation of the first such quarterly report was scheduled for July 26, 1993 . The report was not presented to our Committee because of the hazardous materials incident which occurred that morning at the General Chemical Company plant in Richmond. Our Committee did receive and consider the first quarterly report at our meeting on August 9 , 1993. In addition, the Board of Supervisors on July 27, 1993 asked the Health Services Director to provide our Committee with an update to the activities which occurred at General Chemical on July 26, 1993 . We also considered this report at our meeting on August 9, 1993 . Both of these reports are attached to this report and should be considered an integral part of this report. In regard to the quarterly report on hazardous materials programs, we are very pleased with the progress which has been made in completing the tasks which were undertaken in response to the Board' s April 20, 1993 directions . Our Committee will continue to provide oversight to insure the completion of all tasks in a timely manner. In regard to the General Chemical Company incident, we would make the following observations : * There are clearly problems with the state and federal statutes and regulations pertaining to railroad tank cars in .terms of the transportation and storage of hazardous materials and the requirements for reporting the presence of hazardous materials to appropriate local health and public safety agencies . We believe that Congressman Miller will address these problems in his hearing which is scheduled for August 10, 1993 in Richmond. We are asking the Health Services Director to make further recommendations to our Committee for action in this area on October 25, 1993 . * The Community Alert Network (CAN) system worked as well as could be expected. As has been emphasized before, CAN is only one part of the County' s emergency alert system. It fulfills its part of the alert system very well . We are pleased that SB 222 is making good progress through the State Legislature, since its passage and enactment will provide additional information on unlisted telephone numbers and on unlisted addresses for listed telephone numbers . The availability of this additional information should make CAN even more effective than it has been to date. * We strongly concur with the "shelter-in-place" decision which was made by our Health Services Department staff, based on all of the information which was available at the time of the incident. The fact that an evacuation would probably have exposed more residents to the cloud of sulfuric acid, the logistical difficulty of evacuating several thousand residents, particularly with the closure of Interstate 80, the fact that shelter-in-place was the most appropriate method of avoiding damage from the cloud and the difficulty of j predicting with any degree of certainty what wind changes might occur, thereby potentially exposing those who were being evacuated to further hazard, all supported the decision to order "shelter-in-place" as opposed to any wide spread evacuation. -2- I t i *` We believe that the Health Services Department needs to undertake a debriefing with industry, including not only General Chemical, but with all major industry in the County since any number of industries in the County are susceptible to creating public health hazards by mishandling the materials they use in industrial processes . As a result, we believe that the Health Services Department should schedule a meeting with the industrial associations in the County, including the Contra Costa Council and other organizations or individual companies which the Health Services Department would like to invite to such a meeting or who indicate an interest in being included in such a meeting. . This meeting should be scheduled for the second week in September if at all possible. The purpose of the meeting should be to develop an agreement or protocol to be used by industry which will insure that industry takes responsibility for such incidents and which addresses the problems which are created when management makes decisions which have the effect of circumventing all existing regulatory processes and increasing the likelihood that a public health hazard will occur. Appropriate members of the Board of Supervisors should be included in this meeting. Our Committee will continue to follow-up on this incident and attempt to generalize what we can learn from this incident that can help to avoid similar incidents in the future. We will report back to the Board following our October 25, 1993 meeting. cc: County Administrator Health Services Director William B. Walker, M.D. , County Health Officer Wendel Brunner, M.D. , Public Health Director Barbara Masters, Executive Assistant to the Hazardous Materials Commission i i -3- Contra Costa County The Board of Supervisors HEALTH SERVICES DEPARTMENT OFFICE OF THE DIRECTOR Tom Powers, 1st District Jeff Smith,2nd District Mark FlnuCane, Director aE-..s---•.c Gayle Bishop,3rd District - _' 20 Allen Street Sunne Wright McPeak,4th District f �' =_ Martinez, Cciifornia 94553-3191 Tom Torlakson,5th District - _ (510)370-5003 o: County Administrator , y �s FAX(510)370-5098 y4 Phil Batchelor �osra couNft �Pti County Administrator DATE: July 21, 1993 TO: Internal Operations Committee Supervisor Sunne Wright McPeak Supervisor Jeff Smith FROM: Mark Finuc Health Services Direct r SUBJECT: Hazardous Materials Program This is first quarterly report to the IO Committee following the Committee's consideration of the January 31 Grand Jury report on the management of the Hazardous Materials Program. I. Oversight of the Hazardous Materials Program. As the Committee is aware, on February 23, I announced that Mr. Lewis Pascalli, Safety Officer of the Health Services Department, was reassigned full time to provide on-site management of the Hazardous Materials Program. Mr. Pascalli developed a detailed Plan of Correction that was presented to the IO Committee in April, which will be described below, which is now nearly completed. I believe that Mr. Pascalli has done an exemplary job in overseeing the Program and will continue in that position until a permanent replacement is found. We have utilized this opportunity to evaluate the appropriate qualifications and managerial skills for this position. While technical expertise is important I believe that, in general, high-level administrative capabilities and interpersonal skills are absolutely essential. I continue to meet weekly with Mr. Pascalli, Dr. Walker, Dr. Brunner and Barbara Masters as part of our ongoing Hazardous Materials Management Team coordination. In addition, Mr. Pascalli, Dr. Walker, Barbara Masters and I have met biweekly with Mr. Batchelor to brief him on our progress. As the Plan of Correction is now nearly complete, our meetings with Mr. Batchelor will continue on a monthly basis. The Hazardous Materials Council and Merrithew Memorial Hospital&Clinics Public Health • Mental Health • Substance Abuse Environmental Health Contra Costa Health Plan Emergency Medical Services - Home Health Agency Geriatrics A-345 (2/93) r � t . r the Hazardous Materials Commission also continue to receive updates and provide oversight, although they are meeting bimonthly for the summer months. I also want to stress the ongoing work to coordinate our Department's efforts with those of other agencies. The Hazardous Materials Interagency Task Force, made up of HSD, BAAQMD, Water District, Fish and Game, Cal-EPA, Fed EPA., Coast Guard, State Lands _ Commission, and State Fire Marshal, among others, continues to make significant progress. A mission statement and workplan were developed and the matrix delineating each agency's role in prevention, inspection and emergency response activities is nearly complete. This will be reviewed with the public and other agencies and may serve as a model document for interagency cooperation. The Task Force is also developing plans to conduct a multijurisdictional inspection to provide coordinated review which will enhance inspection activities and streamline the process for business. Likewise, the Regional Hazardous Materials Responders Organization is developing an MOU to ensure cooperation with agencies within and outside of this county as well as industry during a hazardous materials incident. As discussed below, these organizations will also be involved in the update and review of the Hazardous Materials Area Plan. II. Plan of Correction. The February 22 Board Order from Mr. Batchelor identified 11.key issues in the Grand Jury report. These became the basis for the Plan of Correction, which was provided to the IO Committee on April 8. In addition, Mr. Pascalli briefed the Grand Jury directly on this Plan. To implement the Plan by the June 30 target date, staff were asked to voluntarily postpone vacations, training and other non-emergent priorities until after July 1. They were also requested to voluntarily give up their 9/80 work schedule during this period of time, which they agreed to do. I am pleased that as of this date, eight of the 11 issues have been completed. See Attachment A for a summary of the issues and completion dates. Detailed discussions of each issue follows: ISSUE A: Inspections of known AB 2185 facilities which have filed business plans with the County have not kept pace with the goal set forth in State Law. STATUS: Completed 6/30/93 The Plan of Corrections identified 503 out of 1256 business sites which had not been inspected within the last three. years, had not been inspected by another Hazardous r r L I ` i 3 Materials Program and were not gas stations. The number of inspections to do were divided among the five geographic districts. Priority of inspections was given to those sites posing the greatest risk to the community. The completed inspections were recorded in the Hazardous Materials Management Information System and a weekly report produced showing how many inspections were done and how many were left to do. This information was shared with all staff. A progress chart was posted and updated weekly in the staff room which presented the progress toward the goal to all staff. Since many of the AB 2185 sites also had underground tanks and/or hazardous waste generator programs, these inspections were also done where circumstances allowed. The target date for completion of these inspections was met on June 30, 1993. (See Attachment B: Progress Chart depicting the Hazardous Materials Programs AB 2185 inspections done and those left to do). ISSUE B: There appears to be no mechanism in place to establish priorities for the order in which facilities will be inspected. STATUS: Completed 4/30/93. The four inspection program team coordinators (the AB 2185, Underground Tank, Hazardous Waste Generator and the Risk Management Prevention Program) met with Mr. Pascalli and developed a written policy on the priorities for the order in which facilities will be inspected. These priorities conform to existing law and generally accepted standards in the administering agency community. The target date for completion of this policy was met on April 30, 1993. (See Attachment C: Hazardous Materials Program Policy Inspection Priorities). ISSUE Q There are no established and generally understood standards for the number or bTe of inspections which should be conducted by a staff member during the year. STATUS: Planned completion 8/31/93. This issue is being researched through contacts with other county programs to find out how they have approached this matter. The ten counties contacted so far experience a diversity of approaches to this question. At least one has set the number of inspections to be done 4: as part of its yearly budget request. Most do not have any number specified, but state all inspection requirements will meet legal requirements. A few counties are working on developing an answer themselves. Some assign inspection quotas by districts. This issue will be addressed organizationally and by emphasis on compliance with State Law and HMP policies by August 31, 1993 along with organizational and staffing questions raised by Issue "K". ISSUE D: The anticipated data management Ustem required by State Law is not yet in place. STATUS: Completion 12/10/93 The Management Information System (MIS) required by the Law (Health & Safety Code §25503(c),(d) is in place now. The Hazardous Materials Program has been working on a four program integrated MIS System since July, 1992. A full-time inspector staff member with MIS skills was dedicated to work on Hazardous Materials MIS issues in January, 1993. This MIS will far exceed any system presently in the State of California. We have investigated two (2) off the shelf systems,but while they presented some immediate benefits, they could not meet our long-term HMP/MIS goals. The decision was made early on to complete the work begun on our system. Five modules were designed to complete the system: (1) Site; (2) Inspections; (3) Business Plan; (4) Tanks; and (5) Hazardous Waste Generator. Modules 1 and 2 were completed on schedule on April 30, 1993. Further analysis of modules 3, 4 and 5 demonstrated that, because of the complexities of the programming involved, we could not meet the original August 31, 1993 target. After several meetings including program review, the decision was made to reset the target date until December 10, 1991 All reports requested to date by program management have been met by our existing information system. ISSUE E: The Hazardous Materials Program of the Health Services Department has not, itself, filed a business plan pursuant to AB 2185 although it is generally agreed that one should have been filed. STATUS: Completed 4/9/93 5 The AB 2185 Business Plan is required for the Contra Costa County Hazardous Materials Program because it has diesel fuel stored on-site in an above-the-ground tank for its emergency standby generator. The AB 2185 Plan was written by the Co-chair of the Hazardous Materials Program Safety Committee. The site survey was performed by the inspector responsible for that area of the county and was reviewed by another inspector. The AB 2185 Plan was completed and filed on March 20, 1993 with the site survey and review completed on April 9, 1993. The target date was April 30, 1993. ISSUE F: No written procedures exist which guide staff in determining when they should respond to a hazardous materials incident, leaving to their individual judgement the evaluation of whether to respond to any given call. STATUS: Completed 4/30/93 While no written policy on this issue existed, the common practice of the Incident Response Team (IRT) (changed from Emergency Response Team to better reflect its purpose and function) was to err on the side of safety and, when in doubt, to respond to a reported event. A summary of ten other counties showed that this practice was in keeping with other IRT's. Notwithstanding the above, meetings were held with the IRT to document the practice and lay out the parameters of response. We developed a policy with definitions, a matrix of incidents ranging from the most serious to the least serious notification with response communications and actions taken, and response goals in order to codify our practice. The target date of April 30, 1993 was met. (See Attachment "D": Hazardous Materials Program Policy Incident Response Criteria). ISSUE G: Incident Response schedule changes can apparently be approved by the involved staff without regard for whether the change might extend response times because no member of the alert team would be in close proximity to the site of the hazardous materials response vehicle. STATUS: Completed 4/30/93 6 The concern raised by this issue is whether or not an IRT member would be available in a timely manner to arrive at an incident scene in the event of a disaster closing the bridges to Contra Costa County. Three of the eleven IRT members live across bridges and the concern was that at any time all three IRT members on call would be across a bridge and notable to respond to Contra Costa County. A policy was developed that addressed the preparation, administration and changes of the IRT schedule along with the concerns of assuring that at least one IRT member was this side of a closed bridge. The target date of April 30, 1993 was met. (See Attachment "E": Hazardous Materials Program Policy Incident Response Team Scheduling). ISSUE H: Response times for Emergency Response have been extended over the past few years,leading in some cases to complaints regarding the need to hold other emergency vehicles on scene . waiting for a response from the Hazardous Materials Incident Response Team. STATUS: Completed 4/30/93 This issue was addressed in the policy developed for issue "F"' (See Attachment "D"). The perception that all reported incidents involving unknown substances are emergent events posing an imminent threat to the health and safety of the community or substantial danger to the environment is not accurate. The overwhelming majority of the calls received by our IRT (approximately 90%) do not require an on-site response and are classified as notifications from business or complaints which are followed up during regular working hours. When there is an untoward event requiring on-scene response, the IRT is not a first responder like fire and police, but arrives on scene after discussion with the first responders to assess the situation. When in doubt, the IRT will respond to the site to make their own on-scene assessment and take appropriate action. ISSUE I: The Area Plan has not been updated as is required by State Law. STATUS: Completed 6/30/93. The Area Plan process is dynamic requiring ongoing review and analysis of the various agencies' responses within Contra Costa County to Hazardous Materials Incidents. State 7 Law requires that an administering agency certify every three years to the State Office of Emergency Services that it has conducted a complete review of its Area Plan and has made any necessary revisions. This requirement still applies even though the State has not yet reviewed or critiqued the Area Plan submitted in 1988 by Contra Costa County. Contra Costa County's Area Plan has been reviewed and revised for changes that have actually occurred. The revised plan was submitted to the State on June 29th. Additional efforts to improve our Hazardous Materials Incident responses are continuing with the Regional Hazardous Materials Response Organization (RHMRO) and the Hazardous materials Interagency Task force (HIT). Both groups were organized by Contra Costa County to improve our ability to meet the needs of the community in the event of a Hazardous Materials Incident. One of the efforts undertaken by HIT is to develop an emergency response matrix involving all major state, local and federal agencies. It is nearly complete and will be essential to conducting a more comprehensive review of the Area Plan. We also will request RHMRO to review the Plan. The target date of June 30, 1993 was met. (See Attachment "F" Letter of Transmittal to the State O.E.S.). ISSUE : Clerical staff working in the Hazardous Materials Program have apparently not been provided the information which is required by State Law and which was indicated in the Department's own internal documents as being a part of the Hazard Communication Plan. STATUS: Completed 3/9/93. The training required by the Health Services Department Policy #152, the Federal Right to Know Law and the HMP's Business Plan has been completed. The program had been developed in September, 1992 by the HMP Safety Committee with training scheduled in the first quarter of 1993. Two hour training classes were presented on February 11, 1993 and March 9, 1993. All administrative support team members attended one of these classes. The target date of March 9 was met. ISSUE K: Determining the most appropriate organizational staffing pattern for the Hazardous Materials Program. , 8 . STATUS: Planned completion 8/31/93. The organizational staffing pattern in the Hazardous Materials Program is being evaluated by analyzing the historical development of the programs and staffing in Contra Costa County, reviewing other comparable counties' experiences and by reviewing pending State Legislation which may affect the Hazardous Materials Program's (HMP) organization. There are only a few HMP's in California that may compare to Contra Costa County's HMP. In addition to telephone surveys to other counties, meetings have been held with the Northern California Hazardous Materials Managers to obtain any insight they may have into this issue. The presence of an on-site manager and individual program supervisor incorporating geographical district team responsibility appears to present the most viable structure at this time. Mr. Pascalli will remain in place until the organizational structure and the staffing pattern are set. The original target date of April 30, 1993 was changed to June 31, 1993 and further revised to August 31, 1993 to coordinate with the completion of Issue "C". III. Status of Discussions with Fire Districts Regarding Organizational Issues of Emergency Response. Evaluating the most cost-effective and efficient organizational structure for carrying our incident response for hazardous materials spills is a difficult and complicated task, particularly given the budget realities the Fire Districts and Health Services Department face. We have undertaken a methodical and careful analysis to identify and evaluate various options and developed a process for making a recommendation to your Committee. First, the HSD met with representatives from the Richmond, Contra Costa and San Ramon Fire Districts. Next, the HSD and the Fire Districts surveyed numerous county hazardous materials IR programs. The different systems were groups into five general models, which range from HSD being responsible for all areas of the county to the Fire Districts assuming the primary responder role. The HSD have developed criteria by which to evaluate the different models. The criteria and the spectrum of models have been distributed to the three Fire Districts for review and comment and meetings will be set up with them over the next few weeks. We will develop a set of joint recommendations which will be submitted to the Hazardous Materials Council and then to the Hazardous Materials Commission for action with regard to community review and meetings. ATTTACB= "A" HEALTH SERVICES DEPARTMENT HAZARDOUS MATERIALSPROGRAMS PLAN OF CORRECTION-SUMMARY SHEET PLANNED COMPLETION DATE DATE COMPLETED ISSUES: A. Inspections of known AB.2185 facilities which have filed business plans with the County have not kept pace with the goal set forth in 6-30-93 6-30-93 State Law. B. There appears to be no mechanism in place to establish,priorities for 4-30-93 4-30-93 the order in which facilities will be inspected. C. There are no established and generally understood standards for the number or type of inspections which should be conducted by a staff 8-31-93 member during the year. D. The anticipated data management system required by State Law is not 12-10-93 yet in place. E. The Hazardous Materials Program of the Health Services Department has not, itself,filed a business plan pursuant to AB 2185 although it is generally agreed that one should have been filed. 4-30-93 4-9-93 F. No written procedures exist which guide staff in determining when they should respond to a hazardous materials incident, leaving to their individual judgment the evaluation of whether to respond to any given call. 4-30-93 4-30-93 G. Incident Response schedule changes can apparently be approved by the involved staff without regard for whether the change might extend response times because no member of the alert team would be in close proximity to the site of the hazardous materials response vehicle. 4-30-93 4-30-93 0 H. Response times for Emergency Response have been extended over the past few years, leading in some cases to complaints regarding the need to hold other emergency vehicles on scene waiting for a response from the Hazardous Materials Incident Response Team. 5-31-93 4-30-93 1. The Area Plan has not been updated as is required by State Law. 6-30-93 6-30-93 J. Clerical staff working in the Hazardous Materials Program have apparently not been provided the information which is required by State Law and which was indicated in the Department's own internal documents as being a part of the Hazard Communication Plan. 3-9-93 3-9-93 K. Determining the most appropriate organizational staffing pattern for the Hazardous Materials Program. 8-31-93 Dated: 6 Jul 93 ATTACFA'!EN'r "B" cor- ANN 1 eiz .l NN tv C4 eev .o O \\ O 1 I . � N f OD 4tn e D� Ln G� L9 - f— V" uU r� CONTRA COSTA COUNTY HEALTH SERVICES DEPARTMENT HAZARDOUS MATERIALS PROGRAMS (HMP) POLICY INSPECTION PRIORITIES I. PURPOSE: This policy enumerates the basis upon which the programs in the Hazardous Materials Programs :(HMP) will prioritize- the inspection schedules. The stated elements of each program's prioritization listing are general guidelines. Changing laws, regulations, and unusual circumstances may cause variances from these listings. II. REFERENCE: ■ California Health and Safety Code, Chapter 6.95, Article I and Article. II, :§§25500..et- seq ■ AB 3777 . ■ Title 19 California Code .of Regulations ■ Contra Costa County Health Services Department RMPP Ranking Process III. POLICY: A. There are four (4) programs which require inspections for.. cites containing hazardous materials:::'the;;Hazard'ous;Waste Generator; the AB 2185; the Underground Tank.;_(UGT) ; and for sites with Acutely Hazardous Materials` a Risk Management and Prevention Program (RMPP) .0) B. The Hazardous Waste Generator Program will conduct timely inspections conforming with existing law and regulations in this order of. priority: • Sites reported to be presenting a potential threat to the health and safety of the community. • Sites reported to be presenting a potential threat to the environment. • Referrals from other regulatory agencies.m • Referrals from local fire or police agencies.m • Complaints filed by an individual.(2) • Regular and routine inspections. 1 Hazardous Materials Programs Policy, ; Inspection Priorities- " Page 3 placed on a ranked list and be scheduled for a Risk Management and Prevention Program (RMPP) . The facility will have one year to prepare an RMPP following notification by the County. The RMPP Team will conduct timely reviews conforming with existing law and regulations in this order of priority: • Facilities reported to be presenting a potentially severe threat to the health and safety of the community. • Facilities reported to be presenting a potentially severe threat "to the environment. • Facilities determined to be of higher relative risk to the community, according to the Modified Chemical Index. • Adjustments to the preceding hierarchy may be made to incorporate additional concerns of County _Staff with regard to. facility risk and management practices or other pertinent considerations. ,. (1)In the event` "that sten` presenting a "potential threat to the health'�and safety of the community or to the environment cannot be inspected with the inspector resources available in a particular program, then inspector resources from other programs will be utilized to address the site. Inspectors will be drawn from all the programs on a prioritized basis. ,,Referrals from other agencies and community complaints will be prioritized by individual inspectors based on the circumstances presented. IV. AUTHORITY• Authority rests with the Hazardous Materials Program Director (HMPD) to ensure that this policy is implemented. Any substantial variance from this policy will be reviewed with the program coordinators affected. This policy will be revised as necessary and reviewed annually. I F) CONTRA COSTA COUNTY HEALTH SERVICES DEPARTMENT HAZARDOUS MATERIALS PROGRAMS (HMP) POLICY INCIDENT RESPONSE CRITERIA I. Purpose .This policy details the matrix of Incident Response criteria (Attachment A) that members of the Incident Response Team will use when evaluating the source of and the information received from a party to determine the proper response to a presented potential hazardous material incident. The matrix contained herein, is a guideline for use by the Incident Team members and does not substitute for the judgement made by the team members based on the circumstances presented to them. II. Reference• • California Health and Safety Code, Chapter 6.95, -Article I, SS 25500 et seq . • The Contra Costa County Area Plan III. Polis It is the- policy `of. the Hazardous. Materials Program Incident Response Team to use the Incident Response Matrix Zs a- guide in determining the response to a presented potential hazardous material incident. The elements of the matrix incidents and the response/time parameters are guidelines and do not replace the judgement made by the team members in determining the response. - -. IV. Authority.- Authority uthority:Authority rests with the Hazardous Materials Program Director (HMPO) to ensure that the policy is implemented. The Incident Response Program Coordinator will assure that this policy is followed by the Incident Response Team. V. Procedure: In determining the response the. following definitions will apply to the terms used in the matrix: • Incident An event involving the possible release of hazardous materials occurring within the geographical limits of Contra Costa County which may pose a possible threat to the health and safety of the community or damage to the environment. lfs� Hazardous Materials Programs Policy: Incident Response Criteria Page 3 • Potential threat The characterization an IRT member makes of a reported incident based on the circumstances presented by the. reporting party. The threat can be to the health and safety of the community or to the environment. • The Environment Any of the, elements air, soil, water, flora and fauna that act upon an ecological community. • Major Road Closure The official cessation of the normal flow of vehicular traffic due to the presence or release of a potentially hazardous material affecting substantial numbers of people. The closure is usually ordered and controlled by an agency of the State or County. • Material Out of Containment A known or .unknowm potential ly:,hazardous substance escaping from or, outside the boundaries of .a restricted,environment. which, if left outside -the restricted environment could cause harm to the health and safety of the community or to the environment. • First Responder An agency of the State, the County or a City responsible for the initial reaction to and arrival on-site to an event posing a threat to the health and safety of the community or to the environment. First responders are usually fire department and law enforcement agencies. • On-Going Activity A reported pursuit or process, usually of a private party who is on frequent occasions observed by another private party and thought to be a violator of the Hazardous Materials Handling, Storing, Processing and Removal laws. 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'7 V' 'x X a .1 v z z ch a` $4 x x z° 14o o x x a a v q � m x a y .Ea 4 4 q C N H d x .e X m p 3 N>1 3 N�4 aa V °a1� „ °„�° 0a z z z z a a° x x x x M U H 4-1 z v, a -4 a o a z 0 00aU •.0 •.0 m m m m 0 � m x� °1U-+ a1'+ o O o 0 ,4oV 0Id$4 U 1 x = x A 1 U a 4J f. y .1 b U U N N d' v _ 1zj a I O cd0 CI QiU mQ 1 I N N Om 144mmwV0r.V .1 .1 V V O o x x x a 0 >' o a z a x° x x 0 O ,. .I S m m E E E 0 W E E E E E @@y m E a v v v v v 0 U 13.0 v 41 93 40 -44 m W 4J 41 °maw: o".I '� �a0 04 yti a U b>.a >, > aU e 0 W pmo EOWem > °H cl41 u 0V L tw `.i ai c Id 4)i u o m o u 0 w o a U ° u w a u z U 000004 z m U U 44 14 1 id I ro w I CO lro y. Contra Costa County ter'. ':..'. - ,� Health Services Department ENVIRONMENTAL HEALTH DIVISION CASE # HAZARDOUS MATERIALS/OCCUPATIONAL HEALTH Date Time of Call Received by ER staff Relayed by COM1 F-1 other Reported by (name, phone #, comp.) Contact Person, phone # (on site) Incident Location facility name site ID#. west county a central county a east county F-1 city Incident Description: Date of- Incident Time of Incident notification only a facility a pipeline F] disposal/abandonment highway/vehicle a drug lab a rail road a tank truck F-1 other a details: Hazardous Materials Involved: Toxic Q Corrosive Flammable n Reactive n AHM description: physical state: solid F] liquid F] gas a material brought back?. F] manifest ? F] Reported Quantity Actual Quantity Response: accept notification a advise a emergency ❑ complaint ❑ referral to: (agency, name, phone number) Other Agencies Notified. (N) or On-scene (O/S) CHP F-1 Fire F] Coast Guard a DOHS 0 City Police a Fish and Game a WvUCB a Nat Resp Ctr Sheriff F-1 State OES a BAAQMD [_-] Other a Time Responded Time Arrived Time Departed Scene 4333 Pacheco 8oulev rd.;• IJlartmez California. .94553' (510) 646 2286 • �`fTk Gt�yv1 eNf CONTRA COSTA COUNTY HEALTH SERVICES DEPARTMENT HAZARDOUS MATERIALS PROGRAMS (HMP) POLICY INCIDENT RESPONSE TEAM SCHEDULING .I. PURPOSE: This policy details the preparation, the administration, and the amending of the Incident Response Team (IRT) schedule. II. REFERENCE: • California. Health and Safety Code, Chapter 6.95, Article 1, §§25500 et seq • Contra Costa County Hazardous Materials Area Plan III. POLICY: It is the policy of the HMP to develop a daily schedule one (1) calendar quarter in advance of eligible Incident Response Team (IRT) members, who "will be assigned the on-call responsibility for responding to presented potential hazardous material incidents. The schedule will be submitted to the Hazardous Materials Program Director prior to the implementation date for review. The schedule will demonstrate that at least one (1) IRT member lives on this side of a bridge for each day scheduled. IV. AUTHORITY: Authority rests in the Hazardous Materials -Program Director (HMPD) to ensure that this policy is followed. The Incident Response Program Coordinator (IRPC) has the authority to develop the schedule and monitor any changes. V. PROCEDURE: A. The HMPC will develop the IRT schedule one (1) calendar quarter in advance i.e. JAN FEB MAR, APR MAY JUN, JUL AUG SEP, OCT NOV DEC. The schedule will show three (3) names of the IRT members for each day. Notation or highlighting will be done for those IRT members who live across a bridge. B. The schedule will be reviewed by the HMPD. After acceptance, a copy of the schedule will be distributed to each IRT member and the master copy posted in the Administrative Support Office on the Communications Wall. AZTAC.� "Flf s L Contra Costa County Health Services Department ' _ William B.Walker, M.D. b s • ��° Medical Director and oosTq- t'i �v County Health Officer covK June 29, 1993 California Office of Emergency Services Hazardous Materials Division 2800 Meadow View Road Sacramento, CA 95832 RE: CALIFORNIA HEALTH & SAFETY CODE § 25503 (c) (d) PARAGRAPH 2 AREA PLAN REVIEW Gentlemen: Pursuant to the above referenced Health and Safety Code Section, Contra Costa County has reviewed and revised, where necessary, our Area Plan. The revisions made reflect actual changes. We realize that the County's Area Plan is a dynamic document which is revised as substantial changes in the laws and operational contingencies dictate. Contra Costa County is presently embarked on two (2) major efforts to improve our response to Hazardous Materials emergencies: the Hazardous Materials Interagency Task Force (HIT) and the Regional Hazardous Materials Response Organization (RHMRO). The HIT meetings are focusing on the coordination and timely response of Federal, State and local agencies to hazardous materials incidents. The RHMRO is exploring the feasibility of developing a Hazardous Materials mutual aid response to an untoward event in the bay area which could exhaust local resources. As these programs are formalized, the Area Plan will be revised. If there are any questions on this, please contact Mr. Lewis G. Pascalli, Jr., Acting Deputy Director for Hazardous Materials Programs at (510) 646-2286. Sincerely, ''� U4 lJ� William B. Walker, M.D. v Health Officer WBW:cbc cc: Lewis Pascalli 20 Allen Street• Martinez,CA 94553• (510)370-5010 Office •(510)370-5098 FAX A-428 (9/91) Contra Costa County The Board of Supervisors HEALTH SERVICES DEPARTMENT OFFICE OF THE DIRECTOR Tom Powers, 1 st District Mark Finucane, Director Jeff Smith,2nd District ?E_-s-•-.-c••o Gayle Bishop,3rd District '=_� 20 Allen Street Sunne Wright McPeak,4th District .f / Martinez,California 94553-3191 Tom Torlakson,5th District (510)370-5003 County Administrator % FAX(510)370-5098 �S'•'yo Phil Batchelorcoitat1 �*~` County Administrator DATE: August 9, 1993 TO: Internal Operations Committee Supervisor Sunne WrighMcPeak Supervisor 4§ff S 'th FROM: Mark Finucane Health Services Director SUBJECT: July 26th General Chemical Oleum Release The Health Services Department response to the July 26th accident at General Chemical was divided into three general areas -- incident response, community notification and medical. 1. Incident Response: The Hazardous Materials Division (HazMat) of the Health Services Department received notification by General Chemical of an oleum release at approximately 7:25 a.m. The release occurred during the unloading of a rail car that was being used to temporarily store the oleum. A total of eight Haz Mat specialists responded to the scene to investigate and stop the release as well as to take samples in the community. I want to point out that our Haz Mat specialists and Health Officer on-call, Dr. Brunner, who were at the incident command worked cooperatively with Richmond Fire,who was the incident commander. Two members of our team, Bruce Benike and Roger Lewis worked for more than an hour to replace the ruptured valve and cap the release. We were ultimately successful in our efforts on scene because of the joint efforts of all emergency responders, including personnel from General Chemical and Chevron. The exercise we held at Chevron just a few months ago contributed greatly to our teamwork. Next Steps: The HSD is participating with the District Attorney and other agencies in investigating the release and issues regarding the regulation and oversight of rail cars that transport and store hazardous materials. We are also reviewing guidelines regarding shelter- in-place and evacuation for chemical accidents. Finally, we are reviewing, with the Hazardous Materials Commission, guidelines for the Risk Management and Prevention Merrithew Memorial Hospital&Clinics Public Health • Mental Health • Substance Abuse Environmental Health Contra Costa Health Plan Emergency Medical Services • Home Health Agency Geriatrics A-345 (2/93) Program to determine whether they provide for appropriate accident analysis and emergency preparedness. 2. Community Notification: Before describing the specifics of how the public was notified of the accident, I want to stress that I believe the Community Alert Network worked as it is designed to work and was a significant tool in getting the message out to the public. I realize it has been the subject of some criticism for not having contacted all residents potentially affected by the release immediately after the release began. We have always acknowledged that CAN has certain limitations and that it is only one component of an integrated notification network. Nevertheless, I believe it was successful in reaching thousands of residents and with improvements scheduled to come on line by the end of the year, CAN's ability to get an emergency message out will be significantly enhanced. As you know, we are the largest jurisdiction to have implemented CAN and the technology is continuously improving -- and I believe that we are driving much of this effort. Richmond Fire first requested activation of the Community Alert Network at 7:40 a.m. HazMat staff determined, based on wind direction and other information, that two previously-established zones around the Chevron refinery would be activated, since General Chemical borders Chevron. Zone 1, which includes North Richmond, was activated first enabling calls to made in priority order -- notifying those closest to the facility first and moving away from General Chemical. The first telephone calls went out beginning at 8:01 a.m. -- less than five minutes after the request to CAN was complete. Residents were given a shelter-in-place message to avoid further exposure to the toxic gas. The first round of calls to residents in this primary notification zone was complete within 48 minutes. Of the 1,569 numbers in that zone, 857 calls were completed in the first attempt. Busy signals and no answers were tried two more times. A total of 6.454 phone numbers were tried by CAN. Including multiple tries, a total of 8,017 calls were made, which took 3 hours and 37 minutes to complete. 3,986 messages were received by a person or answering machine; of those, 3,526 were delivered on the first attempt. An All-Clear message was subsequently sent to the 3,986 phone numbers that received the first message. Of those, 2,804 received the message. Notification through CAN was only one of the tools used to communicate with the public. KISS Radio was activated and relayed the shelter-in-place advisory. In addition, and most significantly, HSD staff--both on-scene and at the Pacheco office--provided up-to-date and ongoing information to all the major radio and TV news stations. Both Drs. Brunner and Walker were given significant air time to urge residents to shelter-in-place. Next Steps: As I mentioned earlier, there are two significant improvements regarding CAN that are scheduled to come on line by the end of the year. First, CAN has stated that the number of telephone lines for delivering simultaneous messages will double from 50 to 100 with an additional expansion to 200 at the end of 1994. This will dramatically increase the speed that we can get information out. 3 Second, legislation sponsored by the Board and authored by Sen. Boatwright, SB 222,which will enable CAN to obtain all unlisted phone numbers, will likely be enacted within a month. Again, our ability to reach vastly more residents will be enhanced. Finally, I want to stress that we have stepped up efforts to develop a comprehensive, countywide proposal for adding sirens along with a community education program to the community notification network. We have been working with CAER (Community Awareness Emergency Response) over the last several months on such a proposal and are now in the process of establishing a committee comprised of industrial, community and agency representatives to put together a detailed plan. Each region of the county can then review the plan and determine whether and how it wants to implement it. It is critical, however, for there to be consistency, particularly for the community education program, so that a siren sound will mean the same thing everywhere throughout the county. 3. Medical Response: After the release was stopped and an All-Clear was sounded, thousands of residents began seeking medical care at area emergency rooms and the Richmond Health Clinic. In order to accommodate the overflow at the RHC, all family practice clinics in Martinez were shut down and physicians and nurses were detailed to the RHC. A special triage system was established to screen residents quickly and refer those needing further evaluation to urgent care. Over 4,300 patients were screened and examined from July 26 through July 30 at the RHC. At the same time, Kaiser-Richmond, Brookside Hospital and Doctor's Hospital of Pinole examined thousands more individuals. As the weekend approached, we recognized the need to establish a special clinic to prevent further strain on the ERs. Kaiser took the lead in putting the clinic together that was staffed by the three hospitals and RHC. The clinic operated at the YWCA Memorial Youth Center from Saturday, July 31, through Wednesday, August 4. Although the total figures have not been determine, we expect that more than 20,000 will have sought treatment. Although many individuals no longer exhibited any symptoms, particularly as the week wore on, they did come looking for reassurance. Next Steps: The HSD, in coordination with the State Department of Health Services and Cal-EPA Office of Environmental Health Hazard Assessment, is working with community members to conduct a follow up study regarding health effects resulting from exposure to the sulfuric acid cloud. Our chemical engineers also continue to work with Lawrence Livermore Lab to analyze the data regarding how much sulfuric acid was released and how far the plume extended. This information will supplement the health study in determining areas of highest exposure. 4. Conclusion: The release at General Chemical was a terrible accident that affected thousands of residents. At the same time, I think we can be proud of the response of the entire community. Our training and planning made a significant difference in being able to respond quickly, efficiently and professionally to minimize what could have been an even more serious situation. Preliminary CBE Review of Chemical Disaster Prevention Issues Following the Toxic Gas Release from General Chemical, Richmond, July .26, 1993 y RECEIVa. :� AUG 1 7 199" Statement of CLERK BOARD OF SUPERVISORS CONTRA COSTA CO. Michael Belliveau, Executive Director of Citizens for a Better Environment - California (CBE) Before the Subcommittee on Oversight and Investigations of the House Committee on Natural Resources Regarding Hazardous Materials, Industry and Community Safety in Contra Costa County, California and Beyond Richmond, California 10 August 93 Prepared by CBE staff members Julia May, Michael Leedie, and Michael Belliveau. Table of Contents Page number Preamble i I. Introduction 1 II. Summary 2 III. The Magnitude of the Threat is Severe 3 IV. Chemical Disaster Prevention Must Come First 5 V. The Public Has a Right-to-Know / Right-to-Act 7 VI. Regulatory Policy Reforms Are Feasible and 8 Urgently Needed A. State and Local Chemical Disaster 8 Prevention Programs are Failing 1. Accident modelling in California does not 9 include worst-case catastrophic releases 2. Basis of accident modelling (Haz Ops) are 10 generally kept secret from the public 3. Regulators are not mandating prevention 11 measures 4. Local Administering Agencies (AAs) have 12 virtually no oversight by the state . i 5. AAs are far behind in completing RMPPs 13 (Risk Management & Prevention Programs) 6. Regional Air Quality Management Districts 13 must become active in regulating acutely hazardous materials B. The Federal Government has failed to 14 implement the chemical accident prevention requirements of the Clean Air Act Amendments of 1990 C. Available Technologies Must Be Mandated: 15 Relief Valves D. Warning systems and evacuation plans must 16 be improved E. Railcar regulations and local authority must be 16 ° clarified and expanded F. Union safety certification, worker training , 17 • ii Preamble Good Morning. My name is Michael Belliveau. I'm the Executive Director of Citizens for a Better Environment - California, also known as "CBE." We are urban environmental health advocates of clean air and water and toxic free communities. We work.to reduce and prevent industrial pollution hazards, to empower affected residents and to promote a sustainable economy. Nearly 20,000 CBE members throughout the San Francisco Bay Area and Los Angeles County support our efforts. Much of our work in the last fifteen years has focused on documenting and reducing the environmental health hazards posed by the petrochemical industry in Contra Costa County. Along with local residents, we have been instrumental in the enactment and enforcement of policies to reduce smog-producing and toxic air pollution, to prevent toxic metal pollution of the Bay and to begin a chemical disaster prevention program for the oil refineries, chemical plants and other industrial plants that line the Contra Costa County shoreline. We've hardly been alone in this effort. We work closely with and support the efforts of grassroots community, organizations that have sprung up to fight industrial pollution, including the West County Toxics,Coalition (Richmond) - which we helped start in 1986, Communities for a Safe Environment (Martinez), Rodeo Citizens Association (Rodeo), the Toxic Cloud Task Force (Point Richmond) and others. A report published by Citizens for a Better Environment in February 1989 presaged the current concern with acutely hazardous materials releases. Entitled "Richmond At Risk: Community Demographics and Toxic Hazards from Industrial Polluters," the report found that more than 39 million pounds of extremely hazardous chemicals were stored in the Richmond area alone at any one time. The CBE report also documented an example of "environmental racism:" the toxic hazards in the Richmond industrial zones were located adjacent to 14 neighborhoods where 70% to 90% of the residents were African-American. Latinos also lived near the, high risk areas. A recent San Francisco Chronicle editorial decried the failure of land use decisions to address environmental racism and issued a call "to sharply reduce the amount of toxic materials stored at industrial sites." (August 1, 1993). iii I. Introduction The July 26 release of more than 7,000 pounds of sulfuric acid fumes from the General Chemical plant in Richmond injured thousands of people and disrupted the lives of tens of thousands more. For CBE this was more than a vindication of long stated community concerns and a harsh reminder of our failure to secure the public's safety from acutely hazardous materials; this toxic gas cloud also exposed and injured one of our staff members and her family in North Richmond. The General Chemical toxic gas cloud was a tragic wake up call. It was no "accident;" it was a statistically predictable event. Nor was this an isolated event; there has been a rash of fires, explosions and toxic gas clouds in recent years, and extremely hazardous chemicals surround this and nearby communities in staggering quantities. The July 26 release must serve as a tragic and costly warning; with another chemical there could have been dead bodies in the streets of Richmond. Tragically, this chemical release was entirely preventable. The backdrop for this latest toxic trespass is an ineffectual prevention program, incomplete response efforts, failed government leadership and short-sighted industrial planning. To make matters worse, the people at greatest risk from disastrous chemical releases have been denied information, left out of decision making, and all too often discriminated against. If public scrutiny of this chemical emergency exposes and corrects these faults, then true public safety from hazardous. industrial materials might emerge from the personal tragedies of the many thousands of .people exposed, injured and terrified on July 26. Please Note: The analysis and recommendations presented in this statement are preliminary and not meant to be exhaustive. Although we present a broad overview of the acutely hazardous materials threat and identify many specific and feasible and needed reforms, in the two weeks since the toxic gas cloud was released by General Chemical we have had little time to document in-depth the many shortcomings of preventive programs or the institutional complexities. We recommend that further investigative research and legal analysis be commissioned by this Oversight Committee. . 1 II.. Summary Our analysis of the facts and our long history of involvement in chemical plant safety issues provides the basis for four major findings and recommendations. These are summarized here and discussed in depth in.the sections that follow. First, the threat of a catastrophic release of extremely hazardous chemicals poses a real and present danger to residents and workers throughout much of Contra Costa County and other communities. Nearly 127 million pounds of 50 different acutely hazardous chemicals are in storage at any one time at 129 industrial plants and public facilities in Contra Costa County. Reported chemical releases are not isolated or chance events. Over the last five years, more than ten other major chemical releases and explosions have killed one person, severely burned four people and exposed thousands more throughout the County. Second, existing chemical disaster prevention programs are grossly deficient - i.e. behind schedule, underfunded, uncoordinated and relegated to nonurgent status. Since 1986, only two chemical disaster prevention plans submitted by industry have been approved by the County. Chemical disaster prevention programs must be dramatically upgraded and given. primacy over emergency response efforts. For example, in one pioneering effort, the South Coast Air Quality Management District did a study that found the use of hydrogen fluoride gas in the Los Angeles to be incompatible with nearby residential neighborhoods. Following political outcry after a series of chemical releases, the District adopted a regulation banning HF use in the region. Third, the public is being shut out of chemical disaster prevention and emergency response planning. At-risk community members and workers ,must be fully informed of chemical hazards and empowered to join as equal partners in government and industry decision making regarding hazardous materials. The public has a right to know about toxic hazards. Creation of a Community Technical Advisor at the Bay Area Air Quality Management District would help community groups-to have access to an expert advocate. Fourth, present hazardous materials policies are full of loopholes and serve to cover up the serious hazards posed to public safety. Feasible regulatory policy reforms must be immediately enacted, including: close the loophole on rail car storage of toxics, require pressure relief valves to vent to treatment & containment devices, publicize worst case toxics release scenarios, and create meaningful state-level oversight and accountability for chemical disaster prevention and emergency planning. 2 III. The Magnitude of the Threat is Severe ' Summary: The threat of a catastrophic release of extremely hazardous chemicals poses a real and present danger to residents and workers throughout much of Contra Costa County and other communities. Nearly 127 million pounds of 50 different acutely hazardous chemicals are in storage at any one time at 129 industrial plants and public facilities in Contra Costa County. Reported chemical releases are not isolated or chance events. Over the last five years, more than ten other major chemical releases and explosions have killed one person, severely burned four people and exposed thousands. About 400 toxic chemicals are formally designated as "acutely hazardous materials" (AHMs) under state law (AB 3777, Statutes of 1986) and "extremely hazardous substances" (EHSs) under federal law (Title III, Superfund Amendments and Reauthorization Act of 1986 [SARA]). These chemicals were so listed and distinguished from other hazardous chemicals because they are so highly toxic as to pose an immediate threat of death or serious injury upon a sudden short term exposure. Contra Costa County is one of several regions in California, the United States and the world where large quantities of AHMs are produced, used, transported or stored in dose proximity to people. Nearly 127 million pounds of 50 different acutely hazardous chemicals are in storage at any one time at 129 industrial plants and public facilities in Contra Costa County. This does not includes AHMs in storage in rail cars, pipelines, trucks, ships or barges, all of which are exempt from hazardous materials reporting requirements under SARA Title III or parallel state law. (Note: a much larger quantity of materials in storage are not AHMs but are flammable, combustible and/or hazardous for other reasons). :Based on the Acutely Hazardous Materials Registration Forms on file with the Contra Costa County Health Services Department, the San Francisco Examiner, at the suggestion of CBE, recently analyzed the distribution of AHMs by region (zip code), company and chemical. (See attachments). Residential communities where more than 100,000 pounds of AHMs are in storage at any one time include Martinez, Richmond, Pittsburg, Antioch, Rodeo, Hercules and portions of 3 Concord. The top ten industrial sites with AHM storage, by maximum total quantity, include four oil refineries (TOSCO, Chevron, Shell and Unocal) and six chemical plants (Rhone- Poulenc, General Chemical - 2 plants, Zeneca, Chevron Chemical and duPont). The greatest volume AHMs in storage in Contra Costa County include sulfuric acid, oleum (fuming sulfuric acid), carbon disulfide, ammonia, nitric acid, chlorine, hydrogen fluoride, phenol, sulfur dioxide and hydrogen sulfide. Although exposure to sulfuric acid fumes (from the release of sulfur trioxide from oleum) from General Chemical resulted in a massive toxic gas plume that exposed and injured thousands, more severe injuries or even deaths could result from major releases of other acutely hazardous materials which.are stored in large quantities in Contra Costa County. Anhydrous ammonia, a highly dispersive toxic gas usually stored under pressure and lethal at high concentrations, is present in large quantities close to neighborhoods. For example, the Chevron Chemical fertilizer plant on Castro Street stores up to one million pounds of ammonia on property that borders closely with residential North Richmond. Ammonia is produced and stored at all the oil refineries in the county with especially large quantity storage at the Chevron refinery (Richmond) and TOSCO (near Martinez). About thirty industrial plants report nearly 6 million pounds of ammonia storage. Ammonia is also often shipped by rail car through the County. Hydrogen fluoride gas, a deadly poison and insidious acid that can dissolve glass and bone and could result in a Bhopal-like asphixiating release, poses hazards to residents and others downwind of the duPont chemical (Antioch), Dow Chemical (Pittsburg) and General Chemical (Pittsburg) plants. Chlorine gas, an all too common hazard at industrial plants, water/sewage treatment plants and large swimming pools, is highly toxic, lethal at high concentrations, and dispersive. About forty plants in the county report maximum storage of more than two million pounds of chlorine gas. The highest volume storage sites for chlorine include duPont chemical (Antioch), Imperial West Chemical (Pittsburg), Central Contra Costa Sanitary District (Martinez) and Imperial West Chemical (Antioch). Earthquake hazards exacerbate toxic chemical storage hazards. There is a high probability that a significant earthquake will occur on the northern Hayward Fault which runs through western Contra Costa County. (See attachments). Seismic activity on other faults can also affect the county. Given the proven severity of this natural hazard even greater priority 4 should be given to solving the hazardous materials threat. Imagine if the General Chemical release had occurred during a major earthquake when response capabilities may have been paralyzed and other chemical releases and fires triggered by the quake. These provide just a few examples of the lethal hazards posed by extremely hazardous chemicals in Contra Costa County. Many different toxic release scenarios could result in serious injury and death. Other communities in other counties also face toxic gas cloud threats, including Silicon Valley (semiconductor manufacturing), Los Angeles (petrochemical) and so on. IV. Chemical Disaster Prevention Must Come First Summary: Existing chemical disaster prevention programs are grossly deficient - i.e. behind schedule, underfunded, uncoordinated and relegated to nonurgent status. Since 1986, only two chemical disaster prevention plans submitted by industry have been approved by the County. Chemical disaster prevention programs must be dramatically upgraded and given primacy over emergency response efforts. For example, in one pioneering effort, the South Coast Air Quality Management District did a study that found the use of hydrogen fluoride gas in the Los Angeles region to be incompatible with nearby residential neighborhoods. Following political outcry after a series of chemical releases, the District adopted a regulation banning HF use in the region. For a discussion of the pronounced deficiencies in prevention programs, see the section below entitled "Regulatory Reforms are Feasible, Urgently Needed." A principle of any good public health program stresses that prevention offers a much better investment in avoiding human suffering than responding with treatment after an injury or disease has set in. Similarly, catastrophic chemical releases are better prevented than responded to after an emergency. Although clear improvements are needed in emergency response, prevention must be given primacy. 5 Serious AHM releases can be prevented by a variety of means: • phase out the use/production of AHMs, replace AHMs with safer substitutes, • reduce the total amount in storage, • reduce the maximum amount in storage in a single container, • relocate storage further away from people, • store the substance in a safer chemical form, • upgrade storage vessels and equipment to best available technology, • maintain plenty of highly trained union personnel, • enclose with secondary containment, • add scrubbers or other gas plume knockdown systems, • vent pressure relief valves to enclosed systems, • upgrade seismic safety precautions, and so on. The best means of prevention is to eliminate or dramatically reduce the use and storage of acutely hazardous materials. Due to a lack of leadership from the EPA, the Governor's Office, the State Office.of Emergency Services and others, no single agency is targeting specific AHvI's for priority efforts to phase out use and reduce sudden release risks. Several chemicals that are AHMs. should be placed on a fast track for "sunsetting" (i.e. a complete phase out) because of.the hazard posed and because safer substitutes are available or within reach. For example, phase out efforts should target hydrogen fluoride gas, chlorine gas, ammonia gas (in refrigeration applications), arsine gas (used in semiconductor manufacturing), ethylene oxide (a sterilant), organic lead compounds and several pesticides. Other AHMs which are more difficult to eliminate outright in the short term should be targeted for aggressive hazard reduction efforts. Land use reform is another critical venue for chemical disaster prevention. Submitted with this statement to the Committee is one copy of a report prepared by the.Environmental Health Coalition of San Diego entitled "Toxic Free Neighborhoods Community Planning Guide". This. documents profiles a successful effort to reform zoning requirements in San Diego to phase out the use of certain highly toxic materials in close proximity to people over time, establishing protective buffer zones around sensitive residential areas. Copies of this report can be ordered from EHC by calling (619) 235-0281. Improved prevention.can also result from industrial process decisions which reduce the use of acutely hazardous materials. Conversely, major shifts in local refining could cause more 6 severe future chemical catastrophes in Contra Costa County. Oil companies plan td invest billions of dollars in Bay Area refining complexes starting in 1993 and 1994. Working with a refinery process engineer (see attached analysis), CBE discovered three facts about some of these refinery proposals. First, they will increase the number of sudden releases with "upsets" when new equipment is brought on line and fine-tuned. Second, they will increase the severi of sudden chemical releases by drastically increasing the amounts of explosive and acutely toxic chemicals that are held in and moved between petrochemical facilities in the County. Third, despite oil company claims, they are not needed to produce required cleaner-burning gasoline.. Other refineries produce cleaner gasoline without using the cheapest crude oil and dirtiest refining methods available. Without preventive actions, present investments may lock area refiners into cheaper and more lucrative oil refining at the expense of their workers and neighbors, who would suffer even more from acute exposures to petrochemicals in the future than they have in the past. V. The Public Has a Right-to-Know / Right-To-Act Summary: The public is being shut out of chemical disaster prevention and emergency response planning. At-risk community members and workers must be fully informed of chemical hazards and empowered to join as equal partners in government and industry decision making regarding hazardous materials. The public has a right to know about toxic hazards. Creation of a Community Technical Advisor at the Bay Area Air Quality Management District would help community groups to have access to an expert advocate. Efforts to reduce and prevent chemical disaster hazards'are being seriously undermined by minimizing public involvement in hazardous materials planning, contrary to state and federal legislative intent, and by restricting public access to critical information. The public has both a right to know about chemical hazards and a right to act on that knowledge to improve the safety of the community and workplace. A few specific ways that these rights are being violated are discussed in greater detail in the following section and include: technical studies (called HazOps), on what failures can lead to chemical releases are routinely withheld from the public. Worst case release scenarios that profile off-site consequences are routinely withheld from the public, and the Local Emergency Planning Committees (LEPCs) established under federal law have been rendered virtually ineffectual in California by the failed leadership of the State Office of Emergency Services (OES). 7 One partial remedy would be the creation of a Community Technical Advisor Program to provide technical assistance to community and environmental groups concerned about chemical plant safety. Such a proposal is actively under consideration by the Bay Area Air Quality Management District (BAAQMD). (See attachments). This program would provide an independent technical expert to review safety documents and relevant data, monitor facilities and assist community members in developing recommendations for continuous improvements. The BAAQMD should complete its review of this program, and work out remaining details under discussion with community members, and implement the program immediately. Locally, the City of Richmond should establish an Environmental Affairs Commission made up of appointed residents to evaluate environmental problems, including chemical hazards, in the Richmond area and to develop recommendations to the City, other agencies and industry regarding environmental improvements. Most major California cities with serious environmental problems have constituted such citizen commissions. The City of Richmond should join the modern era and involve its citizenry in responding to this critical concern. VI. Regulatory Reforms are Feasible, Urgently Needed Summary: Present hazardous materials policies are full of loopholes and serve to cover up the serious hazards posed to public safety. Feasible regulatory policy reforms must be immediately enacted, including: • Create meaningful state-level oversight and accountability for chemical disaster prevention and emergency planning. • Publicize worst case toxics release scenarios, and • Require pressure relief valves to vent to treatment & containment devices, • Close the loophole on rail car storage of toxics, 8 A. State and Local Chemical Disaster Prevention Programs are Failing California has one of the few chemical disaster prevention laws in the country. Enacted in 1986 as AB 3777, it requires local administering agencies (AAs) to maintain an inventory of acutely hazardous materials based on facility reporting and to require chemical disaster prevention plans, known formally as Risk Management and Prevention Programs (RMPPs), to be prepared by facilities with AHMs that may pose a significant risk. The RMPPs are to be based on Hazard and Operability (HazOp) studies, that plot modes for failure/error and chemical release, and Off-Site Consequence Analyses (OSCA) which are supposed to map out what exposures, injuries and deaths could result from a significant release. The RMPPs, which must be approved by.the AAs, are supposed to include measures to be taken by the facility to prevent the release of acutely hazardous materials. Poor implementation of this statute has hindered progress in preventing AHM releases and has created an illusion of public safety that does not exist. Among the many problems that plague this program are: 1. Accident in California does not include worst-case catastrophic releases 2. Basis of accident modelling (Haz Ops) are generally kept secret from the public 3. Regulators are not mandating.prevention measures 4. Local Administering Agencies (AAs) have virtually no oversight by the state 5. AAs are far behind in completing RMPPs (Risk Management & Prevention Plans) 6. Regional Air Quality Management Districts must become active in regulating acutely hazardous materials 1. Accident modelling in California does not include worst-case catastrophic releases Recommendations: --» RMPPs (Risk Management -and Prevention Programs) must include modelling of true worst case scenarios in order to identify potential offsite consequences, to enable planning and prevention, and to honor the public's right to know. --» State law should clarify and mandate that real worst case scenario releases be analyzed. 9 —» State OES should require real worst case analysis in order to comply with federal law and guidance. • RMPPs only model small releases. RMPP (Risk Management and Prevention Program) modelling of accidents in Contra Costa County has allowed the use of unrealistically small releases to be called "worst case credible" accidents. • Small release modelling generally predicts no offsite consequences. So called "worst case credible" accident modelling allowed by the Contra Costa County Health Services Department and used by industry predicts that likely scenarios for accidental releases of acutely hazardous materials will generally not go outside company fencelines, and not affect neighbors. • In reality,large releases with major exposure to neighbors have been frequent. The large (and increasing) number of major accidents in Contra Costa County in the last couple of years clearly show that the County and the petrochemical industry have been greatly underestimating the amount of acutely hazardous materials which are likely to be released during accidents. Many accidents have resulted in offsite plumes over large areas, with exposure of large numbers of neighbors to toxic materials. (See attachments on series of accidents.) • Federal EPA guidance recommends modelling real worst case analysis,but California Administering Agencies are not performing them. According to an EPA guidance document, modelling to identify vulnerable zones should be done based on the "maximum quantity that could be released from [the] largest vessel or incremental vessels." (Technical Guidance for Hazards Analysis, EPA, Dec. 1987, p. .2-17, see attached) • Federal Clean Air Act amendments (of 1990) also require worst case analysis. Section 112(r) requires that industrial plant-specific hazard assessments include "an evaluation of worst case accidental releases." The regulations implementing these sections are hung up in OMB (Office of Management and Budget) and need to be expedited. 2. Basis of accident modelling (Haz Op) are generally kept secret from the public Recommendation —» Hazard and Operability (Haz Ops) studies should be submitted to regulatory agencies. —>> Independent review to determine what is and is not trade secret in RMPP- related documents should be done by regulators, in order to allow public review and meaningful comment,on the documents which form the basis of RMPPs. 10 • Industry has kept its Haz Ops studies from public review. Haz Ops studies identify sources of potential leaks and releases and are the basis of RMPPs, but are generally kept from public review, due to over-broad claims of trade secrecy. • Contra Costa County has helped companies to shelter Haz Ops from public review. Contra Costa County has encouraged the sheltering of Haz Ops from public review, by allowing companies to retain Haz Ops onsite, rather than requiring submittal to the County where they would be subject to Public Records Act requests that would make non-trade secret material publicly available. 3. Regulators-are not mandating prevention measures Recommendations ®»The state RMPP law should be amended to clarify that regulators have clear authority to require affirmative steps to prevent catastrophic releases. —>> Counties should also take advantage of existing authority under California Civil Code for potential nuisances. • Industry claims Contra Costa County cannot mandate prevention actions, and to date, the County has sided with industry. Industry claims the County has no authority to require companies to take particular actions to reduce or eliminate risk of release of acutely hazardous materials. • State law does provide ability to disapprove RMPPs if inadequate. In fact, state Health & Safety Code gives the County authority to disapprove an RMPP if it is inadequate in preventing accidents. 1 • Industry incorrectly claims that Contra Costa County cannot mandate prevention actions, and the County has sided with industry. Industry.claims that the County has no authority to require companies to take particular actions to reduce or eliminate risk of release of acutely hazardous materials. This position is clearly contradicted by well-established law. Within the meaning of California Civil Code 1 Health&Safety Code,Section 25534,'1f...the administering agency determines that the handlers RMPP is deficient in any way,the administering agency shall notify the handler of these defects. The handler shall submit a corrected RMPP within 60 days of the notice. Section 25535,"...Failure to fully comply with this notice or the requirements of this section shall be deemed a violation of this article for purposes of Section 25540." Section 25534,"...The RMPP shall include all of the following elements: Design,operating,and maintenance controls which minimize the risk of an accident involving acutely hazardous materials." 2Vedder v.County of ImRg6al.36 Cal.App.3d 654,661 (1974). 3County of San Diego v.Carlstrom.196 Cal.App.2d 485,491 (1961). 11 section 3494, the County is perhaps the best recognized "public body" to abate public nuisances. The California courts have held that "the storage of gasoline and other highly combustible chemicals and not requiring or providing adequate fire protection facilities," could constitute a public nuisance, even if no fire has yet occurred.2 Similarly, the courts have held that a County may exercise its nuisance authority to require prospective actions to reduce the latent but foreseeable risk of fire created by the storage of hazardous materials in a residential neighborhood.3 4. Local Administering Agencies (AAs) have virtually no oversight by the state Recommendations -->> Require oversight of AAs by the state so that all federal and state requirements are met, possibly through additional state legislation. —>> Reconstitute LEPCs (Local Emergency Planning Committees) so that they correspond to each AA. —>> Require AAs or LEPCs to do jurisdiction-wide cumulative hazards analyses, as required by federal law. • The State does not provide oversight for local Administering Agencies (AAs). The approximately 130 California Administering Agencies (cities, counties, fire departments) are designated by the state to implement state and federal law on storage of hazardous materials, but are lacking state oversight on performing their duties. There is a lack of accountability for AAs, and a lack of communication between AAs, AAs and LEPCs, and with the California OES (Office of Emergency Services).. • Local AAs are not part of an integrated state network. AAs have no formal inter- coordination, standardization of methods, or centralization of data. Implementation of state and federal law by them is done very poorly by many, better by others, but left to ad hoc, case by case development. • The geographic boundaries of the LEPCs cover too much area to effectively discharge their responsibilities of coordinating the activities of the administering agencies. Contra Costa County is one of sixteen counties in only one LEPC which extends from Monterey to Del Norte County. The concentration of toxic materials in Contra Costa County and other Bay Area communities alone could easily warrant the designation of a separate LEPC. In addition, the large geographic area makes the job of oversight more difficult because of pronounced regional differences in population and industry types. • Proper oversight could correct deficiencies, such as a failure for cumulative hazards analyses to be performed. Hazards analyses are jurisdiction-wide analyses 12 l ' A required by federal law which look cumulatively at the risks from all industries in the area, and take into account transportation through the area. 5.AAs are far behind in completing RMPPs Recommendations —>> Administering Agencies should increase fees to administer RMPP programs in order to hire additional engineers to expedite the RMPP program. For example, • About 129 facilities store Acutely Hazardous Materials in Contra Costa County. • 26 RMPPs have been requested by the County. • 16 RMPPs have been submitted. • 2 have been reviewed and accepted. (Source: personal communication, Randy Sawyer, Engineer under contract to the Contra Costa County Health Services Department, August 6, 1993.) 6. Regional Air Quality Management Districts (AQMDs) must become active in regulating acutely hazardous materials Regional air quality agencies, like the Bay Area Air Quality Management District, who have the expertise, staffing, and authority to act, have generally refused to get involved in the prevention of airborne releases of AHMs. (A positive exception is the South Coast Air Quality Management District (SCAQMD) which adopted a regulation calling for the phase out of hydrogen fluoride (HF) gas in the L.A. area). Recommendations: -->> Regional AQMDs should be involved in all aspects of the RMPP process, including making pollution prevention recommendations. . ®» Regional AQMDs should regulate priority AHMs for phaseout, especially those stored near residences. • Regional AQMDs have authority to regulate airborne pollutants including Acutely Hazardous Materials (ARMs)—through its general authorities and through nuisance authorities. (See attachments) • Regional AQMDs have large, expertstaff available 13 AQMDs often utilize measures to prevent ongoing air pollution which can also be used to reduce releases of AHMs • AQMDs have the regulatory structure and region-wide jurisdiction to enact industry-wide phaseouts, or use reduction, of high priority chemicals B. The Federal Government has failed to implement the chemical accident prevention requirements of the Clean Air Act Amendments of 1990 In four respects, the U.S. Environmental Protection Agency (EPA) and the Clinton Administration have fallen short of the intent and requirements of Section 301 of the Clean Air Act Amendments of 1990 (Section 112(r) of the Clean Air Act). EPA has missed statutory deadlines and not yet produced required research studies on the dangers of hydrogen fluoride and hydrogen sulfide gas. The studies must document the worst case catastrophic impacts of releases of these materials. Both of these materials are present in significant quantities in Contra Costa County. Section 112 (r)(3)-(4) • President Clinton has failed to appoint five technical members to the new Chemical Safety and Hazard Investigation Board. Despite Congress' willingness to fund this independent oversight body, no effort is underway due to the lack of appointments. (Former President Bush had left positions on this Board vacant until .the very end of his tenure.) Section 112 (r)(6) • EPA has failed to adopt comprehensive Risk Management Program regulations intended to establish a first-ever national chemical disaster prevention program. The hazard analyses required by statute under this program must include "an evaluation of worst case accidental releases" Section 112(r). EPA's failure to act is contrasted with that of the Occupational Safety and Health Administration (OSHA) which completed on time its task, under the same statute, to adopt Chemical Process Safety regulations for the chemical industry. EPA's proposed regulations have been languishing for 16 months at the Office of Management and Budget (OMB). • EPA has failed to vigorously pursue the research opportunity to use facilities in southern Nevada to examine properties of toxic gas clouds deliberately released into the environment in the absence of people. This research effort needs $3 to $4 14 rn,llion per year to generate critical information that can be used to set priorities for ' preventing catastrophic chemical releases.. (We are grateful to Dr. Fred Millar of Friends of the Earth, Washington, D.C. for assisting with this profile of federal inaction). C. Available Technologies Must Be Mandated Relief Valves Recommendations: -->> Relief valves must not be allowed to vent gases to the atmosphere, but instead be piped to widely available containment systems such as scrubbers. ®» The BAAQMD (Bay Area Air Quality Management District) should implement its Clean Air Plan, which identifies a regulation on pressure Relief Valves, due for adoption in 1993. (Rulemaking has not yet started, and should be expedited.) This regulation should ban venting of pressure relief systems from all sources to the air. • Relief valves are designed to open up under high pressure, and so must be routed to containment systems. Relief valves, rupture disks, and other relief systems are for the purpose of allowing over-pressured vessels to release gases when the pressure reaches a certain threshhold, so that the vessels won't explode. Railcars, tanks, processing vessels, etc. have such pressure relief systems. Older petrochemical plants routinely allow relief system gases to dump to the atmosphere. Older refinery and chemical plants vent their pressure relief systems to the atmosphere and are major sources of ongoing air pollution, and cause major releases during accidents. General Chemical and Tosco had major accidents involving pressure relief valves this year. General Chemical in Richmond, and Tosco Refinery in Martinez dumped many tons of toxic materials through pressure relief systems which were unequipped with containment systems during accidents this year. • Scrubber systems are widely available. Newer refinery and chemical plants vent their pressure relief systems to scrubbers or flares, instead of dumping to the atmosphere. • Exxon & other refineries collect relief valve gases into flare systems. Exxon in Benicia (a newer facility, built in the '60s) and newer portions of other Bay Area refineries vent their relief gases to flares. 15 r I. W ,•,, Dow Chemical collects toxic relief valve gases in scrubbers. Dow Chemical in • Pittsburg pipes their relief valves to scrubbers so that they will not dump to the atmosphere, when they open to relieve pressures. • BAAMQD has not yet set its schedule for.implementing its Clean Air Plan for requiring controls on pressure relief valves.. The BAAQMD has not yet scheduled any workshops to implement the Clean Air Plan's requirement for adoption of a pressure relief valve regulation this year. (See attached excerpt from BAAQMD Clean Air Plan.) D. Warning systems and evacuation plans must be improved Recommendations: —>> Siren systems must be put into place, with community education on their meaning so that people know how to protect themselves. s> The CAN (Community Alert Network, telephone warning system) must be made to work, or be replaced. >> Evacuation plans, with advance community education, should be developed in ,detail to provide an additional option aside from the "Shelter in Place" policy. • Siren systems could provide instant warning. People walked directly into the sulfur trioxide / sulfuric acid cloud during the General Chemical July 26th release and were overcome by it, thinking that it was a cloud of fog. A siren system may have allowed more people to recognize the hazard and escape exposure. • The CAN system has repeatedly failed. During several major accidental toxics releases in Contra Costa County, the computerized telephone system has missed calling large, and even the majority of people in critical areas, it has called late (even after the release was over), or has not worked at all. • "Shelter in Place" has been promoted as a policy without clear criteria for its use, and without testing it. Shelter in Place has been treated as a well-tested system and replacement for a broader variety of options such as evacuation plans and public education to prepare people for protecting themselves and escaping exposure. In reality, "Shelter in Place" has not been well tested, and would clearly be the wrong choice in cases where lethal gases can overtake people inside their homes, and in other cases. (See attachment.) 16 . 5 E. Railcar regulations and local authority must be clarified and expanded Recommendations: ->> Railcar regulations must be clarified to emphasize.local regulatory oversight for inspection, and limitations in maximum amounts on site at one time. —» Railcar regulations should not allow temporary storage exemptions from other storage regulations. Railcar regulations should be modified to provide centralized inventories of amounts of materials stored, time stored, locations, etc. —>> Railcar regulations should be modified to provide phaseout of storage of AHMs near neighbors. >> Railcar regulations and jurisdiction of different agencies should be reviewed, and a report of gaps and solutions provided to the public. • Railcars have been widely used to temporarily store toxic and Acutely Hazardous Materials (AHMs) and avoid regulatory oversight Facilities using AHMs have used regulatory loopholes which allow temporary storage of AHMs in railcars without tripping local, state, and federal requirements for inspection, and permit storage limits. F. Union safety certification, worker training Recommendations: -->> Require that workers in areas where Acutely Hazardous Materials (AHMs) are present, to be fully trained through intensive, certified safety programs offering 80 hour or more hours, such as the Oil, Chemical, and Atomic Workers (OCAW) and Pipes Trades training programs. -->> Assess the current status of worker training to identify gaps. -->> Existing trade unions which have extensive information on worker safety training and accidents should be consulted for developing higher standards for all workers in areas where AHMs are used. • Union training programs prevent accidents. OCAW, and Pipe Trades, and other union training programs offer extensive safety training to workers, greater than 80 hours. 17 • Many non-union contract workers have little safety training. Workers have reported accidents caused by untrained, non-union contract workers. • A trend in using undertrained, non-union workers, and reducing maintenance may be causing more accidents. The Gray Institute Report (Lamar University, Beaumont, Texas, July 1991), found a greater dependence in recent years on outside contract workers, with less safety training than union-represented workers. The OCAW has stated that unsafe work by contract workers has caused major catastrophes and cost OCAW members their lives. (OCAW / Labor Institute Emergency Response & Prevention Workbook First Edition, p.27) 18