North Central Florida Local Emergency Planning Committee comment on proposed RMP "worst case scenario" rule.
Return to main RMP proposed rule page and send your own comment.
May 12, 2000
Environmental Protection Agency
Office of Air and Radiation
Docket and Information Center
Ariel Rios Building, M6102
1200 Pennsylvania Avenue NW
Washington DC 20460
Attn: Docket No. A-2000-20
Dear Sirs/Madams:
Today the North Central Florida Local Emergency Planning Committee voted
to
forward the following comments on the proposed rule on public disclosure
of
OCA data. We concluded that the rule generally achieves the difficult
balance between decreasing the risk of accidents through public
disclosure
versus not increasing the risk of a terrorist attack through enhanced
targeting.
We agree with EPA that maximum accident prevention results are best
achieved
at the local level, especially under the leadership of an active LEPC.
Two
suggestions are offered that will make it easier for LEPCs in general to
participate in providing enhanced chemical safety information to the
public.
We would also like to commend the EPA for including solutions to many of
our
OCA-related concerns.
First, we recommend EPA or the delegated agency provide LEPCs upon
request,
free of charge, a binder with OCA information on all of the 112(r) sites
within an LEPC district. More LEPCs will be willing to serve as local
reading rooms if we just have to show the information, rather than also
being required to put the book together.
Second, the "Risk Indicator System" is a great idea. The public needs to
be
able to type in an address and find out where they can learn more about
the
specific risks to home or school. The EPA must make this procedure easy
for
all fire departments and LEPCs in order for "enhanced access to local
OCA
information" to become a reality. We believe that local officials
should
not have to figure out which facilities triggered a "yes" indicating that
an
address could be at risk.
The Rule must avoid creating a situation where the public can learn on
the
internet that they are in a danger zone, but are told they must drive
hundreds of miles to a reading room to learn from which facility and
what
chemical. We believe that it is critical that in responding to queries,
the
EPA should provide the names of all facilities that have a release
scenario
that could impact that address. For example, "Click here and EPA will
send
you a list of facility names and who to contact for additional
information."
This is necessary to avoid creating problems at the local level.
EPA Docket No. A-2000-20
page 2
May 12, 2000
Ideally, the LEPC should be notified when facility names are provided by
the
EPA. We concluded that RMP*Review will allow only the more
technologically
advanced organizations the ability to locally answer the key question of
which facilities could impact a given address.
The proposed rule does a good job in addressing the following
OCA-related
concerns of our LEPC:
- Members of LEPCs, fire departments and SERCs that voluntarily use or
provide access to the OCA data are not subject to criminal liability and
penalties.
- The rule clarifies that, "a covered person may convey, orally or in
writing, the OCA results for a facility..."
- The EPA will provide updated LEPC contact information to the public.
We
have been unable for two years to have our contact information corrected
on
RTK Net.
- LEPCs are offered additional tools to help do our job of increasing
chemical safety in the community, but are not being burdened with an
unfunded mandate.
For your information, at the last meeting of the Florida LEPC
Chairs/staff
group, the issue of updating the Florida SERC criteria for LEPC plans
once
again came up. There was agreement that after the OCA issue is resolved
that updated hazmat planning guidance is needed. One issue is that Green
Book vulnerable zones (VZs) required in LEPC plans should be more
consistent
with Section 112(r) VZs reported by the same facilities for the same
chemicals. We suggest that RMP*Comp be considered as the default model
for
preparing Section 302 hazards analyses required in LEPC plans.
Thank you for your consideration of our comments on how to best use OCA
data
to help increase chemical safety in our communities. If you have any
questions regarding these comments, do not hesitate to contact LEPC
staff
Dwayne Mundy at (352) 955-2200 x108 or email mundy@ncfrpc.org.
Sincerely,
John Hudson,
Chairman
www.ncflepc.org
xc: Florida SERC and LEPCs
Return to main RMP proposed rule page and send your own comment.
