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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.

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