The U.S. EPA has been reimbursing local governments for hazmat responses since 1986, but it seems that many LEPCs and other eligible groups are still unfamiliar with the program.  From the LGR website: “In the event of a release (or threatened release) of hazardous substances, EPA may reimburse local governments for expenses related to the release and associated emergency response measures.  The Local Governments Reimbursement (LGR) Program provides a ‘safety net’ of up to $25,000 per incident to local governments that do not have funds available to pay for response actions.”  So with over $3 million in reimbursements awarded to date, how do you get your money back?  It really is not all that complicated, but first we need a basic understanding of the relevant terms and requirements.

Guidance on the Use of Chemical Countermeasures on Inland Oil Spills

The U.S. Environmental Protection Agency (USEPA) recognizes the major role of local government responders, such as firefighters, as the first line of defense for mitigating threats to public health and the environment from spills of oil and hazardous substances, and tries to provide them with the tools necessary to safely and effectively mitigate such incidents.  Chemical countermeasures (CCMs) are one of those tools, but their use must be authorized and carefully managed.  This article describes that process where countermeasures are proposed for use on inland events such as fuel spills that may affect navigable waters.  These may include surface waters and conduits to them, including road ditches and storm drains, though the exact definition remains in flux.

Video (with audio) from an EPA cleanup site in east Texas.  Cans of crystallized ether had to be exploded on-site.  This material is shock-sensitive, has to be handled like an unstable explosive and is too dangerous to move anywhere else.  The solution here was a “blow-in-place” scenario.  Our ATF bomb tech put the cans in shallow holes, rigged them with a small donor charge and we remote-detonated them.

Refer to the EPA web site at http://www.epaosc.org/site_profile.asp?site_id=06RZ for detailed information.

EPA FOSC Homepage (EPA Federal On-Scene Coordinators, responses and cleanups)

KAM (Ky Association of Manufacturers)

NIOSH Pocket Guide (e-version of latest Pocket Guide)

DOT ERG (e-version of DOT Emergency Response Guidebook)

EPA – LMOP (EPA Landfill Methane Outreach Program)

Proposed GHG Rule (Proposed EPA rule on greenhouse gas reporting)

Drug-Free Workplace Advisor (Wizard for DFWA program)

ATSDR – ToxFAQs™ Hazardous Substance Fact Sheets (Detailed toxicology info)

Available CFR Titles on GPO Access (Search for CFRs)

Occupational Safety & Health Administration (OSHA Home Page)

SIRI MSDS Index (Search for MSDSs)

Independent audits and reviews are one very good way of evaluating a program objectively and accurately to determine vulnerabilities and risk. These plans and programs come in many forms and serve many purposes, ranging from EPA and OSHA compliance and Emergency Action Plans to Risk Management Plans, Worst-case Scenarios and Off-site Consequence Analysis to SPCC and RCRA contingency plans.

A related critical risk management tool follows an environmental incident, such as a spill or explosion, and is frequently referred to as an Emergency Response Review or “Hotwash.” Following the review, you may be asked to develop a “lessons learned” or “after-action report” to help do the job better and safer the next time. EPA or other Agencies often require this following an emergency response in which they were involved.

This is our Pandemic Influenza Control Plan.  Please feel free to use it at your facility, or to distribute it to others.

IESO, LLC Pandemic Influenza Control Plan

Keep up with the latest official information at the Centers for Disease Control (CDC) site, and don’t hesitate to contact us for support in developing and implementing a plan at your facility.

Our Senior Risk Manager, Dr. Scott Harris, was the Region 6 EPA lead for BioWatch, a national sentry program for early detection of biological WMD events. He served on national workgroups and developed BMPs and Agency capabilities for surveillance, first response, hotzone sampling and decontamination procedures, and authored response plans for numerous major cities and international airports.  Scott led and participated in biological WMD exercises and responses, and provided related training to state and federal agencies.

On Being an EPA Superfund PRP

CERCLA, more commonly known as Superfund, allows EPA’s Emergency Response Program to take or compel action by others at sites contaminated or potentially contaminated by hazardous substances, pollutants or contaminants, and then recover costs associated with those activities.  Whether an emergency response or a longer-term investigation and cleanup, EPA uses an Enforcement First Policy (EFP) to identify potentially responsible parties (PRPs) to cover the cost of any action underway or anticipated.  The hunt for you will be thorough, and there is a specific 381-page manual to guide it.  There is even a directory of Agency experts (PRP Search Enhancement Team) available to support the effort.