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Top-Twenty Texas Counties Ranked by Total Toxic Releases for 1988. Jefferson Harris Brazoria Calhoun Galveston Victoria Orange ElPaso Nueces Tarrant Hutchinson Dallas Brown Harrison Ellis Potter Ector Jasper Guadalupe Travis 145,089 539 123,661 545 122,892,064 83,004,046 57,911,864 19,630,665 18,250,995 12,842,257 12 268,629 9 217..908 9,106,977 9,052,775 9,034,016 8 947,059 6,947,803 5 728 444 4,903,5;16 4,556.034 4,200,223 4 170 380 Source: Toxic Release Inventory Program 1988 Report, Texas Water Commission, March 1991. new openness policies. Most do not. Some LEPCs do not know exactly what they have recieved from whom. For example, the Brown County LEPC, which just turned in its 3M emergency plan, now has no current members, no meetings and no information management program. “We are not really a committee,” said Patsy White, administrative assistant to the Brown County Commissioner’s Court. “Everything goes to the county judge and he doesn’t open it but sends it on to me. And I open it and say, I sure am glad to have this. Now what do I do with it?” Like many LEPC managers, she files it. “I have the Tier II forms [chemical lists] in my office,” White said. “We haven’t done anything with them. Hopefully we will do better in the next six months, now that we’ve got our plan.” The reporting requirements are usually fulfilled on a voluntary basis, and Texas LEPCs rarely collect or distribute detailed risk maps for any facility. Billy Smith of Jaspar County said, “We’re taking what we get right now.” None of the facilities surveyed collected worst case scenarios. Deputy Emergency Management Coordinator Pat McAllister, of Ector County, took the local yellow pages and tried to identify all the facilities that ought to turn in chemical inventories and MSDS forms, but could not be sure that her list was complete. Danny McLerran, chair of the El Paso LEPC said that they have not forced companies to supply SARA information nor has it collected facility emergency plans. The LEPCs, under SARA Sec. 325 may assess penalties of $25,000 for each reporting violation, and sue facilities for failure to provide none of the LEPCs surveyed have ever filed civil suits or fined manufacturers. “They would rather talk people into it [compliance],” said Les Breeding. “Because of the makeup of the committee there’s no way anyone is going to agree to assess fines.” In order to produce a useful emergency plan, the National Response Team’s Hazardous Materials Emergency Planning Guide suggests that LEPCs take advantage of their broader powers to request information under [LEPC] the owner or operator of the facility shall promptly provide information to such committee necessary for developing and implementing the emergency plan.” national body of 14 federal agencies responsible for coordinating federal response to oil and hazardous materials emergencies, notes that requests should include descriptions of those situations that pose the most serious threat of damage. “Location maps and charts are an excellent means of depicting this information.” Emergency plans should analyze the extent of vulnerable zones for hazardous population, property and sensitive environmental areas near particular releases. The 6 JUNE 14, 1991 NRT adds that worst case scenarios provide valuable information for risk analysis. Said Pat McAllister, “We’ve done a hazard analysis for all the hazards in the community as a whole, but not for each neighborhood or facility. That’s where most of us are lacking.” No LEPCs surveyed actively sought to reduce.the amounts of highly toxic chemicals at area facilities. Nor did they in -corporate detailed internal safety audits, often created by major companies for vulnerable areas, into their emergency planning. LEPC’s do not ask for or develop worst case scenarios for hazardous accidents, although they have the authority to do so under federal law. Who’s Counting? LEPCs often do not know if every facility with hazardous chemicals on site reports them, or if it reports accurately. Sometimes the amounts and container sizes of chemicals listed in the emergency plans are simply in correct. , Travis County LEPC submitted a plan to the SERC that was basically the plan for the City of Austin put together previously under the Texas Hazardous Materials Act \(minutes from their only meeting in 18 months focus city emergency plan notes that the Thomas Green Water Treatment Plant downtown has 15 one ton cylinders of chlorine and 3,500 pounds of ammonia. The plant manager claims that they store 18 cylinders and 5,625 pounds of ammonia. Listings of container sizes and amounts in the Travis County plan for other waste-water treatment plants were also inaccurate, as were the contact names and a phone number. “Obviously there is a discrepancy,” admitted Steve Collier, director of the Emergency Management Office for the City of Austin. “I’m not sure when that plan was submitted. Changes have occured and we have not been made aware df them.” According to Collier, the data is often entered from older lists and not checked, and then rarely updated. “We get the information but we don’t actually call those people up. We get some of it from the Chamber. It [the plan] needs to be updated more often than it is.” The Emergency Management Office is currently in the process of updating the plan, and Collier promised to check all the discrepancies in its Critical Facilities Database. However, the information in the emergency plan may never be used by any emergency responding agency. Collier described the plans created by the LEPCs as reference documents for use by other planning agencies. “The difference between 10 and 20 tons of material on site is not significant,” he said. “We use it to assess the general magnitude of the problem.” Run By the Experts Those LEPCs run out of a fire department office often have strong safety response development programs. Emergency managers and fire department officials identify and try to correct the deficiencies in the current emergency response structure as they see them. Typically, however, they do not have the time or funding to provide organized public information as required of LEPCs. Fred Millar notes, “If you emphasize expertise you run the risk that the fire chief or other officials will not release the information to the public. Congress did not intend this to be a replication of the emergency planning establishment. Here volunteers from the community can start something new. It’s a democratization of emergency planning.” Danny McLerran, emergency manager and member of the El Paso LEPC, emphasizes that his loose and unofficial group has both created a hazardous materials emergency plan and revised the fire code to create a hazardous materials ordinance. It has implemented a fee system to run the hazardous material program and mapped transportation route. Public information, however, has not recieved much