CHAPTER 9

 

PROCEDURES AND FORMS

 

A number of forms and procedures are included in this Guidance Manual as aids and guides in complying with the “Hazardous Materials Ordinance”.

 

DESCRIPTION OF FORMS AND PROCEDURES

 

1.  Permit Application Form (1 page)

 

Hazardous materials storage facilities applying after the date of issue of this manual for initial permits, permit renewals, permit modifications or provisional or temporary permits must use the “Permit Application Form” included herein.  The “Permit Application Form” includes a “For Official use Only” section which the LFD will use to record the approval or disapproval of the application.  A copy of this page will be returned to the applicant by the LFD. 

 

2.  Request for Variance from Secondary Containment Form (1 page)

 

In accordance with 33-18.16A.2, a person or entity may apply for a variance from the secondary containment requirements if the applicant can demonstrate that the requirement of secondary containment creates an unusual and particular hardship; that an equivalent degree of protection is provided by the proposed alternative; and that the proposed alternative has been appropriately certified as providing an equivalent degree of protection by a qualified independent engineer professionally registered in the State of Texas and retained in accordance with §33‑16.4.  The request for a variance must be submitted to the LFD using this form.

 

3.  Appeal of Application Denial (1 page)

 

In the event that an application for an initial permit, a permit renewal, a permit modification, a provisional or temporary permit, or an application for a variance from secondary containment is denied, the applicant may appeal the decision to deny to the Citizens Environmental Committee.  This form will serve as the cover sheet for such an appeal.

 

4.  Hazardous Materials Inventory Statement Preparation Guide and forms (6 pages)

 

The ordinance requires the submission of a hazardous materials inventory statement along with the submission of a permit application.  The preparation guide is based on the Standard Fire Protection Code, the inventory reporting procedures establishes by San Diego, CA for its hazardous materials management program, and on the EPA’s Tier II reporting requirements.  The intent is to make the Laredo HMIS reporting relatively easy , but at the same time put the information in a form that is easily transposed onto (or from) a Tier II report.

 

5.  Discharge Reporting Procedures (2 pages)

 

Unauthorized discharges of hazardous materials from long term, short term or temporary storage facilities must be immediately reported to the Laredo Fire Department if the discharge is more than just a “recordable unauthorized discharge”.  Certain hazardous materials incidents (or spills) must also be reported to the National Response Center, and in certain instances detailed written reports must also be filed.  This procedure describes the reports required for the LFD, and outlines certain other reports that may be required.

 

6.  DOT Form F 5800.1 (Rev. 6/89) – DOT’s incident report form (2 pages)

 

This is the form DOT requires for detailed incident reports in cases where they are required.

 

7. Emergency Response Plan Preparation Guide (5 pages)

 

A facility must file an Emergency Response Plan as part of its hazardous materials management plan.  The ERP must be a plan that is effective for the facility, and there is therefore no fixed procedure for its preparation.  This “Guide” may prove useful.  It calls for the inclusion of the following sections: a First Response Procedure; an Employee Notification Procedure; an Employee Response Procedure; information on Evacuation Routes, Emergency Exits, and Staging Areas; a Spill Mitigation Procedure; an Emergency Equipment Record; a Preparedness Checklist; and Agency Notification Procedures and Telephone Numbers.  The user is also referred to OSHA’s 29 CFR 1910.38 for minimum standards for OSHA required fire prevention plans; and, in the appendix, provides a non-mandatory guideline to assist employers in preparing an emergency action plan.

 

8. Preparation Guide for Employee Training Records (1 page)

 

Employers must provide training to employees, must keep records of training performed, and must make the training records and certifications available for inspection by LFD.  This document provides a suggested format for maintaining employee training records.

 

9.  Compliance Inspection Checklist (1 page)

 

This is a checklist that will be utilized by the LFD as it carries out compliance inspections of storage facilities.  The list may change from time-to-time, and LFD inspections for non-compliance are not limited by the publishing of this list.