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

2. 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

3. 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.

4. 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

5. 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

6. 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

7. 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

8. 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

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

10. 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

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

12. 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

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

14. 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

15. 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