Apoyo a los proyectos EMPACT a nivel Europol

There is another set of rules enacted by the federal government for the protection, not of workers, but for other stakeholders that may be affected by chemicals used at waste-water treatment plants. These stakeholders are the surrounding communities that may be affected by any chemical releases. This set of rules is called the Superfund Amend-ments and Reauthorization Act of 1986, also known as SARA or the Emergency Plan-ning and Community Right-to-Know Act (EPCRA). The latter is actually a free-stand-ing law included in SARA, commonly known as SARA Title III. The purposes of the regulations are to encourage and support emergency planning efforts at the state and more localized levels, so that information concerning potential chemical hazards is known and emergency response plans can be formulated.

Why is this necessary? One would think that somewhere in state records are the design criteria and process records for all wastewater plants and the chemicals they use; however, this is not the case. In one instance, a wastewater treatment professional attempted to obtain authorization that would have changed the treatment process of a small mountain wastewater treatment plant. The county had lost all records that such a facility existed. Later, when going to the state, the professional found that the original site and process applications had been lost and discharge permit renewal applications contained none of this information because they were incomplete as filed. Before com-puters were used, many databases were manually kept on hand-designed graphs, charts, and checklists, and many regulatory agencies do not have the budget to trans-fer hand-kept files into state-of-the-art relational databases; these conditions can create problems when attempting to access information. In addition, problems can arise in plants where the operations staff may have changed the processes internally and failed to mention changes on permit update paperwork.

The EPCRA rules are an amendment of the Comprehensive Environmental Re-sponse, Compensation, and Liability Act (commonly known as Superfund) regulations of 1980 (CERCLA, 1980). The U.S. Environmental Protection Agency (U.S. EPA) (Washington, D.C.) administers the EPCRA. States create emergency response com-missions who, in turn, set up emergency planning committees and districts. These committees typically consist of a representative of the emergency response personnel, state and county officials, environmental personnel, fire departments, and law enforce-ment. It is their responsibility to ensure that all potentially hazardous materials used in the district are accounted for and that there is a solution in the event of a hazardous re-lease. For example, very large municipal plants may have the trained personnel to deal with chlorine gas leaks safely, but many small communities cannot afford the training of personnel, let alone the materials, tools, and staff to handle emergencies, so they

coordinate with districts to make sure that trained personnel exist nearby and that they know who to contact. Title III exists so that communities know what hazardous mate-rials are produced, transported, or used by industries and services so that emergency planning and response activities can be coordinated. The law covers industries and businesses that produce, store, buy, ship, or use hazardous materials.

The first installment of these regulations, or Tier 1, was enacted in the 1980s and re-quired that producers and users of over 4500 kg (10 000 lb) of chemicals report the loca-tion to local regulatory agencies. Later, the second, more inclusive series of regulaloca-tions, Tier 2, were enacted. The level of chemicals that a plant used were much lower, requir-ing reportrequir-ing to appropriate local special emergency response districts and the state.

Wastewater treatment facilities are typically involved in the use, storing, and ship-ping of hazardous substances. U.S. EPA publishes a list of Extremely Hazardous Sub-stances (EHS) (U.S. EPA, 2001), including the quantitative limits, which are typically 230 kg (500 lb) or the threshold planning quantity, whichever is lower. For example, chlorine gas has a limit of 45 kg (100 lb), which is far less than the typical 230-kg (500-lb) limit. Quantitative limits for other hazardous chemicals (non-EHS) are typically 4500 kg (10 000 lb).

Some examples of hazardous chemicals used at wastewater treatment plants are chlorine gas, alum, ammonia, sulfuric acid, sulfur dioxide, methanol, lime, and sodium hydroxide. Complete lists can be found on the Web or by contacting the local authority.

It is important to become familiar with your local district regulatory interface per-sonnel. They will help you set up emergency plans that are economical and reflect a concern for public safety. They will also typically be the first contact in case of emer-gency. Under SARA and EPCRA, local officials have the decision-making power to lower quantitative limits for hazardous chemicals if they feel that, for some reason, they pose a specific risk because of geographic or localized conditions. In many areas, this district, fire district, and law enforcement departments all have specific laws and jurisdictions that may overlap and may not be the same. For example, a fire district may have more stringent regulations for chlorine than does the county emergency re-sponse district or state regulations. In one case, a water treatment facility had a much lower chlorine storage limit than another because a grade school was built next to the plant and the amount of chlorine gas that could be stored there was drastically reduced when the school was ready to open. It is important to know your local regulatory agen-cies, find the most restrictive regulation, and be sure that you are in compliance with it.

Notification of hazardous chemicals was mandated in 1986. Before that, specific sheets were designed; a Material Safety Data Sheet (MSDS) was allowed to be submit-ted. Currently, there are forms that have been specifically designed for SARA Title III Tier 2 regulations (Figure 5.1). These forms are typically submitted annually to the

ap-propriate agencies. If the regulatory agency does not provide a copy of the form, it can be found on the Web at sites such as local county Web sites (i.e., http://www.co.ha .md.us/lepc/tier2form.html).

There are responsibilities that go beyond basic reporting that typically must be fulfilled. An emergency communication protocol needs to be established. This in-cludes who should be called, in which order, in case of emergency. This contact infor-mation and an emergency action plan should be laminated and displayed in a promi-nent place that will be easy to get to, near a telephone. Emergency response must be practiced so that, in case of emergency, there will be few loose ends that could lead to problematic situations. It is up to management to coordinate these practices with the FIGURE5.1 Tier 2 document (http://www.co.ha.md.us/lepc/tier2form.html).

agencies designated in the emergency response plan. Reviews and practices will lead to the elimination of potential problems before they can happen. It is important to note that, while the topic of emergency response plans is being discussed here under chem-ical emergencies, there are many other emergencies, such as flood, power outages, avalanche, and effects of vandalism, that need to have established action plans. The plan should include specific actions to alleviate the emergency, identification of who should perform the actions, a communication tree for handling the emergency and no-tifying the public, and a method for resolving the situation. A basic list of contents for an emergency response plan follows:

• Identification of the facilities and the transportation routes for extremely haz-ardous chemicals. This would also include transport routes for biosolids and sludge, when being transported near bodies of water.

• Emergency response procedures.

• Designation of community and facility coordinators to carry out the emergency response plan.

• Emergency notification procedures.

• Methods for determining if a chemical release has occurred and the probable affected area and population.

• Description of the community’s emergency response equipment and identity of responsible programs.

• Evacuation plans.

• Description and schedules of a training program for emergency response personnel.

• Methods and schedules for carrying out emergency response plans.

It is important to remember that any paperwork of this nature becomes public record.

Often, diagrams and maps of where hazardous chemicals are kept are submitted with emergency response plans and can be quite detailed. As reported on National Public Radio KCFR 90.1 FM in Denver in April 2003, many of these maps were found on con-fiscated terrorist computers. Some of the sites detailed railcars of chlorine gas at waste-water plants near sensitive population centers. Whenever details of hazardous chemi-cal storage become part of the public record, plans for security of these chemichemi-cals need to be made. In 2004, the U.S. Congress passed a law that requires drinking water facil-ities to perform vulnerability assessments of key chemical holding areas, water reser-voirs, treatment facilities, and pumping stations and submit them to regulatory agen-cies. Because of primacy issues in many states, these laws have become state code in many areas. Please be aware that the states may have primacy in vulnerability

assess-ment issues and that, nationally, the Homeland Security Departassess-ment has taken the lead, instead of U.S. EPA. These are fairly detailed and are designed to thwart terror-ists. With this in mind, there will be a good amount of security around these vulnera-bility assessments. The draft before Congress in 2005 of the Wastewater Treatment Works Security Act (Jim Jeffords, I-VT) included the same type of legislation for waste-water facilities.

In designing emergency response plans, most of the material mentioned is related to the EPCRA. However, when making your emergency response plan, it is important to remember that there are other types of emergencies. These can vary, from sanitary sewer overflows and potential watershed contamination, to floods, tropical storms, earthquakes, and extended power outages. All of these are very real possibilities and, while some are unlikely in some geographic areas, there is a need to be creative when considering all the things that could go wrong so that you will not be unprepared as a public health professional in an emergency situation.

OCCUPATIONAL SAFETY AND HEALTH