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HomeMy WebLinkAboutMINUTES - 12142004 - C.120 TO: BOARD OF SUPERVISORS ----._m:...:.•� ontr *: FROM: William Walker, M.D. Health Services Director I 2_ 1t y Costa DATE: December 14, 2004 ' pountySUBJECT: Hazardous Materials Incident Notification Policy SPECIFIC REQUEST(S) OR RECOMMENDATION(S) & BACKGROUND AND JUSTIFICATION RECOMMENDATION: 1. Approve the attached revised Hazardous Materials Incident Notification Policy BACKGROUND: Businesses are required to notify Health Services Hazardous Materials Programs, the administering agency for Contra Costa County, of a release or threaten release of a hazardous material: ". . the handler or any employee, authorized representative, went, or designee of a handier shall, upon discovery, immediately report any release or threatened release of a hazardous material to the administering agency. . ." Health & Safety Code Chapter 0.95, Article 1 §25507 The Board of Supervisors first passed the Hazardous Materials Incident Notification Policy on November 5, 1991 and has approved two subsequent revisions. The last Board of Supervisors approved revision was June 19, 2001, when the Board accepted the Community Warning System from Contra Costa County CAER Group, Inc. This policy substantial revisions being requested by the Board to accept are as follows: a) References to the Community Alert Network (CAN) has been changed to the Telephone Emergency Notification System (TENS) b) Clarification that non-process fires, such as a grass fire does not require a notification c) Requirement for monthly interim reports up to the time the final report is complete for Community Warning System Level 2 and 3 incidents as defined by the policy d) Request for electronic versions of the 72-hour and 30-day reports for Community Warning System Level 2 and 3 incidents as defined by the policy e) Revised the Hazardous Material Reporting Classification Levels to clarify the reporting requirements FISCAL IMPACT: No fiscal impact. CONTINUED ON ATTACHMENT: W YES NOIGNATURI ,��RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE -APPROVE OTHER a , ACTION OF BO ' `� u,i's ,i.% ffS" F.'4,;'',`- {; APPROVE AS RECOMMENDED OTHER VOTE OF SUPERVi�ORS I HEREBY CERTIFY THAT THIS IS A TRUE AND CORRECT COPY OF AN ACTION TAKEN UNANIMOUS(ABSENT � ) AND ENTERED ON THE MINUTES OF THE t' BOARD OF SUPERVISORS ON THE DATE SHOWN, AYES: NOES: ABSENT: ABSTAIN: Contact: Randy Sawyer((925)646-2285) ATTESTED . cc: Randy Sawyer, Health Services department JOHN SWEETEN, CLERK OF THE BOARD OF" UPERVISOI'; AND COUNTY ADMINISTRATOR BY `` P 6•" , DEPUTY F:fNotification Policy/Board Order 12114/04 Contra Costa health Services HAZARDOUS MATERIALS INCIDENT NOTIFICATION POLICY I. PURPOSE; The purpose of this Policy is to promote prompt and accurate reporting to Contra Costa Health Services("CCHS")of releases or threatened releases of hazardous materials that may result in injury or damage to the community andlor the environment. The primary reason for prompt and accurate notification to CCHS is to enable CCHS to take measures to mitigate the impacts of a hazardous materials release,such as: 1. Dispatching emergency response teams quickly and with the appropriate equipment and personnel 2. Assessing the extent of the release or the potential extent of the release and whether neighboring communities are at risk of exposure 3. Determining whether the Community Warning System should be activated(ifnot already activated)' 4. Responding to inquiries from the public and the media II. BACKGROUND: A. Origin of Policy The Contra Costa County Board of Supervisors approved the original Hazardous Materials Incident,Notification Policy on November 5, 1991. The policy was established in response to incidents, both in Contra Costa County and elsewhere, which demonstrated that preliminary assessments of hazardous materials releases often underestimate the extent and potential danger of such releases. B. Policy Supplements Regulations CCHS administers Article 1 of Chapter 6.95 of the California Health and Safety Code,often referred to as the"AD 2185"or"Business Plan"program,which requires immediate notification in the event of hazardous materials release. The fines that can be assessed for not reporting can be up to $25,000 per day and up to one year in jail for the first conviction.. In addition, the Board of 1 Facilities capable of initiating the Community Warning System shall follow the Community Warning System Operating Protocols established for it in addition to this policy. 2§25515. Any person or business that violates Section 25507 shad, upon conviction, be punished by a fine of not more than twenty-five thousand dollars($25,000)for each day of violation,or by imprisonment in the county jail for not more than one year, or by both the fine and imprisonment. If the conviction is for a December 14,2004 Page 1 Supervisors adapted Chapter 450-2 of the Contra Costa County Ordinance Code to supplement and facilitate the implementation of Chapter 6.95. In particular, Section 450-2.016 requires immediate reporting to CCHS of any release of a hazardous material reportable under any law to any federal, state or other local regulatory agency. CCHS also administers Article 2 of Chapter 6.95 of the California Health and Safety Code, referred to as the California Accidental Release Prevention(CalARP)Program. This policy assists facilities to meet their obligations under these and other laws. C. Community Warning System The CalARP Program requires facilities to determine the potential off-site consequences from accidental releases of a CaIARP Program regulated substance. This information has been used in developing emergency response plans for such potential releases. This information has also been used to design.the Community Warning System.(CWS). The CWS is a computer-integrated alerting and notification system that incorporates safety sirens,emergency responder pagers,Emergency Digital Information System(EDIS),the Emergency Alerting System(EAS),the California Law Enforcement Radio System("CLERS"),and a telephone emergency notification system (TENS). EDI , EAS, and CLERS are different ways of getting messages to emergency responders,including law enforcement,the media,and the National Weather Service(which transmits information to NOAA Weather Radios). The TENS calls households and businesses and transmits short messages about the incident and recommended protective actions. The CWS was developed through the efforts of the Contra Costa County Community Awareness and Emergency Response ("CAER") Group working cooperatively with CCHS, representatives from local industry,the community, and other regulatory agencies to provide local residents with timely notification of emergencies, including hazardous materials releases. The success of the CWS is dependent upon industry's prompt notification to CCHS. CCHS would like the public to be assured that the CWS will be activated in a timely manner to implement preventive measures, such as sheltering-in-place. The CWS may also be activated to allay community concerns when a visible incident occurs,such as an explosion that does not pose a health hazard. (In order to expedite notification, some facilities have CWS terminals on-site and may activate the CWS directly using pre-defined protocols and procedures.) D. Benefits of Prompt Notification and Cooperation violation committed after a first conviction under this section, the person shall be punished by a fine of not less than two thousand dollars($2,000)or more than fifty thousand dollars ($50,000) per day of violation, or by imprisonment in the state prison for 16, 20, or 24 months or in the county jail for not more than one year, or by bath the fine and imprisonment. Furthermore, if the violation results in,or significantly contributes to, an emergency, including a fire,to which the county or city is required to respond,the person shall also be assessed the full cost of the county or city emergency response,as well as the cost of cleaning up and disposing of the hazardous materials. December 1.4, 2004 Page 2 CCHS is aware that information provided during the initial notification may be preliminary and that facilities may not be able to provide completely accurate information. CCHS also does not intend for the need to provide notification to CCHS to impede either emergency response activities related to the release. However,CCHS's ability to make quick and informed decisions to mitigate the impacts of a release is dependent upon receiving prompt notification and accurate information about the release. Since its adoption in 1991,this policy has improved cooperation and communication between industry, CCHS, and the public during hazardous materials emergency events. CCHS remains committed to ongoing improvement of this policy as industry,CCHS,and the public gain additional experience. III. POLICY: A. When Immediate Notification Required. Responsible businesses are required to provide immediate notification to CCHS of release or threatened release in the following situations. 1. General. Immediate notification is required upon discovery of any release or threatened release of a hazardous material for which exposure to the release concentration poses or results in adverse health effects. 2. Specific Situations. Immediate notification is required in the following situations. a. The release or threatened release of a hazardous material that results in a substantial probability of harm to nearby workers or the general public, due to the tonic properties of the material. At a minimum, this includes all hazardous materials incidents in which ambulance response is requested or medical attention,other than first aid,is sought on-site or off-site. (Do not delay reporting if the level of treatment is uncertain.) b. The release or threatened release of any CalARP Program Regulated Substance that, due to size,concentration.,or physical properties,results in a substantial probability of adverse health effects other than mild transient effects to nearby workers or the general public. c. The release or threatened release may affect the surrounding population resulting in, at a minimum,odor, eye or respiratory irritation. d. The event may cause general public concern, such as in cases of fire, explosion, 3The tenn"responsible business"or"business" includes facilities and other entities that have custody of the hazardous material at the time that it is accidentally released,or the facility where the release occurs. For example,a transportation company is the responsible business if the material is released in transit. If there is a release from a transport vehicle when the vehicle is at a fixed facility, the fixed facility is primarily responsible for notifying CCHS under this policy. December 14, 2004 Page 3 smoke,or excessive flaring. This does not include a non-process fire,such as a grass fire, as long as the non-process fire will not impact a process. e. The release or threatened release may contaminate surface water,groundwater or soil, either on-site (unless the spill is entirely contained and the clean-up is initiated immediately and completed expeditiously)or off-site. f: The release or threatened release may cause off-site environmental damage. g. The release or threatened release occurs during transport,storage,or loading of such material, via vehicle, rail,pipeline,marine vessel, or aircraft. h. The facility's Safety Supervisor or equivalent personnel is placed on alert due to a release or threatened release resulting from an emergency situation,including,but not limited to, emergency shutdowns or major unit start-ups. B. Who to Notify.Immediately notify the CCHS Incident Response Team (on-call 24 hours a day)by any of the following methods 1. Directly via emergency response pagers(To receive the pager number,please contact the CCHS Incident Response Team in advance at(925) 646-2286.) 2. Any time by phone at (925) 646-1112 3. Through a CWS communication terminal C. Required Information. Provide the information required by the Facility Incident Checklist (Attachment A). Dry not delay the notification due to inability to provide any of the information called for in the Facility Incident Checklist. D. Notification under this policy does not relieve the responsible business from having to comply with any legal requirement to notify other local, state or federal agencies. E. When Notification Not Required. This policy does not require reporting of a release of hazardous material that clearly does not meet any of the criteria described in Subsection A, above. Examples of such situations are: 1. Ambulance calls not associated with hazardous materials incidents(e.g.,falling off of ladder). 2. Small spills where the spill is contained,and where it is clear that none of the situations described in Subsection A apply. Spill containment means: a. The spilled material is caught in a fixed berm or dike or other impermeable surface, or is contained by using effective spill control measures (NOTE: Petroleum refineries the spill is less than three fifty-five gallon drums.) b. All of the spilled material is prevented from contaminating surface or groundwater c. The spill does not pose a substantial probability of adverse health effects to the general public December 14, 2004 Page 4 3. Non-process fires or incidents,such as a grass fire,where a process is not expected to be impacted. F. Follow-up Reporting of a Hazardous Materials Release. I. For all Level 2 and Level 3 incidents(as defined in Attachment A-1),or upon request of CCHS,a written follow-up report ofthe incident shall be submitted within 72--hours. (If the due date falls on a weekend or holiday,the Director of Hazardous Materials Programs may allow the report to be submitted on the next business day.) The report shall confirm, modify and/or update the information provided in the initial notification (Facility Incident Checklist). The report shall be submitted on the 72-Hour Follow-Up Report Form (Attachment B). A hard copy and electronic copy of the report should be, submitted. 2. A written final report of the incident shall be made to CCHS as soon as practicable,but no later than 30 calendar days from the date of the release, for all Level 2 and Level 3 incidents and for any incident for which CCHS requests such a report. If the investigation has not been completed within 30 calendar days,an interim report shall be submitted and a final report submitted when the investigation is completed. The facility shall give written monthly status reports of the incident investigation,which is submitted the last day of the month following the 30-day report..,until the incident investigation is complete and the final report has been issued to CCHS. Refer to Attachment C for the 30-Day Final Incident Report format. A hard and an electronic copy of the 30-day and subsequent reports should be submitted. 3. All"Major Chemical Accidents or Releases"(defined at County Ordinance Code section 450-8.014(h))should be investigated using root cause investigation methodology. CCHS will either participate in or closely monitor the investigation.(County Ordinance Code,§ 450.8.016(C)(1).) 4. If the release requires a written emergency release follow-up report to be submitted to the Chemical Emergency Planning and Response Commission pursuant to section 2705(b)of Title 19 of the California Code of Regulations, a copy of such report shall be sent to CCHS within 15 calendar days. 5. A facility may elect to include with the 30-Day Incident Report Form(Attachment C)a brief narrative of how this incident relates to any of the prevention programs required by CaIARP Program regulations and described in the CCHS CaIARP Program guidance document. 6. Reports should be sent to the following address: Contra Costa Health Services Department ATTENTION: Randall L. Sawyer Hazardous Materials Programs Director 4333 Pacheco Boulevard Martinez, CA 94553 December 14,2004 Page 5 PV. REFERENCES: California Health and Safety Code Chapter 6.95 (§ 25500 et seq.); 19 Cal.Code Regs§2703 et seq.;County Ordinance Code Chapter 450.2. (Californian Public Utilities Commission Decision 91-08-019/R.88-07-039 requires similar notification for rail accidents.) Bd approved 11/5/91 Revised Bd Approved 1/93 Revised Bd Approved 6119/01 Revised Bd Approval 12/14/04 December 14, 2004 Page 6 Figure 1. CCHS Hazardous Materials incident Notification Policy Flowchart DISCOVERY OF HAZARDOUS MATERIALS RELEASE DOES Event MEET N NO FURTHER NOTIFICATION ACTION REQMNTS? REQUIRED Ak Y IMMEDIATE NOTIFICATION TO CCHS by TELEPHONE,PACER, ANDIOR CWS PROVIDE INFORMATION IN ATTACHMENT`A' N IS RELEASE CCHS REQUEST EITHER.LEVEL Y FOLLOWUP 0 OR LEVEL 1? REPORT? FOR INITIAL RESPONSE ONLY N WRITTEN FOLLOWUP y REPORT TO CCHS APPLICABLE WITHIN 72-HOURS TO 72-HOUR REPORT APPLICABLE TO 30-DAY REPORT INVESTIGATION SUBMIT BEEN N COMPLETED INTERIM WITHIN 30 DAYS? REPORT(S) Y SUBMIT FINAL REPORT (ATTACHMENT`C') (cont.) December 14, 2004 Page 7 (Figure 1,cont.} IS FOLLOWUP SUBMIT APPROPRIATE REPORT TO Y REPORT TO CCHS STATE OES WITHIN 15 DAYS REQUIRED?' NT IS NO FURTHER INCIDENT MAJOR a ACTION REQUIRED CHEMICAL ACCIDENT OR RFT.FACF9 Y INVESTIGATE INCIDENT USING ROOT CAUSE METHOD, IN CONJUNCTION WITH CCHS2 as per Section 2705(b)of Title 19 CCR. zContra Costa County Ordinance Code Chapter 450-8.016(C)(1)(where applicable) December 14, 2004 Page 8 ATTACHMENT A FACILITY INCIDENT CHECKLIST Date: Time: Initial: A.Can/Page CCC Hazardous Materials Programs Division[Phone:(925)646-1112,Pager: ] INFORMATION NEEDED IMMEDIATELY(IF KNOWN) LJ B.State your name and identify your facility and its address. C.State your phone number or a number with immediate access to an individual who can answer further questions from CCHS. (No voice mail phone numbers.) D.State the Community Warning System (CWS) Plant Reporting Classification Level (0, 1, 2 or 3): (See Attachment A-1). Ll E.Has the material gone off-site?Yes/No/Unknown. If yes,what area is being impacted? What is the direction of flow? Is there any impact to storm drains or surface waters? ❑ F.Have TENS Zones been activated?Yes/No? If yes,which TENS Zones have been activated? If no, which TENS Zones should be activated,if any? LJG.State,if known,the chemical or material released and describe the physical state (solid,liquid,gas and/or vapor). Has this been verified? Yes/No/Unknown ❑ H.Have you received any public complaints? Yes/No/Unknown. ❑ I. State wind direction out of(from)the to the and degrees if known. (e.g.,"Wind is blowing from the Northwest(300°)to the Southeast(1200)). ❑ J. State wind speed. (If wind speed is unknown, inform CCHS whether the wind is blowing significantly or not.) INFORMATION NEEDED AS SOON AS POSSIBLE ❑ K.Are there any injuries on-site or off-site? Yes/No/Unknown ❑ L. State the on-site contact person and gate number or address to which the CCHS Incident Response(IR)Team should respond. ❑ M. Are any sensitive receptors or subdivisions nearby? (e.g., School/Day Care facilities/Hospitals/Nursing Homes) N.Has the facility's "Emergency Operations Center" or emergency response staff been activated? Yes/ No/ Unknown ❑ O.State estimated quantity of chemical released(over-estimate rather than under-estimate release) P.Have other agencies been notified? Yes/No. If yes,state list. ❑ Q.Is there potential for involvement of other hazardous materials due to the proximity to the incident? December 14, 2004 Page 9 ATTACHMENT A-1 HAZARDOUS MATERIAL REPORTING CLASSIFICATION LEVELS LEVEL Q: Easily contained and controlled by plant personnel is informational only, on-site only,no offsite consequences, not detectable offsite and is categorized by any of the following: Safety Supervisor,or equivalent,is placed on alert due to a release or threatened release resulting from an emergency situation,including,but not limited to,emergency shutdowns or major unit start-ups. 2. Uncontained liquid spill.(For petroleum material,the spill is more than three 55-gallon drums-165 gallons—and does not meet any of requirements for notification listed in levels 1 -3.) 3. Three(3)or more unconfirmed odor complaints within an hour. 4. Vapor release that is not expected to pose an immediate threat to the health and safety of people in the affected area. The release is more than instantaneous or a"puff." LEVEL 1: On-site,possible offsite, no health impact expected and categorized by any of the following: . Confirmed(3 or more odor complaints within one hour and substantiated by plant personnel as an on-site problem)off- site odor from facility. 2. Fire/smoke which requires a response from workers outside the immediate area,but not visible off-site. 3. Excess flaring(flaring that occurs when the conditions are not normal and because of the flame could raise concerns from the community). 4. Spill or release incident that meets an RQ(Reportable Quantity)requirement and does not meet any of the requirements of Level 2 or 3. 5. Fire/smoke/plume(other than steam)visible from an off-site location(does not include fire training exercises). LEVEL 2: Offsite impact with possible health impact and categorized by any of the following: 1. Off-site impact where eye,skin,nose and/or respiratory irritation may be possible for individuals with respiratory sensitivities. 2. Explosion with noise/pressure wave impact off-site. 3. Fire/smoke/plume(other than steam)leaving or expected to leave site. LEVEL 3: Offsite impact and categorized by any of the following: I. Off-site impact that may cause eye,skin,nose and/or respiratory irritation to the general population. 2. Fire,explosion,heat,or smoke with an off-site impact. Example: On a process unit/storage tank where mutual aid is requested to mitigate the event and the fire will last longer than 15 minutes. 3. Hazardous material or fire incident where the incident commander or unified command,through consultation with the Contra Costa Health Services Hazardous Material Incident Response Team,requests that sirens should be sounded. December 14, 2004 Page 10 ATTACHMENT B For CCHS Use Only: 72 HOUR.FOLLOW-UP NOTIFICATION REPORT FORM CON'T'RA COSTA HEALTH SERVICES Received By: Gate Received: INSTRUCTIONS:A hardcopy and an electronic copy of this report is to be Incident Number: submitted for all Level 2 and 3 incidents or when requested by C CHS. See Cop led To: Attachment B-1 for suggestions regarding the type of information to be Event Classification Level: included in the report. Attach additional sheets as necessary. Forward the completed form to: ATTENTION: Randall L. Sawyer Hazardous Materials Programs Director Contra Costa Health Services 4333 Pacheco Boulevard Martinez, CA 94553 INCIDENT DATE: INCIDENT TIME: FACILITY: PERSON TO CONTACT FOR ADDITIONAL INFORMATION Phone number I. SUMMARY OF EVENT: IT. AGENCIES NOTIFIED,INCLUDING TIME OF NOTIFICATION: III. AGENCIES RESPONDING,INCLUDING CONTACT NAMES AND PHONE NUMBERS: IV. EMERGENCY RESPONSE ACTIONS: V. IDENTITY OF MATERIAL RELEASED AND ESTIMATED OR KNOWN QUANTITIES: December 14, 2004 Page I I 72-HOUR REPORT,PAGE 2 INCIDENT DATE: FACILITY: VI. METEOROLOGICAL CONDITIONS AT TIME OF EVENT including wind speed,direction,and temperature: VII. DESCRIPTION OF INJURIES: VIII. COMMUNITY IMPACT including number of off-site complaints,air sampling data during event,etc.: IX. INCIDENT INVESTIGATION RESULTS Is the investigation of the incident complete at this time? Yes No If the answer is no, submit a 30 day final or interim report. If the answer is yes,complete the following: X. SUMMARIZE INVESTIGATION RESULTS BELOW OR ATTACH COPY OF REPORT: XI. SUMMARIZE PREVENTATIVE MEASURES TO BE TAKEN TO PREVENT RECURRENCE INCLUDING MILESTONE AND COMPLETION DATES FOR IMPLEMENTATION: December 14, 2004 Page 12 ATTACHMENT B-1 72-flour Report Guidelines The following list suggests items that may be included in the 72-HourReportto CCHSfollowing an accidental release of a hazardous material. Not all of the items below may be applicable or available at the time of submission. 1. Summary of the Event Background Information/Events Preceding the Incident • Incident Summary,including timing of key events • Shift Logs,real-time computer/instrument logs,fenceline monitor data,etc. 11. Emergency Notifications(include names,phone numbers and times) + CCHS • Time/Level of CWS Activation • Other Agencies • Copy of State OES Emergency Release Follow-Up Notice Reporting Form III. Agencies Responding • Agency • Person or people responding • Contact person with telephone number IV. Emergency Response Actions Mutual Aid Activated? Fire Department Response? V. Material Involved • Estimated Quantities • CalARP Regulated Substances? • Material Safety Data Sheets V1. Meteorological Data(wind speed,direction,temperature,rain/sun,etc.) V11. Injuries(including number,type and severity) VIII. Community Impact • Community Complaints • Off-Site Consequence Impact Analysis(i.e.,injury,property damage,etc.) • Sampling Data,including fenceline monitors,if applicable • Community Monitoring Results IX. Incident Investigation • Procedure Summary �► Will Root Cause Analysis Be Performed? • Investigation Team/Contact Person(s) • Findings/Conclusions - Root Causes "Safety System"Flaws • Corrective Action/Preventative Measures • Description • Implementation bates December 14, 2004 Page 13 ATTACHMENT C For CCHS Use Only. 30-DAY FOLLOW-UP NOTIFICATION REPORT FORM CONTRA COSTA HEALTH SERVICES Received By: Cate Recelved: INSTRUCTIONS: A hardcopy and an electronic copy of this report is to be Incident Number: submitted for all Level 2 and 3 incidents or when requested by CCHS. See Copied To: Attachment C-1 for suggestions regarding the type of information to be Event Classification Level: included in the report. Attach additional sheets as necessary. This form is to be used for update reports after the initial 30-day report has been submitted. Forward the completed form to: ATTENTION: Randall L. Sawyer Hazardous Materials Programs Director Contra Costa Health Services 4333 Pacheco Boulevard Martinez, CA 94553 INCIDENT DATE: INCIDENT TIME: FACILITY: PERSON TO CONTACT FOR ADDITIONAL INFORMATION Phone number PROVIDE ANY ADDITIONAL INFORMATION THAT WAS NOT INCLUDED IN THE 72-HOUR REPORT WHEN THE 72-HOUR REPORT WAS SUBMITTED, INCLUDING MATERIAL RELEASED AND ESTIMATED OR KNOWN QUANTITIES,COMMMUNITY IMPACT,13 JURIES,ETC.: I. INCIDENT INVESTIGATION RESULTS Is the investigation of the incident complete at this time? Yes No If the answer is no,when do you expect completion ofthe Investigation? If the answer is yes, complete the following: SUMMARIZE INVESTIGATION RESULTS BELOW OR ATTACH COPY OF REPORT: SUMMARIZE PREVENTATIVE MEASURES TO BE TAKEN TO PREVENT RECURRENCE INCLUDING MILESTONE AND COMPLETION DATES FOR IMPLEMENTATION: December I4,2004 Page 14 __...._._.... _ ...._...................................................................................................................................................................................... ............................................................................................................................................................................................................................................................................................................................ 30-DAY REPORT,PAGE 2 INCIDENT DATE: FACILITY: STATE AND DESCRIBE THE ROOT-CAUSE(S)OF THE INCIDENT: December 14, 2004 Page 15 ATTACHMENT C-1 30-Hay Report Guidelines The following outline suggevs items in addition to those listed on the 72-Hour report guidelines (Attachments B and B-1)that may be included in the 30-Day Final.Report to CCHS following the accidental release of a hazardous material. (Some of the items listed below may not be applicable or available at the time of submission.) I. ADDITIONAL INFORMATION i Detailed Event Timeline Correspondence(if determined to be relevant) • Relevant History of Incidents with Similar Equipment or Procedures Il. INCIDENT INVESTIGATION, • Findings/Conclusions,including causal factors,contributing factors,and root causes or their equivalent • Preliminary Corrective Action/Preventative Measures — Immediate — Long-Term — Implementation Dates December 14, 2004 Page 16 HAZARDOUS MATERIALS INCIDENT NOTIFICATION POLICY GLOSSARY s Environmental damage: detrimental impact on surroundings beyond facility operations. Excessive flaring: flaring beyond a normal manner, in a way that may cause community concern. + Responsible Business: The business that has the custody of the hazardous material when there is an accidental release or the business where the accidental release occurs. Examples are 1)transportation companies when they are offsite from a business is then the responsible business when there is a release from their transport vehicle, 2) if there is a release from a transport vehicle at a fixed facility, then the fixed facility is the responsible business. • Root cause investigation.: a method for investigating and categorizing the root causes of hazardous materials incidents with safety,health,AND environmental impacts. Root causes are the most basic causes that can reasonably be identified,that management has control to fix, and for which effective recommendations for preventing recurrence can be generated. • Safety supervisor: facility employee(s)responsible for coordinating and/or implementing emergency response activities.Note: This position may be incident specific. + Telephone Emergency Notification System (TENS): The automated telephone calling system that notifies the community downwind during an incident. December 14,2004 Page 17 Contra Costa Health Services HAZARDOUS MATERIALS INCIDENT NOTIFICATION POLICY I. PURPOSE: The purpose of this Policy is to promote prompt and accurate reporting to Contra Costa Health Services("CCHS'}of releases or threatened releases of hazardous materials that may result in injury or damage to the community and/or the environment. The primary reason for prompt and accurate notification to CCHS is to enable CCHS to take measures to mitigate the impacts of a hazardous materials release, such as: 1. Dispatching emergency response teams quickly and with the appropriate equipment and personnel 2. Assessing the extent of the release or the potential extent of the release and whether neighboring communities are at risk of exposure 3. Determining whether the Community Warning System should be activated(ifnot already activated)' 4. Responding to inquiries from the public and the media II. BACKGROUND: A. Origin of Policy The Contra Costa County Board of Supervisors approved the original Hazardous Materials Incident Notification Policy on November 5, 1991. The policy was established in response to incidents, both in Contra Costa County and elsewhere, which demonstrated that preliminary assessments of hazardous materials releases often underestimate the extent and potential danger of such releases. B. Policy Supplements Regulations CCHS administers Article 1 of Chapter 6.95 of the California Health and Safety Code,often referred to as the"AB 2185"or"Business Plan"program,which requires immediate notification in the event of a hazardous materials release. The fines that can be assessed for not reporting can be up to $25,000 per day and up to one year in jail for the first conviction.2 In addition, the Board of ' Facilities capable of initiating the Community Warning System shall follow the Community Warning System Operating Protocols established for it in addition to this policy. Z§25515. Any person or business that violates Section 25507 shall, upon conviction, be punished by a fine of not more than twenty-five thousand dollars{$25,000}for each clay of violation, or by imprisonment in the county jail for not more than one year, or by both the fine and imprisonment. If the conviction is for a December 14, 2004 Page 1 Supervisors adapted Chapter 450-2 of the Contra Costa County Ordinance Code to supplement and facilitate the implementation of Chapter 6.95. In particular, Section 450-2.016 requires immediate reporting to CCHS of any release of a hazardous material reportable under any law to any federal, state or other local regulatory agency. CCHS also administers Article 2 of Chapter 6.95 of the California Health and Safety Code, referred to as the California Accidental Release Prevention(CalARP)Program. This policy assists facilities to meet their obligations under these and other laws. C. Community Warning System The CalARP Program requires facilities to determine the potential off-site consequences from accidental releases of a CaIARP Program regulated substance. This information has been used in developing emergency response plans for such potential releases. This information has also been used to design the Community Warning System(CWS). The CWS is a computer-integrated alerting and notification system that incorporates safety sirens,emergency responder pagers,Emergency Digital Information System(EDI ),the Emergency Alerting System(EAS),the California Law Enforcement Radio System("CLERS"),and a telephone emergency notification system (TENS). EMS, EAS, and CLERS are different ways of getting messages to emergency responders,including law enforcement,the media,and the National Weather Service(which transmits information to NOAA Weather Radios). The TENS calls households and businesses and transmits short messages about the incident and recommended protective actions. The CWS was developed through the efforts of the Contra Costa County Community Awareness and Emergency Response ("CAER") Group working cooperatively with CCHS, representatives from local industry,the community, and other regulatory agencies to provide local residents with timely notification of emergencies,including hazardous materials releases. The success of the CWS is dependent upon industry's prompt notification to CCHS. CCHS would like the public to be assured that the CWS will be activated in a timely manner to implement preventive measures, such as sheltering-in-place. The CWS may also be activated to allay community concerns when a visible incident occurs,such as an explosion that does not pose ahealth hazard. (In order to expedite notification, some facilities have CWS terminals on-site and may activate the CWS directly using pre-defined protocols and procedures.) D. Benefits of Prompt Notification and Cooperation violation committed after a first conviction under this section,the person shall be punished by a fine of not less than two thousand dollars($2,000)or more than fifty thousand dollars($50,000)per day of violation, or by imprisonment in the state prison for 16, 20, or 24 months or in the county jail for not more than one year, or by both the fine and imprisonment. Furthermore, if the violation results in, or significantly contributes to, an emergency, including a fire,to which the county or city is required to respond,the person shall also be assessed the full cost of the county or city emergency response, as well as the cost of cleaning up and disposing of the hazardous materials. December 14, 2004 Page 2 CCHS is aware that information provided during the initial notification may be preliminary and that facilities may not be able to provide completely accurate information. CCHS also does not intend for the need to provide notification to CCHS to impede other emergency response activities related to the release. However,CCHS's ability to make quick and informed decisions to mitigate the impacts of a release is dependent upon receiving prompt notification and accurate information about the release. Since its adoption in 1991,this policy has improved cooperation and communication between industry, CCHS, and the public during hazardous materials emergency events. CCHS remains committed to ongoing improvement of this policy as industry,CCHS,and the public gain additional experience. III. POLICY: A. When Immediate Notification Required. Responsible businesses3 are required to provide immediate notification to CCHS of release or threatened release in the following situations. 1. General. Immediate notification is required upon discovery of any release or threatened release of a hazardous material for which exposure to the release concentration poses or results in adverse health effects. 2. Specific Situations. Immediate notification is required in the following situations: a. The release or threatened release of a hazardous material that results in a substantial probability of harm to nearby workers or the general public, due to the toxic properties of the material. At a minimum, this includes all hazardous materials incidents in which ambulance response is requested or medical attention,other than first aid,is sought on-site or off-site. (leo not delay reporting if the level of treatment is uncertain.) b. The release or threatened release of any CalARP Program Regulated Substance that, due to size, concentration,or physical properties,results in a substantial probability of adverse health effects other than mild transient effects to nearby workers or the general public. c. The release or threatened release may affect the surrounding population resulting in, at a minimum, odor, eye or respiratory irritation. d. The event may cause general public concern, such as in cases of fire, explosion, 3The term"responsible business"or"business"includes facilities and other entities that have custody of the hazardous material at the time that it is accidentally released,or the facility where the release occurs. For example, a transportation company is the responsible business if the material is released in transit. If there is a release from a transport vehicle when the vehicle is at a fixed facility,the fixed facility is primarily responsible for notifying CCHS under this policy. December 14, 2004 Page 3 smoke,or excessive flaring. This does not include a non-process fire,such as a grass fire, as long as the non-process fire will not impact a process. e. The release or threatened release may contaminate surface water,groundwater or soil, either on-site (unless the spill is entirely contained and the clean-up is initiated immediately and completed expeditiously) or off-site. f. The release or threatened release may cause off-site environmental damage. g. The release or threatened release occurs during transport,storage,or loading of such material,via vehicle, rail,pipeline,marine vessel, or aircraft. h. The facility's Safety Supervisor or equivalent personnel is placed on alert due to a release or threatened release resulting from an emergency situation,including,but not limited to, emergency shutdowns or major unit start-ups. B. Who to Notify.Immediately notify the CCHS Incident Response Team (on-call 24 hours a day)by any of the following methods 1. Directly via emergency response pagers(To receive the pager number,please contact the CCHS Incident Response Team in advance at(925)646-2286.) 2. Any time by phone at(925) 646-111.2 3. Through a CWS communication terminal C. Required Information. Provide the information required by the Facility Incident Checklist (Attachment A). Do not delay the notification due to inability to provide any of the information called for in the Facility Incident Checklist. D. Notification under this policy does not relieve the responsible business from having to comply with any legal requirement to notify other local, state or federal agencies. E. When Notification Not Required. This policy does not require reporting of a release of a hazardous material that clearly does not meet any of the criteria described in Subsection A, above. Examples of such situations are: 1. Ambulance calls not associated with hazardous materials incidents(e.g.,falling off of a ladder). 2. Small spills where the spill is contained, and where it is clear that none of the situations described in Subsection A apply. Spill containment means: a. The spilled material is caught in a fixed berm or dike or other impermeable surface, or is contained by using effective spill control measures (NOTE: Petroleum refineries the spill is less than three fifty-five gallon drums.) b. All of the spilled material is prevented from contaminating surface or groundwater c. The spill does not pose a substantial probability of adverse health effects to the general public December 14, 2004 Page 4 3. Non-process fires or incidents,such as a grass fire,where a process is not expected to be impacted. F. Follow-up Reporting of a Hazardous Materials Release. I. For all Level 2 and Level 3 incidents(as defined in Attachment A-1),or upon request of CCHS,a written follow-up report of the incident shall be submitted within 72-hours. (If the due date falls on a weekend or holiday,the Director of Hazardous Materials Programs may allow the report to be submitted on the next business day.) The report shall confirm, modify and/or update the information provided in the initial notification (Facility Incident Checklist). The report shall be submitted on the 72-Hour Follow-Up Report Form (Attachment B). A hard copy and electronic copy of the report should be, submitted. 2. A written final report of the incident shall be made to CCHS as soon as practicable,but no later than 30 calendar days from the date of the release, for all Level 2 and Level 3 incidents and for any incident for which CCHS requests such a report. If the investigation has not been completed within 30 calendar days,an interim report shall be submitted and a final report submitted when the investigation is completed. The facility shall give written monthly status reports of the incident investigation,which is submitted the last day of the month following the 30-day report,until the incident investigation is complete and the final report has been issued to CCHS. Refer to Attachment C for the 30-Day Final Incident Report format. A hard and an electronic copy of the 30-day and subsequent reports should be submitted. 3. All"Major Chemical Accidents or Releases"(defined at County Ordinance Code section 454-8.014(h))should be investigated using root cause investigation methodology. CCHS will either participate in or closely monitor the investigation.(County Ordinance Code,§ 454.8.416(C)(1).) 4. If the release requires a written emergency release follow-up report to be submitted to the Chemical Emergency Planning and Response Commission pursuant to section 2705(b)of Title 19 of the California Code of Regulations, a copy of such report shall be sent to CCHS within 15 calendar days. 5. A facility may elect to include with the 30-Day Incident Report Form(Attachment C)a brief narrative of how this incident relates to any of the prevention programs required by CaIARP Program regulations and described in the CCHS CalARP Program guidance document. 6. Reports should be sent to the following address: Contra Costa Health Services Department ATTENTION: Randall L. Sawyer Hazardous Materials Programs Director 4333 Pacheco Boulevard Martinez, CA 94553 December 14, 2004 Page 5 IV. REFERENCES: California Health and Safety Code Chapter 6.95 (§ 25500 et seq.); 19 Cal.Code Regs§2703 et seq.;County Ordinance Code Chapter 450.2. (Californian Public Utilities Commission Decision 91-08-019/R-88-07-039 requires similar notification for rail accidents.) Bd approved 11/5/91 Revised Bd Approved 1193 Revised Bd Approved 6/19/01 Revised Bd Approval 12/14/04 December 14, 2004 Page 6 Figure 1. CCHS Hazardous Materials Incident Notification Policy Flowchart DISCOVERY OF HAZARDOUS MATERIALS RELEASE DOES Event NO FURTHER MEET N NOTIFICATION ACTION REQMNTS? REQUIRED AL Yfi .J IMMEDIATE NOTIFICATION TO CCHS by TELEPHONE,PAGER, AND/OR CWS PROVIDE INFORMATION IN ATTACHMENT`A' h IS RELEASE _ CCHS REQUEST EITHER LEVEL FOLLOWUP 0 OR LEVEL I? REPORT? FOR INITIAL RESPONSE ONLY WRITTEN FOLLOWUP Y REPORT TO CCHS APPLICABLE WITHIN'72-HOURS TOPORTOUR RE APPLICABLE TO 30-DAY REPORT INVESTIGATION SUBMIT BEEN N INTERIM COMPLETED WITHIN 30 DAYS? REPORT(S) Y SUBMIT FINAL REPORT (ATTACHMENT`C') {cant.) December 14, 2004 Page 7 (Figure 1,cont.) IS FOLLOWUP Y SUBMIT APPROPRIATE REPORT TO Y REPORT TO CCHS STATE OES WITHIN 15 DAPS REQUIRED?' rN Is NO FURTHER INCIDENT MAJOR i`1 ACTION REQUIRED CHEMICAL ACCIDENT OR Y TN'VESTIGATE INCIDENT USING ROOT CAUSE METHOD, IN CONJUNCT ION WITH CCHS` as per Section 2705(b)of Title 19 CCR. '`Contra Costa County Ordinance Code Chapter 4513-8.016(C)(1)(where applicable) December 14, 2004 Page 8 ATTACHMENT A FACILITY INCIDENT CHECKLIST Date: Time: Initial:_ U A.Call/Page CCC Hazardous Materials Programs Division[Phone:(925)646-1112,Pager: j INFORMATION NEEDED IMMEDIATELY(IF KNOWN) B.State your name and identify your facility and its address. C.State your phone number or a number with immediate access to an individual who can answer further questions from CCHS. (No voice mail phone numbers.) Ll D.State the Community Warning System (CWS) Plant Reporting Classification Level (0, 1, 2 or 3): (See Attachment A-1). LlE.Has the material gone off-site?Yes/No/Unknown. If yes,what area is being impacted? What is the direction of flow? Is there any impact to storm drains or surface waters? W F.Have TENS Zones been activated?Yes/No? If yes,which TENS Zones have been activated? If no,which TENS Zones should be activated,if any? F1 G.State,if known,the chemical or material released and describe the physical state (solid,liquid,gas and/or vapor). Has this been verified? Yes/NTo/Unknown _u QH.Have you received any public complaints? Yes/No/Unknow, Ll I. State wind direction out of(from)the to the and degrees if known. [e g,"Wind is blowing from the Northwest(3001)to the Southeast(120°)j. LJ J. State wind speed. (If wind speed is unknown, inform CCHS whether the wind is blowing significantly or not.) INFORMATION NEEDED AS SOON AS POSSIBLE LJ K.Are there any injuries on-site or off-site? Yes/No/Unknown LJL.State the on-site contact person and gate number or address to which the CCHS Incident Response(IR)Team should respond. QM. Are any sensitive receptors or subdivisions nearby? (e.g., School/Day Care facilities/Hospitals/Nursing Homes) __ N.Has the facility's "Emergency Operations Center" or emergency response staff'been activated? Yes/ No/ Unknow ® O.State estimated quantity of chemical released(over-estimate rather than under-estimate release) Ll P.Have other agencies been notified? Yes/No._ If yes,state list. QQ.Is there potential for involvement of other hazardous materials due to the proximity to the incident? December 14, 2004 Page 9 ATTACHMENT A-1 HAZARDOUS MATERIAL REPORTING CLASSIFICATION LEVELS LEVEL 0: Easily contained and controlled by plant personnel is informational only, on-site only,no offsite consequences, not detectable offsite and is categorized by any of the following: . Safety Supervisor,or equivalent,is placed on alert due to a release or threatened release resulting from an emergency situation,including,but not limited to,emergency shutdowns or major unit start-ups. 2. Uncontained liquid spill.(For petroleum material,the spill is more than three 55-gallon drums-165 gallons--and does not meet any of requirements for notification listed in levels 1-3.) 3. Three(3)or more unconfirmed odor complaints within an hour. 4. Vapor release that is not expected to pose an immediate threat to the health and safety of people in the affected area. The release is more than instantaneous or a"puff." LEVEL 1: On-site, possible offsite, no health impact expected and categorized by any of the following: . Confirmed(3 or more odor complaints within one hour and substantiated by plant personnel as an on-site problem)off- site odor from facility. Fire/smoke which requires a response from workers outside the immediate area,but not visible off-site. 3. Excess flaring(flaring that occurs when the conditions are not normal and because of the flame could raise concerns from the community). 4. Spill or release incident that meets an RQ(Reportable Quantity)requirement and does not meet any of the requirements of Level 2 or 3. ). Fire/smoke/plume(other than steam)visible from an off-site location(does not include fire training exercises). LEVEL 2: Offsite impact with possible health impact and categorized by any of the following: I. Off-site impact where eye,skin,nose and/or respiratory irritation may be possible for individuals with respiratory sensitivities. 2. Explosion with noise/pressure wave impact off-site. 3. Fire/smoke/plume(other than steam)leaving or expected to leave site. LEVEL 3: Offsite impact and categorized by any of the following: 1. Off-site impact that may cause eye,skin,nose and/or respiratory irritation to the general population. Z. Fire,explosion,heat,or smoke with an off-site impact. Example: On a process unit/storage tank where mutual aid is requested to mitigate the event and the fire will last longer than 15 minutes. 3. Hazardous material or fire incident where the incident commander or unified command,through consultation with the Contra Costa Health Services Hazardous Material Incident Response Team,requests that sirens should be sounded. December 14, 2004 Page 10 __ ATTACHMENT B For CCHS Use Only: 72 HOUR FOLLOW-UP NOTIFICATION REPORT FORM CONTRA COSTA.HEALTH SERVICES Received By: Date Received: INSTRUCTIONS:A hardcopy and an electronic copy of this report is to be incident Number: submitted for all Level 2 and 3 incidents or when requested by CCHS. See Copied To: Attachment B-1 for suggestions regarding the type of information to be went Classification Level: included in the report. Attach additional sheets as necessary. Forward the completed form to: ATTENTION: Randall L. Sawyer Hazardous Materials Programs Director Contra Costa Health Services 4333 Pacheco Boulevard Martinez, CA 94553 INCIDENT DATE: INCIDENT TIME: FACILITY: PERSON TO CONTACT FOR ADDITIONAL INFORMATION Phone number I. SUMMARY OF EVENT: II. AGENCIES NOTIFIED,INCLUDING TIME OF NOTIFICATION: III. AGENCIES RESPONDING,INCLUDING CONTACT NAMES AND PRONE NUMBERS: IV. EMERGENCY RESPONSE AC'T'IONS: V. IDENTITY OF MATERIAL RELEASED AND ESTIMATED OR KNOWN QUANTITIES: December 14, 2004 Page I I _ 72-HOUR REPORT,PAGE 2 INCIDENT DATE: FACILITY: VI. METEOROLOGICAL CONDITIONS AT TIME OF EVENT including wind speed,direction,and temperature: VII. DESCRIPTION OF INJURIES: VIII. COMMUNITY IMPACT including number of off-site complaints,air sampling data during event,etc.: IX. INCIDENT INVESTIGATION RESULTS Is the investigation of the incident complete at this time? Yes No If the answer is no,submit a 30 day final or interim report. If the answer is yes,complete the following: X. SUMMARIZE INVESTIGATION RESULTS BELOW OR ATTACH COPY OF REPORT: XI. SUMMARIZE PREVENTATIVE MEASURES TO BE TAKEN TO PREVENT RECURRENCE INCLUDING MILESTONE AND COMPLETION DATES FOR IMPLEMENTATION: December 14, 2004 Page 12 ATTACHMENT B-1 72-Hater Report Guidelines The following list suggests items that may be included in the 72-HourReport to CCHSfoll©wing an accidental release of a hazardous material. Not all of the items below may be applicable or available at the time of submission. I. Summary of the Event + Background Information/Events Preceding the Incident + Incident Summary,including timing of key events • Shift Logs,real-time computer/instrument logs,fenceline monitor data,etc. 11. Emergency Notifications(include names,phone numbers and times) + CCHS + Timel Level of CWS Activation + Other Agencies • Copy of State OES Emergency Release Follow-Up Notice Reporting Form III. Agencies Responding + Agency • Person or people responding + Contact person with telephone number IV. Emergency Response Actions + Mutual Aid Activated? �aterial Fire Department Response? V. Involved • Estimated Quantities + CaIARP Regulated Substances? • Material Safety Data Sheets VI. Meteorological Data(wind speed,direction,temperature,rain/sun,etc.) VII. Injuries(including number,type and severity) VIII. Community Impact + Community Complaints + Off-Site Consequence Impact Analysis(i.e.,injury,property damage, etc.) + Sampling Data,including fenceline monitors, if applicable + Community Monitoring Results IX. Incident Investigation • Procedure Summary • Will Root Cause Analysis Be Performed? • Investigation Team/Contact Person(s) + Findings/Conclusions Root Causes "Safety System"Flaws + Corrective Action/Preventative Measures + Description �► Implementation Dates December 14, 2004 Page 13 ATTACHMENT C For CCHS Use Only: 30-DAY FOLLOW-UP NOTIFICATION REPORT FORINT CONTRA COSTA HEALTH SERVICES Received By: Cate Received: INSTRUCTIONS: A hardcopy and an electronic copy of this report is to be incident plumber: submitted for all Level 2 and 3 incidents or when requested by CCHS. See Copied To: Attachment C-1 for suggestions regarding the type of information to be included in the report. Attach additional sheets as necessary. This form is to Event Classification Level: be used for update reports after the initial 30-day report has been submitted. Forward the completed form to: ATTENTION: Randall L. Sawyer Hazardous Materials Programs Director Contra Costa Health Services 4333 Pacheco Boulevard Martinez,CA 94553 INCIDENT DATE: INCIDENT TIME: FACILITY: PERSON TO CONTACT FOR ADDITIONAL INFORMATION Phone number PROVIDE ANY ADDITIONAL INFORMATION THAT WAS NOT INCLUDED IN THE 72-HOUR REPORT WHEN THE 72-HOUR REPORT WAS SUBMITTED, INCLUDING MATERIAL RELEASED AND ESTIMATED OR KNOWN QUANTITIES,COMMUNITY IMPACT,INJURIES,ETC.: I. INCIDENT INVESTIGATION RESULTS Is the investigation of the incident complete at this time? Yes No If the answer is no,when do you expect completion of the Investigation? If the answer is yes,complete the following: SUMMARIZE INVESTIGATION RESULTS BELOW OR ATTACH COPY OF REPORT: SUMMARIZE PREVENTATIVE MEASURES TO BE TAKEN TO PREVENT RECURRENCE INCLUDING MILESTONE AND COMPLETION DATES FOR IMPLEMENTATION: December 14, 2004 Page 14 30-DAY REPORT,PAGE 2 INCIDENT DATE: FACILITY: STATE AND DESCRIBE THE ROUT-CAUSES)OF THE INCIDENT: December 14, 2004 Page 15 ATTACHMENT C-1 30-Day Report Guidelines The following outline suggots items in addition to those listed on the 72-Hour report guidelines (Attachments B and B-1) that may be included in the 30-Day Final Report to CCHS following the accidental release of a hazardous material. (Some of the items listed below may not be applicable or available at the time of submission) I. ADDITIONAL INFORMATION * Detailed Event Timeline * Correspondence (if determined to be relevant) * Relevant History of Incidents with Similar Equipment or Procedures Tl, INCIDENT INVESTIGATION * Findings/Conclusions,including causal factors,contributing factors,and root causes or their equivalent * Preliminary Corrective Action./Preventative Measures — Immediate — Long-Term — Implementation Dates December 14,2404 Page 16 HAZARDOUS MATERIALS INCIDENT NOTIFICATION POLICY GLOSSARY • Environmental damage: detrimental impact on surroundings beyond facility operations. • Excessive flaring: flaring beyond a normal manner, in a way that may cause community concern. Responsible Business: The business that has the custody of the hazardous material when there is an accidental release or the business where the accidental release occurs. Examples are 1)transportation companies when they are offsite from a business is then the responsible business when there is a release from their transport vehicle, 2) if there is a release from a transport vehicle at a fixed facility,then the fixed facility is the responsible business. Root cause investigation: a method for investigating and categorizing the root causes of hazardous materials incidents with safety,health,AND environmental impacts. Root causes are the most basic causes that can reasonably be identified,that management has control to fix, and for which effective recommendations for preventing recurrence can be generated. +► Safety supervisor: facility employee(s)responsible for coordinating and/or implementing emergency response activities. Note: This position may be incident specific. i Telephone Emergency Notification System (TENS): The automated telephone calling system that notifies the community downwind during an incident. December 14, 2004 Page 17