Emergency Planning

1
Emergency Planning Community Right-to-Know Act
Overview

• Presented at the Environmental Training Symposium
• 7 11 Feb 2005

Laura Maxwell, P.E. HQ AF Center for
Environmental Excellence laura.maxwell_at_brooks.af.
mil 210/536-4218
2
Overview

• Regulations
• 301-304
• 311-312
• 313 Thresholds Reporting
• Issues
• New Goals
• Training and References
• Class Exercise

3
Regulations

• Emergency Planning and Community Right-to-Know
  Act (EPCRA)
• Title III of the 1986 Superfund Amendments and
  Reauthorization Act (SARA)
• Executive Order (EO) 13148, Greening the
  Government Through Leadership in Environmental
  Management, Apr 2000

4
EPCRA Sections

• 301 Local Emergency Plans
• 302 Report Extremely Hazardous Substances
  (EHSs)
• 303 Coordinate with LEPCs
• 304 Report Releases of EHSs CERCLAs
• 311-312 Report Storage of Chemicals
• 313 Report Releases of Toxics

5
EPCRA - Section 301 Local Emergency Plans

• State Governor creates State Emergency Response
  Commission (SERC)
• SERC designates emergency planning districts
• Each emergency planning district creates Local
  Emergency Planning Committee (LEPC)

6
EPCRA - Section 301 Local Emergency Plans

• What Do I DO?
• KNOW who are the SERC and LEPC
• KNOW who on your installation is your LEPC
  representative or point of contact

7
EPCRA - Section 302 Extremely Hazardous
Substances

• EPA publishes EHS list and Threshold Planning
  Quantities (TPQs)
• Range from 1 to 10,000 lbs
• List has 356 chemicals
• EPA defines Facility
• Fence to Fence stationary items owned or operated
  by the same person
• Facilities provide list of EHSs to LEPC SERC

8
EPCRA - Section 302 Report EHS

• What Do I DO?
• Designate a facility Emergency Coordinator
• Review all EHSs present at the facility
• Maximum amount on-site at one time during the
  year
• Letter to LEPC/SERC that Facility is subject to
  planning provisions of EPCRA
• Provide info to LEPC for their Emergency Plan

9
EPCRA - Section 303 Coordinate with LEPCs

• LEPCs prepare comprehensive emergency response
  plans
• Based on EHS data from Facilities

10
EPCRA - Section 303 Coordinate with LEPCs

• What Do I DO?
• Coordinate with the LEPC
• Develop mutual aid agreements
• Coordinate training and exercises
• Community Outreach efforts
• Document any changes to EHSs or POCs

11
EPCRA - Section 304 Report Releases of EHSs
CERCLAs

• Releases over Reportable Quantity (RQ) be
  reported to LEPC/SERC
• RQ Levels 1, 10, 100, 1000, 5000 lbs
• Intent is to catch chemicals that may migrate
  off-site
• List of Chemicals is EHSs and CERCLA chemicals

12
EPCRA - Section 304 Report Releases of EHSs
CERCLAs

• Similar to requirements of CERCLA Section 103(a),
  but NOT QUITE
• CERCLA report to National Response Center which
  triggers the National Response System
• Facility includes any site or area where
  hazardous substance has come to be located
• Includes vessels, vehicles, pipes, pits, lagoons,
  wells.

13
EPCRA - Section 304 Report Releases of EHSs
CERCLAs

• Exemptions
• Exposure to personnel only within Facility
• Federally Permitted releases
• Continuous releases
• Pesticides exempt from CERCLA
• Releases not considered CERCLA releases
• Radionuclides

14
EPCRA - Section 304 Report Releases of EHSs
CERCLAs

• What Do I DO?
• Report release immediately to LEPC and SERC
• Phone, radio, in person, smoke signals, carrier
  pigeon
• Provide written notification ASAP
• Actions taken to respond and contain
• Anticipated health risks
• Medical advice for exposed individuals

15
EPCRA - Sections 311-312 Storage of Chemicals

• Provide information on Hazardous Chemicals
  present above thresholds
• OSHA driven
• Thresholds are HazChem 10,000 lbs, EHSs 500 lbs
  or TPQ
• See 40 CFR 355
• Submit info to local Fire Dept, LEPC, SERC

16
EPCRA - Section 311 Reporting MSDSs

• What Do I DO?
• Submit copy of MSDS or LIST of hazardous
  chemicals
• Reports to LEPC, SERC and local Fire Dept
• How?
• Identify all Hazardous Chemicals
• Estimate maximum on-site quantity
• Check against thresholds

17
EPCRA - Section 311 Reporting MSDSs

• When?
• Within 90 days of exceeding threshold or
  significant new info
• Some LEPCs/SERCs accept Tier II (312) in place of
  separate 311 report

18
EPCRA 312 Tier I II Reports

• Tier I and Tier II Reports
• Identification of Hazardous Chemicals
  Substances exceeding thresholds
• Hazardous Chemicals - 10,000 lbs
• EHSs that are HCs - 500 lbs or the TPQ
• No specific list cited
• Any substance requiring an MSDS

19
EPCRA 312 Tier I II Reports

• Tier I and Tier II Reports
• Identification of Hazard Category
• Fire
• Sudden Release of Pressure
• Reactive
• Acute Health Hazard
• Delayed Health Hazard
• Report may be by compound (JP-8) versus
  chemical (benzene)
• Tier II requires quantities and locations

20
EPCRA 312 Tier I II Reports

• States may have additional reporting requirements
• Tier II forms (may skip Tier I)
• Their own State forms
• Exact Lists in addition to Tier forms
• Exact quantities
• Lower thresholds
• Fees for data entry

21
EPCRA - Sections 311-312 Storage of Chemicals

• Exemptions
• Solids/Article
• Personal Use
• Lab/Hospital
• Food
• Agriculture

22
EPCRA 312 Tier I II Reports

• What Do I DO?
• Check maximum quantity on-site of EHSs/etc
  against thresholds
• File Tier reports for chemicals over thresholds
• To LEPC, SERC, and local Fire Dept
• When?
• 1 March, annually
• Within 90 days of change

23
EPCRA 313 Form R Reporting

• Section 313 requires Facilities that meet
  chemical thresholds to annually report amounts
  released
• Routine operations and spills
• Form Rs report RELEASES of TOXIC CHEMICALS to EPA
  database The Toxic Release Inventory (TRI)
• Data is published for public and special interest
  groups

24
EPCRA 313 Form R Reporting

• Toxic Chemical List
• 667 chemicals including delimited chemicals
• TRI focuses on wastes and processes
• Facility
• Still Fence to Fence
• Under DOD, each AGENCY responsible for their
  pieceof the installation

25
EPCRA 313 Form R Reporting

• What Do I DO?
• Perform Threshold Determinations
• Identify Toxic Chemicals
• Apply Exemptions
• Perform Release Calculations
• Prepare and submit Form Rs
• Document, Document, Document
• Keep Documents for 5 years

26
EPCRA 313 Three Thresholds

• Is Facility Under Standard Industrial
  Classification (SIC) Code?
• Does Facility Pass Employee Threshold?
• Does Chemical Pass Activity Threshold?

27
EPCRA 313 First Two Thresholds

• Facility Under SIC Code?
• DOD is Code 9711
• DOD will be NAICS Code 928110
• Employee Threshold
• 10 Full Time Equivalents or 20,000 hours
• Only an issue in Ranges, Remote Locations
• If not up to 10, QUIT. Document decision. Move on.

28
EPCRA 313 Chemicals for Thresholds

• Chemical Thresholds
• Listed in the EPCRA List of Lists
• First Step Identify the Chemicals
• ID pure chemicals
• ID chemicals as components of mixtures
• ID chemicals created on-site

29
EPCRA 313 Chemicals for Thresholds

• Sources of Chemical Information
• Pharmacy data
• Bulk fuels
• Storage tanks
• Fuel System Shop (Hydrazine, Chlorine)
• Compressed Gas Cylinders
• Fire Dept - Halon 1211 and 1301, AFFF
• Intuition

30
EPCRA 313 Chemicals for Thresholds

• More Sources of Chemical Information
• Motor Pool, Communications Shop, Life Support,
  AGE, CE Power Production Shop (Batteries)
• Fabrication Shop (Sheet Metal)
• Environmental, POL (Liquid Oxygen, Liquid
  Nitrogen)
• Contract/Waste Management (Solvent Cleaning
  Tanks)
• On-Base Contractors

31
EPCRA 313 Chemicals for Thresholds

• More Sources of Chemical Information
• Flightline and CE (Deicing compounds)
• Materials purchased on IMPAC cards
• CE (Materials used by state employees on base)
• CE, Base Contracting (Materials brought on-site
  by Contractors)
• Munitions, EOD, Ranges

32
EPCRA 313 Chemical Thresholds

• Identify if the Chemical Exceeds the Thresholds
• Manufacturing (Importing) - 25,000 lbs
• Processing - 25,000 lbs
• Otherwise Use - 10,000 lbs
• Persistent Bioaccumulative Toxins (PBTs)
• 0.1 grams/10 lbs/ 100 lbs

33
EPCRA 313 PBTs

• Persistent Bioaccumulative Toxins (PBTs)

• Remain in environment (and the food chain) for
  long periods of time
• Are not readily destroyed
• Build up (accumulate) in body tissue
• Reporting began in 2001

34
EPCRA 313 About PBTs

• How it applies to us
• Many PBTs are pesticides DOD banned long ago
• Common PBTs
• Mercury
• Polycyclic Aromatic Compounds (PACs)
• Polychlorinated Biphenyls (PCBs)
• Lead and Lead Compounds
• Dioxin and Dioxin-Like Compounds

35
EPCRA 313 PBT Sources

• Typical Sources
• Thermostats
• Fuel Oils (No. 6 and No 2) by Coincidental
  Manufacture
• Coal
• Munitions (Manufacturing, Disassembly, OB/OD,
  Firing)

36
EPCRA 313 PBTs

• Accuracy of Pharmacy data
• EPA only requires BEST AVAILABLE INFORMATION
• LEARN FROM EACH OTHER

37
EPCRA 313 PBTs Known as Lead and Lead Compounds

• Sources
• Electronics
• Sheet metal
• Battery maintenance
• NDI shops
• Ranges
• Sealants, greases, coatings
• Fuels No.s 2 6 oils, Natural gas

38
EPCRA 313 Sources of Lead/Lead Compounds

• Approach
• Take a reasonable course of data gathering
• Document all rationales and findings
• Look for more sources next year
• Update your Form R reports when more sources are
  found

39
EPCRA 313 TO-DO LIST

• Perform First 2 Threshold Determinations
• Identify Toxic Chemicals
• Apply Exemptions
• Perform Chemical Threshold Determination
• Perform Release Calculations
• Prepare and submit Form Rs
• Document, Document, Document
• Keep Documents for 5 years

40
EPCRA 313 Exemptions

• Apply Otherwise Use Exemptions
• National Security
• De Minimis
• Article
• Laboratory Activity
• Use Exemptions Structural, Janitorial, Grounds
  Maintenance, Motor Vehicle, Personal Use, Intake
  Water and Air
• Mining

41
EPCRA 313 Lead and Lead Compounds Exemptions

• Exemptions still apply
• Articles
• Lead-acid batteries
• Computer monitors
• NDI lettering for X-Rays
• Structural use
• Metal beams/bricks
• Coatings Pavement paint
• Lead shielding for X-Ray systems

42
EPCRA 313 TO-DO LIST

• Perform First 2 Threshold Determinations
• Identify Toxic Chemicals
• Apply Exemptions
• Perform Chemical Threshold Determination
• Perform Release Calculations
• Prepare and submit Form Rs
• Document, Document, Document
• Keep Documents for 5 years

43
EPCRA 313 Calculate Releases

• Use Best Available Information and Best
  Estimation Methods
• Sources of Information
• Air Emissions Inventory
• Permits
• Waste and disposal reports
• Metrics
• Sampling Results

44
EPCRA 313 Releases

• Release values are NOT the Threshold values
• Threshold is how much chemical is in the M/P/OU
  activity
• Release is how much chemical is released to the
  Air, Land, Water or Treated Off-Site

45
EPCRA 313 Filling Out Form R

• Information Required for Form R
• Chemical name, CAS number
• Maximum amount on-site during year
• Amount released to air, land, water
• Amount transported for disposal, treatment,
  recycling, energy recovery
• Amount, method and efficiency of waste treatment
• Pollution prevention and chemical recycling
  activities

46
EPCRA 313 Form R Rules

• DOD must use the EPAs Electronic Form R Software
  per EO 13148
• Toxic Release Inventory Made Easy (TRI-ME)
• http//www.epa.gov/tri/
• Any NEW FACILITY
• Facility Name must be
• U.S. DOD USAF ANYWHERE AFB STATE
• DOD not permitted to use Form A

47
EPCRA 313 More Form R Rules

• No Range Codes allowed
• A 010 pounds, B 11-100 pounds, etc.
• Use Whole Numbers
• 112 pounds, not 112.345678 pounds
• Except for PBTs
• Even then, dont go overboard

48
EPCRA 313 PBT Form R Rules

• Final Rules
• Thresholds are 0.1 grams (dioxins), 10 lbs, and
  100 lbs
• NO De Minimis exemption (lt 1.0)
• NO Range reporting in Sections 5 6
• Not a huge deal because DOD is not allowed to use
  ranges anyway
• Added data reporting precision to Form R software
  (x10-7 lbs)

49
EPCRA 313 Submit Form R

• Submit Form R through the TRI-ME program to EPA
  by 1 Jul annually
• CDX is secure one-way transmission
• Submit via 3-1/2 disk
• Most States prefer disk
• Submit to AFCEE via email or disk
• Required for AF-wide roll-up

50
EPCRA 313 Form R on the Web

• EPA posts your data by Nov
• Amendments may/may not be posted on a timely
  basis
• Check your Base posting
• Verify accuracy
• Check your own neighborhood
• EPA TRI website
• Follow the directions for TRI Explorer or
  Electronic-Facility Data Release (e-FDR)

51
EPAs Electronic Facility Data Release (e-FDR)
www.epa.gov/tri-efdr
52
EPCRA Quick Review

• 301 Local Emergency Plans
• 302 Report Extremely Hazardous Substances (EHSs)
• 303 Coordinate with LEPCs
• 304 Report Releases of EHSs CERCLAs
• 311-312 Report Storage of Chemicals
• 313 Report Releases of Toxics

53
EPCRA Issues

• Coincidental Manufacture
• Contractors and Tenants
• Munitions and Ranges
• Lead and Lead Compounds
• Fueling Activities

54
EPCRA Issues Coincidental Manufacture

• Definition Manufacture of a chemical as a
  byproduct or impurity as a result of the M, P,
  OU, treatment, disposal of other chemical
  substances
• You cannot exempt coincidental manufacture even
  if the originating activity was exempt

55
EPCRA Issues - Coincidental Manufacture

• Examples
• Wastewater treatment
• Nitrate Compounds
• Combustion of fuels
• Coal - Hydrochloric Acid, Hydrogen Fluoride,
  Mercury, Dioxins
• No. 2 Fuel Oil - Formaldehyde
• No. 6 Fuel Oil - Polycyclic Aromatic Compounds
  (PACs), Benzo(G,H,I)perylene

56
EPCRA Issues Coincidental Manufacture

• Reporting Releases
• Generally, these chemicals are NOT measured
• Use best estimations and known calculating
  methods
• If you missed reporting CM chemicals, report as
  soon as you notice or are told
• Back reporting may be required for any activity
  EXCEPT Coal Burning prior to CY 2000

57
EPCRA Issues Contractors Tenants

• Contractors comply with all provisions of EO
  13148 per section 1505, including goals
• Facility is Fence to Fence
• Know ALL sources just to determine THRESHOLD
• Report only your Part of a Facility RELEASES
• Enlist cooperation from all entities on the
  Facility

58
EPCRA Issues Contractors Tenants

• General Steps
• Find their EPCRA POC
• Compare rough data to determine if thresholds are
  vulnerable
• If busted, you report/they report
• If well below threshold, document and QUIT

59
EPCRA Issues Contractors Tenants

• Basically, encourage participation without
  requiring more deliverables
• Document review
• Emergency plans, hazardous waste reports
• Contract clauses, permits, approvals,
  registrations
• Could take list of at risk chemicals to
  Contractor
• Make threshold determination on best available
  data

60
EPCRA ISSUES Munitions and Ranges

• Apply EPCRA to Munitions and Ranges
• Data collection
• There are NO duds
• Apply Exemptions
• Evaluate against thresholds
• Calculate releases
• Follow DOD/AF policy
• Posted on DENIX or get from Pro-Act

61
EPCRA ISSUES Munitions and Ranges

• Thresholds
• Ranges are separate from the rest of the
  installation
• Range Employee Threshold - 10 FTEs
• Count personnel with any job related to the range
• Employees do not have to be physically located ON
  the range to be counted
• COUNT Target maintenance/construction, range
  clearance sweeps, natural resource activities,
  range control work

62
EPCRA ISSUES Munitions and Ranges
C Permitted Open Burn Area
B3 EOD and A3 Permitted Open Burn Area
B2 Indoor Small Arms Range
A1 Installation
D Small Arms Range
A2 Permitted Open Detonation Area
B4 Bombing Range
B1 Outdoor Small Arms Range
E Bombing Range
63
EPCRA ISSUES Munitions and Ranges

• According to the DOD and AF Policy (9 Nov 01,
  ADUSD(E) memo)
• Facility A Main Installation
• A1, A2 and A3
• Facility B Installation Ranges
• B1, B2, B3 and B4
• Facility C Off-Site Open Burn Area
• Facility D Off-Site Small Arms Range
• Facility E Off-Site Bombing Range

64
EPCRA 313 Lead and Lead Compounds Thresholds

• Thresholds?
• Manufacturing - 25,000 pounds
• Processing - 25,000 pounds
• Otherwise Use - 10,000 pounds
• M, P, OU - 100 pounds

65
EPCRA 313 Lead and Lead Compounds Thresholds!

• ALL Lead Including in Stainless Steel, Brass and
  Bronze Alloys
• Manufacturing - 25,000 pounds
• Processing - 25,000 pounds
• Otherwise Use - 10,000 pounds
• Lead NOT in SS, Brass and Bronze
• M, P, OU - 100 pounds

66
EPCRA 313 Lead and Lead Compounds Threshold

• Example Facility processes
• 20,000 lbs lead in SS alloy and
• 275 lbs lead in non-SS/brass/bronze alloy
• Under the 25,000 lb Processing Threshold
• Over the 100 lb Processing Threshold

67
EPCRA ISSUES - Lead and Lead Compounds

• Example Firing Range Alpha. Data indicates
• 130 lbs lead and
• 80 lbs lead compounds Otherwise Used.
• Report will be generated for 130 lbs lead
• RELEASE is different than THRESHOLD
• Under the 100 lb threshold for lead compounds

68
EPCRA ISSUES Munitions and Range Data

• Data Collection and Release Calculations
• TRI-Data Delivery System (TRI-DDS)
• Mandated for DOD use by DUSD(ES), 9 Feb 00
• Generates DATA to assist you in determining
  thresholds and releases

69
EPCRA ISSUES Munitions and Range Data

• TRI-DDS software
• Easy to use, web-based
• Gives air/land releases, recycled amounts
• Record keeping by munitions range personnel is
  critical
• Recommend using this software for record keeping
• http//www.dod-tridds.org

70
www.dod-tridds.org
71
EPCRA ISSUES Fueling Activities

• ADUSD(E) Memo, 9 Nov 01, we will report releases
  associated with TRANSIENT AIRCRAFT
• Started with CY 2002 activities
• Multiple memos regarding how to report fueling
  activities
• Contact Pro-Act for copies

72
EPCRA ISSUES Transient Aircraft Fueling

• AF Definition of Transient
• Not under operational control of installation
  providing chemicals
• Do not include in-air refueling
• Major chemicals in JP-8
• Napthalene
• Benzene
• Ethylbenzene
• 1,2,4-Trimethylbenzene
• Xylene

73
EO 13148 Goals

• Part 5 Goals 3 New Goals
• Section 502 Reduce TRI Releases Off-Site
  Transfers by 40 by Dec 2006
• Section 503 Reduce Use of selected Toxic
  Chemicals and Hazardous Substances and Other
  Pollutants by 50 by Dec 2006
• Priority 5 published Oct 04
• Section 505 Phase out Class I ODCs by Dec 2010

74
EO 13148 Goal Section 503 Reduce Use

• Mercury
• Devices (Medical and Industrial) Switches
• Cadmium
• Electroplating Processes
• Lead
• Tin/Lead Soldering (Electrical)
• Naphthalene
• Pesticides
• PCBs ? 500ppm
• Insulating Material (Transformers Ballasts)

75
Training

• Training EPA hosts every spring
• EPAs policy does not always match AFCEEs
• Training off the net
• AFCEE Web University
• http//webu.brooks.af.mil/webu/
• EPA www.epa.gov/tri (Reporting Materials)
• Commercial on the web and classroom
• Training by Contractors
• GAIA, URS, TetraTech, BAH, others

76
References

• Useful References
• Air National Guard EPCRA Weapons System
  Assessment, Dec 2003
• EPCRA Munitions Reporting Handbook for the U.S.
  Army, May 2002
• Getting Started with EPCRA Basic Guidance for
  Navy Facilities, QA, Sep 2002
• Air Emissions Inventory Guide for Stationary
  Sources, AFIOH, Dec 2003
• AFCEE EPCRA Website

77
Support

• Air Force EPCRA On-Line Forum through DENIX
• Mailing list for dialogue between all
  installations
• Open to all AF and DOD
• Intended for AF and Contracted support
• Non-attribution discussion so that we can help
  each other
• Send a blank message to join-af-epcra-forum_at_list.
  denix.osd.mil
• AFCEE/TDE is Administrator

78
EPCRA CLASS EXERCISE Calculations for TRI

• Class Problem
• Thresholds
• Releases
• Filling in a Form R

79
How to Calculate Thresholds

• Thresholds
• NAICS
• Number of People/Work Hours
• Pounds of Chemical per Activity
• Chemical on List above Deminimus
• Collect data PER ACTIVITY (M,P,OU)

80
EPCRA 313 Filling Out Form R

• Information Required for Form R
• Chemical name, CAS number
• Maximum amount on-site during year
• Amount released to air, land, water
• Amount transported for disposal, treatment,
  recycling, energy recovery
• Amount, method and efficiency of waste treatment
• Pollution prevention and chemical recycling
  activities

81
EPCRA Where to Begin?

• Your Base has 750,000 gallons attributed to
  transient aircraft fueling.
• The MSDS shows chemicals
• Kerosine, 90 - 100
• Benzene, 0.2
• Napthalene, 3
• 1,2,4-Trimethylbenzene, 0.5
• Do you report?

82
FIRST THRESHOLDS

• Fueling is considered Otherwise Use
• Threshold for any chemical is 10,000 pounds
• Except PBTs
• Deminimus is 1 unless stated differently in List
  of Lists
• Except PBTs
• Check chemicals

83
FIRST THRESHOLDS

• Benzene Deminimus is 0.1
• Napthalene 1,2,4 TriMeth Deminimus is 1.0
• Kerosine, 90 - 100 ...No
• Benzene, 0.2 .Yes
• Napthalene, 3 Yes
• 1,2,4-Trimethylbenzene, 0.5 No
• Threshold calculation Need pounds of chemical
  to compare to threshold

84
Example of Threshold Calculation

• Pounds of Chemical in JP- 8
• (Gallons of JP-8) x
• (Specific Gravity of Chemical) x (Chemical in
  JP-8) x
• (62.43 pounds/cubic feet) /
• (7.48 gallons/cubic feet)
• ? Lbs chem (Gal JP-8)(Sp Gr)()(62.43)
• 7.48

85
Calculate Napthalene Threshold

• ? Lbs chem (Gal JP-8)(SpGr)()(62.43)
• 7.48
• ? Lbs Napthalene
• (750,000 gal JP-8) (0.82)(0.03)(62.43)/7.48
• 153,998 pounds Napthalene
• Do we report Napthalene?
• (HINT OU threshold 10,000 pounds)

86
Next Releases - Sources

• Sources for Air Emissions calculations
• Your Air Emissions Inventory (AEI)
• ANG EPCRA Weapon Systems Assessment, Dec 2003
• AFIOH AEI Guide for
• Stationary Sources,
• Dec 2003
• AP-42
• Other sources

87
Next Releases - Data

• Number of gallons in OU activity
• 750,000 gallons JP-8
• Need number of POUNDS of each chemical RELEASED.
• Find constants, density, conversion factors,
  specific gravity of chemical

88
Next Releases - Data
Threshold Value for Class Example Approx
154,000 pounds Napthalene OU
89
Next Releases - Equations

• Napthalene, Using the ANG WSA Guide
• Pounds Napthalene released

(JP-8 Dispensed in gal/yr) x 1,000
0.9208 pounds VOC x Million
gallons JP-8 0.00003 pounds napthalene Pound
VOC
Developed for ANG by URS using the AFIOH AEI
Stationary Sources Guide and AP-42.
90
Next Releases - Napthalene

• Napthalene
• Pounds Napthalene released
• (750,000) x 0.9208 x 0.00003
• 1,000 106 1
• 0.0000002 pounds Napthalene
• What goes on the Form R?
• HINT Use whole numbers.
• HINT Air, Land or Water release?

91
CY2003 Form R, Page 2 of 5
Where to put Napthalene Fugitive Emissions
x
0
E
X
NA
92
CY2003 Form R, Page 5 of 5
New Facility
Napthalene
X
X
Where to put Napthalene total releases
NA
NA
NA
NA
0
0
0
NA
93
Next Releases Other Sources of Air Water
Emissions

• Tanks Storage of ONLY the transient fuel
• Hush Houses could be Lab Exemption
• Test Cells also could be Lab exemption
• Spills from refueling
• Absorbents from spill clean up
• Storm water releases to streams

94
REVIEW - Sections 301-303

• Know your SERC and LEPC
• Determine Extremely Hazardous Substance (EHS)
  Thresholds are broken
• Report to LEPC that Installation is Subject to
  Emergency Planning, and Point of Contact

95
REVIEW - Section 304

• Provide VERBAL notification to SERC and LEPC if
  release occurs above the Reportable Quantity (RQ)
  of an EHS or CERLCA Hazardous Substance (HS)
• Follow-up with WRITTEN report of Actions

96
REVIEW - Sections 311 312

• 311 - To the LEPC and SERC and local Fire Dept
• Submit list of EHSs and Hazardous Chemicals
  (ANYTHING WITH AN MSDS) that exceed thresholds
• 312 Submit Tier I or II form annually (1 Mar)
  to LEPC SERC local Fire Dept
• EHSs and hazchems locations and amounts

97
REVIEW - Section 313

• Submit TRI Form R to EPA by 1 Jul annually
• Report RELEASES of Toxic Chemicals that break
  on-site THRESHOLDS during the previous calendar
  year
• Follow DOD and AF Policy
• DOCUMENT EVERYTHING

98
Points of Contact

• HQ USAF/ILEVQ, David Kumar, 703/604-0647,
  david.kumar_at_pentagon.af.mil
• HQ ACC/CEVQM, Rob Kemether, DSN 574-9310
• HQ AFSPC/MSEV, Pat Woods, DSN 692-3846
• HQ AFMC/MS (CEVO), David Martin, DSN 787-0106
• HQ AMC/A7VQ, Mark Horstman, DSN 576-0904
• HQ AFRC/CEVQ, Butch Folsom, DSN 497-1067
• HQ ANG/CEVQ, Michelle Lewis, DSN 278-8293
• HQ AFCEE/TDE, Laura Maxwell, DSN 240-4218
• PRO-ACT at 1-800-233-4356

99
SUMMARY

• Installations must
• comply with
• 302, 303 and 304
• of EPCRA, as well as
• 311, 312, and 313