2009 LEPC CONFERENCE Pulse of the LEPCs Challenges for LEPC Compliance Ian Ewusi IERC Field Representative.
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2009 LEPC CONFERENCE Pulse of the LEPCs Challenges for LEPC Compliance Ian Ewusi IERC Field Representative Past Challenges Present Challenges Future Challenges Challenge 1: Statutory Authority State laws County ordinances City ordinances EPCRA Regulations AMENDMENTS to 40 CFR Parts 355 and 370 (Proposed 6/8/98, finalized on 10/17/08 and published 11/3/08 Emergency Planning—Sections 302 & 303 [40 CFR Part 355.30] Amended Emergency Notification—Section 304 & Comprehensive Environmental Response, Compensation, Liability Act CERCLA 103 [40 CFR Parts 302 & 355.40] Amended Hazardous Chemical Reporting— Sections 311 & 312 [40 CFR Part 370] Amended Toxic Chemical Reporting—Section 313 [40 CFR Part 372] Challenge 2: LEPC Leadership County government officials Local industry officials Community leaders Challenge 3: Manpower/Volunteers Membership drives Community cleanup day Retired persons Local college students Public Exposure County fairs Parades Trinket giveaways Local advertisement Challenge 4: Education/Training LEPCs Workshops and seminars Joint LEPC meetings Visits to facilities Public Brochures Local school visits Community exercises Challenge 5: Technical Resources EPA assistance (Region V coordinators) IERC assistance (field reps) LEPC assistance (neighboring LEPCs) Challenge 6: LEPC Funding ‡ Annual requirements completed ‡ Special projects ‡ Solicitation from local governments and businesses ‡ Grant information from federal websites Challenge 7: Facility Compliance LEPC awareness of reporting facilities Education for reporting facilities Noncompliant reporting facilities identified to IERC/EPA Facility inspections Challenge 8: Sustainability/Continuity of LEPCs New leadership Involvement of all LEPC members Proper resources Diligence in fulfilling requirements Challenge 9: Personnel Burnout Rotating member responsibilities New members Fresh ideas Joint-agency exercises Challenge 10: Record Keeping Organization Computerization Appropriate tools Appropriate storage Challenge 11: Plan Exercises Interagency/district exercises Realistic/challenging scenarios Account for worst-case situations Full-scale exercises Involvement of public Challenge 12: Media Exposure Radio/TV spots Information to local media Advertisement of exercises & public appearances C3: coordination, communication, cooperation Challenge 13: Innovation Communication with other LEPCs nationally Use of current technology Receptivity to new ideas Challenge 14: Personnel Diversity Retired persons Local college students Gender diversity (Women) Ethnic groups Challenge 15: Data Sharing Computerization of facility information Use of CAMEO software Electronic Tier II submittal/management Internet EPCRA management Challenge 16: Illegal Public Use of Title III Chemicals Identification of illicit drug production Mechanism to involve local law enforcement Location/notification of facilities with chemicals used in illicit drugs Challenge 17: New Chemical Dangers Federal information (EPA) State information (IERC) Local information (other LEPCs) Funding Status on 91 LEPCs 2005 (64 – 70%) 2006 (67 – 74%) 2007 (75 – 82%) 2008 (71 – 78%) 2009 (61 – 67%) 2010 Requirements & Due Dates The Big 7 Legal Notices January 31 Roster March 1 Fiscal Report March 1 Plan Review December 31 Bylaws December 31 Meeting Minutes December 31 Exercise Report December 31 Contact Information John Steel, LEPC Coordinator Indiana Department of Homeland Security 302 West Washington Street, E208 Indianapolis, IN 46204 Office: (317) 233-6519 [email protected] Ian Ewusi, IERC Representative Indiana Department of Homeland Security 302 West Washington Street, E208 Indianapolis, IN 46204 Mobile: (317) 695-2119 [email protected]