Document MLd8aLjqY8b29nZzaR2OQzwx

/4ffrf O PLAINTIFF'S EXHIBIT SH-2658 A STRATEGY TO REDUCE RISKS TO PUBLIC HEALTH FROM AIR TOXICS U.S. Environmental Protection Agency Washington, D.C. June 1985 LAM 003626 DPMC-09717 V TABLE OF CONTENTS I. The Nature of the Problem........................................................................3 II. Routine Releases: Programs in Place .................................... III. Routine Releases: Needed Actions .............................................. 11 IV. Sudden, Accidental Releases: Programs in Place . . . 22 V. Sudden, Accidental Releases: Needed Actions .... 30 VI. Conclusion . . . . 36 LAM 003627 DPMC-09718 A STRATEGY TO REDUCE RISKS TO PUBLIC HEALTH FROM AIR TOXICS This report presents the results of an eighteen-month examination of air toxics--whether emitted routinely or sud denly, under accidental conditions--and the means to reduce their risks. Air toxics result from all the activities of a modern society, from driving a car, to burning fossil fuel, to producing and using industrial chemicals. Public exposure to air toxics presents risks to human health that call for an aggressive and measured response. As a Nation we must target our efforts on those control lable air toxics that present the greatest health risks to the American public. Controls in place have already made, and continue to make significant inroads in the problem. Yet this report concludes that much remains to be done by EPA, the States, and the private sector. In light of the air-toxics problem as EPA now understands it, this report sets out a comprehensive action agenda, calling for both reinforcement of existing public programs and initiation of several important new undertakings. Highlights of EPA's action plan are: National Regulation. While maintaining a strong program to con trol industrial (point) sources, EPA will vigorously control "area" (that is, small, but numerous and broadly distributed) sources, multiple-pollutant sources, and other non-trad i tional sources of complex toxic emissions that appear to account for a sipnifioa- :orti >n of the controllable .oealth risk. LAM 003628 DPMC-09719 2 State Air-Toxics Control Programs. The air-toxics problem is not limited to problems of national concern. In some cases areas of locally elevated risk may require targeted action by State or local agencies. EPA will help States to build strong air-toxics programs of their own and, when appropriate, refer problems of specifically local concern to States for evaluation and appropriate action. Developing Multi-Media Control Methods. EPA will expand its multi-media studies of local toxic problems as a basis for a Federal/State partnership to address any areas of localized risk from multiple sources. The Agency will work with State and local authorities to measure risks across media and assess alternative strategies for appropriate abatement. Sudden, Accidental Releases. EPA will expand its program for emergency preparedness and response. This expansion includes evaluating and improving information systems, training State and local response teams, and planning for emergencies, in cluding exercises to test how well systems are working and how they can be improved. Besides reinforcing existing emer gency preparedness, EPA will undertake three new efforts: 1.Step Up Enforcement of Chemical-Hazard iNotification EPA will increase resources to enforce Reportable Quantity requirements, and require recordkeeping and reporting authorized under TSCA. This will disclose patterns of chemical mishandling, lam 003629 DPMC-09720 3 heighten industry consciousness of specific chemical hazards, promote realistic contingency plans, and enable prompt res ponse to emergencies. 2. Issue an Acute-Hazards List. EPA will prepare and issue a list highlighting substances most likely to cause serious harm in the event of a large acci dental release. It would include substances known for their acute toxicity and potential for release. 3. Promote Community Right to Know EPA will work with those who support a program to ensure that communities have ready access to information on chemicals in use for the purpose of realistic contingency planning. EPA's Acute-Hazards List will support this effort. ********** I. The Nature of the Problem Along with the growth of our industrial society, there has been an increase in the number and types of toxic chemicals to be found in our environment. The problem we face takes two forms: risks posed by emissions from the normal activities of modern society (hereinafter referred to as "routine" releases), and risks from sudden, accidental releases of substances capable lam 003630 DPMC-09721 4 of inducing immediate health effects. The two parts of the problem stem from different causes and therefore demand separate solutions. The Problem of Routine Releases Air toxics enter the atmosphere through many of the everyday processes of American life. In fact, some of the most potent releases originate in our most mundane activities, such as burning wood and coal, or driving cars and trucks. EPA's job is to determine which chemicals cause the most serious health effects, identify those that can be controlled, and apply appropriate tools to control them. The size of the health-effects problem associated with routine emissions of air toxics is difficult to define in abso lute terms. Available models project statistically the incidence of cancer likely to be associated with long-term exposure to certain airborne substances. While it is easier to estimate cancer incidence than that of other diseases, we believe that controls effected to reduce the risk of cancer tend to reduce the incidence of other diseases as well. Reduction of cancer is an important goal for our society, but it is important to keep in mind the limits on the progress that can be made by environmental control programs. According to the National Cancer Society, in 1983 the total number of deaths due to cancer in the United States is estimated to have LAM 003631 DPMC-09722 5 been 440,000. Diet and smoking a.>pear to account for the vast majority of these deaths. Of the relatively small number likely to be associated with exposure to air toxics, only a portion can be prevented through national 'intervention. For Federal action to be effective within such a narrow target area, it is essential that we select appropriate and efficient tools, and use them wisely. The Problem of Chemical Accidents As for the sudden, accidental release of toxic chemicals, the Nation is now engaged in a thorough reexamination of the systems in place for chemical accident prevention, preparedness, and response. In approaching this problem we must recognize the fundamental paradox that it presents. Accidental chemical releases occur in the United States every day. In 1981, 1665 such releases (other than oil) were reported to the National Response Center. Although a natural gas explosion killed 40 as recently as 1973, we must go back to 1947 to find a chemical accident involving catastrophic loss of life. In that year a French fertilizer-transport ship explo ded off Texas City, Texas, killing 565 and injuring 3000. Perhaps the most notable factor associated with this acci dent, beyond its magnitude, is its singularity and remoteness in time. Our society's dependence on industrial chemicals has increased since the accidents of the forties, but so have our LAM 003632 DPMC-09723 6 defenses against such calamities. A chemical release does not necessarily equate to an immediate health or environmental hazard. For people to be hurt, there must be a coincidence of potency, volume, and exposure sufficient to overwhelm physical and natural defenses. Based on records of actual injury, these factors do not coincide very often in the United States. As a matter of fact, in recent years the chemical industry has often placed first on the National Safety Council's industrial safety ranking. In this country, most accidental chemical releases are quickly controlled so that people are not seriously injured. Since Bhopal, however, American chemical companies have been taking a long, hard look at their safety programs, seeking to prevent serious accidents in the first place, and to prepare for quick response to cohtain incipient accidents. The task for EPA, in cooperation with the Federal Emergency Management Admin istration (FEMA), is to reinforce those private efforts at preven tion, and to ensure the strongest possible public capability to prepare for and respond to chemical release accidents if and when they occur. II. Routine Releases: Programs in Place % EPA has completed a new study, based on available data and entitled "The Air-Toxics Problem in the United States: An Analy sis of Cancer Risk for Selected Pollutants" (hereafter, "The Air Toxics Study"). It considers the effect of conventional controls for criteria pollutants (air pollutants for which ambient stancarcs DPMC-09724 7 havebeen set) as well as mobile-source controls, on toxic emis sions--and subsequent changes in ambient levels. Such controls frequently reduce toxic emissions in the process of removing the pollutant against which they are specifically directed. Based on a comparison of measured ambient levels arid estimated emissions, the Air Toxics Study estimates the number of cancer cases annually associated with exposure to a group of air toxics in 1970 to be about 3600. The estimate for 1980 is better than 50% lower.* Stationary-Source Controls. Toxic reductions realized from steps taken primarily for other purposes can be quite substantial. For example, National Ambient Air Quality Standards (NAAQS) for par ticulate attained through State Implementation Plans frequently control toxic metals from point sources by 80 to 98 percent. Controls for ozone generally reduce emissions of volatile organ ics from 30 to as much as 90 percent, while New Source Performance Standards are usually from 90 to 99 percent effective for these pollutants. We can expect the trend toward lower ambient levels of toxic air pollutants to continue as we sustain the momentum built into the stationary-source provisions of the Clean Air Act. *It is important to understand that these figures take into ac count only a select group of air toxics chosen for their signifi cant toxicity and the ready availability of credible data re garding their effects. Estimates are statistical, not actual: they are probably inaccurate in absolute terms. But it is fair to compare them in relative terms to determine the direction, and estimate the degree, of change. lam 003634 DPMC-09725 8 Mobile-Source Controls. Control of mobile-source pollution plays a major role in toxic-risk reduction as well. One of the most important examples of this is the control of ambient lead through mobile-source standards. During the 1970's and 80's, the amount of lead in gasoline dropped as EPA's standards tightened. Recently, EPA set new rules that will sharply reduce even this residual lead in gasoline over the next year, from 1.1 grams-per-leaded-gallon (gplg) to 0.1 gplg, and is considering a complete ban by as early as 1987. (Use of ethylene dibromide-- EDB--falls along with the lead content of gasoline, implying a further reduction in toxic risk from these actions.) The Agency estimates that in 1986 alone this new standard will prevent 172,000 children from exceeding the lead blood level of health concern set by the Centers for Disease Control. Other Environmental Authorities. Outside the air program itself, actions taken or proposed under other authorities, such as the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the Toxic Substances Control Act (TSCA), the Resource Conserva tion and Recovery Act (RCRA), the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, or Superfund), and the Clean Water Act (CWA), have implications for air-toxics reduction. For example, controls being developed under RCRA for volatile organics from emitted hazardous waste dumps will impede release of these toxics to the ambient air. LAM 003635 DPMC-09726 9 Installation of pretreatment controls under the Clean Water Act, already underway, reduces air emissions from municipal waste treatment plants. Such regulations as FIFRA's control of carbon tetrachloride and EDB from grain fumigation also have a direct and immediate impact on toxic air emissions. National Emission Standards for Hazardous Air Pollutants. Despite the existence of such varied tools for control of air toxics, EPA has invested a great deal in the administration of National Emission Standards for Hazardous Air Pollutants (NESHAPS) under S112 of the Clean Air Act. Although more NESHAPS standards will soon be set, the number issued to date (six) reflects the relative infrequency of the specific set of conditions for which a national standard under NESHAPS is an effective means to protect public health. For EPA to set a national standard under NESHAPS, the Agency requires a finding that a pollutant/source category presentssignificant risk to public health nationally (e.g., as a carcinogen), and that it can be subjected to reasonable and effective control through the imposition of uniform, national standards. In fact, an individual pollutant/source category is often found to account for relatively little national disease incidence, or is in any case unsuited to reasonable control oy national regulation. For many reasons, too, NESHAPS reviews have concentrated or. pollutant/source categories associated with the chemical industry. However, several years of experience has led us to conclude that the chemical industry is not the major source of our national LAM 003636 DPMC-09727 10 air-toxics problem. In fact, we now estimate that point sources associated-with heavy industry (of which chemical manufacture is but a small part) account for only 20-25% of cancer incidence from national air toxics. By comparison, over 50% of national incidence appears due to road vehicles (including gasoline vapors and diesel particulates) and heating sources (including fossil fuel burning, coke ovens, and wood stoves). It is evident that we must look beyond national regulation under NESHAPS to add other effective controls for air toxics. In this regard, work is underway that may soon improve control of air toxics at the State or local level, a movement which EPA will foster. As of now, 22 States and local agencies have established air-toxics control programs, and a number of others are considering a similar step. Over a dozen States with sources of the carcinogen acrylonitrile are actively working with EPA to evaluate data on local sources of this chemical. As announced in another action today, this cooperation may soon lead to additional, site-specific, State regulation of sources of acrylonitrile. Unlike a national standard issued under NESHAPS, State-imposed controls allow more precisely tailored and efficient control of the relatively few sources of acrylonitrile across the country. This is because States are highly competent in setting emission limits for individual sources (they do this as a matter of daily business under State Implementation Plans), and because different types anc levels of control may well be required in separate situat ions. DPMC-09728 11 In addition, EPA is sponsoring projects in Baltimore, Phila delphia, and the Santa Clara Valley to evaluate site-specific hazards from air toxics (as well as risks conveyed through other \ environmental media) and to seek local control strategies. These strategies can be targeted to solve geographic-based problems without introducing the imprecision implied by a single level of control that must be applied indiscriminately to all situations throughout the State and Nation. III. Routine Releases: Needed Actions Our reexamination of the air-toxics problem from routine emissions reveals that more can be done, effectively, to reduce risks. The program-outlined below identifies remaining needs in our national effort and presents the actions we will take in response to those needs. In some cases, EPA's program reflects an evolution in concepts and activities that have been underway for as long as two years. In other cases, we propose actions that are substantially new. National Regulation EPA will deal aggressively with the remaining routine emis sions of air toxics. To ensure maximum benefits for the effort expended, the Agency must make careful choices concerning which regulatory targets to emphasize, and make wise use of all appro priate authorities, including 112 of the Clean Air Act. In LAM 003638 DPMC-09729 12 some 'cases this means broadening our scope of action and in others it means redirecting existing programs to yield greater risk reduction. ACTION STEPS 1. Regulate Stationary Sources of Multiple Toxic Pollutants Although regulating a single pollutant from point sources will at times prove the right approach, EPA will now broaden its emphasis by regulating not only single pollutants but also multiple pollutants from whole source categories. In many cases this will allow EPA to control several toxic pollutants with a single regulation. More importantly, EPA will now expand its work on air toxics to encompass "area" and non-traditional sources through a variety' of provisions of the Clean Air Act, such as 111, 112, 202, and 211, as well as other relevant statutes. In air-pollution par lance, "area sources" are small, widespread sources, such as degreasing operations, motor vehicles and fuels, and small combustion sources. Non-traditional sources include hazardous waste treatment, storage, and disposal facilities (TSDFs) and publicly owned sewage treatment works (POTWs), which we have recently recognized as potentially significant sources of air pollution. This shift from EPA's traditional regulatory priori ties will allow us to more effectively reduce public exposures to air toxics, in that (1) we will consider more types of sources LAM 003639 DPMC-09730 13 for needed control, (2) we will seek to evaluate entire emission streams, rather than isolated chemical constituents, and (3) we will take into account short-term, as well as long-term exposures of the public. In November of 1983 EPA committed to review 20.to 25 indivi dual chemicals and to decide by the end of 1985 whether to list them as substances we intend to regulate under the Clean Air Act. This decision-making process is on schedule and will be completed as promised. Although each of these decisions affects a single pollutant, in examining them EPA has begun to build the foundation for the more inclusive approach. For example, several of the pollutants under review are emitted from the same source category: several metals are emitted from municipal incinerators, and several volatile organic compounds originate from POTWs. For some chemicals, we are considering various area-source categories for regulatory action. In this way, while the Agency completes its review of these chemicals individually, we are also supporting subsequent regulation of source categories of multiple pollutants where possible. In this regard, the Agency recently listed an entire emission stream--coke oven emissions--as a hazardous air pollu tant under 112. We will propose regulations for this source category in early 1986. We are also reviewing such source categories of multiple toxic pclljtants as chemical production, sewage sludge incinera tion, smelters, metal degreasing operations, sewage treatment lam 003640 DPMC-09731 14 plants, and gasoline marketing under one or more of several possible authorities. Under Sill of the Clean Air Act (New Source Performance Standards), EPA expects to regulate such categories of multiple pollutants as the synthetic organic chemi cals industry and residential woodstoves. To support further work in this area, the Agency will study still other source categories to determine which may emit multi ple pollutants of concern. Examples of categories to be examined include chemical production facilities, chemical users, and combustion operations. EPA's ongoing research programs on the health effects of exposure to individual airborne chemicals and complex mixtures will be fed into this effort. Work to character ize the major sources of air toxics and identify new candidates for regulation will take place regardless of competing demands for chemical-by-chemical review during FY 1986. Outside of the Clean Air Act itself, the Agency will estab lish standards under 30Q4(n) of the Resource Conservationand Recovery Act (RCRA) for air emissions from hazardous waste treatment, storage, and disposal facilities (TSDFs). Table I presents a list of major air-toxic regulatory actions currently underway and planned for stationary sources. EPA is also considering use of TSCA to control air exposures for a variety of sub stances, including asbestos and methylene chloride. Table II lists some actual and potential actions under TSCA and FIFRA that would have an effect on air toxics. 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Regulate Mobile Sources of the Most Hazardous Air Toxics Vehicle emissions account for a significant portion of the V air-toxics loadings in urban areas. Historically, motor vehi cles have contributed a substantial part of the inventory of lead, EDB, diesel particulates, benzene, various polycyclic organic matter (POM) compounds, and other toxic pollutants. In the past these emissions have been considered separately from the Agency's air-toxics programs. In the future EPA will administer both the stationary and mobile-source control programs related to toxic emissions as two portions of an integrated air-toxics program. A number of activities to reduce the risk from mobile-source toxics are in progress. Besides the lead-reduction rules des cribed earlier, beginning in 1985, standards to control evapora tive hydrocarbons (including toxic components) become effective for heavy-duty trucks. Particulate emission standards have been enacted for light and heavy-duty vehicles. Beginning in 1987, light-duty vehicles will meet standards based on new technology called trap-oxidizer technology. Heavy-duty engines will also be required to meet trap-based standards in 1991 (with interim standards in 1988). These standards, expected to reduce the risk from diesel particulates by as much as 400 incidences of cancer annually, will require close monitoring of technological development and fuel quality. LAM 003644 DPMC-09735 16 Other measures to reduce the risk from mobile-source toxics are planned. In the near future EPA will consider controls of gasoline vapors (including benzene) emitted during vehicle refueling, as well as controls related to fuel volatility due to high levels of in-use evaporative emissions. The Agency will also propose standards for health-effects testing of fuels and fuel additives, and consider action to control the quality of diesel fuel as a way of insuring the effectiveness of diesel particulate controls. We will also propose standards for methanol-fueled vehicles. Table III lists planned mobilesource regulatory actions that will affect air toxics. State Air-Toxics Control Programs The air-toxics problem involves not only problems of national concern but also localized problems, which may be best evaluated and controlled by State and local air pollution agencies. Many States have recognized this fact and have initiated State-run air-toxics efforts. Several local agencies also have active programs. EPA considers it essential to strengthen these State and local programs in order to allow the fullest possible concentration of effort on all aspects of the national air-toxics control effort. 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G pH 'uH y pOp AA G 0O > >> ph V 3 O j. tt --* o o XZ /c-- JJ PA-H3 3 --tt O > X > G" L- ax A3 a: cpi ----- -- -x. --G CL -- > tt H tt C-- --* O-- a tt -- -- 2> > -- \ tt c *0H 0J a: 4J CO a a Ga Poi > jC X Ca > so c pca tt HtPt Cau * pGa p0- C tt > Xu -- -r: cr cc A! A3 A h> -X O 2 c c pH --* 03 4. G V pi -- rJ -- O' > DPMC-09737 17 ACTION STEPS 1. Build State Air-Toxics Programs EPA is now in the process of negotiating air program grant awards for FY 1986. EPA will set aside funds within the amount appropriated for State program support, with the goal that all States have an operating program for air-toxics control by the end of FY 1986. EPA will assign an additional $3 million from other areas in FY 1986 to assist the States as they initiate or expand this effort, especially to build the data bases they need to make reasonable regulatory decisions. Working with selected States, EPA will design a model State air-toxics pro gram to guide all States as they develop air-toxics strategies of their own, tailored to the problems of each jurisdiction. 2. Referral of Air Toxic Problems of Local Concern EPA will initiate a Federal/S tate/local partnership under which States will evaluate and, if appropriate, regulate large point sources not amenable to national regulation. States are in a unique position to deal with problems caused by individual plants or sources--problems that are not so prevalent as to be of national scope, but that nevertheless may account for small areas of high risk in some communities. A State-led examination of a specific toxics problem on a site-by-site basis can reflect such locally unique factors as: the actual emissions of the specific plant, control technology suitable to that specific plant, and meteorology and population patterns that influence t.ne degree of exposure of peoole to the pollutants. LAM 003647 DPMC-09738 18 'EPA is now negotiating the operational details of a "State Referral" program with State and local agencies. We expect to complete these negotiations in the next several months. By early 1986 EPA will identify the first group of pollutants and source categories to be referred for evaluation by States. To support these referrals, EPA will make available to specific States additional financial support (about $1.5 million) and extensive technical guidance, including information on health effects, emissions, and exposures with regard to the referred pollutants and source-categories. States and local agencies will be expected to evaluate the sources identified in the program and to control them, if needed. EPA will audit State activities and provide public information on pollutants refer red and State decisions. In order to foster consistency, EPA may prescribe minimum responses in certain situations, such as for new sources and in interstate areas. This program will build on our continuing experience with the pilot acrylonitrile control project (see p. 10). 3. Inaugurate the Air-Toxics Information Clearinghouse EPA will soon begin operating the Air-Toxics Information Clearinghouse, which will facilitate exchange of information on air toxics among State and local air agencies and provide those agencies with references to other sources of related information. The Clearinghouse will be accessible to State anc local agencies by computer link-up. LAM 003648 DPMC-09739 19 Develop Multi-Media Methods To Control Toxic Pollutants EPA's concern with air toxics must increasingly take into account comparative risks in other media. For this reason, part of our overall air-toxics program must include intensive examina tion of the cross-media implication of air-toxics controls. EPA is already putting existing knowledge to work to support States in practical ways. For instance, EPA has just agreed to support the State of West Virginia as it seeks to determine health risks in the Kanawha Valley, where methyl isocyanate (MIC) is manufactured, and where numerous other chemical processess are located. EPA's Region III will be supporting cooperative efforts by State officials and a private organiza tion representing community interests to monitor air, water, and land sites in the Valley for the presence of toxic pollu tants. While providing other services, EPA will also help the State develop an emissions inventory. This will allow West Virginia to make realistic judgments on the need for further . emissions controls on sources of air toxics in the Kanawha Valley. Beyond offering such immediate support to solve current problems, EPA recognizes the need to consider all pollutants from all sources; to view air toxics within the context of pollution loadings in other media; and to obtain as much risk reduction as possible from a given investment. In undertaking investigation of multi-media/multi-source issues, we will work LAM 003649 DPMC-09740 20 with States and localities to apply the resources and expertise of all three levels of government to standard-setting, research, permitting and enforcement, and the other constituent pieces of toxic control. We will participate with States and locali ties in making the hard decisions that balance environmental protection on the same scale with the other social goals. ACTION STEPS 1. Three Area Studies EPA will undertake three initial projects that will explore environmental problems in the air and other media. They will demonstrate the use of locally based multi-media/multi-source approaches to reach regulatory control decisions in specific areas. Two of the studies will be extensions of work already begun in Philadelphia and Baltimore, communities that have been especially creative in seeking ways to ensure high envir onmental quality for their citizens. The first such project will build on recent work in Phila delphia by EPA's Integrated Environmental Management Division (IEMD). This six-month study will estimate cancer risks from major air pollutants, and the costs and risk reductions associ ated with alternative control options. It will compare options for tightened standards, and other controls as a basis for dis cussions with the City and local industry aimed at selecting appropriate responses to the problems specific to Phildelphia. LAM 003650 DPMC-09741 21 The second project will build on an IEMD study now under way in Baltimore. As in Philadelphia, the Baltimore work will devise strategies for controlling local air toxics. Because EPA has been working closely with Maryland and Baltimore officials throughout the project, we expect the State to be in a position to implement controls where appropriate and as information becomes available. This work will last 18 months. A third project, scheduled over thirty months, will entail a multi-media assessment of local environmental releases in an area yet to be chosen. 2. Conduct Detailed- Studies of Personal Exposure To broaden and deepen the knowledge gained from these three initial studies, EPA will conduct a personal-exposure study. This study would use total exposure assessment method ologies (referred to as TEAM) and the Toxics Air Monitoring System (TAMS) to assess total personal exposure to pollutants in air and water. The TEAM and TAMS studies will tie together estimates of emissions, ambient levels, and exposures in a single, integrated analysis. 3. Priority Screening of Geographic Areas As a complement to these pilot projects, EPA will examine the geographic distribution of air-toxics problems across the country. EPA will screen areas on the basis of estimated risk to determine where the Agency should conduct further sitespecific analyses. Availaole data will not support quantitative risk assessment on such a scale. Therefore, we will use surrogate LAM 003651 DPMC-09742 22 values for toxic exposure (e.g. , monitoring and emissions data for hydrocarbons and total particulates, combined with data on population distribution). The method will be approximate, rather than precise, but it should be useful for identifying locations for "high-payoff" examination. 4. Support Multi-Media Decision-Making By States EPA is committed to help build State capacity to analyze, make decisions, and mount effective multi-media control programs. Recently, EPA awarded grants to several State governments to fund cross-media priority-setting exercises at the State level. Participation by industry and public interest groups is an impor tant component of these State initiatives, as is the attempt to build better working relationships among the various levels of government. EPA will continue to work with States to assess risks and costs from multiple pollutants and across media as we continue to devise more efficient and effective intergovernmental pollution-control programs. IV. Sudden, Accidental Releases: Programs in Place The other side of the air-toxics problem is the need to protect the public from the immediate and lingering health % effects of a sudden, accidental release of acutely toxic chemicals. Federal Agencies such as OSHA and DOT have rules affecting accident prevention in the workplace and during transit. 5y and large, however, the Federal roie--uncer the \_AM 003652 DPMC-09743 23 overall coordination of the National Response Team, which includes EPA, -the Coast Guard, FEMA, DOT and other agencies with emergency authorities -- emphasizes preparing the public to safeguard itself from the consequences of any accident, and responding to emergencies as they arise. Accident Prevention Although EPA does not play a central role in chemical acci dent prevention, the Agency's programs probably have an ancillary effect on reducing the incidence of sudden, hazardous releases. For example, under TSCA, EPA evaluates the hazards of chemical products and intermediates, and restricts or imposes controls on market entry, manufacture, and use of chemicals that present unreasonable risks. To strengthen this key chemical-regulatory program, EPA recently proposed a rule that would require manu facturers and importers of substances on the TSCA Chemical Substances Inventory to report current data on the production volume, plant site, and site-limited status of each substance. Besides this, compliance with emission standards under the Clean Air Act reinforces the integrity of systems designed to limit routine chemical releases to the atmosphere, and thereby reduces the likelihood of an accidental release. One of the most important authorities is the set of require ments under CERCLA governing Reportable Quantities (RQ). These rules, recently toughened, serve a dual function. In the first case, they serve notice to each chemical firm as to the level of release at which public authorities will involve themselves LAM 003653 DPMC-097 44 24 in a firm's operations- This exerts pressure on firms to avoid accidental releases as far as possible, to ensure the availability of emergency response facilities, and to under take such response when needed. Second, public records built on reports made under RQ rules provide a basis for disciplined oversight of firms whose performance suggests sloppy practices. The CERCLA RQ function provides information to support various governmental enforcement options that can discourage unsafe industrial practices. Beyond this, of course, the RQ program provides EPA with early notice of releases, so that EPA or States can take quick action to protect the environment from preventable further damage. Under TSCA S8(c) and S8(e) EPA has other mechanisms to help identify potential problems. TSCA $8(c) requires anyone who manufactures, processes, or distributes a chemical to keep records of significant adverse reactions affecting health and the environment. These reactions can range from eye irritation to fish kills to chronic disease, and can be reported by any individual, whether or not employed by the firm. While these reports are primarily anecdotal in nature, they often serve as the basis for further investigations, which may yield new information on the toxicity of a chemical. TSCA 3(e) requires firms to notify EPA of any new infor mation that a substance presents a substantial risk of injury. These notices can supplement information obtained under RQ's. The 3(e) notices serve as the basis for other investigations LAM 003654 DPMC-09745 25 by EPA, and are distributed to other Federal agencies, chemical manufacturers, and users. As a result of information reported in this way, firms often take voluntary actions to mitigate V potential exposures, such as changing formulations or processes, or reducing exposure to the chemical. In some cases firms have simply withdrawn the chemical from the situation of concern. Programs of other Federal agencies are also relevant in this regard. For instance, OSHA sets Threshold Limit Values, or maximum ambient concentrations in the workplace, for chem icals of concern and requires a variety of safety measures to protect workers from exposure to chemical releases. Worker Right to Know requirements will soon exert pressure on firms to inform and protect employees against potential dangers. DOT requires appropriate hazard labeling and regulates trans portation of chemicals with acute hazardous characteristics. DOT requirements include proper classification of materials, shipping papers, markings on packages, and safety features and precautions for transport vehicles. States and localities also contribute in some measure to chemical accident prevention. Most localities have zoning ordinances, building codes, and fire codes. Some States impose annual inspection and certification*requirements for such sensitive equipment as pressure vessels. LAM 003655 DPMC-09746 26 Much of the capacity in place to prevent sudden accidental releases of acutely toxic chemicals is the product of corporate self-interest. Fear of a major liability suit, with its impli cations for corporate profitability and future insurability, is undeniably a powerful incentive to promote safe operations within the chemical industry. Self-interest motivates corporate prevention of smaller accidents as well, since such accidents lead to process down-time, implying lost production and profit. Concern for worker safety is another compelling motive for the installation of accident-control systems. Further, most firms are cautious about the introduction of hazardous chemicals to their plants in the first place. The cost of hazardous-chemical management is an important consider ation in comparing' the relative efficiency of alternative pro cesses. With accident liability a central concern of corporate management, both safety and efficiency tend to be prominent fac tors in decisions on chemical-process design. Although sophisticated safety systems characterize the operations of the major firms in the chemical industry, not every firm shares the safety consciousness of the industry leaders; implementation of safety systems can vary from firm to firm, and from plant to plant within a firm. The task of "lifting the bottom" performance in the field of chemical safety is a continuous one that must engage various sectors cf society. No simple or single solution is feasi-ole; LAM 003656 DPMC-09747 27 we must instead attack on many fronts. Industry associations are launching new training and information exchange programs; insurers are taking a much harder look at the risks specific plants impose. Professional associations are active. Citizens associations are taking responsibility to investigate the safe operations of local chemical facilities. All levels of govern ment are taking an active role to ensure chemical safety within their borders. Some have said an accident on the scope of Bhopal can take place only if a great many highly unlikely events occur all at once, or at least in rapid succession. Nevertheless, such a chain of unlikely events did take place at Bhopal. Because of safety measures already in place, the likelihood of such an occurrence is considerably lower here than in a developing country*. However, we can by no means dismiss the possibility. For that reason, despite all of society's effort to prevent accidents, we must be well prepared to deal with them if they occur. Emergency Preparedness and Response Although the United States has rarely experienced a truly catastrophic chemical-release accident, we, have in place a na tional system to prepare for and respond to any accident that might happen. It, too, divides responsibility among Federal, State, local, and private bodies. LAM 003657 DPMC-09748 28 The Federal role in emergency preparedness and response stresses planning, coordination, and technical support to State and local agencies. Within EPA's jurisdiction, CERCLA provides a mechanism for drawing together Federal response capabilities and coordinating comprehensive responses to imminent-hazard situations. The National Contingency Plan (NCP) prescribes Federal responses to releases into the environment of hazardous substances that may present an imminent and substantial threat to human health or welfare. Under the National Contingency Plan, the National Response Team (NRT) carries out national planning and response coordination and serves as the head of a twelve-agency. Federal emergencyresponse network. EPA serves as the NRT chair, and the Coast Guard as vice-chair. For each of the ten Federal regions there is also a standing Regional Response Team (RRT) comprising representatives of the NRT agencies, as well as State and local governments. Either the National or a Regional Response Team can be activated for emergency response. They marshal and coordinate Federal funding, equipment, personnel, and expertise during major incidents. EPA and the Coast Guard also maintain trained staffs both Regional Offices and Coast Guard districts across the country. These On-Scene Coordinators direct and coordinate response actions, summoning expertise and resources from otner Federal agencies as well as private contractors. EPA also provides technical support through an Environmental LAM 003658 UFnu-uy 29 Response Team staffed by specially trained scientists and engineers. States play a central role in emergency response, respond ing to more releases than do EPA and the Coast Guard. Local authorities are also key to the system. In most cases, in fact, the first public agencies to respond to a spill or release are the local fire and police departments. With respect to chemical accidents, the quickest (and, for that reason, most crucial) type of emergency response is that handled by the chemical firms themselves. Many emergencyresponse mechanisms are automatic, such as sprinkler systems or foam-release mechanisms, and automatic evacuation alarms or sirens. Many firms, too, set up internal facilities (including, in many cases, full-scale fire-fighting apparatus) and procedures that go into effect in the event of an emergency. Each employee is trained in the event of an emergency, has an assigned station and function, and can perform interchangeable functions as needed. Often, a number of neighboring industrial facilities organize themselves to provide mutual help in the event of a particularly serious emergency. The systems in place in the United States to ensure chemi- cal accident prevention, as well as emergency preparedness and response, are substantial and, on the record, largely effective. Nevertheless, they are far from perfect, and in the aftermath of Bhopal, it is appropriate to reexamine and, where necessary, reinforce them, since they represent a major element of our LAM 003659 DPMC-09750 30 national program to protect the public from air toxics. This reinforcement of the existing systems will be accomplished through the steps outlined below. V. Sudden, Accidental Releases: Needed Actions The Bhopal calamity has had a profound effect on the Ameri can chemical industry. Since December 1984 many firms that have long concerned themselves with safety have increased their efforts to prevent, prepare for, and respond to accidental chem ical releases, a fact that EPA has acknowledged in making our own plans to promote better emergency preparedness. For example, the Hazardous Materials Advisory Council (HMAC) is surveying the chemical industry to assess the state of emergency response preparedness and contingency planning and coordination with the public sector. The Chemical Manufac turers Association (CMA) has begun the Community Awareness and Emergency Response (CAER) program to establish or renew community emergency response plans and communications networks. CMA has also established the Chemical Response and Information Center (CRIC) to coordinate responses to requests for information on chemicals and train non-industry emergency personnel at the local level. Also, the American Institute of Chemical Engineers has established a Center for Chemical Plant Safety (CCPS) to address four issues: hazardous evaluation procedures, bulk storage and handling of toxic or reactive materials, plant operating procedures, and safety training. LAM 003660 DPMC-09751 31 Parallel with these private initiatives, EPA has begun dis cussions with representatives of several labor unions, regarding joint activity in information dissemination and worker safety training. Through these means, we expect a substantial number of workers to become trained in the hazards of toxic chemicals. There are, however, still further actions needed to forge an appropriate and comprehensive approach to enhance the nation's preparedness and ability to respond to environmental emergencies. The first two actions deal with better planning and coordination of existing activities; the last three involve a significant acceleration of ongoing efforts as well as some altogether new activities. ACTION STEPS 1. Improve State and Local Capabilities for Emergency Prepared ness and Response Emergency preparedness and response begin at the local level, where the initial reaction to an incident takes place. EPA intends to build State and local capabilities of such quality that the Federal government need respond directly only in extraordinary circumstances for which State and local authorities are inadequately equipped or ineffective in their response. EPA is dedicating 20 workyears on its Regional staff to enhance emergency preparedness and response at the Federal, State, anc local levels. LAM 003661 DPMC-09752 32 With the support and encouragement of many States, EPA's Regions are offering a variety of services to help prepare States and localities anticipate and respond to incidents, including: o Guidance on suggested standards for contingency planning; o Technical assistance in the development of contingency plans themselves; o Guidance on how to test contingency plans through exer cises built around field simulations of hazardous releases; and o Coordination and delivery of increased training for State personnel. 2. Improve Federal Coordination for Emergency Preparedness and Response Within its Office of Solid Waste and Emergency Response, EPA will assign a central staff to coordinate EPA policy on emergency preparedness, as well as response to major emergencies with the various national program and Regional offices and with other Federal agencies involved. The Office will serve as a central point for information gathering and dissemination, and to facilitate immediate decision-making when warranted. To support Federal emergency planning, EPA's Office of Emergency and Remedial Response is analyzing the notification data bases of the National Response Center (NRC); the Hazardous Materials Information Reporting System (HMIR) of the Department LAM 003662 DPMC-09753 33 of Transportation; the Pollution Incident Reporting System (PIRS) of the U.S. Coast Guard, and other Federal and State information sources. This analysis seeks patterns and trends in incidents reported in 1983-84. The results will be used by both the National and Regional Response Teams to direct Federal assistance to those areas with the greatest incidence of release. 3. Step Up Enforcement of Chemical-Hazard Notification EPA is undertaking more vigorous enforcement against those who fail to report under CERCLA Reportable Quantities regulations. OSWER will also work with the Criminal Enforcement Office of the National Enforcement Information Center (NEIC) and the Criminal Division of the Department of Justice to develop criteria for identifying violations that call for criminal.enforcement. EPA's Headquarters Office of Solid Waste and Emergency Response, and the Regional civil enforcement and removal programs, will assist in the preliminary screening of releases to identify potential violations that merit further investigation. EPA has also proposed to Congress amendments to CERCLA that would toughen criminal penalties and for the first time provide civil penalties for notification violations. Under EPA's proposal the Agency could impose civil penalties through an administrative process without the delay occasioned by the need to involve the Department of Justice or the United States Attorney. In situations where Reportable Quantities notifications reveal a pattern of suspected chemical mishandling, EPA will also constcer ;c:r.mg with other Federal agencies and affected LAM 003663 DPMC-09754 34 States to inspect plants with apparent safety problems. EPA is also requesting authority from the Congress under Superfund to respond to a spill of a substance with hazardous characteris tics, even when the substance is not officially listed as a solid waste. Similarly, under TSCA, EPA is stepping up implementation and enforcement of its $8(c) and S8(e) programs. The Agency is placing increased emphasis on monitoring compliance.in this area during FY 1985 and will further strengthen this program in FY 1986. EPA has directed its Regions to conduct 8(c) inspections 'in conjunction with other TSCA manufacture inspec tions this fiscal year. Improved inspection guidance and inspector-training programs are also under development. In instances when, companies keep indadequate records or fail to maintain required records, the Agency may take criminal or civil adminstrative action under TSCA. EPA also conducts a compliance monitoring program to ensure compliance with 8(e) notification requirements, and may initiate criminal or civil administrative actions where violations are found. To date, the emphasis under 8(e) has been on follow-up to "tips" and other complaints. The Agency is reemphasizing routine 8(e) inspections, particularly in conjuction with 8(c) inspections, where records on significant adverse reactions may trigger reporting under 8(c). lam 003664 DPMC-09755 35 4. Issue An Acute-Hazards List EPA has begun to develop a list of those chemicals that could lead to accidents resulting in serious acute exposures threatening human life and health. Most existing lists are based on criteria other than those that would indicate the potential for dispersion of toxic chemicals. They are often unacceptably narrow, too, in that they do not include all chemicals of potential concern, such as process intermediates. EPA's new list will represent EPA's advice to the public as to which chemicals warrant special attention. It will be modified and amended as further experience presents new and useful data. Upon completion of the list in late summer, EPA will take the following specific actions: o Provide the list to State and local governments, industry, public interest groups, and emergency and medical officials; o Develop and supply guidance in the use of the list to appropriate State and local officials and organizations as a focal point for contingency planning; o Supplement the written guidance with workshops, training programs, and technical assistance through Agency staff and the Regional Response Teams. EPA will also review the Reportable Quantities regulation and revise it as appropriate to be consistent with this list. LAM 003665 DPMC-09756 36 5. Advance Efforts to Develop a Community Right to Know Program The interest in local emergency preparedness and response has led to several proposals for Community Right to Know legis lation. EPA endorses in principle the need for a program in which chemical firms disclose certain information to communities about hazardous substances on-site, although it is as yet unclear how such a program should be structured. However, when fully developed, such a program would serve as an important basis for realistic emergency planning at the local level. The Acute-Hazards List will prove useful in this regard. To the extent possible, EPA will provide data about listed chemicals to appropriate officials, including whatever may be known regarding their location. Although it will be the respon sibility of individual communities, working together with industry, to determine the presence of these chemicals locally, EPA will respond to inquiries as to the risks they may present and the proper level of contingency planning to be undertaken. VI. Conclusion From the vantage point of the eighties, the challenge of air toxics seems complex, as did the probl'em of conventional pollutants from the perspective of 1970. But this problem, like the more traditional form of pollution, can be substantially reduced oy a similar application of national will and cooperation. LAM 003666 DPMC-09757 37 The enactment by Congress of the toxics-control laws of the seventies has led to fundamental change in the nature, of environmental action at the national level. Through the administration of these statutes, we have learned some essential lessons: o The need for priorities. Toxic substances are an intrin sic component of modern life. Since it is not feasible to eliminate them entirely we must instead target our efforts to treat or remove those substances that can be effectively controlled and that are responsible for the greatest human harm. o The need to account for cross-media transfer. Removing a substance from the air may be fruitless if it is merely shifted to land or water, and vice-versa. We must consider all media, even as we concentrate on one. o The need to use the right tools. Rote application of a single program authority will not solve the prob lem. We must consider all the tools available and select the appropriate combination to deal with a situ ation as complex as that posed by environmental toxics. o The need to involve States and localities appropriately. States have a better understanding of locally significant problems than does a national agency. We need to divide the iabor with States and localities so that each level of government is able to make its unicue contribution. LAW 003667 DPMC-09758 38 o The need to protect against immediate hazards. Long-term risk from cancer is the natural focus of a public health agency, but immediate hazards from a sudden release of acute toxics demand rigorous attention as well. EPA has developed a comprehensive program for air toxics which originates with a revised understanding of the nature and source of the air-toxics problem and which draws on these essential lessons. As we learn more about this problem, we will, of necessity, adjust our strategy. In the meantime, however, EPA is committed to vigorously implement the most effective approaches of the past, while immediately initiating the new activities identified in this report. EPA solicits the support of the American public. State and local governments, industry, and the Congress as we work to deal * effectively with the air-toxics problem. By doing so we can all fulfill our demonstrated national commitment to protect the public health and the environment for all Americans. LAM 003668 DPMC-09759 SPECIFIC ACTIONS AND INITIATIVES TO REDUCE RISKS FROM AIRBORNE TOXICS The following list indicates actions and initiatives discussed above and provides time-frames for accomplishing the work. Please consult the text of the Strategy at the page cited for a more specific reference. Approximate date of: initiation completion page New and Expanded Actions to Control Air Toxics 11 o Routine Releases: National Regulation 12 1. Regulate Stationary Sources of Multiple Tbxic Pollutants - Complete decisions on 20-25 specific pollutants. underway Dec. 1985 - Assess and regulate where appropriate on a source-category basis: -- coke oven emissions o listing action .......................................................................... o NESHAP proposed......................................................................... o NESHAP issued .......................................................................... FY 1984 FY 1986 FY 1987 - Regulate source categories emitting * multiple pollutants using New Source Performance Standards: -- synthetic organic chemicals industry (4 source categories) Underway FY 1985 & FY 1986 -- residential woodstoves FY 1985 FY 1988 - Complete review of need for and ifneeded. appropriate regulatory mechanism for regulating gasoline marketing. Underway FY 1966 - Establish RCRA standardsfor air emissions from hazardous waste treatment, storage and disposal facilities. FY 1984 FY 1988 2. Regulate Mobile Sources of the Most Hazardous, Air Toxics 15 - implement standards for: -- evaporative hydrocarbons from trucks Underway FY 1985 -- particulate emissions from light vehicles Underway FY 1967 -- particulate emissions from heavy duty ver.icles Underway FY 1968 LAM 003669 DPMC-09760 2- - Approximate date of: initiation coupletion age o Routine Releases: National Regulation (cont'd) 2. Regulate Mobile Sources of the Most Hazardous Air Toxics (cont'd) - continue review of appropriateness of a total ban on lead in gasoline - consider controls on: -- vehicle refueling -- fuel volatility -- diesel fuel quality - propose standards for health effects testing of fuel and fuel additives - propose standards for methanol-fueled vehicles 3. Perform Studies to Support Future Regulation of Sources of Multiple Toxic Air Pollutants - perform a study to ascertain which source categories are emitting several pollutants of concern. Ongoing FY 1986 FY 1985 FY 1987 FY 1987 FY 1985 FY 1985 N.A. N. A. N.A. N.A. FY 1988 FY 1986 FY 1986 15 o Routine Releases: State Control Programs 1. Build State Air-Toxics Programs - Set aside funds within State program support grants for support of State air toxics programs. Ongoing - Set aside S3 million fran other areas to assist States as they initiate this effort. FY 1985 - Design a model State-level air-toxics program. FY 1985 - Establish a computerized Air Toxics Information Clearinghouse with direct State access. FY 1984 2. Pranote State Control of Air-Toxics Problems of Local Concern - Negotiate the form of this cooperative Federal/State/local program with the States. FY 1985 - Identify first group of pollutants anc source categories to be referred for State action. FY 1985 16 FY 1986 FY 1986 FY 1986 FY 1985 FY 1985 i LAM 003670 DPMC-09761 -3- o Routine Releases: State Control Programs (cont'd) 2. Promote State Control of Air-Toxics Problems of Local Concern (cont'd) - Provide financial support to States (to do necessary assessments and to establish control requirements, where needed]. - Provide technical guidance including information on health effects, emissions, control technology and exposures. - State and local agencies evaluate the sources identified and control them if necessary. - EPA audits State activities. - EPA will provide public information on matters referred and State decisions. Approximate date of: initiation completion page 17 FY 1986 Ongoing FY 1986 Ongoing FY 1986 Ongoing FY 1986 FY 1986 Ongoing Ongoing o Routine Releases: Intergovernmental, Multi-Media Regulation of Toxic Pollutants 1. Area projects to explore the use of multi-media approaches to the assessnent and control of toxics risks. - Proiect #1: Add to the project already substantially completed in Philadelphia by examining exposures to and risks from metals, organic particulates, and organic gases. - Project #2: Add to the project now underway in Baltimore. This project considers eco logical effects as well as health risks associated with toxic exposure. - Project #3: Conduct a new study (in an area yet to be selected) to examine the effects of pollution on human health and the environment leading to an assessnent of cost-effective controls. - Conduct a personal exposure study using Total Exposure Assessnent Methodologies anc the Toxics Air Monitoring System. FY 1985 FY 1985 FY 1986 FY 1986 FY 1986 FY 1937 FY 1988 FY 1988 19 LAM 003671 DPMC-09762 4- - o Routine Releases: Intergovernmental, Multi-Media Regulation of Toxic Pollutants (cont'd) 2. Risk-Based Screening of Geographic Areas - Devise methodology for identifying areas that would be candidates for future sitespecific studies. Approximate date of: initiation completion page FY 1985 Uncertain 21 3. Adapt Analytic Methods for State Air-Toxics Programs - Continue to work with States to assess risks and costs from multiple pollutants and across media. FY 1985 Oigoing 22 o Sudden, Accidental Releases 1. Improve State and local capabilities for emergency preparedness and response. - Dedicate 20 workyears in the Regional Offices to act through Regions and RRT to provide the following to States and localities: o assistance in the review of contingency plans, o coordination and delivery of training, o guidance on how to test contingency plans in the context of field simulations of hazardous material releases. FY 1985 Ongoing 22 31 FY 1986 FY 1985 FY 1986 Ongoing Ongoing Ongoing - To support the above activities, use the recent survey of the National Response Team on the status of emergency preparedness, contingency planning, training, and equipment to identify deficiencies in capability and direct Federal assistance to State and local governments. FY 1985 FY 1986 LAW 003672 DPMC-09763 -5- V o Sudden, Accidental Releases (cont'd) 2. Improve Federal Coordination for Emergency Preparedness and Response ' - Establish an integrated EPA coordinating staff to respond to major emergencies with the various national program and Regional offices, and with other Federal agencies. - Analyze notification data bases to identify patterns and trends in incidents reported in 1983-84, in order to direct Federal assistance to areas with the greatest incidence of release. 3. Step up Enforcement of Chemical Hazard Notification - Step up enforcement of Reportable Cuantities Notification requirements using the current statutory provision for criminal penalties. -- Work with the Department of Justice to develop criteria for identifying violations that call for criminal enforcement. -- Set up system for preliminary screening of release incidents to determine which merit further investigation. -If Congress provides the necessary statutory authority, establish a civil enforcement program. -- Request authority frcm Congress for civil enforcement of reportable quantities violations. Approximate date of: initiation coupletion page Underway FY 1985 32 FY 1985 FY 1985 FY 1985 33 Ongoing FY 1985 FY 1986 FY 1986 Ongoing FY 1985 N. A. LAM 003673 DPMC-09764 6- - o Sudden, Accidental Releases (cont'd) Step up Enforcement of Chemical Hazard Notification (cont'd) - Explore the potential for joining with other Federal agencies and affected States to assess plant safety (with regard to the potential for accidental releases) when conducting inspections of the plants to assess compliance with other regulatory requirements. - Request authority from the Congress under Superfund to respond to spills of substances with hazardous characteristics which are not officially listed. - Step up enforcement of the requirements of 8(c) and 8(e) of TSCA. -- Increase emphasis on compliance monitoring. -- EPA Regions conduct 8(c) inspections in conduction with other TSCA manufacturer inspections. -- Eevelop improved inspection guidance and inspector training programs. -- Take civil or criminal enforcement action where companies fail to maintain required records or maintain inadequate records. -- Increase monitoring for compliance with 8(e) reporting requirements, primarily in conjunction with 8(c) inspections. Approximate date of: initiation completion page FY 1985 FY 1986 33 FY 1985 N.A. FY 1985 Ongoing FY 1985 Ongoing strengthen further in FY 1986 Ongoing FY 1985 FY 1985 FY 1985 Ongoing FY 1985 Ongoing LAM 003674 DPMC-097 65 -7- o Sudden, Accidental Releases (cont'd) 4. Issue an Acute-Hazards List - Develop list which reflects both degree of hazard of the chemical and likelihood of release (i.e., due to volatility, etc). - Provide the list to State and local governments, to industry, to public interest groups and to emergency and medical officials. - Develop and supply guidance on the use of the list to appropriate State and local officials and organizations as a focal point for contingency planning. - Supplement the written guidance with workshops, training programs, and technical assistance through Agency staff and the Regional Response Teams. - Review the Reportable Quantities regulation and revise it as appropriate to be consistent with the list. - Use the list to support current and future ccmmunity rignt-to-know programs. Approximate date of: initiation caroletion Dace FY 1985 FY 1985 35 FY 1985 Ongoing FY 1985 FY 1986 FY 1986 Ongoing FY 1986 Ongoing FY 1985 Oigoing LAM 003675