I n s i d e t h i s i s s u e :

Volume XII, Edition 10 October 1, 2012

GATEKEEPER NEWSLETTER

Lou Trammell, Chair

http://www.dem.azdema.gov/ Janice K. Brewer, Governor http://www.governor.state.az.us/

Mark Howard, Executive Director

http://www.azserc.org

Arizona Emergency Response Commission 5636 East McDowell Road

Phoenix, Arizona 85008-3495

EPA Adds 12 Hazard-ous Waste Sites to Superfund’s National Priorities List:

2

EPA Awards Almost $11 Million to Ad-vance Chemical Safety Research:

4

Officals concerned about collection of hazardous chemicals in old Slinger factory:

6

11 Container Compli-ance Tips: 8

Scotts Miracle-Gro Will Pay $12.5 Mil-lion in Criminal Fines and Civil Penalties for Violations of Federal Pesticide Laws:

10

Mapping Alternative Routes to CFATS Compliance - ACC working with DHS on alternative security programs:

12

The Most Common Container Violations: 14

How do you deal with the irate TV station manager? What do you tell the rest of the media about the mishap? How do you address the fears of local parents whose children attend school one-quarter mile away from the accident scene? How could the injury to the cam-era person have been avoided? What would you do differently next time? This type of exercise, together with emergency response simu-lations, is invaluable. With prac-tice, you will know better when to activate your plan and in-crease the chances that you will follow the plan that you worked so diligently to develop. If you need information about an important environmental issue, Enviro.BLR.com provides all the information you need, 24/7. This essential online environ-mental management tool puts practical RCRA, CAA, CWA, hazardous waste regulatory analysis and activity, news, and compliance tools at your finger-tips whenever you need it. With instant access, your expensive calls to lawyers and consultants, and the risk of costly mistakes from "not knowing," are a thing of the past.

Ok so you’ve got your plan together but without practice, attempts at crisis communica-tion are often unsuccessful. Without a plan, the chances of success diminish. Planning alone is not enough. The plan must be practiced. Written exercises and simula-tions are both excellent training tools to ensure that the plan works, that the thinking among management officials is sound and consistent, and that inter-views will be conducted suc-cessfully. The following hypothetical crisis exercise is an example of a useful and painless training tool. A truck carrying a volatile chemical intermediate that your facility uses in pesticide formu-lations overturns en route to your facility. Four drums in the shipment are breached. Con-tainment and cleanup are well under way without further mis-hap when the local newspapers and TV camera crews arrive. The camera person, who, of course, is wearing no protective gear, strays too close to the leaking drums and is overcome by the vapors. He is quickly taken to the hospital, where he is resting comfortably the next day. Answer these questions:

Being prepared means you should already have a plan that addresses crisis communication. Why? Com-panies that isolate themselves in times of crisis will be blamed by a distrustful public. Companies that openly and honestly deal with the press and the community are apt to receive fair coverage resulting in improved public perception and trust--even in the face of problems. What’s In the Plan? A crisis communications plan should outline the steps that ensure an ade-quate facility response to the press and the community at large in the event of an accident. Adequate plan-ning provides the essential founda-tion upon which successful crisis communication is built. The crisis communications plan should ad-dress: Company policy on public commu-nication Company background document Spokesperson and duties Media contacts development Interview policy Practice Crisis planning for a chemical emer-gency is 95 percent of the game. Effective on the-scene crisis com-munications depends on the preplan-ning: the choice of a spokesperson, the ability to follow the plan, and ability to perform well during inter-views and press conferences. Practice the Plan

Why You Need a Crisis Communication Plan:

P a g e 2 G A T E K E E P E R EPA Corner EPA Adds 12 Hazardous Waste Sites to Superfund’s National Priorities List: Eight Other Sites Proposed To Be Added WASHINGTON - The U.S. Environmental Protection Agency (EPA) is adding 12 new hazardous waste sites that pose public health and environ-mental risks to the National Priorities List (NPL) for cleanup under the Superfund program. EPA is also proposing to add another eight sites to the list. Superfund is the federal pro-gram that investigates and cleans up the most complex, uncontrolled or abandoned haz-ardous waste sites in the coun-try. For each of the 20 sites announced today, EPA has re-ceived letters of concurrence from state officials supporting the NPL listing. “Cleaning up contamination is vitally important to the health of America’s communities," said Mathy Stanislaus, assistant administrator for EPA’s Office of Solid Waste and Emergency Response. “Putting clean land back into productive use leads to increases in property values, generates new jobs and creates a stronger local economy that will strengthen these communi-ties for years to come.” Since 1983, 1,676 sites have been listed on the NPL. Of these sites, 360 sites have been cleaned up resulting in 1,316 sites currently on the NPL (including the 12 sites added today). There are 54 proposed sites (including the eight an-nounced today) awaiting final agency action.

Contaminants found at the sites include acetone, arsenic, benzene, cadmium, chro-mium, copper, dichloroethene (DCE), hexavalent chromium, lead, mercury, methyl ethyl ketone (MEK), polynuclear aromatic hydrocarbons (PAHs), polychlorinated bi-phenyls (PCBs), tetrachloro-ethylene (PCE), pentachloro-phenol (PCP), trichloroethane (TCA), trichloroethylene (TCE), xylene and zinc. With all NPL sites, EPA works to identify companies or people responsible for the contamination at a site, and requires them to conduct or pay for the cleanup. For the newly listed sites without viable potentially responsible parties, EPA will investigate the full extent of the contami-nation before starting signifi-cant cleanup at the site. There-fore, it may be several years before significant EPA clean up funding is required for these sites. The following 12 sites have been added to the National Priorities List: • Alabama Plating Com-pany, Inc. (former electro-plater) in Vincent, Ala. • Cedar Chemical Corpora-tion (former chemical manu-facturer) in West Helena, Ark. • Fairfax St. Wood Treaters (former wood treating opera-tion) in Jacksonville, Fla. • Bautsch-Gray Mine (former lead and zinc mine) in Galena, Ill. • EVR-Wood Treating/Evangeline Refining Com-pany (former wood treating

operation) in Jennings, La. • Leeds Metal (abandoned scrap metal facility) in Leeds, Maine • Holcomb Creosote Co (former wood treating opera-tion) in Yadkinville, N.C. • Orange Valley Regional Ground Water Contamina-tion (contaminated ground water plume) in Orange/West Orange, N.J. • Peters Cartridge Factory (former ammunition manu-facturer) in Kings Mills, Ohio • West Troy Contaminated Aquifer (contaminated ground water plume) in Troy, Ohio • Circle Court Ground Wa-ter Plume (contaminated ground water plume) in Wil-low Park, Texas • U.S. Oil Recovery (former used oil recovery operation) in Pasadena, Texas The following eight sites have been proposed for addi-tion to the National Priorities List: • Pike and Mulberry Streets PCE Plume (former dry cleaner) in Martinsville, Ind. • Former United Zinc & Associated Smelters (former zinc smelter) in Iola, Kan. • Creese & Cook Tannery (former tannery and finishing facility) in Danvers, Mass. • Walton & Lonsbury Inc. (former chrome plating op-eration) in Attelboro, Mass. • Matlack, Inc. (former chemical transportation busi-ness) in Woolwich Town-ship, N.J.

• Riverside Industrial Park (former paint manufacturer) in Newark, N.J. • Clinch River Corpora-tion (former pulp and paper mill) in Harriman, Tenn. • 700 South 1600 East PCE Plume (ground water plume) in Salt Lake City, Utah EPA is also withdrawing its earlier proposal to add the Evergreen Manor Ground Water Contamination site in Winnebago County, Illinois to the NPL because reme-dial action has been com-pleted. Affected residences have been connected to the public water supply, a county ordinance is in place which restricts the installa-tion of private wells in the affected area, and contami-nants of concern have re-mained below cleanup stan-dards since 2006. Federal Register notices and supporting documents for the final and proposed sites: http://www.epa.gov/superfund/sites/npl/current.htm Information about how a site is listed on the NPL: http://www.epa.gov/superfund/sites/npl/npl_hrs.htm Superfund sites in local communities: http://www.epa.gov/superfund/sites/index.htm

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Electro-Coatings of Cedar Rapids agrees to pay EPA fine, install new equipment: Associated Press – (Iowa) Electro-Coatings of Cedar Rapids agrees to pay EPA fine, install new equipment. Electro-Coatings of Iowa Inc. in Cedar Rapids, Iowa, agreed to pay more than $19,000 in fines, and to spend at least $110,000 to install new equipment to reduce the amount of chrome waste it

generates following violations of hazardous waste regulations, the Associated Press reported July 26. The chrome, nickel, and zinc plating operation reached an agreement with the Environmental Protection Agency (EPA) to pay the civil penalty. EPA documents stated a May 2011 inspection revealed many violations of the federal

act that regulates hazardous waste. Violations included stor-age of hazardous waste for longer than 90 days without a permit, and hazardous waste container management violations. Source: http://www.therepublic.com/view/story/8005ac79dbac4251b87b338d1ccb2d24/IA--Chrome-Waste-Violation

Contact: Dean Higuchi, 808-541-2711, higuchi.dean@epa.gov Group given leadership award for environ-mental education and outreach HONOLULU - The U.S. Environmental Protection Agency recognized the Guam Environmental Education Committee for their work to further environmental aware-ness throughout Guam as part of the EPA Pacific Southwest Region’s environmental awards program. “EPA is pleased to recognize the Guam Environmental Education Committee for its commitment to unify Guam’s environ-mental education efforts,” said Jared Blu-menfeld, EPA’s Regional Administrator for the Pacific Southwest. “Their activities and efforts have and continue to reach thousands of island residents in an effort to protect the quality of Guam’s air, water and land.” The Guam Environmental Education Committee has transformed environmental

education and outreach on Guam since its inception in 2004. The Committee – whose members include local and federal govern-ment agencies, nonprofit groups, teachers, students, and the private sector – organizes over a dozen environmental education and out-reach events each year. The Com-mittee's success is due to the com-mitment and dedication of its or-ganizers and participants, and also to the comprehensive approach that the group has taken to unify the island's environmental educa-tion resources. The Committee organizes the an-nual island-wide Earth Day activi-ties, which in 2012 expanded to a full month of events. They also hold regular free, public events such as snorkeling tours and litter cleanups, and also organize speak-

ers for classrooms and produces out-reach materials. The Committee has three subgroups focusing on different areas: Tano (land), Tasi (sea), and Hanom (water). In 2011, it developed a comprehensive environmental education strategy for Guam, the first of its kind for the is-land. The EPA Pacific Southwest Region’s Environmental Awards program ac-knowledges commitments and signifi-cant contributions to the environment in California, Arizona, Nevada, Ha-waii, Pacific Islands and tribal lands. Groups and individuals were selected from nominees received this year from businesses, local, government officials, tribes, media, environmental organiza-tions and community activists. For more information on the other 2012 award winners please visit: http://epa.gov/region9/awards

U.S. EPA recognizes the Guam Environmental Education Committee:

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EPA Awards Almost $11 Million to Advance Chemical Safety Research: WASHINGTON - Today the U.S. Environmental Protection Agency (EPA) announced nearly $11 million in grants to eight universities through EPA’s Science to Achieve Re-sults (STAR) program. These grants will help the universities develop fast and effective meth-ods to test chemicals’ toxicity to people and the environment. These innovative testing meth-ods will be used to predict a chemical’s potential to interact with biological processes that could lead to reproductive and developmental problems, and disruption of the endocrine sys-tem. The grantees will focus on de-veloping methods and models to predict how exposure to envi-ronmental and synthetic (man-made) chemicals and chemical mixtures may harm the public. Some synthetic chemicals are known endocrine disruptors, which interfere with or even mimic natural hormones and cause damage to the develop-ment and function of vital or-gans, particularly in young chil-dren and developing fetuses. There are currently thousands of chemicals in use and hundreds more introduced every year.

“These projects highlight EPA’s commitment to pro-tecting people’s health and the environment by devel-oping innovative methods that are on the cutting edge of chemical toxicity re-search,” said Lek Kadeli, acting assistant administra-tor for EPA’s Office of Research and Development. The grantees are: • University of Texas at Austin – testing chemicals that impact fertility and embryonic development, and developing a model to classify chemicals accord-ing to the risks they pose • North Carolina State University – developing innovative methods to un-derstand how chemicals influence the regulation of development, reproduction, and metabolism • University of Oregon – using zebrafish testing methods to determine if they have results similar to traditional toxicity tests and to determine if these meth-

ods could be used as alterna-tives for existing toxicity tests • University of California Davis – investigating the effect of environmental agents on thyroid hormones and modeling how the chemicals affect organism health • Battelle Memorial Insti-tute, Pacific Northwest Divi-sion, state of Washington – working with assay systems of the rainbow trout pitui-tary, liver and ovary to screen for environmental toxins and measure repro-ductive endocrine functions impaired by these toxins • University of North Carolina at Chapel Hill – developing chemical effect testing for in vitro systems and computational toxicol-ogy solutions to measure risk in populations, and cre-ating models based on the resulting data • University of Michigan – improving upon an existing in vitro, neurochemical screening assay platform,

and modeling adverse repro-ductive effects associated with toxic exposure in wild-life • University of South Caro-lina – developing a targeted innovative animal imaging method to screen and identify chemicals that exhibit abnor-mal development in the car-diovascular and nervous sys-tems that lead to indirect ad-verse effects on muscle de-velopment within zebrafish larvae EPA’s STAR grant program supports human health, ecol-ogy, economics and engineer-ing sciences through grants, centers, and fellowships. More information on the grant awards: http://www.epa.gov/ncer/hi_thruput_assays More information on STAR grants: http://epa.gov/ncer/ More information on EPA’s chemical safety re-search: http://www.epa.gov/research/chemicalscience/

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Los Angeles, Compton Compa-nies improperly discharge wastewater, fail to treat hazard-ous waste Media Contact: Nahal Mogharabi, mogharabi.nahal@epa.gov LOS ANGELES—The U.S. Environmental Protection Agency today announced the conclusion of three recent inves-tigations of Southern California metal finishing companies which will collectively spend more than $196,650 for hazard-ous waste and Clean Water Act violations. All three facilities are located along the I-710 free-way corridor where the effects of pollution are disproportion-ately higher than in other areas of Los Angeles County. AAA Plating and Inspection, located in Compton, Calif. has agreed to pay $74,000 in fines for failure to treat their indus-trial wastewater to federal stan-dards before discharge into the Los Angeles County sewer sys-tem. Morrell’s Electro Plating, also located in Compton, Calif., will pay $19,500 in fines for the improper management and treatment of hazardous waste. In addition, Morrell’s will spend at least $100,000 on the purchase and installation of a sludge dryer, reducing hazardous waste generated at the facility by 336 pounds a day. Service Plating Co. Inc., located in Los Ange-les, Calif., will pay $3,150 for failure to properly label hazard-ous waste containers at its facil-ity. “The violation of federal regula-

tions at metal finishing companies poses a risk to workers, as well as surrounding residents,” said Ja-red Blumenfeld, EPA’s Regional Administrator for the Pacific South-west. “EPA will continue to rigorously enforce against facilities like these espe-cially those located in the I-710 corridor, a priority area for the agency.” AAA Plating, located in the city of Compton, is a metal finishing company that cleans, plates, coats, paints, and tests various parts for the aerospace industry. In March, 2010, an EPA in-vestigation discovered that the facility had discharged industrial wastewater to the Los Angeles County sewer system above federal limits for toxics such as chro-mium, cadmium, nickel and cyanide —a violation of the Clean Water Act. EPA’s standards are designed to protect municipal sewer systems and wastewater treatment plants from ad-verse effects of toxic dis-charges, including the po-tential pass through of toxic metals to the Pacific Ocean. AAA Plating has installed equipment to reduce liquid from the wastewater, leav-ing only solids which are hauled away for proper disposal off site. This will result in the facility becom-

ing a zero-discharge permit-ted facility. Morrell’s, also located in the city of Compton, is a metal fin-ishing/chemical

processing company which does work primarily for the aerospace industry. In an October 27, 2010 inspec-tion, EPA found several violations including failure to properly label and cover hazardous waste and con-ducting treatment of hazard-ous waste without a permit. In addition, Morrell’s failed to properly identify waste generated at its facility as federally regulated hazard-ous waste -- resulting in its mismanagement. Morrell’s will also spend at least $100,000 to purchase and install a sludge dryer at its facility. Used to remove water and reduce volume, the sludge dryer will im-prove efficiency and reduce the amount of hazardous waste that must be disposed. The addition of the sludge dryer will result in the re-duction of hazardous waste generated at Morrell’s by 336 pounds a day, approxi-mately 85% of the facility’s daily production — reduc-ing the potential for similar violations in the future. Service Plating is a metal finishing company located in the city of Los Angeles.

Three Southern California Metal Companies to spend more than $196,000 for Federal Violations:

During a routine inspection in October 4, 2011, EPA investi-gators discovered federal vio-lations including failure to properly close and label haz-ardous waste containers. In addition, the company failed to properly label, contain and date discarded fluorescent lamps, a violation of federal regulations for universal waste. Southern California’s I-710 freeway passes through 15 cities and unincorporated areas where the effects of pollution are disproportionately higher than in other areas of Los An-geles County. Approximately 1 million people, about 70% of whom are minority and low-income households, are se-verely impacted by industrial activities and goods movement in the area. In a multiyear ef-fort, federal, state, and local governments and nonprofit organizations are working together to improve the envi-ronmental and public health conditions for residents along this corridor. For more information on The Clean Water Act, please visit: http://www.epa.gov/lawsregs/laws/cwa.html For more information on the Resource Conservation and Recovery Act, please visit: http://www.epa.gov/compliance/civil/rcra/index.html For more information on EPA’s work at the I-710 corri-dor, please visit: http://www.epa.gov/region9/

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P a g e 6 G A T E K E E P E R

Officals concerned about collection of hazardous chemicals in old Slinger factory: WTAQ 1360 AM / 97.5 FM Green Bay – (Wisconsin) Officals concerned about collection of hazardous chemicals in old Slinger factory. A inspection showed dozens of drums and barrels containing hazardous chemi-cals in an abandoned metal plating factory in Slinger, Wisconsin, WTAQ Green Bay reported September 9. Federal regulators and con-tractors want to get inside that

building in the next 2 weeks to assess the threat. Washington County emergency manage-ment officials are worried a fire could release the toxic chemi-cals or that vandals could get inside and damage containers causing spills. So far, nothing has been done since the August 20 inspection. It has been esti-mated there are 750 pounds of copper cyanide, nearly 14 tons of nickel sulfate, almost 4,200 pounds of nitric acid, and 3,500

pounds of sodium cyanide in the building, which is surrounded by homes and only a few blocks from three Slinger schools. The owner reportedly signed an agree-ment giving the U.S. Environ-mental Protection Agency access to the property. Source: http://wtaq.com/news/articles/2012/sep/09/officals-concerned-about-collection-of-hazardous-chemicals-in-old-slinger-factory/

Buffalo News – (New York) Firefighter injured in Tona-wanda chemical fire. A HAZMAT team was called as a precaution to a two-alarm fire September 9 at a Town of Tona-wanda, New York chemical

plant. Smoke was reported on the second floor of the FMC plant where firefight-ers found a machine on fire. The machine contained a hazardous material known as ammonium persulfate,

which is capable of intensi-fying a fire. FMC, a world-wide company based in Philadelphia, produces in-dustrial chemicals at the plant. One firefighter suf-fered burns to his hand in

Firefighter injured in Tonawanda chemical fire: battling the blaze and was taken to a hospital. Source: http://www.buffalonews.com/article/20120909/CITYANDRE-GION/120909554/1010

Braithwaite receded, and officials should have results of surface water tests later the week of September 10, said a Louisiana Department of Envi-ronmental Quality spokesman. Air quality samples had not revealed dan-gerous levels of chemicals, he added. Stolthaven’s Web site said the firm provides integrated transportation so-lutions for bulk liquid chemicals, edi-ble oils, and acids. Source: http://www.wwltv.com/home/Evacuation-order-still-in-effect-surrounding-Braithwaite-chemical-plant-169125596.html

ers carried chemicals that can be-come explosive if they exceed a certain temperature, a big concern because the plant lost power. HAZMAT teams brought in chill-ers and inhibitors to curb chemical reactions. A State police spokes-man said there was no immediate threat and no evidence of a chemi-cal release, but the potential re-mained. An attorney filed a class action lawsuit against England-based Stolthaven September 4 on behalf of residents impacted by the situation. Much of the water in

WWL 4 New Orleans – (Louisiana) Evacuation order still in effect sur-rounding Braithwaite chemical plant. People in Braithwaite, Louisiana, who live half a mile north or south of the Stolthaven chemical plant remained under an evacuation order September 10 because officials are still cleaning up damage caused by Hurricane Isaac. State police have been working to re-pair the facility for days. Flooding at the facility pushed more than 100 rail cars off tracks, some of which carried hazardous material. Some tanks were also knocked off their foundations; oth-

Evacuation order still in effect surrounding Braithwaite chemical plant:

LEPC Corner

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Chemical Industry Disputes Claim That Security Program is Burdensome: By Douglas P. Guarino

WASHINGTON – Suggestions by an influential conservative group that a federal chemical security program ought to be dis-continued is creating a stir amongst industry officials, who widely regard participation in the initiative as the most efficient way to protect their facilities from terrorist attacks. Congress created the Homeland Security Department’s Chemical Facility Antiterrorism Standards initiative in 2007, after years of debate on Capitol Hill regarding how best to ensure that chemical manufacturing plants and other high-risk facilities could not be used as tools of terrorism in the post-9/11 world. Industry lobbied against a pro-posal that would have required plants to use specific “inherently safer technology” less vulnerable to attacks that what companies might already be using. Ulti-mately they got behind the en-acted DHS program in which government can set security stan-dards, but cannot dictate the spe-cific technology that a company uses to meet those mandates. Congressional authorization for the program is due to expire in October, and industry groups are backing legislation in the Repub-lican-controlled House that would extend the initiative. An Aug. 14 report released by the Heritage Foundation argues, how-ever, that the regulations imposed by the DHS program “are the wrong approach to chemical facil-ity security and only represent an unnecessary burden on the chemi-cal industry.” The assessment says the CFATS effort overprescribes “federal solutions with which the private sector must comply, threatening innovation and economic expan-

sion.” Rather than continue the program, the Homeland Security Department “and Congress should collaborate to develop common-sense, market-conscious policy solutions for U.S. chemical security.” Jessica Zuckerman, the re-port’s author, told Global Security Newswire that the organization does not sup-port continuing the program in its current form and that the document is meant to convey that fact to the Obama administration and Congress. Industry officials are con-cerned, however, that discon-tinuing the program could backfire. Labor and environ-mental groups are pushing the U.S. Environmental Pro-tection Agency to develop chemical security rules that are more stringent than the existing DHS regulations -- an effort one industry official says could be bolstered by a cancellation of the current DHS program. “If you were to sort of move away from CFATS it might encourage EPA or some other entity to occupy that space,” Scott Jensen, director of issues communication for the American Chemistry Council, told GSN. Bill Allmond, vice president of government relations for the Society of Chemical Manufacturers & Affiliates trade group, also suggested that canceling the DHS pro-gram would be bad for busi-ness. “A lot of our companies have spent a lot of money to im-plement” the DHS initiative,

Allmond said. “Industry [assisted] DHS in establishing these standards and … we are committed to ensuring what is currently required gets imple-mented.” Allmond said the Heritage Foundation’s report was “full of assumptions, inaccuracies and contradictions” and, along with other industry officials, disputed the claim that the DHS regulations are unnecessarily demanding. “Seventy percent of our mem-bers are small businesses and none of them have come to us and said CFATS is overly burdensome” or that “we should do everything on a voluntary basis,” Allmond said. “None of our members have suggested that.” Similarly, Jensen, of the American Chemistry Council, said surveys have shown companies regulated under the DHS initiative are suppor-tive of the current situation. “I think industry has been pretty clear,” he said. Zuckerman, the Heritage Foundation author, defended her conclusions. Even if in-dustry officials support the program and say that it is not burdening their businesses “it still doesn’t mean that its good policy,” Zuckerman told GSN. “We’ve seen a lot of program-matic issues that really have made this overly burdensome on the private sector in our view at little added value to the security,” she said. Zuck-erman said that she had spo-ken to industry officials who shared this view, but declined to identify them.

The DHS program has been under scrutiny since an internal report detailing a host of prob-lems with the initiative was leaked to the media late last year. The reported issues in-cluded a failure by DHS offi-cials to conduct inspections of chemical facilities that could be targeted by terrorists and to approve security plans submit-ted by the plants. The Heritage Foundation paper references these and other im-plementation problems that have reportedly plagued the initiative. It notes that many of the issues are thought to be related to the Homeland Secu-rity Department’s “inability to adequately conduct hires, or to properly train those that it does hire within the CFATS pro-gram.” Industry officials say they agree with the report’s assess-ment of the implementation problems with the chemical security program but argue that the suggestion that it be re-placed with “common-sense, market-conscious policy solu-tions” is contradictory. The report “gives little indica-tion what these [solutions] would be, and it is hard to imagine because CFATS was intended precisely to be a sim-ple, market-based approach,” argued James Conrad, a former security lawyer for the Ameri-can Chemistry Council who now represents individual com-panies on chemical security matters. According to Conrad, the “logical recommendation would be that DHS needs to fix its implementation,” rather than abandon the current regu-latory framework.

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Industry Corner

Feds settle claims over radioactive waste disposal: Associated Press – (Kentucky) Feds settle claims over radioac-tive waste disposal. The federal government and a U.S. Department of Energy contractor reached a $230,000 settlement over allega-tions that the company improperly handled and disposed of radioactive waste from a nuclear reprocessing plant in Paducah, Kentucky, be-tween 1998 and 2004, the Associ-ated Press reported August 24. The settlement ends a 10-year legal

battle started by two former em-ployees at the Paducah Gaseous Diffusion Plant on behalf of the federal government. The employ-ees sued in 2002, claiming the con-tractor, Bechtel Jacobs, mishandled waste from the plant over a 6 year period. This included hazardous waste being handled as nonhazard-ous, lack of proper licenses and permits on the part of a subcontrac-tor, disposing of “no radiation added” waste at a radioactive waste

site instead of the plant‟s sanitary landfill, and disposing of waste at the same landfill with excessive amounts of free liquids. The plant produces enriched uranium for use at nuclear power plants. Source: http://www.chem.info/News/2012/08/Environmental-Controls-Feds-Settle-Claims-over-Radioactive-Waste-Disposal/

Hazardous waste handlers LOVE contain-ers that’s why they are the most common unit used to store and transport hazardous waste. Why? Containers are relatively cheap and easy to handle compared to tanks and surface impoundments. Also, containers are a good option for hazard-ous waste handlers who want to store, transport, and dispose of hazardous waste without changing the unit. But that doesn’t mean complying with RCRA container management regulations doesn’t come with their own set of head-aches. Here are 11 expert container com-pliance tips to help you out. #1 Ensure containers are sturdy and strong enough to withstand side or bottom shock, when full, without leaking waste. Rust, other corrosion, or dents in seam areas indicate a container may not be strong enough to use. #2 Ensure that a full container will not release waste even when dropped or over-turned. To meet this requirement, any con-tainers that hold free liquid must be liquid-tight, even when overturned. #3 Is the container lid easily closable for employees? The additional cost of spring-loaded snap rings, funnels with valves, or similar equipment may be a cost-effective means of ensuring containers are closed. #4 To prevent waste spills from destroying a label, place the label on the side of the

container, but not directly under the bung. To protect labels, cover them with clear packing tape or a clear finish or enclose them in a plastic pouch designed for that purpose. #5 For quick identification, put all marks and labels on the same side of the container (but not under the bung). # 6 Before shipping, check to make sure containers and labels meet DOT requirements for that waste. #7 Hang your container inspection log on a clipboard in the storage area. When it is full, file it in your permanent records for at least 3 years. #8 When storing an empty con-tainer outside, place it on its side to prevent accumulation of rain-water and melting snow. #9 Snow can fill curbed outdoor storage areas; remove it when sidewalks are shoveled. #10 A rule of thumb to differenti-ate satellite accumulation contain-ers from storage containers: Satel-lite accumulation containers will generally be either emptied into another container or moved to a storage area when full, while stor-age containers will generally be

shipped off-site as is when full. #11 You may choose to place a date on a satellite accumulation container when you begin to use it to help you track how quickly the waste is gener-ated. If you do, clearly identify the container as a satellite accumulation container to avoid confusing it with a storage container. Note: These tips are from Fact Sheet No. 1.04/1.05, Label and Store Hazard-ous Wastes prepared by the Minnesota Pollution Control Agency (MPCA). This fact sheet summarizes the Minne-sota hazardous waste container rules for generators found in Minnesota Rules 7045.0270 and 7045.0292. How-ever, because the Minnesota regula-tions closely follow the federal rules, with some more stringent require-ments, the compliance tips should ap-ply to most persons using a container to store or accumulate hazardous waste. Although the tips reflect the requirements of many states, they can also stand on their own as good busi-ness practices. See tomorrow’s Advisor to find out what NOT to do when managing con-tainers. We’ll have a compilation of the most common container violations found by EPA inspectors.

11 Container Compliance Tips:

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If you are a hazardous waste generator that crushes hazard-ous waste as part of your man-agement practices, you are con-ducting a form of hazardous waste treatment. Treatment is defined as any method, technique, or process, including neutralization, de-signed to change the physical, chemical, or biological charac-

ter or composition of any hazardous waste so as to neutralize such waste, or so as to recover energy or ma-terial resources from the waste, or so as to render such waste non-hazardous, or less hazardous; safer to transport, store, or dispose of; or amenable for recov-ery, amenable for storage, or reduced in volume (40

CFR 260.10). EPA has previously noted that crushing aerosol cans (EPA Memorandum, Petruska to Citizen; September 12, 1989 (RCRA Online 11466)) and decanning and crushing op-erations (EPA Memorandum, Skinner to Scarborough; April 26, 1984 (RCRA Online 12214)) meet the definition of

Crushing Hazardous Waste is Regulated as Treatment [40 CFR 260.10]:

treatment. However, hazardous waste generators may conduct treatment, including crush-ing, in regulated units with-out a permit as long as they are not conducting thermal treatment (56 FR 10146, 10168; March 24, 1986).

TRANSCAER® (Transportation Community Awareness and Emergency Response) is a voluntary national outreach effort that focuses on assisting communities prepare for and respond to a possible hazardous material transportation incident. TRAN-SCAER® members consist of volunteer representatives from the chemical manufacturing, transportation, distributor, and emer-gency response industries, as well as the government. Visit: http://www.transcaer.com/state.aspx for more information.

OSHA has published criteria for removing employers from the agency’s Severe Violator En-forcement Program (SVEP). SVEP has been in effect since June 18, 2010, and is intended to focus agency resources on employers that demonstrate indifference to their responsi-bilities under the Occupational Safety and Health Act with will-ful, repeat, or failure-to-abate violations.

On August 16, 2012, OSHA issued employer removal criteria from the SVEP program to all fed-eral OSHA offices. Gener-ally, an employer may be considered for removal from the program by an OSHA Regional Adminis-trator after: • A period of three years from the date of the final

disposition of the SVEP in-spection citation items includ-ing: failure to contest, settle-ment agreement, Review Commission final order, or court of appeals decision. All affirmed violations have been abated, all final penalties have been paid, the employer has abided by and completed all settlement provisions, and has not received any addi-tional serious citations related

How to Get Out of OSHA’s Severe Violator Enforcement Program:

to the hazards identified in the SVEP inspection at the initial establishment or at any related establishments. In the event an employer fails to adhere to the terms and provisions of the agreement, the employer will remain in the program for an additional three years and will then be re-evaluated.

P a g e 1 0 G A T E K E E P E R

WASHINGTON – The Scotts Miracle-Gro Company, a pro-ducer of pesticides for commer-cial and consumer lawn and gar-den uses, was sentenced today in federal district court in Columbus, Ohio, to pay a $4 million fine and perform community service for eleven criminal violations of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), which governs the manufacture, distribution, and sale of pesti-cides. Scotts pleaded guilty in February 2012 to illegally apply-ing insecticides to its wild bird food products that are toxic to birds, falsifying pesticide registra-tion documents, distributing pesti-cides with misleading and unap-proved labels, and distributing unregistered pesticides. This is the largest criminal penalty under FIFRA to date. In a separate civil agreement with the U.S. Environmental Protection Agency (EPA), Scotts agreed to pay more than $6 million in pen-alties and spend $2 million on environmental projects to resolves additional civil pesticide viola-tions. The violations include dis-tributing or selling unregistered, canceled, or misbranded pesti-cides, including products with inadequate warnings or cautions. This is the largest civil settlement under FIFRA to date. “The misuse or mislabeling of pesticide products can cause seri-ous illness in humans and be toxic to wildlife,” said Cynthia Giles, assistant administrator for EPA’s Office of Enforcement and Com-pliance Assurance. “Today’s sen-tence and unprecedented civil settlement hold Scotts account-able for widespread company noncompliance with pesticide laws, which put products into the hands of consumers without the proper authorization or warning labels.” “As the world’s largest marketer

of residential use pesticides, Scotts has a special obliga-tion to make certain that it observes the laws governing the sale and use of its prod-ucts. For having failed to do so, Scotts has been sentenced to pay the largest fine in the history of FIFRA enforce-ment," said Ignacia S. Mo-reno, assistant attorney gen-eral for the Environment and Natural Resources Division of the Department of Justice. “The Department of Justice will continue to work with EPA to assure that pesticides applied in homes and on lawns and food are sold and used in compliance with the laws intended to assure their safety.” In the plea agreement, Scotts admitted that it applied the pesticides Actellic 5E and Storcide II to its bird food products even though EPA had prohibited this use. Scotts had done so to protect its bird foods from insect infestation during storage. Scotts admitted that it used these pesticides contrary to EPA directives and in spite of the warning label appear-ing on all Storicide II con-tainers stating, “Storcide II is extremely toxic to fish and toxic to birds and other wild-life.” Scotts sold this illegally treated bird food for two years after it began market-ing its bird food line and for six months after employees specifically warned Scotts management of the dangers of these pesticides. By the time it voluntarily recalled these products in March 2008, Scotts had sold more than 70 million units of bird food illegally treated with pesticide that is toxic to birds.

Scotts also pleaded guilty to submitting false documents to EPA and to state regulatory agencies in an effort to de-ceive them into believing that numerous pesticides were registered with EPA when in fact they were not. The com-pany also pleaded guilty to having illegally sold the un-registered pesticides and to marketing pesticides bearing labels containing false and misleading claims not ap-proved by EPA. The falsified documents submitted to EPA and states were attributed to a federal product manager at Scotts. In addition to the $4 million criminal fine, Scotts will con-tribute $500,000 to organiza-tions that protect bird habitat, including $100,000 each to the Ohio Audubon’s Impor-tant Bird Area Program, the Ohio Department of Natural Resources’ Urban Forestry Program, the Columbus Metro-Parks Bird Habitat Enhance-ment Program, the Cornell University Ornithology Labo-ratory, and The Nature Con-servancy of Ohio to support the protection of bird popula-tions and habitats through conservation, research, and education. At the time the criminal viola-tions were discovered, EPA also began a civil investiga-tion that uncovered numerous civil violations spanning five years. Scotts’ FIFRA civil violations included the nation-wide distribution or sale of unregistered, canceled, or misbranded pesticides, includ-ing products with inadequate warnings or cautions. As a result, EPA issued more than 40 Stop Sale, Use or Removal Orders to Scotts to address more than 100 pesticide prod-

Scotts Miracle-Gro Will Pay $12.5 Million in Criminal Fines and Civil Penalties for Violations of Federal Pesticide Laws:

ucts. In addition to the $6 million civil penalty, Scotts will com-plete environmental projects, valued at $2 million, to acquire, restore and protect 300 acres of land to prevent runoff of agri-cultural chemicals into nearby waterways. The criminal case was investi-gated by EPA’s Criminal In-vestigation Division and the Environmental Enforcement Unit of the Ohio Attorney Gen-eral's Office, Bureau of Crimi-nal Identification & Investiga-tion. It was prosecuted by Sen-ior Trial Attorney Jeremy F. Korzenik of the Justice Depart-ment’s Environmental Crimes Section of the Environment and Natural Resources Division, by Michael J. McClary, EPA Criminal Enforcement Counsel and Special Assistant U.S. At-torney and by Assistant U.S. Attorney J. Michael Marous. The civil case was investigated by U.S. EPA Region 5’s Land and Chemicals Division and Office of Regional Counsel, and the U.S. EPA Headquarters Office of Civil Enforcement, assisted by the Office of Pesti-cides Program. More information about the civil settlement and recalled products: http://www.epa.gov/compliance/resources/cases/civil/fifra/scottsmiraclegro.html More information about EPA’s criminal enforcement program: http://www.epa.gov/enforcement/criminal/index.html More information about EPA’s pesticide program: http://epa.gov/pesticides/

P a g e 1 1 V o l u m e X I I , E d i t i o n 1 0

For the environmental manager, the task of communicating envi-ronmental risk to a wary or un-suspecting public is going to be one of the biggest challenges of EPCRA compliance. Citizens, local officials, and the media annually receive infor-mation about hazardous sub-stances and the potential threats to the community posed by these chemicals. There is usu-ally an onslaught of questions and concerns when the informa-tion is publicly available. Here are the 10 most common mistakes environmental manag-ers make when they are com-municating with the public about the event of an environ-mental incident. 1. You have not accepted re-sponsibility for real and per-ceived environmental risks. 2. You have not effectively communicated the actual risks at your facility.

3. You have underestimated the media and community action groups. 4. You do not have a writ-ten community public rela-tions policy. 5. You have missed oppor-tunities to reach out to the community and press to cultivate relationships. 6. You do not have a facil-ity spokesperson assigned in the event of an emer-gency. 7. Your workers are not aware of emergency re-sponse activities and risk reduction measures at your facility. 8. You do not have a pre-pared background docu-ment about your facility. 9. You do not have a pre-pared list of press contacts, local officials, and con-cerned citizens. 10. You do not have an

interview policy. Crisis Communications Checklist The key component of suc-cessful crisis communica-tions is planning. This checklist will help you gauge how well you have prepared for the emergency and the onslaught of ques-tions and concern that will surely follow. ___ Do you have a written community public relations policy? ___ Does the plan address emergencies? ___ Has a facility spokes-person been assigned? ___ Do employees know who this person is? ___ Have the spokesper-son’s duties been defined? ___ Are workers aware of emergency response activi-ties and risk-reduction measures at the facility? ___ Has a background docu-ment on the company and/or facility been prepared? ___ Has chemical or techni-

10 Mistakes Everybody Makes When Communicating an Enviro Crisis:

cal information about the facil-ity been translated into every-day language? ___ Have risks been defined relative to other risks that the press, local representatives, or citizens can understand? ___ Has a list of press contacts, local officials, and concerned citizens been prepared? ___ Have opportunities to meet with local civic, business, pub-lic interest groups, and the press been identified? ___ Has management been en-couraged to reach out to the community and to the press to cultivate relationships? How? ___ Have you conducted a me-dia briefing/training session? ___ Has an interview policy been defined? ___ Have interviewing tech-niques been practiced? ___ Have written exercises been provided? ___ Has the crisis communica-tions plan been tested under a simulated emergency response exercise?

PCB Manifest Revised to Match RCRA Hazardous Waste Manifest: The EPA has issued a direct final rule (http://www.gpo.gov/fdsys/pkg/FR-2012-09-06/html/2012-21674.htm )to update and clarify several sections of the Polychlorinated Biphenyl (PCB) regulations associated with the manifesting require-

ments, which uses the Resource Conservation and Recovery Act (RCRA) Uniform Hazardous Waste Manifest, under the Toxic Substances Control Act (TSCA). These changes are to match, as much as possible, the manifest-

ing requirements for PCBs under TSCA to the manifesting require-ments for hazardous waste under RCRA, of which the regulatory changes to implement the Uni-form Hazardous Waste Manifest form were promulgated on March 4, 2005.

P a g e 1 2 G A T E K E E P E R

Chemical companies seeking to comply with federal Chemical Facility Anti-Terrorism Stan-dards (CFATS) regulations have focused almost entirely on using the Department of Home-land Security's Web-based Chemical Security Assessment Tool (CSAT) to create and sub-mit a Site Security Plan. The American Chemistry Coun-cil (ACC) is now reviving inter-est in an alternative. The chemi-cal association is working with the Department of Homeland Security to revamp the Alterna-tive Security Program (ASP) to make it a useful tool for CFATS compliance. A new ASP Guid-ance Document will comple-ment the current Site Security Plan (SSP) process and help to accelerate plan approvals by clarifying aspects of the process that remain undefined, such as what level of detail to include in the SSP. The new alternative approach will enhance the infor-mation provided to better guide security enhancements for a faster and more efficient route to CFATS compliance. Although the Alternative Secu-rity Program (ASP) route has been part of the CFATS regula-tion from the beginning, it has previously been rarely used, and the industry – with the full en-couragement of the DHS – has instead focused mostly on using the CSAT. However, SSPs do have certain deficiencies, and the ASP option allowed by

CFATS regulations is being revisited as a route to com-pliance. DHS defines an ASP as a security initiative that a “third party” has de-veloped and that the Assis-tant Secretary of DHS has determined meets the re-quirements of the CFATS Site Security Plan process. Many chemical security professionals have wit-nessed firsthand the limita-tions of the online DSAT and the resulting SSPs. For example, the Web-based DSAT asks hundreds of “yes” or “no” questions about the generic elements of a facility's security pos-ture, such as “Does the facility have a CCTV sys-tem?” One-word answers to such questions may provide inadequate information to enable the DHS to assess a facility's real security pos-ture. In fact, a survey of 1,000 high-risk chemical facilities by the American Chemistry Council in 2011 agreed that the SSP process is un-wieldy and provides limited value to a facility or DHS inspectors. To enhance the security assessment process, the American Chemistry Coun-cil's proposed Alternative Security Program includes examples of security meas-

ures deployed at various facilities to make aspects of the assessment process as clear as possible. The proposed ASP Guid-ance Document will also include: A general overview of the ASP process; An actual ASP template that security directors may be able to use to gather and present relevant informa-tion; Specific guidance on the “level of detail” required; Checklists on the required security measures to be documented and associated with the corresponding Risk-Based Performance Stan-dards (RBPS), which cover requirements such as secur-ing site assets, screening and controlling access, sabotage and dealing with specific threats, vulnerabilities or risks; Examples of potential security measures; and A “cross-walk” between CFATS and ACC's Respon-sible Care Security Code. ACC has actively promoted chemical facility security since it created the stringent Responsible Care Security Code within months of the terrorist attacks of 9/11. ACC says its member com-panies have invested more than $11.2 billion to further

enhance site, transportation and cyber security at their facilities under the Security Code, which has become a gold standard for the industry and served as a model for regulatory programs. Clarify-ing and facilitating continu-ing compliance with CFATS is a logical extension of that effort. ACC and DHS plan to start a pilot ASP program this sum-mer, and the progress of the pilot is being shared during the DHS Chemical Security Summit this summer in Balti-more. CFATS also includes provi-sions addressing inspections and audits, record keeping and the protection of chemi-cal vulnerability information. The DHS has staffed up with additional manpower to ag-gressively enforce compli-ance with CFATS regula-tions. Non-compliance can result in fines of $25,000 per day and closure of a facility, so clearly there is a lot at stake. Any initiative that can provide additional clarity to the current SSP process is a good idea and may be the solution to CFATS' greatest challenge: clear, concise and unambiguous guidance on what to do and what not to do in connection with security measures.

Mapping Alternative Routes to CFATS Compliance - ACC working with DHS on alternative security programs:

P a g e 1 3 V o l u m e X I I , E d i t i o n 1 0

PHMSA Moves to Implement Tougher Pipeline Safety Regulations:

.Seeks public input on doubling maximum civil penalties, amend-ing enforcement procedures WASHINGTON – The U.S. De-partment of Transportation’s Pipeline and Hazardous Materials Safety Administration is moving forward to implement its new statutory authority to strengthen federal pipeline safety regulations. This notice of proposed rulemak-ing (NPRM) is the first step to implement the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011, which toughened pipeline safety regula-tions and PHMSA’s ability to enforce them. “There are 2.6 million miles of pipeline crisscrossing this nation that impact each and every one of us. Our job at the Department of Transportation is to make sure they operate safely,” said U.S. Department of Transportation Secretary Ray LaHood. “I encour-age the public to provide input on this NPRM as we move forward to improve pipeline safety and hold violators accountable.”

The Act authorizes PHMSA to

increase the maximum civil pen-alty for pipeline safety violations from $100,000 to $200,000 per violation per day. In addition, the agency will be able to collect a maximum of $2,000,000 for a related series of violations, up from $1,000,000. PHMSA pro-poses to apply the new maximums in cases that occur after Jan. 3, 2012, the date President Obama signed the act into law.

Proposed amendments to the Pipeline Safety Regulations also include technical changes and other minor corrections, including returning PHMSA’s authority to enforce the provisions of the Oil Pollution Act of 1990, which had been transferred to the Coast Guard during the establishment of the Department of Homeland Se-curity.

PHMSA seeks public comment on these proposed amendments. The NPRM is available in the Federal Register, and comments can be made using the link pro-vided at the top of the notice. All

comments must include the agency name and docket number PHMSA-2012-0102 at the beginning of the comment and must be submitted by September 12, 2012. The NPRM also provides instructions for sub-mitting comments by fax or by mail. Pipeline safety is a top priority at PHMSA. In April 2011, Secretary LaHood issued a Call to Action on pipeline safety, asking pipeline op-erators to replace and rehabilitate aging pipelines. PHMSA closed a record number of enforcement cases in 2011 and is collecting more data about pipelines and stepping up ef-forts to educate the public about staying safe around pipelines.

The Pipeline and Hazardous Mate-rials Safety Administration develops and enforces regulations for the safe, reliable, and environmentally sound operation of the nation's 2.6 million mile pipeline transportation system and the nearly 1 million daily shipments of hazardous mate-rials by land, sea, and air. Please visit http://phmsa.dot.gov for more information.

“There are 2.6 million miles of

pipeline crisscrossing this

nation that impact each and every one of us. Our job at the Department of

Transportation is to make sure they operate safely,”

said U.S. Department of Transportation Secretary Ray

LaHood.

Governor's Tribal Community Outreach: Visit: http://azgovernor.gov/eop/TribalOutreach.asp for agency contact information.

Tribal Program Link:

http://www.epa.gov/region09/indian

Tribal Program Newsletter:

http://www.epa.gov/region09/indian/newslet.html

Tribal news:

http://www.navajohopiobserver.com/

L E T ’ S H E A R F R O M Y O U ! Send us your inputs and feedback on the newsletter; including, exercises and other LEPC related activities in which you've been involved. Let us know what you’d like to see in future editions. Talk to us! We appreciate your input

and look forward to hearing from you! Sincerely,

Mark Howard Executive Director

Commercial products and services are mentioned for informational purposes only and should not be construed as AZSERC endorsements.

• October 18-21, 2012 - HOTZONE Conference; Houston, Texas at the Crowne Plaza Hotel. For more infor-mation go to: http://hotzone.org/HotzoneMain.aspx

U P C O M I N G E V E N T S :

The majority of regulatory viola-tions found by state EPA inspec-tors are in connection with haz-ardous waste containers, par-ticularly those used by hazard-ous waste generators. Not listed by severity, or frequency of find-ings, here are the most common container violations. -Failure to keep containers closed. Inspectors often ob-serve hazardous waste drums that have been left open during the entire work shift, or drums with open funnels. See this Environmental Daily Advisor post for more information on closed containers. -Failure to mark the accumula-tion start date on the container. Generators accumulating haz-ardous waste on-site without a permit must be sure to clearly mark on each container the date on which each period of accumulation begins.

-Failure to document in-spections. Generators as well as TSDF owners and operators are required to inspect, at least weekly, areas where containers are stored. These facilities often cannot produce docu-mentation that such inspec-tions have occurred. In-spectors may ask to review up to 3 years of inspection records.

-Containers missing the words "Hazardous Waste" or other required informa-tion on the container. Some states also require additional information on the container, such as the hazardous waste number or chemical name that identi-fies the container's con-tents.

-Using improper containers, or containers in poor con-

dition. Containers must be in good condition and lined with material that will not react with the hazardous waste being stored therein.

-Failing to comply with the special satellite accumulation area rules. Generators accu-mulating hazardous waste on-site without a permit in ac-cordance with the accumula-tion time rules may accumu-late up to 55 gal of hazardous waste or one quart of acutely hazardous waste in their sat-ellite accumulation area, pro-vided specific requirements are met. Violations include an absence of operator con-trol of the process generating the waste, failure to list the date the satellite container reaches its accumulation limit (55 gal for hazardous waste or 1 quart of acutely hazard-ous waste), and failure to

The Most Common Container Violations: remove the waste from the satellite area within 3 days of exceeding the quantity limitations.

These violations can result in the state EPA assessing civil and/or criminal penal-ties, and earn a generator or TSDF owner or operator the dubious distinction of being known as a facility that will need to be carefully exam-ined during future visits by the agency's inspectors. A history of noncompliance can affect the severity of future penalties too. Han-dlers should be aware that many inspectors will make the hazardous waste accu-mulation or storage area their first stop in your facil-ity inspection.

P a g e 1 4 G A T E K E E P E R

ARIZONA EMERGENCY RESPONSE COMMISSION 5636 E. MCDOWELL ROAD PHOENIX, AZ 85008-3495

PHONE: (602) 464-6346 FAX: (602) 464-6519

Visit us on the web:www.azserc.org AZSERC STAFF

Mark Howard Executive Director

Roger Soden HAZMAT Program Coordinator

Paul Culberson Web Portal/ Technology Coordinator

Sylvia Castillo Admin Asst III

Chrissy McCullough Admin Asst III

COMMISSIONERS:

Lou Trammell ADEM Director (Chair)

Will Humble ADHS Acting Director

Henry Darwin ADEQ Director

John Halikowski ADOT Director

Robert Halliday ADPS Director

DESIGNEES:

Mark Howard ADEM

Don Herrington ADHS

Veronica Garcia ADEQ

David Denlinger ADPS

Sonya Herrera ADOT

ADVISORY COMMITTEE:

Corporation Commission - Tom Whitmer

Industrial Commission - Darin Perkins

State Mine Inspector - Joe Hart

State Fire Marshal - Bob Barger

Radiation Regulatory Agency - Aubrey Godwin

Department of Agriculture - Jack Peterson

Arizona Fire Chiefs Association

-Mesa FD - Brady Leffler

-Yuma FD - Jack McArthur

Asst. State Attorney General - Jeffrey Cantrell

SRP - Daniel Casiraro

Intel Corporation - Randy Holmes

APS - Monica Ray

Private Sector - David McWilliams

GATEKEEPER NEWSLETTER:

MARK HOWARD – EDITOR IN CHIEF

CHRISSY MCCULLOUGH - EDITOR

This is accomplished through the receipt and coordination of emer-gency notifications of chemical re-leases, collection and provision of chemical inventory information to interested parties, training and grants programs. Additionally, the AZSERC pro-vides consultative services, conducts and participates in workshops and coordinates development and review of plans and programs for 15 Local Emergency Planning Committees. Further, the AZSERC serves as a state clearinghouse for hazardous chemical emergency preparedness and planning activities and informa-tion through coordination with fed-eral, tribal, state, local governments, industry and community interest

The AZSERC was established by Arizona Law (Arizona Revised Stat-utes-Title 26, Chapter 2, Article 3) and is tasked with the implementa-tion of the Emergency Planning and Community Right to Know Act (EPRCA) in Arizona. This Commission oversees 15 Local Emergency Planning Commit-tees and supports community, indus-try and government and academia in: planning, release and incident reporting, data management guid-ance for inventory reporting, public disclosure of information about haz-ardous chemicals in Arizona as well as development of training and out-reach programs. The Commission supports indi-vidual agency goals and objectives.

A b o u t o u r O r g a n i z a t i o n