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CHAPTER 4 Collect and Review Existing Data After reviewing the baseline information and scoping the HMCFS project, the project team collects and reviews existing data. The project team may enlist volunteers or other project par- ticipants to assist with existing data collection. A flow chart of the HMCFS process, focusing on collection and review of existing data, is shown in Figure 4-1. 4.1 Existing Data Overview Existing data have been previously collected and assembled for some purpose. They can repre- sent a resource-saving supply of information because collection of new data is often expensive, dif- ficult, and/or time consuming. A disadvantage to existing data is that the data collection, analysis, and presentation may not apply directly to the local HMCFS, and the data may have limited appli- cability to current community needs, depending on the source. Existing data include the following: · Locally or institutionally available data sources Prior HMCFS that have been conducted by the LEPC; HMCFS that have been conducted by other adjacent LEPCs or those that share common transport corridors; Information maintained by local, state, or federal agencies; Information maintained by local hazmat facilities and carriers; Trade, environmental, and social advocacy organizations; and Printed maps and academic journals. · Electronic databases and reports that have information about Transportation networks; Commodity movements; System performance (traffic) levels; Population and critical facility locations; Historical incident and accident occurrences and locations; Contact information; and Geographical and environmental data. Appendix D.8, Use Existing Data Sources, includes a checklist that can help users identify and track the applicability of some of the existing data sources for an HMCFS. Remember that all existing data sources should be appropriately credited when they are used. 4.2 Locally or Institutionally Available Data Sources Identifying locally available data sources is similar to the baseline information review but should be revisited by the project team during the existing data collection step to ensure that nothing important was missed. It also may be possible to drill down deeper during the existing 30
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Collect and Review Existing Data 31 Figure 4-1. The HMCFS existing data collection and review process. data collection phase than during the baseline information review. Institutional data from non- local agencies, industries, and organizations also should be considered. 4.2.1 Prior HMCFS Sometimes knowledge of existing resources may become lost, blurred, or develop gaps with changes in organizational leadership and membership. This makes it important to thoroughly review previous documentation, especially if the organization has experienced recent turnover in membership. Information from a CFS that did not focus on hazmat transport, such as a general commodity flow or traffic study for a community or region, also can be useful for identifying hazmat risks or areas of particular interest or concern.
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32 Guidebook for Conducting Local Hazardous Materials Commodity Flow Studies 4.2.2 Adjacent Jurisdiction/Common Corridor HMCFS State and federal agencies can be Jurisdictions that are adjacent or nearby and share common transport cor- important sources of information. ridors are another good, but often overlooked, source of HMCFS data. Traf- Vermont's LEPC #3 used state DOT fic levels and cargo characteristics on shared transport corridors such as rural reports to identify crash locations. Interstates and other highways, railways, waterways, and pipelines are likely Information about hazmat incidents to be very similar unless there are major traffic diversion points. was provided by Vermont's Depart- ment of Emergency Management. Local traffic counts were compared 4.2.3 Local and State Agency Data with BTS 2002 Commodity Flow Local and state planning, public safety, transportation and public works, Survey data for Vermont for con- environmental and natural resources, and other agencies also may have infor- sistency. Peninsula LEPC in Virginia mation about transportation networks, system information such as traffic lev- used truck inspection records from els, commodity movements, population demographics, and environmentally Virginia DOT. Another source of sensitive areas. Jurisdictions that are conducting an HMCFS should develop hazmat incident information is a list of local and state agencies, and contact them to identify what information PHMSA's Incident Reports Database. may be available. Internet searches can help in this effort. Federal agencies are Lewis/Upshur Counties LEPC in West another source of information. Existing data sources from federal agencies Virginia compared national and that were identified as particularly relevant to a local HMCFS are also discussed state incident data in their analysis. in Section 4.3. Local and State Agency Data Considerations · State transportation agencies conduct traffic counts, including truck counts that are used to provide information for federal transportation databases. They may have additional information available beyond that reported to federal agencies. · Local and state emergency management, emergency response, and environmen- tal agencies may have information about facility locations, incidents and accidents, and company contact information. Although an incident may not be required to be reported at the federal level, information is often required to be submit- ted to these agencies for hazmat or other types of incidents. · An incident does not have to involve hazmat to indicate risks. Accidents that occur in the general driving population or for non-hazmat-carrying trucks may also provide an indication of likely incident locations or incident rates. · In the absence of detailed agency records, historical newspaper reports also may provide incident information. · Planning and zoning commissions or departments may have data on community demographics and land use. Local transportation agencies may have traffic study information available that specifically addresses truck traffic. · Chambers of commerce or other local business groups may have information about local hazmat users or transporters, as well as business trends and planned developments. 4.2.4 Information Maintained by Facilities and Carriers Local shippers and receivers may maintain records about hazmat transport that can be used for an HMCFS. This data source may be particularly useful for hazmat transport that is within, originating in, or destined for a jurisdiction. These types of sources can include manufacturing
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Collect and Review Existing Data 33 facilities, petrochemical plants, hospitals, public utilities, public institutions (schools), retail facilities such as fueling stations, and military facilities. Local entities may have a better under- standing about local hazmat shipments than about hazmat shipments that are travelling through their jurisdictions. Shippers and receivers in a jurisdiction are either known or can be relatively easily identified. Carriers serving these associated facilities can be identified through cooperation by shippers and receivers, or may be known to local agencies (e.g., emergency response, public works, planning agencies, etc.). 22.214.171.124 Facilities Facilities that store certain quantities of hazardous materials are required under EPCRA to report hazardous chemical inventories using Tier I or Tier II forms to their state's SERC, their LEPC, and local fire department. Although only facilities that store hazardous chemicals above certain threshold levels are required to report storage information and not transportation infor- mation on the forms, these forms do provide a means to identify significant users of such chem- icals. Local or state jurisdictions may have additional reporting requirements for facilities that store hazmat quantities at less than EPCRA thresholds. Facilities are likely to have information about types, frequencies, and quantities of hazmat shipments. LEPCs can contact facilities that are subject to EPCRA reporting requirements to request information about hazmat transportation that will be used for emergency planning, as provided by EPCRA Section 303(d)(3): Upon request from the emergency planning committee, the owner or operator of the facility shall promptly provide information to such committee necessary for developing and implementing the emergency plan. (42 U.S.C. 11003(d)(3)) Keep in mind that a detailed analysis of existing facility information may be very labor intensive, particularly for very industrialized jurisdictions, because it requires an identification of applica- ble facilities, contacting them, obtaining the information, and processing the information. Infor- mation may not be in a format that is readily usable for analysis (e.g., paper copies of shipping documents that need to be converted to electronic format). 126.96.36.199 Carriers Roadway carriers that operate within a jurisdiction may be well known to community officials, but carriers who operate mostly outside of, or through, a jurisdiction may be difficult to iden- tify. One possible solution for identifying roadway carriers is to work with commercial vehicle inspection agencies. Major (Class I) railroads are part of the Association of American Railroads (AAR) and partners in the TRANSCAER® (Transportation Community Awareness and Emergency Response) Out- reach Effort. LEPCs can request hazmat transport information from Class I rail carriers using AAR's standardized form (see Appendix F). Hazmat transport data provided by most railroads is essen- tially a census of hazmat commodities transported by rail over a time period such as a calendar year. The rail traffic data may be indicated for specific rail segments or for the overall jurisdictional area. Pipeline operators and commodities can be identified by using PHMSA's National Pipeline Mapping System (NPMS) or local knowledge, with additional details requested from pipeline operators as needed. For HMCFS purposes, generally it may be assumed that a pipeline is full and operational, and represents a release risk should the pipeline's integrity be compromised. The U.S. Army Corps of Engineers (USACE) publishes a Vessel Company Summary that can be found at http://www.ndc.iwr.usace.army.mil/veslchar/veslchar.htm. The summary lists vessel company names, contact information, commodities carried, locations of vessel operation, and operating fleet size. Users can identify which companies may be operating in their areas, what
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34 Guidebook for Conducting Local Hazardous Materials Commodity Flow Studies types of commodities they are carrying, and whether they are likely to be hazardous. These com- panies can then be contacted to request information on specific commodities and tonnage car- ried during specific timeframes, such as a previous calendar year. As with railroads, there are a limited number of air carriers that focus exclusively on cargo transport. In addition, airlines focusing on passenger transport also handle air cargo, especially on international flights. In general, availability of air cargo data is extremely limited. Release of air cargo shipment information is highly guarded by air cargo carriers, and many airports do not maintain statistics on hazmat shipments through their facilities, other than aviation fuels. This creates a challenge for obtaining existing information about hazmat transport by air, and the best option available may be to collect new data for roadway corridors serving airport cargo terminals. 188.8.131.52 Sensitive and Proprietary Information As noted, EPCRA provides LEPCs with authority for implementing emergency plans. This notwithstanding, many private or military information sources are sensitive to providing infor- mation that may affect public safety and security, as well as proprietary concerns. Some will pro- vide information for an HMCFS as "good corporate citizens," but others may have reservations about doing so. For these, a request can be made such that the information provided for the HMCFS is at a more general level, instead of information about specific commodities. Although this does not provide information about specific hazards, it does at least provide some informa- tion. Another potential method is for an entity to provide information with the source or spe- cific location of that entity redacted from the record, so that specific hazard information can be included in the HMCFS. As a quasi-public entity, LEPCs may or may not be subject to Freedom of Information Act (FOIA) requirements. An LEPC's ability to establish a formal legal mechanism that exempts the LEPC from disclosure requirements for proprietary information may be an option that must be validated through legal means if it is to be used. Some information provided to LEPCs (e.g., rail- road hazmat transportation data) must be labeled as sensitive security information (SSI) under 49 CFR, Part 1520. This designation effectively limits any release of data and corresponding information to entities with a need to know. Obtaining information from sources that are hesitant to provide information may require some legwork on the part of local jurisdictions. It is also likely to be difficult to obtain their par- ticipation during the study timeframe of a single year (or less) and is probably more suitable for an HMCFS effort conducted over several years, or continuously. This will allow for the develop- ment of procedures to address disclosure requirements; identify shippers, receivers, and carriers; and bring these participants on board for cooperation in the effort. 4.2.5 Trade, Environmental, and Social Advocacy Organizations Hazmat manufacturing and transportation industry trade organizations are numerous and have a vested interest in safe, efficient movements of commodities. Such associations may be able to provide further information about hazmat transport in general and many maintain member- ship listings on their Web sites, which can be used to augment local contact information. The associations identified in this chapter are not an exhaustive list. Hazmat roadway carrier associ- ations include the following: · American Trucking Association (http://www.truckline.com); · National Tank Truck Carriers, Inc. (http://www.tanktruck.org); and · National Association of Chemical Distributors (http://www.nacd.com). National-level statistics about railcar transportation are available from AAR at http://www. aar.org. These statistics can be used to provide a very general sense of the proportion of chemical
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Collect and Review Existing Data 35 railcars that make up overall rail traffic in an area. Some regions may have very high levels of certain types of rail traffic (e.g., coal traffic in the Powder Basin region, grain traffic in the U.S. Midwest, and chemical cars in petroleum refining regions) and very little of other types of traffic depending on the season and economic conditions. The American Waterways Operators (http://www.americanwaterways.org) is the national trade association for the tugboat, towboat, and barge industry in the United States. The American Asso- ciation of Port Authorities (http://www.aapa-ports.org) is an international organization repre- senting deep-draft and shallow-draft ports, including the largest ports in the United States. These associations maintain information about their industries, including transportation statistics, on their Web sites. Regional waterway operator and port associations may be contacted as well. A large number of national and regional trade associations represent the pipeline industry. National associations include the following: · Pipeline Association for Public Awareness, which maintains information about pipeline emer- gency response (http://www.pipelineawareness.org); · Association of Oil Pipe Lines (http://www.aopl.org); and · American Gas Association (http://www.aga.org). A good list of regional pipeline operators is maintained on the Energy Personnel/Energy Associations/Crude Oil and Natural Gas Associations' Web page at http://www.energypersonnel. com/CrudeOilandNaturalGasAssociations.html. Airline associations may be able to provide information about hazmat transport by air or air cargo carrier contact information. These associations include the following: · Cargo Airlines Association (http://www.cargoair.org), which has nine all-cargo airline members; · Air Transport Association (http://www.airlines.org), which has 19 passenger and freight airline members; and · International Air Transport Association (http://www.iata.org), a trade organization that sets guidelines and standards for the airline industry. Manufacturer trade associations include the following: · American Chemistry Council (http://www.americanchemistry.com), formerly the Chemical Manufacturers Association; · American Petroleum Institute (http://www.api.org); and · American Coatings Association (http://www.paint.org). TRANSCAER® is an effort that was started by the Chemical Manufacturers Associa- tion. The organization "is a voluntary national outreach effort that focuses on assisting communities prepare for, and respond to, a possible hazardous material transportation incident" (http://www.transcaer.com) and is well known in the LEPC community as an important partner in emergency planning. TRANSCAER® has a Web page with guidance for planning an HMCFS and examples of HMCFS results. This page can be found at http://www.transcaer.com/resources/planning- flow-studies. Environmental and social advocacy organizations focus on the conservation and preservation of the environment and equity and protection of people, including historically disadvantaged populations. These types of organizations also may have information on impacts of hazmat