As part of the local coordination activities, the final rule specifies what information must be provided to local emergency planning and response organizations, including:
- emergency response plan if one exists;
- emergency action plan;
- updated emergency contact information;
- and any other information that local emergency planning and response organizations identify as relevant to local emergency response planning.
EPA proposed that owners and operators of all RMP-regulated facilities provide certain information to LEPCs or local emergency response officials upon request. Many commenters did not support the requirement, citing various reasons such as: a lack of data supporting the Agency’s concern that LEPCs are not receiving the information they need to develop local emergency response plans; unnecessary redundancy with existing requirements, such as data reported under the Emergency Planning Community Right-to-Know Act (EPCRA); data proposed is too broad and does not provide useful information pertinent to emergency response planning; the data may overwhelm LEPCs with technical information with concern that most LEPCs lack the expertise needed to use this information to develop local emergency response plans; and security concerns regarding how the information is maintained and handled by the LEPC or emergency response officials.
Based on these comments, EPA decided NOT to finalize the proposed requirement and instead added language to the emergency response coordination provisions of the rule, which requires the owner or operator to provide “any other information that local emergency planning and response organizations identify as relevant to local emergency planning.” This allows LEPCs and other local emergency officials to obtain the information they require to meet their emergency response planning needs. It also allows local emergency planners and response officials to ask questions of facility personnel about the risks associated with the chemical hazards at the facility and about appropriate mitigation and response techniques to use in the event of a chemical release. Additionally, it further allows the facility owner or operator and the LEPC to identify information that may need to be maintained securely and discuss strategies to secure the information or to provide only information that is pertinent to emergency response planning without revealing security vulnerabilities.