EH-413 Tree Logo Instructions
for
Module 2:
 
Emergency Planning Notification		 Module 2 graphic
     
 
Instructions for: Step 1, Step 2, Step 3, Step 4, Step 5, Step 6, Step 7, Step 8, Step 9, Step 10, Step 11, Step 12, Step 13, and Step 14.
  
     
 
 
 
Instructions for Step 1        Back to Step 1    GOTO: Top of Instructions Page
 
 
Emergency Planning Notification standards require facilities to provide designated emergency planning agencies with information that would be helpful in developing local emergency plans. These plans must be made available to the public upon request (EPCRA, Section 324(a)). DOE facilities are to comply with EPCRA to the fullest degree compatible with national security interests.
 
There are two ways a facility can become an emergency planning facility: The facility may be designated by the Commissioner or Governor of the state in which the facility is located (The designation can only be made after public notice and opportunity for comment.) or The facility has on-site a substance which is or contains an Extremely Hazardous Substance as defined by the Environmental Protection Agency (EPA) and listed as such in 49 CFR 355.30 part (a).
 
A designated facility must make emergency planning notification and fulfill the other obligations of an emergency planning facility, regardless of the quantities of EHS present.
 
 
 
Instructions for Step 2        Back to Step 2    GOTO: Top of Instructions Page
 
 
Module Two uses information collected in the inventory of hazardous chemicals present at the facility. This inventory should have been completed during Module One: Inventory of Chemicals. The inventory is used to organize the chemical information so that threshold determinations can be made and compliance notifications and documents can be compiled (40 CFR 355.30 (a)).
 
Every page of the Optional Inventory will need to be examined by this procedure.
 
 
 
Instructions for Step 3        Back to Step 3    GOTO: Top of Instructions Page
 
 
Using the Optional Aggregation Worksheet A format is one of the most straight-forward ways of assuring that no EHSs present in the inventory are missed when determining if any EHSs exceed the thresholds. However, the Aggregation Worksheet As are not a regulatory requirement. If the inventory of chemicals at the facility is small enough to be managed by written worksheets and other hard-copy means, then using the copies of the Optional Aggregation Worksheet A in its present form may be the best method of aggregating all EHSs. If the facility manages a more sizeable number of chemicals, it may be advantageous to use an alternate system which performs the same aggregation function, such as implementing a computer database using Worksheets as guidance for developing database specifications. [40 CFR 355.30 (a), (e)]
 
You will end up with one Aggregation Worksheet A for each EHS present at the facility. It is advisable to familiarize yourself with the EHS list and those EHSs present at the facility to avoid starting two worksheets for the same EHS. Be particularly cautions for cases where the chemical manufacturer used a synonym for the EHS rather than the regulatory name used by the EPA. In these cases, use the CAS number to give positive identification to the chemical.
 
 
 
Instructions for Step 4        Back to Step 4    GOTO: Top of Instructions Page
 
 
Each EHS has been assigned a Threshold Planning Quantity (TPQ) and most have been assigned a Reportable Quantity (RQ) by EPA (EHSs which have not been assigned an RQ by EPA have a statutory RQ of one pound).
 
 
 
Instructions for Step 5        Back to Step 5    GOTO: Top of Instructions Page
 
 
Every page of the Optional Inventory will need to be searched individually for each one of the EHSs for which an Optional Worksheet A was begun.
 
This is the first step in the iterative procedure. In this step you choose the EHS for which you will be searching the Inventory.
 
 
 
Instructions for Step 6        Back to Step 6    GOTO: Top of Instructions Page
 
 
Information about each product containing that EHS is transferred to the Optional Aggregation Worksheet A for the particular EHS. This allows all information about the EHS to be aggregated, regardless of the mixtures or locations that the EHS is present.
 
 
 
Instructions for Step 7        Back to Step 7    GOTO: Top of Instructions Page
 
 
The iterative procedure must be preformed on all EHSs for which an Optional Aggregation Worksheet A has been started (i.e., all the reportable EHSs present at the facility).
 
 
 
Instructions for Step 8        Back to Step 8    GOTO: Top of Instructions Page
 
 
Compare the weight on line K with the TPQ. The TPQ should be recorded with the other information at the top of the Worksheet. [40 CRF 355.30 (a)]
 
 
 
Instructions for Step 9        Back to Step 9    GOTO: Top of Instructions Page
 
 
The TPQ is the regulatory threshold at or above which the EHS causes the facility to become an emergency planning facility.
 
The facility must fulfill the obligations as an emergency planning facility due to the presence of even one EHS over the threshold.
 
 
 
Instructions for Step 10        Back to Step 10    GOTO: Top of Instructions Page
 
 
If you have correctly arrived at this point in Module 2, then the facility has no EHS at or above their TPQs and has not been designated as an emergency planning facility. There is therefore no requirement under EPCRA to make emergency planning notification.
 
 
 
Instructions for Step 11        Back to Step 11    GOTO: Top of Instructions Page
 
 
Most of the emergency planning notifications are one-time notifications. The notifications initiate a relationship between the facility and the local emergency planners. It is through this relationship that facilities take on additional emergency planning responsibilities. [40 CFR 355.20 (a), (b), and (c)]
 
The letter only needs to say that the facility is an emergency planning facility. It may be helpful to include a list of EHSs present at the facility, but this is not required under EPCRA. Emergency planning notification to the SERC should have been made by May 17, 1987 or within 60 days after first meeting the TPQ for an EHS. [40 CFR 355.30 (b)]
 
 
 
Instructions for Step 12        Back to Step 12    GOTO: Top of Instructions Page
 
 
The facility emergency planning coordinator will act as a liaison with the LEPC. If the LEPC has additional questions about the facility they will contact the facility through the designated emergency planning coordinator. The coordinator should be reasonably familiar with the emergency response capabilities of the facility.
 
 
 
Instructions for Step 13        Back to Step 13    GOTO: Top of Instructions Page
 
 
This notification can be accomplished with a letter. It may also be helpful to the LEPC to include a list of the EHSs present at the facility, however, this is not required by EPCRA. The LEPC should have been notified of the facility emergency planning coordinator's identity by September 17, 1987 or 30 days after the establishment of an LEPC.
 
 
 
Instructions for Step 14        Back to Step 14    GOTO: Top of Instructions Page
 
 
Once the relationships with the LEPC and SERC have been initiated, EPCRA has given them the responsibility for taking the next step. However, some facilities have benefitted from taking a proactive approach to emergency planning by getting involved in local emergency planning efforts and volunteering additional information to the LEPC.
 
 
 
Instructions for Step 15        Back to Step 15    GOTO: Top of Instructions Page
 
 
Incorporate these requirements into the facility's procedures so that they are always accomplished when the situations arise since there are no predictable reporting dates. [40 CFR 355.30 (d)]
 
LEPCs have the authority to ask for additional information from emergency planning facilities if that information is to assist them in development or implementation of the local emergency plan.
 
The EPCRA regulations require emergency planning facilities to promptly provide the LEPC with any requested emergency planning information.
 
LEPCs have authority to request a great variety of information. Unless the request must be denied for legitimate national security interest, the requests should be fulfilled. Typically LEPCs will request information such as facility plans, emergency equipment inventories, quantities of chemicals present at the facility and facility specific risk analyses.
 
 
 
Instructions for Step 16        Back to Step 16    GOTO: Top of Instructions Page
 
 
Whenever a change occurs at a facility, the LEPC must be notified if that change affects emergency planning. Examples of changes which may affect emergency planning include: significant new quantities of EHS being acquired by or removed from the facility, new emergency response equipment being purchased by the facility, or a change in the facility emergency planning coordinator identity.
 
Notify the LEPC of the change and provide them with the updated material.
 
 
 
End Note        Back to Module 2, Steps 15 and 16    GOTO: Top of Instructions Page
 
 
Module Two covered the Federal EPCRA requirements. Some states may have additional requirements concerning emergency planning. Check with the state to determine if any additional requirements are applicable. Remember to continuously monitor if any of the on going emergency planning requirements must be accomplished (Steps 15 and 16).
 
 
 
DOE Office of Environmental Policy and Guidance