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-2- Every agency should be aware that contract operators of government-owned , contractor-operated (GOCO) facilities are subject to Title III to the same extent as any other operator and , therefore , are statutorily required to comply with the full range of planning, notification and reporting requirements of the Emergency Planning and Community Right-to-Know Act. Federal agencies that have GOCO facilities may wish to determine whether their contractors know of and are complying with all applicable provisions of Title III described in Enclosure 1. EPA realizes that the disclosure of certain information relating to Federal facilities or activities may be prohibited under various statutes governing national security. However, facilities that withhold information because of national security concerns should , to the extent possible, provide other information to assist communities in planning for and responding to emergency situations. EPA is currently examining alternatives for reporting 'classified" information concerning cheinical hazards that will not compromise national security. We strongly recommend that all Federal agencies develop internal policies to address all the major provisions of Title III , in particular the facility requirements under: • Sections 301 - 303: Report the presence of extremely hazardous substances in excess of the Threshold Planning Quantities (TPQ) to the applicable State emergency response commission (SERC) and local emergency planning committee (LEPC). ° Section 304: Provide emergency release notification for extremely azardous substances and all CERCLA hazardous substances to the LEPC and SERC of any area likely to be affected by the release. ° Sections 311 and 312: Submit a material safety data sheet (MSDS) for each chemical or which a MSDS must be prepared under the Occupational Safety and Health Act of 1970 and its implementing regulations or a list of such substances and a Tier I or Tier II inventory form to the appropriate LEPC, SERC and fire department. ° Section 313: Report annually on the amounts of chemicals released to each environmental medium. The purpose of this reporting requirement is to inform the public and government officials about routine releases of toxic chemicals into the environment. In order to assist each Federal agency in developing a comprehensive Title III program, we would like to extend an invitation to your staff to attend a workshop on the Emergency Planning and Community Right-to-Know Act on October 6, 1988. The purpose of this workshop is to provide Federal agencies with a thorough understanding of the Title III provisions and provide technical assistance to enable your agency to design and implement an efficient voluntary program that, were the Federal agency considered a private facility, would satisfy the requirements of the statute. Additional information concerning the workshop is provided in Enclosure 2. Representatives from your agency that attend the EPA Federal Agency Environmental Roundtable have been informed about the upcoming workshop.