Ohio EPA Office of Emergency Response

Transcription

1 Ohio EPA Office of Emergency Response

2 Overview Overview of ER Program ER Assets Release Reporting Obligations Deployment & Response Metrics Incident Communication Documentation and Cost Recovery Other ER Documents 3 Unique Incidents (Time allowing)

3 Emergency Response Program Overview Response capability 24/7 365 days a year. Contractor available when Responsible Party can t or won t clean up. Respond to 1200 incidents annually. Field response objectives designed to redress the imminent emergency not remedial. Authority to recover response costs through statute. Formally refer each incident to appropriate Ohio EPA program for resolution.

4 Emergency Response Assets 12 On Scene Responders statewide; 4 On call at any given time; Each are equipped with MARCs, 5 gas meters, sampling & containment equipment; Jerome meter in Columbus; SME Experts from throughout the Agency; ER Strike Team Response posture for large scale incidents to deploy multiple ER Responders at once; Area RAE System & Strike Team.

5 North ER Operations: Mike Eberle Supervisor Larry Antonelli OSC Kurt Kollar OSC Wade Balser OSC Mike Gerber OSC Dave Schilt OSC John Flegal OSC South ER Operations: Jodi Billman Supervisor Chris Holmes OSC Aaron Wolfe OSC Trevor Irwin OSC Amanda Browne OSC Bill Lohner OSC Vacancy OSC

6 ORC 3750 Release Reporting An owner or operator is required to report a release or discharge under of the Ohio Revised Code anytime there is a release of a regulated chemical which exceeds its assigned RQ (or if oil causes a visible sheen in navigable waters) and leaves the facility. (EHS, CERCLA HS, Oil) Verbal notification to the fire department, LEPC, and Ohio EPA ( ) shall be made within 30 minutes of knowledge of the release, unless notification within that timeframe is impractical due to uncertain circumstances. However, facilities regulated by ORC 1509 can satisfy their release reporting obligations by calling OHCALL1.

7 What happens when you report a spill? Duty Officer creates an incident in MARCs; OSC receives through P1 CAD, triages get verified incident info from scene; Determine response posture via deployment matrix; Affirm with Management; Coordinate incident communications.

8 What are the ER Deployment & Response Posture Options? Immediate Field Response Incident requiring direct deployment to protect HHS&E; Delayed Field Response Incident effectively managed by FD, RP that can wait until business hours; Phone Response Incident that can be managed via phone with RP, locals, photos, and field verification visit; No ER Action Incident that requires no action on ER s part (5 gallons of fuel cleanup by locals); No Spill False or unverified report.

9 Incident Comms Protocol Duty Officer creates IIR with a unique identifying number (Spill ID); OSC begins the incident comms process with summary of report, scene updates, deployment posture and objectives; Incident Comms sent to all senior Agency staff, Governor s Office, and State Partners (EMA, DPS, ODNR, ODH); Update provided via numbered updates with last update marked final.

10 Incident Comms Guide Statement of who is responding to what, where and identify the unique Incident Number. Provide a succinct description of the release and current conditions as initially reported or as vetted on scene. Identify the nearest waterbody or sensitive sub pop. Identify if the location is near a public drinking water facility, within a SWPA or sensitive areas.

11 Incident Comms Guide Provide status statement on evacuations & media interest. Provide status statement regarding County EMA s posture and other responders. Identify the anticipated response objectives. Identify when the next Comms Update will be delivered.

12 Reports and Cost Recovery Responder completes an Officer Narrative which is a report detailing the activities of the Responder(s) in sufficient detail to support Cost Recovery Invoice. The Officer Narrative is now provided with the Cost Recovery Invoice. ER recovers its response costs from the Responsible Party using authority in ORC Response costs include Agency activities associated with the incident, including SME support if needed. ER does not cost recovery for Phone or No Action incidents.

13 Other ER Documents When ER Responder observes a release impacting water, air or land, they will issue a Field NOV to document the release and to identify the abatement actions that need to be taken. An NRRI is issued when a release has not impacted water or air; however, the failure to take immediate action could lead to a violation. This also identifies actions that need to be taken. ER will formally refer the incident to the appropriate program once the emergency is over. The program will RTC if appropriate.

14

15

16

17 Thank you for your time and interest Questions? R. Edwin Gortner Ohio EPA Office of Emergency Response Groveport Field Office Homer Ohio Lane, Groveport, OH (Desk): (Cell): (Fax): Please Report Environmental Emergencies:

18 Response to High Priority Situations Mike Proffitt, Chief, Div. of Environmental Response & Revitalization Isaac Robinson, Chief, Central District Office

19 Identifying and Elevating High Priority Situations Increasing emphasis within Ohio EPA for inspection and field staff to elevate issues identified that require immediate action to prevent, abate or mitigate serious impacts to public health and the environment.

20 Examples of High Priority Situations Imminent threat that poses a risk to people. Situation that could cause immediate and substantive environmental damage. Operating conditions that could cause a fire, explosion or other catastrophic event.

21 Potential High Priority Situations Wastewater Uncontrolled or unpermitted discharges with high likelihood of harmful exposure to the public and/or substantial environmental impact; Unauthorized discharges of pollutants to the ground that threaten public or private water supplies. Gross exceedances of permitted discharge limits where there is a high likelihood of public exposure or immediate environmental impacts. Abandonment of wastewater treatment plant or cessation of activity due to loss of power to the property.

22 Potential High Priority Situations Air and Odors Emission exceedances or releases of an air toxics or other harmful pollutants in areas where there is high potential for public exposure. Gross operational/control equipment concerns (for example, baghouse disconnected, by passing control equipment, no control equipment functioning). A situation where odors from the site have the potential to cause immediate physical discomfort or harm (sensitive populations, headache, nausea, burning nose/throat, etc.), are resulting in a large number of odor complaints and are migrating off site.

23 Potential High Priority Situations Vapor Intrusion A situation where there may be vapor intrusion into buildings, schools, daycare centers, etc. where the public could potentially be exposed to harmful airborne pollutants.

24 Potential High Priority Situations Hazardous, Solid Waste and Industrial Sites Accidental or unauthorized release of hazardous material where there could be immediate impact to public health or significant environmental impact Discovering new activities involving at risk populations in former industrial areas where contamination is suspected to exist.

25 How These Situations Come to Our Attention Inspections Sample Results Complaints New Initiatives (Look Backs)

26 What is Vapor Intrusion to Indoor Air Vapor intrusion to indoor air is a potential human exposure pathway in which people may come into contact with hazardous vapors while performing indoor activities. It can affect both residential and commercial/industrial buildings.

27 RESPONSE ACTION LEVELS AND TIMEFRAMES FOR COMMON CONTAMINANTS OF CONCERN AT VAPOR INTRUSION SITES Sets Action Levels for Volatile Organic Compounds for Indoor Air Situations Evaluates Probable Migration Scenarios Establishes Required Action Timeframes based on Contaminant, Concentration, and Building Use

28 Accelerated, Urgent, and Imminent Hazard Response Action Levels for TCE in Indoor Air Exposure Scenario Accelerated Response Action Level (HQ=1) Urgent Response Action Level (HQ=3) Imminent Hazard Response Action Level 6 µg/m 3 ppbv µg/m 3 ppbv µg/m 3 ppbv Residential >2.1 >0.39 >6.3 >1.2 >20 >3.7 Commercial (8 hour workday) >8.8 >1.6 >26 >4.8 >60 >11 Response Coordinate with appropriate state, local and health authorities. Early or interim response measures evaluated and implemented within a few weeks: Increase building pressure and/or ventilation Seal potential conduits were vapors may enter Install indoor air purification systems Install sub slab or crawl space depressurization systems Coordinate with appropriate state, local and health authorities. Early or interim response measures listed in previous column evaluated and implemented within a few days. Temporary relocation of receptors may be necessary to prevent additional exposure if other mitigation measures are not available or effective. Coordinate with appropriate state, local and health authorities. Relocate receptors until post remedy indoor air samples are below the accelerated response action levels.

29 Accelerated and Urgent Response Action Levels for TCE in Ground Water Exposure Scenario Sandy or unknown soils (HQ=1) Fine course scenario + (HQ=1) Accelerated Response Action Level (µg/l) Sandy or unknown soils (HQ=3) Fine course scenario + (HQ=3) Urgent Response Action Level (µg/l) Residential (24 hours) >11 >21 >32 >63 Commercial (8 hour workday) >44 >89 >130 >270 Response Within a few days to two weeks: Sample sub slab soil gas, if feasible; or Sample soil gas near ground water interface, if capillary fringe is greater than 5 feet bgs Within a few days: Sample sub slab and indoor air concurrently. Follow response actions in Table 1 and/or Table 3 Follow response actions in Table 3

30 Accelerated and Urgent Response Action Levels for TCE in Sub Slab Soil Gas Exposure Scenario Accelerated Response Action Level (HQ=1) Urgent Response Action Level (HQ=3) µg/m 3 ppbv µg/m 3 ppbv Residential (24 hours) >70 >13 >210 >39 Commercial (8 hour workday) >290 >54 >880 >160 Response Within a few days to two weeks: Sample indoor air and collect concurrent sub slab soil gasfollow response actions in Table 1 Within a few days: Sample indoor air and collect concurrent sub slab soil gas sample. Follow response actions in Table 1

31 Vapor Intrusion Sampling

32 Why Ohio EPA Can Take Action Ohio Revised Code (B) If the director determines that conditions at a hazardous waste facility, solid waste facility, or other facility or property where hazardous waste was treated, stored, or disposed of constitute a substantial threat to public health or safety or are causing or contributing to or threatening to cause or contribute to air or water pollution or soil contamination, the director shall initiate appropriate action under this chapter or Chapter or of the Revised Code or seek any other appropriate legal or equitable remedies to abate the pollution or contamination or to protect public health or safety.

33 Possible Exceedance of a Standard Data shows that there could be an exposure to a contaminant which could exceed a health based standard. Soil, Soil Gas, or Ground Water shows elevated contamination that could threaten people on and/or off site

34 Scenarios

35 Industrial Facility Conducting an Investigation Data shows high TCE concentrations in soil Ground Water flow direction shows that it is migrating toward homes across the street Results provided to Ohio EPA at 4:45 on a Friday afternoon in late December Phone conversations between DERR Chief and Facility representative

36 Actions Facility representative would not commit to action within recommended timeframe. Ohio EPA sent field staff to homes early Saturday morning to gain access. Summa Canisters deployed Tuesday and retrieved Wednesday, December 23 rd Ohio EPA laboratory staff received canisters on the 23rd and provided data December 24 th.

37 Significant Air Emissions Wednesday Facility reported air pollution control equipment down attempting to restart Friday Facility revealed that actually explosion had occurred, control equipment totally inoperable Facility Intended to Continue Operating Under Full Production w/o Control Equipment

38 Actions Ohio EPA told Company Operating Full Production Not Acceptable Due to Amount and Type of Air Emissions Company ceased operations Ohio EPA continued working with facility thru weekend to determine acceptable operating parameters

39 Actions Ohio EPA mobilized its air modelers, who worked with company over weekend Constant communication with company After modeling various scenarios, an acceptable scenario was not found Company worked with suppliers to get less toxic formulations

40 Actions Supplier came up with less toxic formulations that were still able to produce acceptable product Ohio EPA review toxicological data on formulations and determined it did not present a health hazard Company resumed operations w/i one week of original incident

41 Exceedance of a Standard Ohio EPA working with Port Authority through our Brownfield Assistance Program. Ground Water TCE data showed unexpectedly high concentrations along sewer in front of homes. Port Authority did not have resources to adequately conduct indoor air sampling.

42 Action Data provided to Ohio EPA at 3:00 Friday, 5:00 that afternoon Ohio EPA staff started going door to door to get access Indoor Air and Sub Slab sampling initiated Sunday. Tuesday, first indoor air data coming in showed exceedance of our residential standard

43 Action continued Tuesday Afternoon Coordination with local and state health departments. Immediately began ventilation. Level of Effort (LOE) Contractor engaged and set up to begin installation of vapor mitigation system on Wednesday.

44 Action continued Two residences identified with pregnant women. Immediately relocated to hotel. 15 mitigation systems installed USEPA CERCLA Time Critical Removal Action installation of 3 more systems

45 Mitigation: Sub Slab Depressurization

46 Look Back at Known Contamination Former Dry Cleaning Site in Urban Residential Area Ohio EPA Re Evaluating Site Due to Known Contamination Records Indicated TCE Contamination TCE Levels Exceeded Vapor Intrusion Levels Based on Updated TCE Toxicity

47 Actions Ohio EPA took soil vapor and ground water samples Soil Gas & Ground Water Samples Exceeded Accelerated Response Level Ohio EPA & Consultant for Company Performed Indoor Air Sampling in 3 Nearby Buildings One Result showed Indoor Air Sampling in Basement Exceeded Urgent Response Level Other Two Building Samples Were Non Detect

48 Actions Ohio EPA requested Immediate Measures Consultant Immediately Increased Basement Ventilation Next Day Installed Sub Slab Depressurization System w/i 14 Days

49 Lead

50 American Legion MHP Study Conducted in early 1990 s by USEPA, with support from Ohio EPA and ODH Lead Contamination as high as 4900 ppm in soil Removal Action threshold of 5000 ppm Public Outreach

51 Action As part of Ohio EPA file lookback, pottery sites were re assessed Lead action levels are lower ODH records showed that local citizens had not participated in lead blood level testing Decided to re engage USEPA Now doing a removal action

52 PFOA PFOS Newest of the emerging contaminants ATSDR has revised toxicity information, which will likely push advisory levels lower from the current 70 ppt level Highly mobile and persistent Difficult to sample and remove

53 What Should You Do? Stay current with changes in contaminant action levels. Assess your vulnerability and be proactive. If you work with volatile organic compounds, establish a relationship with appropriate consultants and contractors. Communicate with regulators.

54 Questions?