Public Meeting MTR Facility Response Plans for Hazardous Substances; Proposed Rule New Orleans, LA May 10-11, 2000 Revised 3/7/00

Public Meeting Offers public venue to present official comments and concerns in person Limited by ex parte communication restrictions Proceedings become part of official docket

Schedule Today - 9 a.m. - 5 p.m. Tomorrow - 9 a.m. - 1 p.m. Allotted time for speakers - please sign in Identify yourself by name and organization Breaks every hour 1 1/2 hour for lunch ~12:00 p.m.

Background and Purpose Clean Water Act as amended by OPA 90 Requires O/O of tank vessels and MTR facilities to prepare and submit hazardous substance response plans ANPRM published in May 3, 1996 VRP NPRM published in March 22, 1999 FRP NPRM published on March 31, 2000

Principles 1. Human Health 2. Recognize best practices 3. Flexibility 4. Not prescriptive 5. Not duplicative 6. Be consistent with Int’l requirements 7. Reflect differences between oil/hazsub 8. Dovetail w/ existing plans

Applies to: Tank vessels transporting or storing hazardous substances in bulk (Clean Water Act list - 40 CFR 116.4). Marine transportation-related facilities transferring bulk hazardous substances. Regulation captures isomers and hydrates, as well as solutions of 10% or more by weight. Revised 3/7/00

Plan Submission 60 days before vessel or facility conducts hazardous substance operations. Once approved, plan good for 5 years Interim operations authorized pending Coast Guard approval Revised 3/7/00

Plan Contents General information Notification procedures and list of contacts Risk based decision support process Describe process to identify, evaluate, control and communicate risk Spill mitigation procedures Response resources (Equipment/Personnel) Training and Exercises Revised 3/7/00

Plan Contents (cont.) Chemical-specific appendix Worst Case Discharge impact analysis Revised 3/7/00

Exercises Same as for oil response plans; exercises may be substituted for oil response exercises. QI Notification - quarterly Spill management team tabletop - annually Equipment deployment - annually Entire plan - every 3 years (announced and unannounced Revised 3/7/00

Contracted/Owned Equipment/Timeframes Air & Water monitoring - 2 hours PPE - 2 hours Modeling - 2 hours Firefighting - 24 hours Revised 3/7/00

Identified Equipment Floaters: 1 hour - 1,000’ containment boom or 2X the length of ship 12 hours - recovery devices - 10,000’ inland boom Sinkers: 12 hours - Containment/sorbent boom, silt curtains, dredges, pumps, chemical detection devices, in situ treatment, etc. Revised 3/7/00

Expertise: Have access to - Product specialist Toxicologist Certified Industrial Hygienist Chemist or Chemical Engineer Revised 3/7/00

Hazardous Substance Specific Appendix Type of information would include: Physical and Chemical properties Cautionary response considerations Hazards (health, fire) Hazard Classifications Shipping Information Exposure limit CHRIS manual will suffice Revised 3/7/00

Public Docket NPRM comment period closes June 29, 2000 All public comments are available for review at dms.dot.gov Encourage you to send any and all comments related to the proposed rule