Page 33 - MGPI_Case_Study

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LEPCs, and submits grant applications to PHMSA. Once PHMSA hazmat transportation flow patterns throughout the state.
awards the grants, KDEM distributes grant awards and monitors Though KDEM uses HMEP grant funds for state and regional
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how award funds are used. In FY 2014-2015, Kansas received activities through which LEPCs and emergency responders can
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$368,000 in grant funding. KDEM can distribute funds directly participate, the CSB found that the Atchison Country LEPC can
to LEPCs; fund exercise and training initiatives that benefit local benefit from applying for grants to fund additional planning
responders; or fund state and regional hazardous materials and training activities. Therefore, the CSB concludes that the
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training through universities and training institutes. The HMEP Atchison LEPC should better utilize the training and information
grant program designates funding priorities for training and resources available at a state and regional level, and work

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planning to prevent hazmat transportation incidents. Among with the state to apply for grants that will provide funding
other priorities, the program includes conducting appropriate specifically directed at preparing for emergencies involving
hazard assessments to determine the level of hazmat risks hazardous materials. In addition the LEPC should conduct more
within a jurisdiction, and conducting drills and exercises to test pre-planning and training with chemical facilities in the county
county emergency response capabilities and identify gaps in to ensure the community is prepared for future incidents.
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training and planning. Eligible training activities can include
chemical specific response training, such as a toxic chemical 6.0 SIMILAR INCIDENTS DURING

release. Planning activities can include hazmat tabletop UNLOADING OPERATIONS
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exercises and hazmat preparedness activities for fixed facilities. The CSB found that over the years a number of injuries have
occurred as a result of similar incidents involving inadvertent
Funding is provided to the Atchison County LEPC from local tax mixing during unloading. PHMSA reviewed incident data from
dollars. The CSB learned that the Atchison County LEPC has not 2003-2007 and found that a significant number of highway
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directly applied for or received HMEP grant funding for planning incidents subject to mandatory reporting occurred
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or training since 2007. In 2007, the LEPC received grant funds during loading and unloading incident to movement of a
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to update the county emergency operations plan. In 2013, it hazardous material. The CSB requested and received,
was included in an application submitted by another county to information regarding similar incidents from PHMSA. One such

conduct a 12-county regional commodity flow study to identify event in Holly Hill, Florida, was similar to the MGPI incident
and involved a carrier delivering sodium hypochlorite.

145 Kansas HMEP Grant Guideline. KDEM: 2016; pp 3, 5. http://www.kansastag.gov/
AdvHTML_doc_upload/HMEP%202015-2016%20Grant%20Guide%20.pdf (accessed The CSB reviewed PHMSA incident data from 2014 through
November 1, 2017).
2017 and found that unloading incidents involving hose
146 Kansas HMEP Grant Guideline. KDEM: 2016; pp 5, 17. http://www.kansastag.gov/
AdvHTML_doc_upload/HMEP%202015-2016%20Grant%20Guide%20.pdf (accessed connections to incorrect tanks occur frequently but most
November 1, 2017).
commonly involve compatible materials and result in tank
147 Kansas HMEP Grant Guideline. KDEM: 2016; pp 5. http://www.kansastag.gov/
AdvHTML_doc_upload/HMEP%202015-2016%20Grant%20Guide%20.pdf (accessed overfills. Less common are incidents similar to the MGPI
November 1, 2017).
incident where two incompatible materials are inadvertently
148 Kansas HMEP Grant Guideline. KDEM: 2016; pp 5. http://www.kansastag.gov/
AdvHTML_doc_upload/HMEP%202015-2016%20Grant%20Guide%20.pdf (accessed mixed due to incorrect tank connections. However, since
November 1, 2017).
149 Kansas HMEP Grant Guideline. KDEM: 2016; pp 5. http://www.kansastag.gov/ 153 PHMSA’s regulations apply to the transportation of hazardous materials in
AdvHTML_doc_upload/HMEP%202015-2016%20Grant%20Guide%20.pdf (accessed commerce, including loading, unloading, and storage incidental to transportation.
November 1, 2017).
See 49 C.F.R. § 171.1(c) (2017), which separates transportation functions into four
150 Kansas HMEP Grant Guideline. KDEM: 2016; pp 7. http://www.kansastag.gov/ areas: (1) movement, (2) loading incidental to movement of a hazardous material,
AdvHTML_doc_upload/HMEP%202015-2016%20Grant%20Guide%20.pdf (accessed (3) unloading incidental to movement of a hazardous material, and (4) storage
November 1, 2017). incidental to movement of a hazardous material.
151 Kansas HMEP Grant Guideline. KDEM: 2016; pp 9. http://www.kansastag.gov/ 154 PHMSA’s regulations require detailed written reports for hazardous materials
AdvHTML_doc_upload/HMEP%202015-2016%20Grant%20Guide%20.pdf (accessed incidents as described in 49 C.F.R. § 171.16 (2017) and mandate immediate
November 1, 2017). reporting for serious incidents that meet thresholds described in 49 C.F.R. § 171.15
(2017).
152 Kansas HMEP Grant Guideline. KDEM: 2016; pp 10-11. http://www.kansastag.gov/
AdvHTML_doc_upload/HMEP%202015-2016%20Grant%20Guide%20.pdf (accessed 155 See Section 8.2.1 PHMSA Guidance for further discussion of PHMSA data and
November 1, 2017). guidance.
CSB MGPI Processing Case Study 33