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HomeMy WebLinkAboutMINUTES - 07151997 - D8 d/, f TO: BOARD OF SUPERVISORS FROM: William Walker, MD Health Services Director DATE: July 15, 1997 SUBJECT: Report from Dr. Paul Hill, President of the National Institute for Chemical Studies,titled "Incident Response in Contra Costa County" SPECIFIC REQUEST(S)OR RECOMMENDATION(S)&BACKGROUND AND JUSTIFICATION Recommendation: ACCEPT the report from Dr. Paul Hill, President of the National Institute of Chemical Studies, entitled"Incident Response in Contra Costa County". Background: On February 25th, 1997, as part of the Board's follow-up actions to the January 21st fire at the Tosco-Avon refinery, the Board directed staff to obtain independent assistance in reviewing hazardous materials incident response in the county. The Department of Health Services entered into a contract for this purpose with the National Institute of Chemical Studies, an independent research and education center. In May, 1997, Dr. Hill conducted research here for the report. Fiscal Impact: None. CONTINUED ON ATTACHMENT: NO SIGNATURE RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE APPROVE OTHER SIGNATURE(S): ACTION OF BOARD ON July 15, 1997 APPROVED AS RECOMMENDED X OTHER X Please See Addendum (Attached) for a list of speakers and Board action. VOTE OF SUPERVISORS X -- I HEREBY CERTIFY THAT THIS IS A TRUE UNANIMOUS (ABSENT ------- ) AND CORRECT COPY OF AN ACTION TAKEN AND ENTERED ON THE MINUTES OF THE BOARD AYES: NOES: OF SUPERVISORS ON THE DATE SHOWN. ABSENT: ABSTAIN: Contact Person: Elinor Blake 370-5022 ATTESTED J ly 15, 1997 CC: County Administrator PHIL BATC RK OF THE BOARD F Health Services Director SUPE R COUNTY ADMINIS OR Hazardous Materials Commission Hazardous Materials Division BY: stine Wampler D.8 ADDENDUM Item D.8 July 15, 1997 Dr. Paul Hill, President of the National Institute of Chemical Studies, provided the Board of Supervisors with an overview of the attached report and recommendations. The Board members discussed the report and then Chairman DeSaulnier called for public comment on the issues. The following person addressed the Board: Denny Larson, Communities for a Better Environment (CBE), 500 Howard Street, Suite 506, San Francisco. All persons desiring to speak having been heard, the Board members further discussed the issues and took the following action: 1. ACCEPTED the report from Dr. Paul Hill, President of the National Institute of Chemical Studies, entitled "Incident Response in Contra Costa County" (Attached); 2. AUTHORIZED Dr. Hill to conduct a ore detailed review of the Tosco report and the root cause analysis relative to the January 21, 1997, Tosco incident; and 3. REQUESTED that Dr. Hill review the County's current industrial safety ordinance, and any alternative ordinances, and that Dr. Hill provide an initial review and report to the County Administrator identifying the amount of additional study necessary in order to furnish the Board of Supervisors with a detailed analysis of issues including: current and alternative industrial safety ordinances(s), a review of refinery fees, and the suggested establishment of a technical advisory board. cc: County Administrator Health Services Director Hazardous Materials Commission Hazardous Materials Division Incident Response in Contra .Costa County i The National Institute Chemical Studies June 15, 1997 R Incident Response in Contra Costa County. An Independent Assessment provided by the National Institute for Chemical Studies This document made possible through a contract authorized by Contra Costa County.Health Services Department, Martinez, California printed on recycled paper Incident Response in Contra Costa National Institute for Chemical Studies ASSESSMENT OF EMERGENCY RESPONSE PREPAREDNESS REPORT TO THE CONTRA COSTA COUNTY BOARD OF SUPERVISORS HEALTH SERVICES DEPARTMENT ENVIRONMENTAL HEALTH DIVISION-HAZARDOUS MATERIALS.PROGRAMS I.Executive Summary Introduction Background and History Analytical Approach Reviewers II.Contra Costa County Hazmat Operations III.Issues of Concern A.Community and Labor B.Industry C.CCCHSD Staff Responsibilities Qualifications Training Mission Procedures Equipment Coordination Training Perceptions and Relationships with Constituents IV.Recent Incidents V.Current Advances VI.Discussion of Prevailing Issues VII.Key Research Questions and Considerations for the Future VIII.Documents/References Investigating Chemical Accidents - CCPS (Ref) Incident Response in Con"Costa National Institute for Chemical Studies AMU FORWARD This report constitutes a snapshot assessment of the programs, communication and perceptions of stakeholders in Contra Costa County regarding hazardous materials releases. Its scope was limited by time and resources. An exhaustive study to determine detailed issues,perceptions and recommendations should, and, in most instances does, take months to complete. Stakeholders and sponsors of this report should pay special attention to the accuracy of perceptions which are reflected herein. Experience with hazardous materials programs across the country has taught us that, in large measure,perception=reality. That is, our best tools for improving programs often rest in the perceptions of stakeholders. The recommendations made by this report should be considered points to further pursue. The National Institute for Chemical Studies, NICS, makes no assurances that the recommendations and observations contained in this report, if implemented, will reduce the level of accidents. Simple solutions to complex problems almost always fall. With diligence and a. commitment of time and resources to hazardous materials response programs, complex,multi-faceted solutions may be achieved. To do otherwise would erode our social system of governing and problem solving. The most frequently asked question during this project was: How is Contra Costa doing (with regard to incident response)? The answer in the view of the NICS is: "Very well." A unique framework, supplemented by several new innovations, ranks Contra Costa County among the top grouping of similar jurisdictions across the nation. But in the words of Dr. William Walker, Director of the Contra Costa County Health Services Department, CCCHSD, "will it ever be good enough?" Incident response,prevention and planning are by their very nature evolutionary activities. Constant feedback, new resources, analysis of data, and critical evaluation provide endless feedback opportunities to gain knowledge and make improvements. Contra Costa County-- from its Board of Supervisors, to its agencies and a variety of stakeholders --has demonstrated diligence in this regard. The evolutionary process of incident response activities is healthy in the County and will, no doubt, provide even greater rewards in the future. Incident Response in Contra Costa i National Institute for Chemical Studies A"U 1W INTRODUCTION 0 n April 16, 1997,the National Institute for Chemical Studies(NICS), a non-profit, non-aligned public interest research group, submitted a proposal for consideration by the Contra Costa County Board of Supervisors (CCCBS). The purpose of the proposal was to conduct an assessment and provide subsequent recommendations regarding the authorities, operations and program implementation of the Contra Costa County Health Services Department (CCCHSD). Specifically, this assessment focused on emergency preparedness and response programs authorized by federal, state and local statutes and ordinances. Hazardous materials incidents in the County and the appropriateness of existing response actions by the CCCHSD prompted the Board to seek this independent review by an objective source. BACKGROUND AND HISTORY. As a geographic region, Contra Costa County is recognized nationally as having a high concentration of industrial facilities. With such facilities come both risks and benefits which must be balanced for the public good of citizens residing within the County. Located on , the northeastern edge of San Francisco � $M e..3 Cai"??�Nth l'#S�5 Bay, the area is ideally situated f,or rld heavy industry. Access to major markets OR is achieved through the deep water channel connecting the bay with facilities along the Sacramento River, Carquinez Straits and San Pablo Bay. Contra Costa County is home to five refineries, six chemical plants, two power plants and numerous smaller facilities which handle hazardous materials. Recent hazardous materials industrial incidents have prompted the Board of Supervisors to initiate discussions of policies which could lead to improved safety. To assist in this process, the Board in conjunction with the County Health Services Director have requested that the National Institute for Chemical Studies provide baseline information and potential enhancements regarding the county's current operations with regard to incident response. This report constitutes the findings of the review. 2 Incident Response in Contra Costa National Institute for Chemical Studies Key issues for consideration included existing authorization, current program implementation, staffing and job descriptions,potential unmet authority and enhancements which might be considered for improved incident response, notification and follow up. CCCHSD is empowered by federal statute(Title 42 of U.S. Code, Section 11001 et. seq. 40 CFR 300, 350, 355, and 372),as well as state statute(Chapter 6.95 of the California Health and Safety Code, Title 19, California Code of Regulations). Additionally the CCCBS is empowered to issue declarations and ordinances which impose requirements on regulated facilities.For example,the December 30, 1996 Ordinance Number 96-50 amended -20 Requiring Add 08 existing Ordinance 96 T �bb,-90.111 ti Land Use Permits for Development 'Comm endedProjects Involving Hazardous Waste or : Hazardous Material. Such authorities, OV .......... from legislative authorization to emergency response ordinances form the scope of this review. Additional work may be identified by this report since an objective is to assess key issues for recommended attention by CCCBS. CCCHSD administers Article I of Chapter 6.95 of the California Health and Safety Code, often referred to as the AB 2185 program(Business Plans). The AB 2185 program requires immediate notification in the event of a hazardous materials release. In addition, the Board of Supervisors adopted Chapter 450-2 of the Contra Costa County Ordinance Code in order to supplement and facilitate the implementation of Chapter 6.95. In particular, Section 450- 2.016 requires that"a handler shall,immediately upon discovery,report to the administering agency, any release of a hazardous material reportable under any law to any federal, state or other local regulatory agency." CCCHSD also administers Article 2 of Chapter 6.95 of the California Health and Safety Code, that allows CCCHSD to implement the California Accidental Release Prevention Program (CARPP) and receive facility Risk Management Plans (RMP). This program requires industries to determine the potential off-site consequences of a release of an acutely hazardous material including "Worst case" and alternate scenarios for regulated substances. The CARPP authorizes the implementation of the federal Risk Management Program created by the Clean Air Act Amendments of 1990. This information from the CARPP is utilized for developing emergency response plans to those potential releases. 3 I 74F Incident Response in Contra Costa National Institute for Chemical Studies This work is a result of discussions and - -- directives given by CCCBS on Feb ' 25, 1997. The transcript and motions recorded for a meeting of the Board on that date include an exchange between x Supervisor DeSaulnier and Supervisor ::.::.::.:: :: Canciamilla regarding "third party" t, i"1i1 . professional assistance. The basis for the present.report was postulated during this discussion which focused on seeking suggestions for improvements by reviewing recent incidents including the January, 1997 incident at the Tosco Refinery. Relevant portions of the transcript are included in reference materials at the end of this report. In commissioning this work, CCCBS is taking a serious and positive step toward self-evaluation and potential improvement of the County's operations. ANALYTICAL APPROACH tatutory language contained in the above-named ordinances and state code was reviewed for authorization regarding the county's current operation as well as any unmet mandates for notification and response. This effort did not constitute an exhaustive legal review and should not be interpreted as such. Several components including an organizational review,job description assessments and staff interviews were conducted (See Table 1-1.). Special attention was paid to the twelve positions assigned to accident response and follow-up. Supervisory personnel and some members of the CCCBS also participated in the process, providing a full range of operational feedback. Stakeholder groups including industry, labor and the public were asked to provide insights as part of the overall work plan. Current record keeping, data management and data utilization were also addressed.Incident response encompassing notification by facilities to CCCHSD,subsequent notification of the public by CCCHSD and the adequacy of existing policy for these activities constituted a central focus of these inquiries.Assessment questions posed included: ► Is the current notification policy working? ► Does it go far enough? ► Is it appropriate? and/or ► Does it need refinement? 4 �I N -2 0 eO� MI) to 0 x co d a pcc a pmt` > d v a x to .to ad � O .-O 77 � N x -A . Z5 E cc m oY C w _ =N uir C Vccc r ccO 0 OO m ev P U C) x N C fEC � x C7 ►- co O C U g E m m a hL N L ` N .� U in O .� CL U E m w Cl) to U H Scc U Q a) M N Z £ (� N E cu to ~ °' ¢ a,Ei = 03 a> m o > iv c ~ m N c y CC o > cp x N CO is Qv v O O S o a PVi E U N N An W a> ~ J yC V 0. U d a S co N d N d n W JQOSS U U Incident Response in Contra Costa National Institute for Chemical Studies The reviewers, in discussing these issues with stakeholders, sought to provide recommendations based on a) stakeholder perspectives and opinion and b) professional observation accumulated over years of experience in emergency response planning. Reviewer credentials are provided below. This review effort relied heavily on the observations and perceptions provided by stakeholders. Results of these and similar efforts provide the reader with a cross-sectional snapshot of how stakeholders feel and what they believe at a given point in time. This process may not identify all technical,statutory or programmatic causes for the observations of reviewers. It may, in fact, identify perceived deficiencies which have already been addressed in other venues. However, in emergency response and preparedness, perceptions equal reality. That is, public, industry, labor and CCCHSD staff perceptions of the responsibilities, requirements and behaviors in emergency events are exactly what will determine behaviors during an actual event. Specific questions for the review process were based upon two central considerations: 1) . Is Contra Costa County utilizing existing authorities and resources for maximum safety policy effectiveness within the jurisdiction? and, 2) Are there modifications to existing authorities which would provide a measurable increase in public safety? Recommendations and suggestions on implementation are also based on the above approach. A team concept was utilized to increase time efficiency, variety of perspectives and the credibility of the process. A verbal presentation to the CCCBS will accompany delivery of this report. This Report addresses • The County's incident response and notification policies for consistency with existing federal,state and local laws.(Not an exhaustive legal review), The County's response to one recent major incident and a sampling of incident responses over the past six months, 0 An organizational review and interviews with staff, 5 Incident Response in Contra Costa National Institute for Chemical Studies • A basic review of record keeping, data management and data utilization for public policy and public needs, • s Incident response and notification by facilities, 0 Stakeholder queries concerning existing operations and functions. REVIEWERS team of three individuals was used to provide this review for Contra Costa County. The inherent value in this approach is that a variety of backgrounds, experiences and perspectives are offered so that the CCCBS and CCCHSD obtain the greatest depth and breadth of constructive thought. Credibility of both the process and communication of results are enhanced by this format. NICS key personnel include Dr. Paul L Hill, Principal Reviewer, Dr. Jan R. Taylor, y teat ; #n # t # als Project Director and Mr. Clark Miller, Senior Staff `las ®ddg AN: Associate. All have training and expertise in risk management planning, emergency preparedness 8 and government operations. f#� s p tsar tt +tint Yap is Because professional services hours were very ' Ces limited by contract conditions, CCCHSD support "! vo staff were assigned to the review team over the #' `•_• '' term of this review. Document location, duplication . and transmittal as well as appointments, scheduling and communication assistance were provided by county staff. The team began by reviewing documents submitted to NICS by County staff. Subsequently, a `questionnaire' was developed for use on site. Ms. Elinor Blake and Mr. Randy Sawyer assisted with compilation of key questions and input for the review. Dr. Hill began by meeting with the staff at CCCHSD as well as with the Director,Dr. William Walker and the Deputy Director for Environmental Health, Lewis Pascalli. After completion of the initial 6 Incident Response in Contra Costa National Institute for Chemical Studies investigative stage, which also included document analyses, materials were assessed for various aspects of authority, communication, response and management. Reviewers looked for patterns or common "themes"when assessing the issues raised during the interviews. Only those concerns which were raised by or agreed upon by a large number of stakeholders (at meetings)are addressed. Also,those issues that seemed to cut across stakeholder groups are more thoroughly discussed in terms of recommendations for potential implementation. 7 Incident Response in Contra Costa National Institute for Chemical Studies CHAPTER H e CONTRA COSTA COUNTY HAZMAT OPERATIONS erhaps the word which most often comes to mind regarding Contra Costa County's Hazardous Materials program is `unique'. Among similar jurisdictions across the United States,few have the authorities,centralized programs and history of governing decisions which have evolved into the county's activities of today. By centralizing hazardous materials programs within the Health Services Department,the area has a dedicated and well- trained staff to deal with an array of hazmat `t ? 3t33f issues. Many counties across the country, on � e mmt !' it� the other hand, have resources spread amongTQ Mat ty ous various fire districts, departments or LEPCS. ue n` ia>rerrafs tr Contra Costa's advantage is in allowing fire departments to serve in their original intended capacity (fighting fires, initial responders, etc.) while coordination, notification and communications activities are provided by CCCHSD. Additionally, centralized authority at CCCHSD provides the opportunity to address prevention,accident investigation and follow-up assessment of incidents for overall County (CCCHSD and CCCBS)decision-making and policy modifications. CCCHSD is organized into seven program areas in addition to standard administrative and public information offices (Fig.1-1). While twelve positions are assigned to the incident response(IR)team,additional assistance is obtained from the AB 2185 Program,Hazardous Waste Generation Program and Underground Storage Tank Program. This flexible arrangement is particularly valuable during major events or during personnel shortages (i.e. sick leave, vacation, etc.). The latter influences the ability to have designated"IR Teams" on call around the clock,seven days per week. Three employees are"on call"at all times and rotate on a standard schedule. 8 1A Incident Response in Contra Costa National Institute for Chemical Studies The California Risk Management and Prevention Program (RMPP) is authorized under the CAL/ARP. The RMPP provides added benefit to emergency response operations with planning,analytical and technical assistance.RMPP specialists review Risk Management and Prevention Plans (soon to be replaced by the federally-mandated RMP) submitted by industry. They also may serve as back-up for the IR team during events by reviewing accident scenarios,dispersion models or technical data previously collected for a particular facility. FJV[PP staff provide the additional service of verifying RMPP submissions with on-site visits which may last up to several months. These in-depth "audits" of physical facilities result in issuance of a letter of"Findings and/or Deficiencies"by the CCCHSD Director, The Director may request additional information from facilities which have 90 days to respond. Specific details are usually resolved prior to CCCHSD's final acceptance of the RMPP. Off-site consequence analysis, provided with the RMPP, is often used by CCCHSD for emergency response planning, adjacent land use decisions and hazard reduction. Risk reduction assessments are frequently initiated by facility-county discussions of the RMPP ' and off-site consequence analyses. Current activities of the CCCHSD include re-issuance of the "Notification Policy", on-line operation of the new Community Warning System and recent root cause investigations. CAL/ARP further specifies the authority to review the federal program developed by USEPA for Risk Management Planning(RMP). Full implementation of the federal program by May 1999 will supersede the California RMPP provisions.These initiatives present both opportunities and challenges to the existing operation. A discussion of these activities is provided in section V, Current Advances, of this report. 9 Incident Response in Contra Costa National Institute for Chemical Studies CHAPTER I// ISSUES OF CONCERN A. Community and Labor 0 n May 28, 1997 a meeting of community residents was held in Martinez to solicit comments on the proposed assessment documented by this report. After a brief presentation by the project review director, individual citizens as well as representatives from organized groups provided ideas, concerns and suggestions for improving incident response in Contra Costa County. Fliers about the meeting were distributed to several community and labor organizations by Ms. Blake of CCCHSD. A meeting notice was also published in the West County Times. Thirty-one individuals were present and nearly all provided some level of commentary included in the items below. In addition,phone interviews were conducted with individuals who could not be present at the meeting. Due to the large number of issues raised at the meeting, groups of "issue areas" are presented for 'COMMU WWIS, -_:b ........... purpose of discussion. Readers should not conclude that some concerns have been neglected, but rather that some issues simply fell outside the purview of this report. The entire list is provided so that county officials or future reviewers may address those additional concerns to the extent possible. Clearly, there is no lack of issues raised by community and labor interests. Common concerns raised by this group relative to other stakeholders is further discussed in Section VI of this report. First however, a discussion of community/labor issues is provided 10 Incident Response in Contra Costa National Institute for Chemical Studies IDEAS FOR IMPROVING INCIDENT RESPONSE MAY 28, 1997 COMMUNITY MEETING, MARTINEZ The following groups,businesses, agencies and affiliations were represented at the May 28, 1997 community meeting OCAW Local 1-5 OCAW health and safety reps from Locals 1-326 and 1-5 Plumbers and Pipefitters Local 342 Member of the County Board of Supervisors County Planning Commission County Hazardous Materials Commission County Public and Environmental Health Advisory Board Shell CAP ( Community Advisory Panel) Rhone-Poulenc CAP Tosco Refining (Avon)(non-represented managers) Gray Panthers Diablo Valley College student Sierra Club, West County Group local residents with no designated affiliation Three important issue areas emerged during this meeting: ► Information Access and Quality ► Policy, Authority and Communication ► CCCHSD Programs and Resources Issue Area: INFORMATION ACCESS AND QUALITY Comments: • Better Data • Centralized Data • Inter-agency coordination and reports to public • Centralize records nationally re: violations 11 Incident Response in Contra Costa National Institute for Chemical Studies These comments and concerns address the central issue of data access, credibility and quality. Community and labor representatives want to access not only current information but also the history of regulatory actions against a corporation which may hold permits in other jurisdictions. The one-stop shopping concept for information is desirable and has been raised in other states and localities both within agencies and with interested stakeholders. There is no doubt that such a system would be useful in Contra Costa County if accident data, root cause findings, permit information, governing ordinances and company compliance records could be included. However, such endeavors have proven costly and difficult to achieve given the current state of computer technology,inter-agency information, legal authorities and regulatory constraints. The related issue of interagency coordination and reporting supports the public's view of government as a single operating unit. Within government, agencies tend to respect the jurisdictional boundaries and responsibilities of"sister"agencies. This is a common theme from federal to local levels across the country and is poorly understood by the general public. The public wants comprehensive, informative answers to each issue raised. While all government agencies should recognize this perception and work toward a comprehensive response to public needs, outreach to assist the public with a better understanding of government operations is also required. Issue Area: POLICY,AUTHORITY AND COMMUNICATION Comments: • Overcome"Proprietary"information • Overcome"Liability"information • Give workers"Right to Act" 0 Land Use Policies • Certify Employees 0 Give CCHSD authority to review PSM(Process Safety Management)elements In this series of comments,public and labor interests expressed the desire to overcome some of the perceived roadblocks to comprehensive information. Obviously, these stakeholders have been frustrated by having certain proprietary or confidential business information(CBI) withheld. While this withheld information may not provide useful insights to the public interests in many situations, the mere fact that it is not available creates a suspicion,that companies are less than completely honest in their disclosures. Failure to comprehend why 12 Incident Response in Contra Costa National institute for Chemical Studies these provisions are in the law further exacerbates this suspicion. Discussion of the"liability"issue has also occurred,in that some members of the public and labor communities seem willing to set aside liability clauses in order to receive greater access to factual information (Root cause we assume). Legal authority and policy to overcome these perceived deficiencies in information are options available only to governing bodies such as CCCBS, the California Legislature and the United States Congress. Labor issues centered on the use of non-certified employees in the hazardous materials industries and frustration of labor at the inability of federal, state and local government to provide comprehensive information about corporations. Giving workers the "right to act" was also presented as an option for swift action by employees. "Right to Act" deserves a more in-depth discussion by all levels of government than can adequately be provided here. Labor interests must be involved directly in such discussions to more clearly define this issue. Land use policies and the provision for review of PSM elements by CCCHSD were also raised as potential ways to improve incident response information in the county. Community and labor organizations favor development of these authorities and the direct communication of PSM reviews to the interested public. Specific review of Land Use Policies was not addressed by the current assessment. Issue Area : CCCHSD PROGRAMS AND RESOURCES Comments: • Resources and skills for root cause analysis • Publicize root causes • Assure root cause findings are addressed (including funding for Health & Safety agencies and facility investments) • Need to talk to workers too, not just industry H&S directors Each of these comments deal directly with the pursuit of root cause information by the CCCHSD and affiliated agencies. Community and labor groups desire not only that such information be obtained,but also that it be well publicized for prevention purposes. Further, requirements and/or procedures to assure preventive measures should be funded both within industry (wherever the problem arose) and within the agencies which would further address the issue. Participants noted that facility workers often have first-hand information about 13 Incident Response in Con"Costa A&W National Institute for Chemical Studies 1111W-7=_ causes of accidents and therefore may assist in root cause investigations. The desire for root cause information was clearly evident within the public and labor communities throughout the discussions. During telephone discussions with environmental, community and labor representatives, some additional issues developed. Those issues not covered above are listed for the record even though they may fall outside the scope of the current review. 0 Clarification of authority -non-listed chemicals 9 County planning and protective action provisions 0 Greater opportunities for independent, third-party dialogue B. Industry At a county-wide meeting of industrial leaders on May 29, 1997,NICS asked representatives to provide frank commentary on the overall objectives of this project and to express their views on specific emergency prevention and preparedness issues_ Represented at the meeting were the Contra Costa County Industrial Association and the Contra Costa.County Council of Industries. Approximately forty representatives were present for the luncheon discussions held in Concord, CA. A regularly scheduled meeting of the CAER(Community Awareness and Emergency Response) Group provided another opportunity to receive industry feedback on issues on May 28, 1997. Industry in general expressed very positive feelings about their efforts to discuss common issues with the public. Frustration was expressed,however,over the perceived-failure of public advocates and some political leaders to meet them on "common ground," that is, the financial, legal and technical bases which drive the industry to act on issues are poorly recognized or understood by stakeholders. Stakeholder concerns are often voiced in terms of simplified social, moral or emotional responses to complex technical and societal needs. When asked about the county's governing accident prevention and emergency preparedness policies, industrial representatives felt the justification for such policies was often questionable. Representatives expressed the view that full opportunity to provide the industrial perspective on policy issues was often lacking. Regarding the specific policy on "Notification", the industry expressed concern over the potential misuse or abuse of the resulting notification data. Because low-level, low consequence hazmat events are reported under the policy, the potential for overstating the "problem" (number of accidents) is a constant concern. On the issue of compliance, facilities did not indicate that they would ignore the current requirements. Policies and statutes, once codified and implemented, are 14 u Incident Response in Contra Costa National Institute for Chemical Studies not ignored by industrial facilities for obvious enforcement and penalty reasons. As a matter of public policy,however, industry clearly has greater concern about how these policies are formulated than with compliance after the fact. Industry plays a vital role in the county in products it produces,jobs it provides and taxes it pays to support governmenthit operations. The fact that industry provides a high level of internal s emergency preparedness and response � o CAS lis �p� e as well as commitments to CAER is atlC6! r �lJ'81lIlA positive farce in dealing with and ` �� preventing accidents. Industry is also recognized for its sponsorship of schools, special community projects and civic events. Following is a list of industry concerns and a discussion of grouped observations. Again, three general categories of concerns surfaced: Relationships Dispute Resolution and Policy/Technical Decision-Making. Relationships The term "relationships" in this sense refers to those between industry and the county, industry and the public, and various county agencies and offices. Industry generally feels very positive about their working relationship with CCCHSD. The view was expressed that technical knowledge and background required for their joint activities are conducive to establishing a factual basis for most discussions. Abuilt-in $ tension of potential enforcement action by CCCHSD encourages a productive ` atmosphere for the working relationship. Industry leaders are frustrated by the public's lack of understanding about industry and how and why technical discussions form the basis of industry's relationships with CCCHSD. Industry also perceives discord or lack of coordination in the responses and 15 Incident Response in Contra Costa National Institute for Chemical Studies relationships among various agencies. Better definition in this area may improve the perceptions of all stakeholders. Points recorded at the meetings include: • Relationships between agencies • Various agendas not coordinated between agencies • Lack of compatability in CCCHSD and industry technical agendas • Need for interagency task force to make designated "lead"decisions • What can be done to improve public relationship? These points express a very real desire by industry leaders to have a better working relationship with various stakeholders -- especially the public. Also, industry comments point to confusion or lack of understanding regarding the overall responsibilities of various county agencies. Dispute Resolution A second area of discussion centered on the need for neutral mediation of disputes and discussions, and a forum3�Ct3 ! fS # 5 '.SSII�sS a on emergency response issues in the county. Many representatives openly welcomed this current assessment as a *� demonstration of the County's support for third-party mediation and relationship building. However, some participants suggested that little progress is being made on important emergency prevention and response issues given the charged nature of most public meetings. Communication and interaction with the public and elected officials in a more neutral,progress-oriented process is desirable. X7 These concerns and desires are grouped below: • Public trust of reporting data • Public perception: Every accident=failure of system • Encourage media training for all CCCHSD personnel • Need independent facilitator or third party to mediate county forums. • Too many non-event incidents reported to public= confusion of real risk. 16 Incident Response in Contra Costa National Institute for Chemical Studies • Outside independent investigations helpful. • Stakeholder expectations=need for public forum. Many comments focused on the need for better communication channels to resolve disputes, better communication to avoid unwarranted expectations, and potential third-party mechanisms to direct such efforts on a continuous basis. One industry representative remarked,"We have meetings,we develop great programs and ideas—and then, we come back a month later and talk about the same things." In essence, the desire for a working group to provide"follow through"was expressed. By their own admission, industry is not doing as good a job in this area as they would Re. Joint sponsorship of an effort to achieve greater stakeholder communications was expressed. Lastly, the desire for third-party action was directed at the federal Chemical Safety and Hazard Investigation Board (CSHIB) created by Congress but as yet unfunded. Many representatives openly expressed support for the Board's independent investigative capacity (also endorsed by CCCBS). Policy/technical decision-making Related to the "relationship"issues described above were several comments directed at the interaction of CCCBS officials with industry on policy decisions. Technology and political policy are BJ d i"OUG often difficult to mesh. However, many in industry feel the work t Y.:O* of CCCHSD may be underutilized when policies are set by the Board. CCCHSD is a good technical resource that few county governments enjoy. Industrial representatives felt it should be relied upon more heavily than in the past. Policy issues are often on decided on factors that go well beyond an absolute technical basis. al But, lack of technical inquiry has led to an industry feeling of being shut out of governmental decision-making. The ability to understand the basis of these suggestions deserves more attention by CCCBS. fci 17 Incident Response in Contra Costa National Institute for Chemical Studies Concerns expressed included: • CCCHSD has good information and expertise,but is not always consulted by CCCBS when making policy • CCCBS not industry friendly—many policies forced on industry • County not facing facts about economics and technical realities The realities of what industry provides in terms of consumer goods, jobs and safe technologies are not always included in the policy-making process according to industry leaders. Many ordinances are viewed as an attempt to"reverse engineer"previous decisions about development near hazardous facilities. A more global approach to county planning may indeed avoid placing an undue burden on any one stakeholder. C. CCCHSD Staff The Hazardous Materials Incident Response Team for Contra Costa County he assessment of capabilities included gathering information about staff positions as well as conducting interviews with staff. CCCHSD staff,primarily the IR team,were questioned regarding their work place environment, guidance, job satisfaction, equipment, resources and duties. Today,the Hazardous Materials Section of the County Health Department has twenty-three technical staff charged with managing the following programs: Hazardous waste generator, hazardous materials business plan, underground storage tank, risk management and prevention, site mitigation, household hazardous.waste, and hazardous material incident response.(See the operations diagram, Fig. 1-1) Twelve of the twenty-three technical staff are members of the hazardous material incident response (IR) team. Those twelve are divided into groups of three that rotate to provide response coverage 24 hours a day, every day of the year. 18 to Incident Response in Contra Costa National Institute for Chemical Studies Responsibilities Contra Costa's hazardous material area plan designates the Health Department's IR team as the group responsible for protecting human and environmental health during hazardous materials incidents. The IR team's duties include: • community air monitoring and sampling • chemical identification • primary entry and mitigation of incident • oversight of clean-up and waste removal • community notification • enforcement follow-up All twelve members of the team are fully trained and experienced in level A entry and release mitigation. Community notification responsibilities include determination of appropriate safety measures to be taken by the public. As with the inspection programs, incident response duties include enforcement follow-up when necessary. Team members are skilled in sample collection and case preparation for referral to the District Attorney's office. Qualifications As specified by Contra Costa County's employment requirements, all technical staff in the Hazardous Materials Section must have a minimum of a Bachelor's degree in the sciences. Employees possess degrees in geology, hydrogeology, environmental science, chemical engineering, physics/biophysics, microbiology, chemistry and environmental health. Five members have master's degrees and two others are California Professional Registered Engineers. Members of the IR team currently average seven years of experience in hazardous materials incident response. According to agency records, the IR team averages over 1,000 calls per year. Of these, about 500 are notifications, 250 are incidents that e irequire immediate response and thl` Ltd remaining calls are complaints that ` 82 ' fl#tS � eS receive responses deemed appropriate liSji 't�Q st by a member of the technical staff 19 D, g Incident Response in Contra Costa National Institute for Chemical Studies Training Members of the IR team receive many hours in specialized annual training. The following is a sample of on-going training that is offered at regular intervals: level A chlorine response * radiological incident response * rail car incident response * chemical compatibility * biohazard training * environmental crimes investigation * risk analysis and decision-making * clandestine drug lab response and mitigation * air sampling and analysis * assessment and mitigation at hazardous waste sites air surveillance instrumentation for hazardous materials * hazard categorization for hazardous materials * sampling strategies and techniques for contaminated soils * code 3 driving * ammonia release incident response * environmental geology * drills with industry and agencies for LPG, hydrofluoric acid, oleum, Vicane and other acutely hazardous materials. Two IR team members are California Specialized Training Institute certified trainers for hazardous materials specialists. These individuals are qualified to instruct further in-house training courses to staff members. 20 Incident Response in Contra Costa National Institute for Chemical Studies The remaining discussions are based solely on direct interviews with staff by the reviewers as well as observations of records and equipment and the like within the CCCHSD offices. Mission The general mission of CCCHSD is well understood by most employees—protection of public health and the environment. While some degree of ambiguity exists regarding the full scope of the county's mission in this regard, the majority of staff members were aware of and comfortable with the mission of the Department. In general, the staff understands the public expectations of CCCHSD. Procedures Most staff readily recognized that many procedures were well established but perhaps not routinely articulated. However, they were quick to add that a degree of flexibility and professional judgement would always be necessary in hazardous materials incident procedures. A major resource manual,the Hazmat Response Resource Guide, exists and is routinely used for procedural guidance during response events. Staff members indicated that training to increase staff confidence in professional judgement might be more heavily emphasized more to enhance the effectiveness of procedural guidance. Resources Staffing: Staffing levels are by their nature constrained by financial, legal and managerial parameters. Based on staff member interviews only, IR staffing levels are perceived as barely sufficient. The view was expressed that if further responsibilities are added,current staffing levels could quickly become inadequate. Staff expressed concern that numbers may be insufficient for a major catastrophe or for any additional responsibilities, however laudable the initiative. Scheduling improvements to allow IR staff to be on-call only part- time was considered to be an improvement. Because the reviewers were not provided financial or managerial information regarding staffing,no further conclusions regarding staff adequacy could be reached. Equipment: Staff members thought that the current equipment owned and utilized by the CCCHSD was above average. They indicated that current equipment needed to be inventoried periodically and that equipment needs should be assessed on a regular basis. A 21 Incident Response in Contra Costa National Institute for Chemical Studies new staff member has been assigned.this responsibility with resounding support of remaining staff. A list of desirable equipment additions has been developed. Labs: Staffers indicated that laboratories and contract laboratory services were good. To the individuals interviewed for this report, laboratory quality and availability was not an issue. Computers: In general, staff members felt that existing computer capability was inadequate. They indicated that staff could utilize laptop computers in the field with the addition of analytical and resource software. A particular software need mentioned by staff was for technical/chemical information CDs to assist in analysis of public protection and emergency response during hazardous materials incidents. With modifications, the centralized IR database was viewed as a valuable, yet probably underutilized resource. Communications equipment: According to interviewed staff members, communications equipment has been improved recently and is considered good. However, several mentioned that they could use some training in the use and maintenance of that equipment. There was also concern that the communications system could not be activated remotely, i.e. that the "mobile"communications unit was not really mobile. In the event of a serious accident, an on-call IR team member must still report to the office to activate the community warning system. (Reviewers note we understand this issue is currently being addressed by the new CWS Training Manual and Protocols. IR team calls to 911 can activate the system from remote locations). Some members of the staff also mentioned their approval of having cell phones available to them. Although the traditional communication method of the emergency response community is by radio, CCCHSD staff are more comfortable with cellular telephones. Data and Planning The staff consensus was that the current system for data management could use improvements. In general, IR team members do not use the database and others have used it only occasionally. Several staffers noted that the data elements were not complete nor particularly useful for their work. There was concern that staff lacked understanding of the data management system, and that with more comprehensive information, individuals from outside the Department might misuse the data. 22 Incident Response in Contra Costa National Institute for Chemical Studies External Relations Staff evaluation of external relations was decidedly mixed. Opinions ranged from "Industry relations are generally good"to"CCCHSD must stand its ground with industry". For some staff members, there was recognition that the Department may be perceived by the public as too close to industry.Department personnel indicated that the agency/industry relationship was actually a"comfortable"working relationship based on mutual respect. Other points raised about external relations were; ► Depends on area (Relations could be better with the city of Richmond.) ► Some animosity between agencies ► Mostly positive- Public lacks respect for duties, constraint on agencies ► Public can be hostile, misled by "activists" ► Public doesn't understand technology and basis of CCCHSD work. Miscellaneous Issues In addition to the above categories, staff were asked if there were additional concerns or issues they wished to mention. The following comments mention various internal and external points. Interestingly,the interagency relations concern was again raised. ► Decision-making within operation ► Relations with other agencies-joint communications, training ► 24-hour"presence" of staff- no one wants to do- but several recognized need ► Need to"toot our horn" more/better, positive reinforcement 23 Do Incident Response in Contra Costa National Institute for Chemical Studies IV. RECENT INCIDENTS As one of the desired activities of this review,NICS was asked to assess at least one incident notification for overall performance. In addressing one of the CCCBS' concerns over performance under the notification policy, the team also looked for standard information reporting, record keeping, timeliness, closure, debriefing, final documentation and recommendation(s). Recently the CCCHSD has begun to add root cause analysis to more thoroughly complete the investigative phase and, therefore, provide public information regarding cause and potential prevention. The review team was given access to a large number of files at the CCCHSD offices on Pecheco Boulevard in Martinez. During discussions with staff, "good" examples of notification and response were requested. We asked which from the large number of files stands out as a"textbook"example of incident notification,response and follow-up. Several cases were mentioned depending on the staff members who responded to a particular incident. No clear case emerged however. After a cursory review, the Tosco Avon Refinery Hydrocracker Explosion and Fire dated January 21, 1997 was selected. This file contains the most comprehensive documentation and was secured within the previous six months. This file was comprehensive based criteria developed by the reviewers. Time line: present and detailed Follow up: Investigative activities and 72- hour report on file Contact Persons: Agency and facility personnel identified Notification:Documented to CCCHSD and CAOES(California Office of Emergency -Services) Response: Actions documented Field Data: Collection of information documented Goals: Well-defined goals established for the investigation final Report: May 29, 1997 report including Root Cause analysis Most noteworthy, this file documents the immediate action by CCCHSD director, Dr. William Walker to ensure coordinated response to the situation created by the incident. Further, the widely-covered press conference held by Dr. Walker demonstrated a high level of responsiveness toward using current information for improvements in the overall system. In this situation, the need for immediate access to incident site by CCCHSD and Incident Response in Contra Costa National Institute for Chemical Studies implementation of the notification policy were highlighted. The reviewers understand that these issues continue to be discussed by County and industry representatives. MICS' assessment of CCCHSD's performance, as indicated by the file in this case, is positive. Good techniques are being applied and improved as information becomes available. In Chapter V11 of this report, an opportunity to further review this particular case is presented for consideration. This file stands out for two reasons: 1)root cause investigation,which demonstrates a major improvement in previous incident records, and 2) follow-up modifications, clarifications or advances which are being pursued by the CCCHSD. These actions indicate a deep dedication to the mission of the agency and lend themselves to further analytical and policy assessments in the future. 25 Incident Response in Contra Costa National Institute for Chemical Studies CHAPTER V CURRENT ADVANCES ontra Costa County has shown a high degree of diligence throughout its history by taking positive steps toward improved service to residents. This report is an effort in that regard. Additional, ongoing advances are _ now emerging to fill some significant voids identified early h9ps :i in this assessment. For example, the recent update of they 1991 Incident Notification Policy more clearly articulates 00,> l � � the county's expectations relative to industry's reporting to l> nCE CCCHSD. What was immediately lacking when the policy JS was first issued was the other half of the equation with questions such as: What procedures would the county S`e3S t# ITaT undertake?How would the public be notified?What orderly behaviors should the public undertake? And, what was the $ rr overall operations plan for complete notification to the public? Many of these questions were addressed by issuance of the Community Warning System Operations Protocol in April, 1997. Other significant initiatives include enhanced utilization of the incident response database and a related effort to conduct root cause analysis. Each of these advances and their subsequent impact on the county's operation are discussed below. Hazardous Material Incident Notification Policy (The following discussion is based on the most recent issuance,) January 1997 The stated purpose of this policy is to establish criteria for prompt and accurate notification of the Contra Costa County Health Services Department (CCCHSD) when the release or threatened release of hazardous materials may cause injury or damage to the community or the environment. Prompt notification of the CCCHSD is essential for: 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 Notification Network should be activated;and 4)responding to inquiries from the public and the press. 26 Incident Response in Contra Costa National Institute for Chemical Studies Under the criteria of the Community Notification policy,the following conditions constitute the need for immediate Notification of a Hazardous Materials Release or Threatened Hazardous Materials Release by the responsible business: 1 Immediate notification is required for any release or threatened release of a hazardous material that poses a present or potential hazard to human health and safety,property or the environment.Such notification is required if any one of the following occurs. a. The release or threatened release of a volatile hazardous material that results in a substantial probability of harm to nearby workers or the general public, due to the toxic characteristics 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. Any release or threatened release of a volatile Acutely Hazardous Material (other than a small drip or instantaneous vapor release, often called a puff) such as a release or threatened release that is the result of equipment failure, operator error, or external events; 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 a fire, explosion, smoke, or excessive flaring; e. The release or threatened release has a substantial probability to contaminate surface water, groundwater or soil, either on-site (unless the spill is entirely contained and the clean-up is completed immediately) or off-site; f. The release or threatened release has a substantial probability of causing off-site environmental damage; g. The release or threatened release occurs during transport or storage of such material,via vehicle, rail, onsite pipeline, marine vessel, or aircraft; or h. The Safety Supervisor 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. 27 Incident Response in Contra Costa National Institute for Chemical Studies 2. Immediate verbal notification shall be made to Health Services Department emergency response teams who are on-call 24 hours a day. The Health Services Department emergency response teams can be reached through emergency numbers during working hours and at Sheriff's Dispatch during off-hours. 3. Initial verbal notification of a release or threatened release should include the items specified on Facility Incident Checklists provided by CCCHSD. 4. This policy does not relieve the responsible party from compliance with any legal request to notify other local, state or federal agencies. 5. A release of a hazardous materials that clearly does not meet any of the criteria described in paragraphs IV(A)(1)(a)through 1(b) does not need to be reported under this policy. Examples of such releases are described below. However, businesses handling hazardous materials that are located in close proximity to .i residential and commercial districts should especially note if spill occurred on facility property and is more than 500 feet from the nearest public road or fence line;whichever is closer. Follow-up Reporting of a Hazardous Materials Release is required under certain conditions: Upon request of the Health Services Department, a written follow-up notification of the incident should be made to Department within 72 hours by the entity responsible for the release either confirming,modifying or updating the information provided in the initial notification under(A)(3). A written final report of the incident shall be made to the Health Services Department as soon as practicable following'a release,but no later than 30 days from the date of the release if the Health Services Department requests such a report. If the release requires a written emergency release follow-up report, pursuant to section 2705(b) of Title 19 of the California Code of Regulations to the Chemical Emergency Planning and Response Commission, a copy of such report shall be sent to the Health Services Department. While this policy clearly articulates anticipated actions on the part of industry to make notification,only the final portion dealing with reports specifies any actions to be taken by CCCHSD. This provides a clear directive to industry. However, questions remained (until 28 J_+ Incident Response in Contra Costa National Institute for Chemical Studies publication of the Community Warning System Protocol) about the overall implementation and response to the notification. A great deal of progress is currently underway in operations, training and communications regarding the Community Warning System, CWS. The following discussion of the CWS more closely links the two components into a comprehensive program. The Community Warning System (April, 1997) he Community Warning System of Contra Costa County provides a new, holistic approach to alerting county residents to emergencies.A combination of sirens,media links and telephone ring-down is collectively designed to warn and inform communities. While some components of this system were operational in the past, new computer-assisted alerting mechanisms are now linked in a more comprehensive system. This system represents a major advancement for the county and ranks it among the most advanced regional alert systems in the nation. The Community Notification Network began in 1991 as a four-part plan for notifying the public of an accidental release of a hazardous material. The first part of the plan was to establish a working relationship with a local radio station to get emergency information to the community. The first radio station approached by the Health Services Department was KKIS located in Contra Costa County. After this initial radio station was convinced of the worthiness of emergency broadcasting, an agreement was also worked out with KCBS,a San Francisco Bay area-wide station,to broadcast emergency information.KCBS has continued as one of the partners in the Community Warning System. The second part of the plan was to have an automated telephone dialing system for notifying the public. This system makes telephone calls to the residents most likely to be affected by an accidental release of hazardous material. The Health Services Department entered into a contract with the Community Alert Network (C.A.N.) to provide this service. C.A.N. continues to be an integral part of the Community Warning System. The third part of the plan was to install Traveler Information Stations (TIS) in the local communities. TIS are low wattage radio stations operated by municipalities to provide pertinent information to the local community and travelers.The cities of Martinez,Pittsburgh and Richmond have installed TIS in their communities. 29 IJ, Incident Response in Contra Costa National Institute for Chemical Studies The fourth part of the plan was to install sirens around the facilities that posed the greatest potential risk to communities. After an accidental release of oleum from a Richmond facility in 1993, The Contra Costa County Community Awareness Emergency Response Group (CHER), in conjunction with the Health Services Department, formed the Community Notification Committee.This committee consisted of representatives from industry,agencies and communities from industrialized areas of Contra Costa County. In December 1993,this committee developed a plan of action which has developed into the Community Warning System. The Contra Costa County Board of Supervisors endorsed this plan of action, and in January 1994,appointed the Community Notification Advisory Board(CNAB)to work with CAER in implementing the Community Warning System. The Community Warning System project began in January 1994 with the development of a formula to fund the project. Oil refineries, chemical plants, water treatment plants, waste water treatment plants and other facilities that use either flammable materials or acutely hazardous materials participated in the funding and design of the project. The Community Warning System is currently in the start-up phase. Responders are receiving training and the linkages of the system are being tested as this report is written. The Community Warning System is designed to alert and notify the community when'there is an accidental release of a hazardous material that could effect the community. The system may also be used in fire, law enforcement,natural disaster, and public health incidents. The alerting portion of the system consists of sirens and is designed to alert people who are outdoors in communities closest to hazardous facilities. The notification portion of the system consists of the following: - Computer terminals with the capability of activating the Community Warning System are located at the facilities which have sirens, the Health Services Department, Contra Costa County Office of Emergency Services, Contra Costa County Fire District,Richmond Fire Department,and 9-1-1 dispatchers in Richmond, Pinole,Martinez,Antioch and Sheriffs Communications. - Emergency Alert Receivers (which are radio receivers that are turned on automatically by the system) at the sensitive receptors (sensitive population centers,such as schools,convalescent homes,day care centers, hospitals) that are located within one mile of facilities that handle acutely hazardous materials or flammables Ability to get emergency information to the media, including television stations, radio stations, and cable television head ends, and An automated telephone dialing system. 30 Incident Response in Contra Costa National Institute for Chemical Studies The Community Warning System has been designed with programmed scenarios for the accidental releases of hazardous materials. These scenarios cover four categories of releases: Toxic Gas Releases;Flammable Non-Toxic Hazardous Releases; Various Fires/Explosions; and Various Spills/Plant Upsets. The required level of emergency response and notification for each scenario category has been developed. These programmed scenarios,along with the categories of releases and levels of emergency responses and notifications,are designed such that the facility will be able to activate the system as quickly as possible. Using the programmed scenarios, the facility will activate the system for Levels 0-2 and all of Level 3,with the exception of audio messages and crawls for the television stations. Activation of the audio messages and crawls will be done by the Sheriffs 9-1-1 dispatch center or Contra Costa County Fire Protection; District. If a major incident that could affect the community occurs at a facility with a system computer terminal,that facility activates the system through choosing the appropriate programmed computer scenario. The emergency responders will be notified, the sirens will be sounded and the Emergency Alert Receivers will be activated. The automated telephone dialing system will also be activated by the facility,while radio, television and cable stations are notified by the 9-1-1 dispatchers. Initially the system is programmed for facilities that pose the greatest potential risk to the communities and that have system computer terminals. In the future, the use of the system will be expanded to include all facilities that have the potential to impact the community from the accidental release of a hazardous material. Eventually, transportation accidents, fire incidents, law enforcement incidents,natural disasters and public health incidents are to be included in the programmed scenarios according to information received from CCCHSD. As of this report, the Community Warning System is just becoming operational. Several testing and training events are ongoing with the CCCHSD staff and industry partners. The Training Manual itself fills a void which was initially identified by the review team. While the existing Hazardous Material Notification Policy issued by CCCHSD in January 1991 specifies the responsibilities of industry to report incidents, it was lacking in defining the action(s)which would be initiated by the agency. Therefore,the public(and reviewers)were unclear regarding the overall expected actions during an event until publication of the Training Manual and Operation Protocols for the Community Warning System. Although this excellent manual was written for purposes of training CCCHSD employee operators, it should provide great insights to all stakeholders(especially the public)regarding the function and expectations of the system. Therefore, both the Community Warning System and the issuance of the Training Manual are positive steps forward for Contra Costa County. 31 Incident Response in Contra Costa National Institute for Chemical studies A Root Cause Analysis n early 1997, CCCHSD made progress in advancing the concept and implementation of "root cause"analyses of incidents. "Root Cause"refers to well-documented engineering investigations and assessments of the underlying, or root, causes) of a particular upset or release event.While this practice has been developed,modified and documented for many years (see Center for Chemical Process Safety,CCPS),its use by both industry and regulatory agencies has been infrequent. Since incidents that affect the environment . y : outside facilities often spark litigation, 18f�4f CF# 'S facilities have had a disincentive to collect mn' W � S#i t�' data on such events. When root cause .. . investigations are conducted by industry, they frequently employ legal counsel and therefore fall under attorney-client privilege. While industry has expressed a desire to make such determinations to better the engineering practices as a whole, fear of litigation has prevented wide-spread dissemination of results. All too frequently,results may not even be distributed within sister facilities of a single company. Regulatory agencies have only recently expressed interest in root cause analysis. With the advent of the Clean Air Act Amendments (CAAA) of 1990, root cause determinations became an expressed intent of the U.S. Congress. Within this Act, Congress created the Chemical Safety and Hazard Investigation Board (CSHIB) patterned after the C +1#; #II�{S1S National ;Transportation Safety >�� t+tlrilrt l er ,roil#ca�ts� Board(JTSB),but focused on fixed- : .. facility incidents. This statutory ` I ;�i�s� e sped language received broad bi-partisan <tlgnl M831r�S5 " support and included incentives and benefits to' a broad group of stakeholders. In basic terms, industry would be relieved of liability suits from the investigations, while communities, laborers and local governments would learn the basic causes of incidents. Collectively, the stakeholders could then make recommendations for technological or policy modifications which address accident prevention. Unfortunately,the CSH M has been unable to provide root cause information to local communities.due to a lack of funding by Congress. 32 Incident Response in Contra Costa National Institute for Chemical Studies In December 1994, President Bill Clinton announced via the Office of Management and Budget that the CSH1B would not be funded in the fiscal year 1995 budget.As an alternative, federal personnel at the Department of Labor, Occupational Safety and Health Administration(OSHA) and Environmental Protection Agency(EPA)would carry out the Board's workload and function.Now,some two and a half years later,members of Congress are becoming increasingly aware of the problems created b the . $ 0 P light administration's action. In li t of this ` tl. G 1 Y @ #� situation, existing regulatory agencies lit5I33t�'� j ,s t Pspat the federal, state and local level have ' looked into ways of moving forward on root-cause investigations. Uncertainty regarding the procedural, legal, jurisdictional and potential enforcement aspects of the joint EPA/OSHA program has led to localized efforts. Contra Costa County is no exception in this regard. In fact, CCCHSD has taken positive steps to improve its abilities to determine,report and address causes of industrial accidents. On May 27, 1997, CCCHSD issued its first root cause report to the public. The report was based on investigations of the January 21, 1997 incident at Tosco's Martinez Refinery. A positive step toward documenting and reporting root-cause information has been initiated. On the other hand, industry remains skeptical of agencies whose traditional role has been to take regulatory and ltlfbri fk? enforcement actions. Basic incentives61 which were placed in the CAAA at the : �, , federal level are currently not available to EPA, OSHA, State, and Local agencies such as CCCHSD. Industry is reluctant to fully cooperate with these agencies due to their "enforcement agenda". Therefore, government entities must resort to subpoena powers, enforcement actions defined in regulations, or federal powers of the National Contingency Plan(NCP)to declare an"eminent threat"to gain entry at.accident sites. Such methods,while they may indeed grant the desired entrance and subsequent investigation,are not conducive to participatory root cause investigation and determination. 33 Incident Response in Contra Costa National Institute for Chemical Studies Putting aside existing duties and responsibilities, CCCHSD has the technical personnel and capability,with perhaps some additional training,to conduct root cause investigation. Three key issues remain,however. First of all,based on the reviewers' knowledge and expertise in this area, such analysis may take weeks to complete. Second, the CCCBS must consider the policy for obtaining full industry participation without threats of liability and/or enforcement action. A recent Government Accounting Office (GAO) report submitted to the President stated that such a system may work IF industry fully cooperates. Unfortunately, without a revised policy, there is no incentive or reason to expect this to occur. Thirdly, 'whether Contra Costa County government can afford the level of technical manpower to support such policies for all accidents must be considered. Federal legislation provides specific criteria for types of accidents to be investigated. This number could be quite large. Current staffing was assessed as marginally adequate for existing responsibilities discussed in section 3.0 of this report. This additional work, if seriously pursued, would require careful review as part of implementing the county's policy or intentions. Otherwise, existing responsibilities and services could be expected to suffer as a result. Incident Response Database AIthough CCCHSD initiated and has maintained a database of chemical incident responses within the county for some time, its usefulness is somewhat limited. However, the fact that CCCHSD has such a system for tracking and analysis of incident information is a noteworthy accomplishment. Few federal or state agencies have such a resource to assist in their overall operations, decisions, documentation and policy recommendations. To date,no other example of a county-based incident response database has been identified by the authors of this report. A current discussion within CCCHSD is focused on improving the"fields"or"data elements"of the system in order to make it more useful.Recommendations regarding the IR database are contained in the"Considerations for the Future" section of this report. 34 Incident Response in Contra Costa National Institute for Chemical Studies The Contra Costa County Hazardous Materials Interagency Task Force Although begun in 1992, the Contra Costa County Hazardous Materials Interagency Task Force is considered a recent advancement in hazmat activities within the County. It was formed to enhance local,regional,state and federal agency efforts to oversee major industrial activities. In order to achieve enhanced coordination and cooperation, it is necessary to understand the role that each agency plays in the realm of hazardous materials regulation and response. Subsequently, efforts to identify gaps and overlaps in the overall regulatory system may be identified and appropriately addressed. For this purpose, the Inter-Agency Matrix has been developed by representatives from each agency, The matrix deals with both prevention and response roles in two segregated sections. An example of the matrix is appended to this report. A narrative document describing the roles, authorities, contacts and other information for each agency is available to support the matrix. Efforts are underway to expand this document and make the matrix more complete by adding agencies which are currently not participants and to reflect changes in legislation and regulations. An ongoing effort to improve inter-agency exchange includes recent issuance of a questionnaire to various non- participants. The Hazardous Materials Interagency Task Force has made recommendations and reports to various federal, state and local agencies. Its members continue to meet monthly to work on these issues. 35 Incident Response in Contra Costa National Institute for Chemical Studies CHAPTER V1 REVIEW & DISCUSSION OF PREVAILING ISSUES ontra Costa County has one of the most unique and advanced systems of hazardous materials response and notification in the United States. It has a dedicated staff to run current operations, and equipment, training opportunities and administrative leadership that are lacking in other jurisdictions. Advances in systems, protocols and data gathering dn.fth``c Pow,t h�S demonstrate that CCCHSD is /' " ambitiously moving forward on several M. 7'$SpQ+ 3�' A sr fronts. In the experience of NICS �, $ 17tl reviewers, Contra Costa County is providing an advanced level of service to its citizens not observed in.many other areas of the country. Throughout the data gathering stages of this project, stakeholders commented on a variety of issues which support this conclusion. It is also supported by the documentation and inventories at CCCHSD which are readily available for further review. It is human nature for all stakeholders to comment on areas that could be improved rather than positive aspects. CCCHSD staff noted that they don't often take credit for the things which are working well. Focusing on negative comments should in no way take away from the significant positive aspects of the Contra Costa County program. This discussion addresses issues which surfaced most often during stakeholder interviews. Interestingly, several themes were common throughout the entire interview process with all constituent groups. Inter-Agency Relations Foremost among these shared concerns was a lack of clear-cut coordination and jurisdiction among agencies. Industry, community groups, labor and CCCHSD agency staff all recognized this as a problem at some level. Confusion over the degree of overlap between agencies and frustration that well-defined protocols addressing all response organizations were lacking were also expressed. While it was recognized that many of these were defined by statute or local ordinance,stakeholders have not been provided comprehensive protocols that distinguish agency roles before,during, and after hazardous materials events. 36 t4 Incident Response in Contra Costa National Institute for Chemical Studies This is not a new issue for Contra Costa County. As discussed in the previous section, the Inter-Agency Task Force was formed in 1993 to provide greater coordination. Most constituents are unaware of the outcomes of this group's efforts. Several stakeholders were aware that the Task Force existed and held meetings but were unaware that the group issued the role-defining information(the matrix)which met their needs. Desire for clear interactive and comprehensive (county-wide) protocols were expressed as well as the need for designation of"lead"agencies for categories of events. Further outreach efforts to all stakeholder groups is suggested to the Task Force. Although the reviewers were aware that some of this work has been completed and published in the past, many constituents were unaware of its existence. Also, written agency designations do not ensure that such protocols are followed during hazmat events. A mechanism to assess coordination and adherence to protocols should be considered. Public Perceptions All stakeholder groups addressed the conflicts between policy, technical fact and public perceptions during interviews. Industry strongly believed the CCCHSD was serving a valuable technical function which was often misperceived or ignored by the public and CCCBS. In policy deliberations, participants suggested that factual technical information from CCCHSD staff often "took a back seat" to political, social, economic or other considerations of County officials. Also identified was a"loss of continuity"on some issues, as these were addressed over long periods of time and with varying attendance at policy- making meetings. On the other hand, public and labor representatives viewed the technically oriented relationship between industry and CCCHSD as one of collusion . "Cozy" and "too close" were terms often used. This, in many ways,reflects a composite of public observations and a lack of understanding of the reasons,technical value and legal requirements for continuous industry/agency relationships. Public perception of the role of agencies includes a strong enforcement regimen and less emphasis on "good will" on behalf of industry to comply. Agency staff on the other hand, often observe greater leaps in compliance by using a combination of the two methods. 37 Incident Response in Contra Costa National Institute for Chemical Studies Policy and Procedures Much of the"perceptions"issue in Contra Costa County is based on a lack of awareness of policy and procedure. Numerous instances of perceived problems can be traced to the lack of, or more frequently lack of knowledge of, standardized procedures -- particularly those dealing with multiple agencies. (See previous discussion). CCCHSD staff �C 016 `� iB1'C l`o#tS" '3t1< >#ff generally recognized that in hazmat � i rSl�B ri #S IS oft 8 .: res onse, a degree of professional P b� judgement and flexibility must always ' ' be available and that a strong training program is useful in providing judgement capability. Further, the ability to refer public inquiries to specific procedures -- or a public education campaign to increase awareness -were viewed as beneficial. Again,the Community Warning System protocols are a positive step in this direction.Public informational events and the inclusion of other agency protocol in the Training and Policy manuals could advance the overall effort within the County. Database The County has a great resource in its IR database, but it is currently underutilized. Except for the draft report entitled"Preliminary Report on Hazardous Materials Incidents and Other Notifications in Contra Costa County, 1989-1996"by Loyd et. al., few analytical examples of database use exist. The Loyd report, although inconclusive, attempted to determine patterns of incidents for technical as well as policy assessments. With the addition of relatively few data elements, this and future analytical inquiries could be more insightful. Other than RMPP staff, few CCCHSD employees are aware of practical uses for the database in their daily work. IR staff members are not currently trained in use of the database and could be encouraged to make application toward their routine activities. Public interest in the database was also expressed. Access, comprehensive information and "tracking"mechanisms were considered desirable. Although analysis and enhancement of database elements would be a separate undertaking,some recommendations along these lines are offered in the next section of this report. 38 Incident Response in Contra Costa National Institute for Chemical Studies Enhanced Authority Several comments by community and labor groups, and,to a degree,by the CCCHSD staff, fall generally into the heading of enhanced regulatory authority. The desire for improved access to confidential business information and the ability of CCCHSD to review and enforce other technical elements are examples of suggested enhancements. Further, use of stronger oversight options and clarification of state and local laws may not only better delineate authorities but also play an important role in moving forward issues relating to public expectations and perceptions. (See previous discussion on perceptions). Industry,too, expressed frustration over issues of questionable authority and lack of clarity in regard to some programs, such as root cause investigations under the Clean Air Act. The concerns over immediate access and notifications deserve further discussion by county stakeholders. Ultimately these may require authority clarifications or modifications to resolve disparity. 39 Incident Response in Contra Costa National Institute for Chemical Studies CHAPTER Vll KEY RESEARCH QUESTIONS & CONSIDERATIONS for the FUTURE Key Research Questions The reviewers began this endeavor by developing several key research questions to be addressed by the review. This work was done in conjunction with County staff and included a review of the CCCBS discussions on this subject. From the outset it was recognized that all pertinent questions posed for an independent assessment would not be answered by a single review with limited scope. Notwithstanding, the NICS team has dedicated many hours to providing professional insights to the Contra Costa County community. The review, a cross-sectional study of programs, policies and perceptions, took place during a time of great change and advancement. Unfortunately, it also occurred on the heels of some tragic accidents. The initial question deals with the County's Notification Policy. Is it working and, if not, could it be improved? Based on the preceding text, interviews and assessment of records,NICS believes the Notification Policy is indeed working and should not be modified at this time. A concern of the public that industry may ignore the policy seems unfounded. At no time did we find that industry would be likely to choose to ignore this policy. Industry expressed greater concerns about how policies are formulated than a reluctance to follow them after the fact. Traditional enforcement incentives are in place to secure reasonable compliance with any public policy once issued. Industry is concerned however, about the potential to provide misleading statistical information relative to the number and types (classifications) of incidents reported. Finally, the issue of access should be resolved as it relates to the Notification Policy. The policy itself is strong and functional,but the latter two concerns should possibly monitored and clarified. A second question related to whether Contra Costa County is using its existing authority and resources for maximum policy effectiveness. This was a much more difficult question to answer. Our response was synthesized from all the observations and information collected. Although an in-depth legal review was not conducted for this report, a cursory survey of legal authorities seemed to provide a positive response: Contra Costa County has a top-rated program when compared to other jurisdictions nationally. While county-level ordinances are more specific,most state and federal statutes provide a similar 40 Incident Response in Contra Costa National Institute for Chemical Studies framework for this comparison and positive conclusion. A survey of Chemical Emergency Preparedness conducted by MICS in March, 1997 shows Contra Costa's programs are among the best in the United States(see next page). Only a detailed legal analysis could provide a concise recommendation for modification of existing legal authority. See the discussion below for suggested improvements offered for consideration. Reviewing the CCCHSD files of numerous incident reports demonstrates a very positive trend; quality of reporting is improving. An assessment of one incident file (Tosca, Jan. 21, 1997)revealed good data gathering, documentation and process techniques. A marked improvement, noted by the NICS reviewers, was the inclusion of root cause analysis and demonstrated follow-up actions for compliance/policy enhancement. A more detailed assessment of this event is potentially available under a NICS-USEPA cooperative agreement to study specific incident documentation for various applications to federal, state and local programs. If arrangements can be made, a more detailed review of the Tosco Incident report may be initiated in the near future. Although it may require a small amount of time from CCCHSD staff, such a review would require no additional financial support from the County. A fourth area of inquiry involved the organizational review of CCCHSD, interviews with staff and a basic review of data management and utilization. As concluded by the review team,the CCCHSD is a very well run, unique organization. It has a dedicated staff which is making great strides toward improved data management and utilization. Contra Costa County has the only known incident reporting database of its kind in the nation. Staff is moving toward greater utilization of the data than ever before. With the recommendations which follow, the administration is strongly urged to look at resources and workload burden which are associated with new endeavors. Lastly,the concerns and recommendations of various stakeholders were sought for this assessment. Stakeholders from industry to labor, environmental activists and citizens provided valued suggestions to the review team.NICS reviewers have attempted to identify these concerns and recommendations, particularly those which were held in common, throughout this report. It was difficult for stakeholders,and often the reviewers themselves, to stay focused on the narrower scope of this inquiry. We were successful however in obtaining a variety of views which have been incorporated into our findings and recommendations. 41 D . 00 co d o � cd oa vs v_ d 3 � t. CSS t,7 y '4 U y; © 4 O d o �y x p. > c � o �• R c o V O � �n a o a � � Rvv� n' Vagi coafl-� .t°c � u to C dv W N d y° : Jtd a A 't3 am_• 5 'd ` o OD . co aopo 0a a T 46 &C dOto - Noto Z C ` p0 � O. 0 0o 0 ® oc o d 0 '_ - ' 8 Incident Response in Contra Costa National Institute for Chemical Studies Now Considerations for the Future Issue: Results of incident investigations. Discussion: Although CCCHSD has been collecting data on incidents for a number of years, most incident files and database records lack final reports on causation, summaries of the overall event or conclusive findings. This type of information is essential for further fine-tuning of programs as well as recommendations to industry. Although in some instances a 72-hour follow-up report is requested, this information could be further developed. In the absence of a federal presence to investigate and issue root cause reports, CCCHSD has just completed its first such report. While there are numerous financial, work load and legal issues to be considered for such efforts in the future, the reviewers see this initiative as filling a major void in the incident response program. Without such data, the agency will continue to lack specific technological guidance on causes, trends, and conclusions which can provide a firm foundation for enhanced policy decisions. Recommendation: Secure the necessary technical, financial and legal support for the fledgling root cause investigation program. Complete a report on each response for agency files. 42 Incident Response in Contra Costa ; National Institute for Chemical Studies Issue: Database enhancement. Discussion: Although CCCHSD is recognized as a national leader in incident database development,the current construction of the database is somewhat deficient in its ability to provide conclusive information about trends in incidents. CCCHSD may wish to utilize the preliminary report by Loyd et al. as a mechanism to establish more refined data elements for incorporation. While specific elements are not recommended in detail by this report, causal information (above) and category (0-3) designation would provide obvious advantages to future analyses and policy recommendations. Recommendation: Develop IR database enhancements through a detailed assessment of future data needs and identifiers. A staff work group with stakeholder input could assist in this process. Database consultants may also provide technical services. 43 D-1 Incident Response in Contra Costa National Institute for Chemical Studies off Issue: Interagency relationships. Discussion: By far the most prevalent concern among all stakeholders was the issue of interagency relationships. Although some relationships are considered good, others hinge on'turf'protection and questions of overlapping responsibilities. The Community Warning System Training Manual has advanced the understanding of the operations of CCCHSD during an incident response--the activities,roles and coordination of other state and county agencies should be similarly specified. Not only would such protocols be useful in training and actual events,they could have a major impact on public education and perception. The Interagency Task Force has made progress in this area but must continue to provide informed guidance to the stakeholders. Many stakeholders are unaware of any results of The Task Force. Recommendation: Continue to provide support for the Inter-agency Task Force. Issue detailed emergency planning and response protocols for all agencies. Further, utilize this information for public education and dialogue. 44 Incident Response in Contra Costa National Institute for Chemical Studies Issue: Enhancement of CCCHSD Operations/Staff. Discussion: Clearly CCCHSD has a premiere operation for jurisdictions of similar size across the United States. The addition of new tasks in root cause investigations, public outreach, database enhancement and others may cause a serious shortage of staff availability considering existing duties and responsibilities. This conclusion was based solely on interviews with existing staff at the time of this report. The only other significant policy/ resource question which arose during the review concerned the 24 hour on-site manning of the operations center. While staff was reluctant to volunteer for round-the-clock assignments of the operations center, this was suggested by several as a mechanism for providing timely activation of the system. Most staff live no closer than one-half hour away from the office. Options to address these issues rest between housing staff on-site at all times versus mobile equipment for remote activation,As of this report, we understand mechanisms for remote activation are being worked out. Recommendation: The CCCHSD may wish to weigh the options for 24-hour activation readiness (financial and personnel) of CWS. Additional initiatives (root cause, public outreach, etc.) may also require a thorough analysis of potential workload increase on existing staff. 45 Incident Response in Contra Costa National Institute for Chemical Studies Issue: Public perception and outreach. Discussion: A consistent issue raised by all stakeholders involved the lack of positive perceptions about County programs, relationships and information provided to the public. Emotionally charged public meetings following release events are not conducive to public outreach and understanding. In order to engage the public in greater understanding of program operations,technical information and regulatory guidelines, frequent opportunities unrelated to specific events have proven to be the most beneficial. Several initiatives by CCCHSD (discussed above)lend themselves to outreach opportunities and could be tailored to meet the needs of public discussion groups. Numerous risk communication techniques are available for consideration.Some stakeholders suggested ongoing third-party sponsorship of public outreach programs,public meetings, and collaborative initiatives. While such initiatives would require increased financial support and staff, the need and desire for more public communication on the issues was indicated to the reviewers. Recommendation: Seek ways to strengthen the public outreach programs. Assess the feasibility of using third-party organizations and neutral facilitators with new or existing stakeholder workgroups. 46 Incident Response in Contra Costa National Institute for Cbernical Studies Issue: Use of technical information in Board policy. Discussion: During the course of discussions with CCCHSD staff and industry leaders, the issue of actual use, reference or consideration of technical data was raised. There is a perception that, while good information is often available, technical facts are often overlooked or discounted during Board-level policy decisions. Industry often feels that their concerns are unaddressed and their technical data underutilized when these may be directly germane to outcome or content of policy. Additionally, the county's resources within CCCHSD are often underutilized by CCCBS in the same fashion in the opinion of industry. If mechanisms are in place for quality control of information which is generated and available for policy discussions, the CCCBS would be wise to further utilize this resource. A S' filrictional units,both industrial facilities and CCCHSD are driven by the technical data they collect. This is entirely appropriate. It is recognized by the reviewers that a governing body such as CCCBS undergoes changes in membership,representation and interests from time to time. Efforts to place technical information components in policy-making procedures may ensure recognition of this issue over time. The frequent agreement between CCCHSD and industry can be often traced to the common underlying scientific and engineering principles on which both are based. Recommendation: CCCBS should request all available data relative to particular policy debates prior to decisions. Insist that quality controls and engineering principles are defined to support the validity of such data. Initiate technical policy-making procedures if not currently in place. 47 Incident Response in Contra Costa National Institute for Chemical Studies A WORD ABOUT NICS he National Institute for Chemical Studies is a 501(c)3 not-for-profit organization. Formed in the wake of the Bhopal,India disaster in 1984,NICS' mission is to serve the public good by providing information, education, assessments, research and reviews which help to bring about improved policies for dealing with the risks and benefits of hazardous materials. For more than a decade, these programs have been sponsored by industry, foundations,public interest groups and government agencies from federal to local levels. Governed by a diverse board of directors,MICS' credibility is ensured by thorough review of all stakeholders when endorsing assessments such as the one provided here. Our services,publications, videos and workshops have been offered and/or provided in all fifty states and several foreign countries. In California, NICS has provided third-party assessments for USEPA Region IX and has participated in the "Continuing Challenge" emergency response workshop in Sacramento for several years. Further information about NICS is available by calling 1-800-282-2796. 48 Incident Response in Contra Costa National Institute for Chemical Studies APPENDIX Proposed Format for New IR Database Case#: No hyphens Date In: With slashes pre-filled Time In: Only accept 4 numeric characters (24-hour clock) Received By: 2 characters (initials of staff member) ER Staff- 2 characters (initials of IR team member) Name of Facility: Site ID: Address: 2 fields: number and street City: I field Area of County: Choice of one character answer- "C", "E", 44SI$, 64W11 Date Occurred: With slashes pre-filled Time Occurred: Only accept 4 number characters (24-hour clock) Type of Report: POP UP WINDOW with choice appearing on main screen Notification HighwayNehicle Facility Drug Lab Pipeline Railroad Disposal/Abandonment Tanker Truck 49 Incident Response in Contra Costa National Institute for Chemical Studies Other(line needed for description) Possible Impact on Storm Drains?: One character answer with choice of"Y"or"N"with a default of'N' Type of Substance: POP UP WINDOW with choice appearing on main screen Toxic Corrosive Flammable Reactive AHM Non-Hazardous Physical State:One character answer with choice of"S", "U, or"G". Nature of Case: Brief one/two word classification Description: Memo field same as site memo field - will include "details" and "description" information from IR form. Response Type: POP UP WINDOW - One field with choice appearing on main screen. Advise Emergency Complaint Other Agencies Involved: POP UP WINDOW with choice of "0", 'W' or blank next to the following: []CHI' []City Police []Sheriff []Fire []Fish & Game []State OES []Coast Guard 50 Incident Response in Contra Costa ' National Institute for Chemical Studies []RWQCB []BAAQMD []DOHS []NatR []Cal EPA []Public Works []Other(line for description) Time En-route: Only accept 4 numeric characters (24-hour clock) Time On Scene: Same as "Time En-route" Time Departed Scene: Same as"Time En-route" 51